**ECMPS Project Stakeholder Meeting**

**February 9, 2004, 9:00 a.m. - 4:15 p.m.**

**Washington, DC**

**FINAL MEETING NOTES**

On February 9, 2004, the EPA Clean Air Markets Division (CAMD) held a
meeting to introduce and discuss ECMPS, and to demonstrate the prototype
to a stakeholder group comprised of DAHS vendors and industry
representatives. Matt Boze, Laurie DeSantis, Rey Forte, Craig Hillock,
Martin Husk, Beth Murray, Thuy Nguyen, Ketan Patel, Janice Wagner, and
Michele Wockenfuss of CAMD; Justin Britt, Peggy Quarles, and Nat Rogers
of Perrin Quarles Associates (PQA) attended the meeting. The list of
stakeholders is provided in Attachment A. The agenda from the meeting is
provided as Attachment B.

**1. [Introduction]{.underline}**

Janice Wagner welcomed all participants and asked each meeting attendee
to introduce themselves. She then gave a history of emissions collection
from 1990 to present, noting that the ECMPS project represents the most
significant change undertaken. Re-engineering allows EPA to leverage
technological change and improve how they do business. She described the
two main benefits of ECMPS: 1) increased levels of customer service, and
2) cost savings. Janice closed by encouraging all participants to
provide feedback and to be honest about what they think about EPA\'s
plans for ECMPS.

**2. [Re-engineering Overview, Vision for ECMPS (Slides 2-15, Michele
Wockenfuss)]{.underline}**

Following Michele\'s presentation the following questions and issues
were raised:

! Who is using the data on the Data and Maps site? Michele indicated
that there are a variety of users, including State agencies, Department
of Energy, the academic community, students, as well as sources.

! Will ECMPS address issues relating to submission of data to both the
State and the EPA (there is one place to submit data to States under
Part 60 and to the EPA under Part 75), and could the EPA work with the
States to coordinate this? Michele indicated that data warehousing
together with the States is something that they would be willing to
offer to the States. Michele said that re-engineering helps move this
type of effort forward by producing a centralized location for both
State and federal data. The quality of EPA data in comparison to State
data also supports use of federal data.

! How are data used by those getting it, and how it is interpreted? For
example, how do users interpret data substitution or application of
BAFs? Michele indicated that it was a primary concern of CAMD that the
data and results available to the public be understood and, where
appropriate, be caveated, so that the data and results are used in the
correct context. For example, when you query data, if there are caveats,
then they are communicated with the results. Janice added that some
categories of users, such as the data modelers, are savvy, and know what
they are looking at and why.

! Michele asked whether the stakeholders know why the online Certificate
of Representation is only used for 20-24% of the representative changes.
One participant responded that one reason for the low online Certificate
of Representation use maybe that it is not a common event. Also,
representatives are not computer savvy and they like to see a paper
trail, which can be put in a file for audit purposes. It was mentioned
that you can always print out a copy of what you submitted online, so
that you have a paper trail for audit purposes. EPA could consider
providing screens that could be printed to look like the paper forms.

**3. [ECMPS Overview (Slides 17-22, Martin Husk)]{.underline}**

Following Martin\'s presentation, the following questions and issues
were raised:

! Will there be a place to store data in a test environment? Martin
indicated that after the data are checked through the first level of
checks and passes, that it would need to be housed in a pending
database. Housing this data would allow you to check your data on a
frequency that can be determined by the user; for example, daily,
monthly or quarterly. This eliminates the need to maintain the mainframe
(server more cost-effective than maintaining the mainframe).

! One industry participant noted that setting the frequency lower, to
say daily, would hopefully give you less to clean up later on.

! Another commented that they want EPA to make all of the checks
available and asked if there would still be a post-review of the data?
Martin indicated that there would be some audit processes performed once
data are submitted (passes all checks, etc). Another industry
participant responded if the focus is on the data and the process is
complete, then the audit should be complete.

