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Questions and Answers: Changes to the Process
ECMPS Additional Information
New FAQs appear at the beginning of each section.
Changes to the Process
Q: What will the EPA receive to indicate that all checks have been performed?
A: One of the features of the ECMPS process is all checks will be performed through the Client Tool by the source. Feedback on any errors will be generated to allow the source to make corrections prior to submitting the final data to the CAMD Host System. When the final data are submitted, the results of the checking will also be submitted to EPA.
Q: There are currently raw files for the quarterly reports posted on the CAMD web site. Will these files still be available once the ECMPS process is implemented?
A: When the ECMPS process is implemented, there will no longer be one file that contains all of the data, as with the current EDR file. The unit and facility attribute data will be maintained outside of the quarterly report process, the monitoring plan will not necessarily be submitted each quarter, and the quality assurance and certification test data may be submitted right after the tests are performed. Furthermore, each set of data will generate its own XML file to support the flexibility of the ECMPS process. Since CAMD is moving away from reliance on data files, the XML files will not be posted on the CAMD web site. However, all of the emissions data submitted, including historic data, will be available through the Data and Maps web site.
Q: What procedure is EPA developing to create a record of the time of an electronic "submission" so that utilities can establish that they have met a "submission" deadline? A record of "receipt" by EPA is not sufficient under the rules because compliance with the deadline is tied to "submission" and not to "receipt." If EPA's software could provide a record of "submission" to the U.S. Government (similar to a post mark), that could eliminate the need for a backup method of submission for those problems that are limited to the availability of EPA's computer system.
A: Under the current ETS-FTP and SecuRemote process, the feedback generated from the processing of an electronic data report includes the year and quarter for which the report was submitted, the date and time of the submission, and the User ID of the submitter. Under the ECMPS process, sources will receive feedback from the CAMD host system when the data are received. That feedback will include, at a minimum, the date and time of the submission and the User ID of the submitter. EPA will certainly look into adding the submission date and time to any feedback sent to the source based on a submission of data to the CAMD host system.
Q: What procedure is EPA developing to ensure that the checks it imposes in its software are supported by rule requirements (i.e., that the checks do not impose any new substantive requirements) and that utilities have ample time to evaluate the software and adjust their reports prior to the relevant submission deadline? Will EPA solicit comment on new checks prior to implementation?
A: The ECMPS Client Tool will have a Help function that contains a catalog of all checks performed on the data. The catalog will include the name of the check, the actual specification language to show what data are being checked and how they are being checked, the associated error text message, and the level of severity of the check. All checks will be based on the data that are required to be reported by Part 75. EPA does not now solicit comments from affected sources when implementing new checks and does not intend to do so after the implementation of the ECMPS process.