! What does the EPA envision for submission criteria? Martin indicated
that they are still trying to determine the checking criteria including
minimum requirements. An industry participant stressed that you should
be allowed to meet your statutory requirement with any file that is
submitted, even if it has errors, as long as it is submitted before the
deadline.

! An industry attorney asked how Re-engineering/ECMPS relates to
CROMERRR. Michele responded that CROMERRR is the electronic reporting
rule requirement, which deals with how users will be authenticated and
what constitutes authenticity/user\'s signature. Michele indicated the
rule will be coming out this August, and there is a two-year period for
implementation. Michele also indicated that there is a federal wide
e-authentication policy that is currently under review and is more
restrictive than CROMERRR.

**4. [Submission Process Prototype Presentation (Slides 23-25, Justin
Britt)]{.underline}**

> Following the ECMPS Prototype Demonstration, the following questions
> and issues were raised:

! What software is used to run the application? Justin responded that on
the client-side, the desktop tool would require SQL Server 2000 and the
.NET framework. On the EPA-side, data would be stored in Oracle tables,
and the website accessed by the desktop tool would be a ColdFusion
application.

! Will the EPA distribute the technical requirements? Yes. Martin
indicated that the technical specifications would be released. An
industry participant indicated that this would be helpful because their
IT people are planning for the future.

! What is the relationship between the Oracle and SQL Servers? Justin
stated that the client machine (source-side) will need SQL Server and
the EPA would use Oracle. Sources would not need to purchase a SQL
Server license unless more than 10 users in one networked environment
are active (free for 9 users or less). The client application would run
on standard Windows-based operating systems.

! How does the structure of a file change in terms of looking at an EDR
file as compared to an XML file? Justin opened an XML file to show the
group that the data are organized by hour instead of by record type. XML
is more flexible than an EDR file and more easily understood. It was
apparent that the majority of the group are very familiar with the
existing EDR format, and did not necessarily agree that XML is easier,
at least at first glance. It was pointed out that XML data are easily
viewed through a viewer which are widely available and make the data
understandable and useable. An XML format gives you the ability to query
data; therefore, XML provides more information that flat files because
flat files have no database functionality. Martin noted that the EPA
will maintain both options for some period of time.

! What is the difference in size between XML and EDR? Justin indicated
that an average quarterly EDR file is about 1 MB and when it is
converted to XML it is about 7 MB, a seven fold increase in size. When
the file is compressed as part of the ECMPS application, the stored size
is just about 400 KB. The compression occurs when all of the processing
is completed just before the data gets sent to the EPA server production
location (during communication). WinZIP, which is a free tool, can be
used to unzip the file.

! Who has permission to perform analyses on a source\'s data, as well as
submit or retrieve the data? Martin responded that industry
representatives could do this. In addition, representatives could assign
agents to transact certain business functions on their behalf, including
DAHS vendors. One participant commented that he did not want anyone else
looking at his data until the EPA says the data are OK. Another asked if
passwords to the ECMPS application could be shared with DAHS vendors to
allow them access. Michele responded that sharing passwords is not
allowed. Michele indicated that each DAHS vendor who is authorized by a
representative as an agent would be assigned their own User ID and
password. Each user would have their own security settings based on the
permission granted by the DR. It was suggested that a view-only feature
to the official EPA database could be provided. This view-only feature
would allow the data to be \"read\" by the DAHS vendor. One industry
participant indicated that his company struggles with these kinds of
things because everything has to go through their attorneys first.

! Can the application include an Export capability so that the data
could be exported and saved to an Excel or Access file? Yes.

! Will it be possible to perform checks and evaluations offline? Justin
indicated that you could import your EDR offline and check it without
having an internet connection.

! Can the software be developed to facilitate integration into DAHS
software? The EPA should provide ways to integrate software into their
processes (available to the source-side). Martin agreed to explore
whether this would be feasible.

! Will there be batch processing of quarterly reports? Yes.

**5. [Rethinking the Process (Slides 27-29, Beth Murray)]{.underline}**

Following the presentation, the following questions and issues were
raised:

! Is EPA\'s monitoring rule stable? Is the rule likely to change between
now and the time ECMPS is online? Michele indicated that was a question
for Rey Forte, EMB Branch Chief, but did not think so. She said that the
EPA is trying to minimize the impact of the transition. Beth indicated
that they were not anticipating substantive changes to the monitoring
requirements between now and then. Several participants commented that
EPA must manage carefully any changes to the rule to ensure that we
limit the amount of revisions to which they have to react. It was
suggested that the rule changes developed as part of the ECMPS process
be coupled with other rule changes.

! Who would be the judge about what data are right or wrong (if there
are problems with the software, gray areas of reporting)? Beth pointed
out that there are benefits and consequences of having gray areas in the
reporting. Getting too specific allows for no flexibility and being too
gray increases false errors, there is some balance to strike.

! Will there be a backup process to submit data to the EPA if the online
process is down? Yes. Michele agreed that backup systems would need to
be in place to accommodate catastrophic events or unforeseen short term
events from impacting access to the online site or the ability to
submit.

! Is EPA considering the redesign of certifications (RT 9XX)? Michele
replied that we have a need to verify the authenticity of the user
certifying the data and this will likely be done differently then having
RT9XX reported. Beth indicated that EPA would consider reevaluating
these areas to see if it makes sense to do so.

! Is the timing of the project sensible? Beth said that the three years
for planning, testing and deployment are needed to get all the ideas
together and get everything tested. A full year will be used for
testing. Michele stated that they also did not want to deploy in the
middle of the year; the earliest data is the first quarter of 2007. One
industry participant agreed; the two year time frame for requirements
collection and development seemed about right, and he indicated that
this would lay the foundation for new pollutants. Another participant
agreed, but asked to have the period of time that either system can be
used to submit files (legacy or ECMPS) be as long as possible.

! Will EPA consider whether there are data reported that is too onerous,
for example, re-certification data. Can EPA prioritize what is going to
be streamlined? Beth stated that this was outside of the discussion for
today, but the request would be noted.

! What is the CPTS box on Slide 7 of the presentation? Michele answered
that this area of the flow chart covered the permits under Title IV and
compliance data and tracking for true-up.

! Another participant was concerned that moving to a 21 day prior to
testing instead of 45 days for initial monitoring plan submission was
too beyond the scope of re-engineering. Martin responded that they were
trying to harmonize the initial monitoring plan requirement with QA Test
requirements, and that if both are the same, perhaps you would have
better monitoring plan data.

! Is XML the correct standard? Michele indicated that XML will be the
EPA\'s standard format, and she mentioned that the central data exchange
(CDX) housing all data on the EPA\'s server is based on this standard.

! If one of the stated reasons for ECMPS is to save on costs and to
improve efficiency, what is the actual reduction in cost? Janice
indicated that processing time on the mainframe is the main cost
savings, although cost savings in terms of dollars have not been
quantified. She believes that EPA would probably break even in terms of
cost but would be able to offer improved performance and service levels.

**6. [Recap of ECMPS and Roundtable Discussion (Slides 31-32, Martin
Husk and]{.underline}**

**[Beth Murray]{.underline}**

> Following a basic overview of ECMPS, Beth convened a Roundtable
> Discussion and the following questions and issues were raised.

! Will your problems or concerns about the current process be addressed
by re-engineering? One industry participant commented that in general,
his concerns have been addressed. He is concerned about determining when
a quarterly report is final \-- when is done done? Michele responded
that there is a line that needs to be determined, and that is still up
for discussion. Beth said it would be helpful to have all the checks
available on your desktop. This will allow you to quality assure your
data and check acceptability before submitting. A DAHS vendor added that
EPA needs to incorporate as many checks as possible (in terms checks \--
ETS, MDC, MDC Hourly, MDC Quarterly Review) in the software. Having all
checks in one place is a big reason for re-engineering. Beth said that
new checks can be tested online before they count, which is another
benefit of ECMPS. There was also a comment that this approach would also
solve the version number issue, for example, having different versions
of MDC give different results.

! How much time is reasonable for desktop checking? Michele said that
the EPA needs to figure out how long it will take to do all the checks,
particularly for big submissions and whether this amount of time is
acceptable to industry. One participant replied that the source should
be able to decide \-- do you want the five minute check or the two day
check. He said they want the comprehensive check, that does all the
checking. There was agreement that it is important to get all the
checks, even if it takes longer to do them, to avoid surprises later on.

! Can ECMPS be integrated with the DAHS? One commenter asked if there
would be a way to integrate this with the DAHS, so you can periodically
check your data \-- that would be a big benefit. A DAHS vendor asked the
other attendees if their DAHS had access to the internet, and indicated
that currently many do not. So allowing the DAHS to connect to the
internet to do the checking is a change, and there may be privacy issues
related to this. An industry participant responded that in general the
DAHS should not have contact with the internet, but instead have a patch
to the CAMD site.

! How and when will new checks be incorporated? There was concern from a
participant about the timing of adding new checks, and that they not be
made official checks in the middle of a quarter, but at the beginning of
a new quarter/submission period. Martin agreed that implementing a new
check in the middle of a quarter was not something they would do, but
that they would try and figure out when it is most advantageous to do
so. An industry participant asked how this was different than what virus
checking does on our computers already, every night there is a potential
for a new download of checks \-- maybe there is an indication that a new
tool with new updates is ready to be downloaded. This would allow
sources to stay on top of changes, and provide some flexibility for
running updates.

! Is it important to check multiple files? The group responded that this
was essential, and that there needed to be a mechanism to allow for
large batch sizes in the submission and evaluation process. For example,
it would be useful to run a batch process each night on all of your
data, push one button before you go home, let the process validate the
data, do its checks, and create log files. Then the next morning, you
have an error file waiting for you that can be addressed and cleaned up.

! If there are minimum criteria checks and a file did not meet those
requirements, what kinds of problems does this create for sources? One
participant commented that the critical checks resulting in file
rejection which are in place now are fine, no one is complaining about
those. Another disagreed, and thought the checks should be more general,
as long as a file had an ORIS code, Unit IDs and emissions data, it
should be allowed to be submitted. Michele indicated that there are two
views on this inside the EPA, some think the current checks are OK, some
think there are too many. An industry lawyer commented that there needs
to be a clear demarcation point of when the system prevents someone from
submitting because the data does not follow the EDR instructions or the
rule. Michele responded that each file must have fundamental qualities
that allow it to be checked. Does the EPA want a file that it cannot
check? That is the fundamental question. The participant suggested that
the rule should say what is fundamental and clearly state that every
file must contain specific data. Michele responded that we first have to
figure out what is fundamental. If a file passes to the temporary
holding location, could that be the minimum level that is required for a
source to meet its statutory filing requirement? An industry participant
made a suggestion that to minimize rejected data files, that the EPA
should consider putting in flags or markers to identify issues. Michele
agreed to consider something like this.

! Who should be contacted about EDR problems? There was also another
issue raised relating to using agents to conduct business for the DR,
and that is when informational errors are received, that the DR not be
notified of these messages, but just the EDR contact be notified.
Michele responded that only one person is responsible and that is the
DR. She said that the EPA will look into whether there is any
flexibility to first notify an EDR contact.

! Could there be more categories of errors, for example warnings, notes;
or ways to associate errors or regroup errors? Yes, Michele added that
\"Did you know\" kind of checks could be considered as well.

! Can EPA distribute a list of all possible checks, errors and
resolutions? Yes.

! Should there be a change in responsibility for emissions calculations?
One industry representative stated that most data rejections are due to
recalculation errors. Instead of the source doing the calculation, why
not just report the basic data \-- ppm values, etc. \-- and let the EPA
calculate the emissions values and call that the gold standard? Then the
source would recalculate to match the EPA\'s numbers. A DAHS vendor also
commented that they spend a lot of time matching the EPA\'s calculated
and source reported emissions data. Michele commented that cost would be
a factor in what the options may be. An industry participant said that
the source could just submit the RT 200 and 301 data, and let the EPA do
the 310, 320 etc. Peggy Quarles said that this is shifting the
responsibility of calculation to EPA and shifting back the
responsibility of comparison to the DAHS on industry side.

! How much tolerance they would be granted, due to for example, the way
XML converts characters to string \-- how is that rounded? Remaining
issues will be addressed by determining appropriate tolerances or
clarifying rounding requirements.

! Should EPA consider using monitoring data to improve checking? Michele
asked about using monitoring methodology data to allow for better
checking. Does it work? Is it acceptable? It was explained that using RT
585 (monitoring methodology) to check hourly data is a different check
than what is being done now. One industry participant agreed that this
was good, although there are many issues/details to work out. Michele
commented that the idea would be to make the initial monitoring plan
submission on line. Thereafter, you would download the official data
from CAMD production to the ECMPS client database where it
[would]{.mark} then be edited and sent back up.

! Is EPA going to maintain the same monitoring plan checks that MDC is
doing now? Michele indicated that the EPA wants to keep all good checks
in place.

! How will EPA handle a resubmission of edited, old monitoring plan
data? Michele said that software will control whether monitoring plan
data are add-on, replace or delete, it is complicated. There are two
problems: that the computer has difficulty distinguishing between
errors; and the policy that allows for the reuse of old System IDs.
Martin asked the group what they thought of not being able to reuse old
System IDs and indicated that this was a policy that EPA planned to
reevaluate.

! A DAHS vendor said he liked the idea of matching a monitoring plan
with a particular quarter, having the software look at aging records.
Michele said she was very concerned about this and that managing
historical data is very difficult.

! Should EPA provide the ability to sources to submit data changes more
frequently than quarterly? Would they tend to use it more frequently
(daily) to do data checking, but not submit as frequently as that? It
was responded that it is a business decision on how often a source would
check their data, but having the ability to check anytime is good.

! Is EPA getting out of the data checking business? Martin responded no,
they were just giving industry the opportunity to do it as well.

**Other issues comments raised by the participants**

! At least one source is required to submit data directly to the states.
Several participants want EPA to lead the effort to coordinate data
collection requirements with the States. Is it possible to find a way
for the EPA to send the data to the States?

! Use the Pending area of the database to accept all emissions files,
regardless of the quality.

**7. [Next Steps]{.underline}**

Martin asked how EPA should communicate with stakeholders on an ongoing
basis: more meetings, emails, and how often and when? One participant
recommended a conference call in six weeks. Martin agreed, saying that
CAMD hopes to have the submission process summary and the proposed
changes to the rule ready soon. It was agreed to have a conference call
in approximately six weeks. Martin also indicated that CAMD will be
attending EPRI in May 2004, and they would like to host a meeting there
on Monday morning to continue the discussion.

Martin will send out the presentation and list of attendees to all
meeting

participants. PQA will prepare meeting minutes and forward to the group.

Michele reminded everyone that this is an open process, available to
anyone that is nterested.Others are invited to participate in future
planned stakeholder meetings.

**Attachment A**

**Meeting Participants**

[Name]{.underline} [Company]{.underline}

Dave Naegele AEP Corporation

Eric Swisher All4Inc.

Orvella Shipman Alliant Energy

Marsha Layman ESC

Jack Wang ESC

John Tutak First Energy

Katie Lindblom GE Power Systems

Ed Wentling GE Power Systems

Lauren Freeman Hunton & Williams

Amy Earley Merck and Company

Orlando Cartagena NRG Energy

Dwight Dailey Ohio Valley Electric Corporation

Steve Norfleet RMB Consulting

Rod Seagle Salt River Project

Kim Mireles Texas Utilities

Rudi Muenster VIM Technologies

Matt Caldwell VIM Technologies

Kevin Sullivan VIM Technologies

Jon Konings WE Energies

**Attachment B**

**AGENDA**

Objective: Provide an overview of the project and get feedback from the
group

+----------------------------------+--------------------+--------------+
| [Topic]{.underline}              | [Time]{.underline} | [Presenter]  |
|                                  |                    | {.underline} |
+----------------------------------+--------------------+--------------+
| 1\) Introduction                 | 9:00 a.m. \_ 9:15  | Janice       |
|                                  | a.m.               | Wagner       |
| a\. EPA Project Team Members     |                    |              |
|                                  |                    |              |
| b\. Industry Members             |                    |              |
|                                  |                    |              |
| c\. Other Guests                 |                    |              |
|                                  |                    |              |
| d\. Purpose of the Meeting       |                    |              |
+----------------------------------+--------------------+--------------+
| 2\) Re_engineering Overview      | 9:15 a.m. \_ 10:00 | Michele      |
|                                  | a.m.               | Wockenfuss   |
| a\. What is Re_engineering?      |                    |              |
|                                  |                    |              |
| b\. Why EPA is Re_engineering?   |                    |              |
|                                  |                    |              |
| c\. Where is EPA in the Process? |                    |              |
|                                  |                    |              |
| d\. What is ECMPS?               |                    |              |
|                                  |                    |              |
| e\. Vision for ECMPS             |                    |              |
+----------------------------------+--------------------+--------------+
| Break                            | 10:00 a.m. \_      |              |
|                                  | 10:20 a.m.         |              |
+----------------------------------+--------------------+--------------+
| 3\) ECMPS Overview               | 10:20 a.m. \_      | Martin Husk  |
|                                  | 11:15 a.m.         |              |
| a\. Gathering Input              |                    |              |
|                                  |                    |              |
| b\. Defining Requirements        |                    |              |
|                                  |                    |              |
| c\. Develop, Test and Implement  |                    |              |
|                                  |                    |              |
| d\. Status of ECMPS              |                    |              |
+----------------------------------+--------------------+--------------+
| 4\) Submission Process Prototype | 11:15 a.m. \_      | Justin Britt |
|                                  | 11:45 a.m.         |              |
+----------------------------------+--------------------+--------------+
| Lunch                            | 11:45 a.m. \_ 1:00 |              |
|                                  | p.m.               |              |
+----------------------------------+--------------------+--------------+
| 5\) Rethinking the Process       | 1:00 p.m. \_ 1:45  | Beth Murray  |
|                                  | p.m.               |              |
| a\. Non_technical Changes to     |                    |              |
| Part 75 b. Changes to the        |                    |              |
| EDR/Instructions                 |                    |              |
+----------------------------------+--------------------+--------------+
| Break                            | 1:45 p.m. \_ 2:00  |              |
|                                  | p.m.               |              |
+----------------------------------+--------------------+--------------+
| 6\) Recap of ECMPS               | 2:00 p.m. \_ 2:15  | Martin Husk  |
|                                  | p.m.               |              |
+----------------------------------+--------------------+--------------+
| 7\) Roundtable Discussion of the | 2:15 p.m. \_ 4:00  | Beth Murray  |
| ECMPS Project                    | p.m.               |              |
|                                  |                    | /All         |
+----------------------------------+--------------------+--------------+
| 8\) Follow_up Items and Adjourn  | 4:00 p.m. \_ 4:15  | Martin Husk  |
|                                  | p.m.               |              |
+----------------------------------+--------------------+--------------+