MEMORANDUM

TO: Docket EPA-HQ-OAR-2009-0174

FROM: Gerri G. Garwood, P.E., EPA/OAR/OAQPS/SPPD

DATE: May 26, 2015

SUBJECT: Summary of Meeting with Air Permitting Forum Representatives on May 20, 2015

On May 20, 2015 at 8:30 a.m., the EPA held a meeting with members of the Air 

Permitting Forum. A list of attendees is included as Attachment A to this memo. The first hour 

of the meeting covered topics related to electronic reporting, monitoring, and emissions factors. 

During this portion of the meeting, the proposed Electronic Reporting and Recordkeeping 

Requirements for NSPS rulemaking was discussed. The Air Permitting Forum representatives 

provided a list of tentative comments:

• When developing comments, the Air Permitting Forum members are looking at 

overarching issues, e.g. does the system create more work, does the system cost 

more money, does the system add more requirements, is there flexibility, is there 

a sufficient amount of time for compliance, and what are the available beta testing 

opportunities.

• The representatives noted that there should be Federal Register notices as the 

Compliance and Emissions Data Reporting Interface (CEDRI) forms and the 

Electronic Reporting Tool (ERT) methods become available, instead of a 

Clearinghouse for Inventories and Emissions Factors (CHIEF) listserv notice. 

The representatives advised the EPA to review the response to comments on the 

Tailoring Rule.

• The representatives noted that the proposed rule increases burden by requiring a 

different report for the EPA and states; by not incorporating additional data 

required for states; and by the training needed to implement the system.

• The representatives expressed concern that the templates are not yet available and 

expressed an interest in seeing these templates before being required to use them. 

The representatives stated that the main concern is managing the transition to 
electronic reporting in a responsible way, i.e. beta testing, shakedown period, etc. 

Good, reliable information serves everyone.

• The EPA clarified that in development of past forms, beta testing was used, and 

the EPA envisions such opportunities going forward. The EPA also clarified that 

the intent is to mirror the regulations, not to change the requirements.

• The representatives expressed that the templates should not change the certifier 

requirements. Currently, many reports are signed by an environmental 

supervisor, not the responsible official. Templates should not change who can 

sign the reports.

• The representatives stated that the EPA should hold off on implementing 

electronic reporting as a piecemeal effort and instead implement electronic 

reporting when it can also include Title V reporting so that all reporting goes 

through the EPA.

• The representatives stated that they need the ability to upload files and provide 

explanatory notes.

• The representatives stated that they need more than 90 days after promulgation of 

the final rule to start implementing the proposed rule.

• The representatives stated that they should be able to submit hard copies of 

reports when the electronic system is down.

• The representatives stated that electronic reporting should not be a requirement 

but instead should be an alternative to current reporting requirements. 

• The representatives noted that the members had split opinions on reporting of 

long-term production/emissions data. 

• The representatives questioned whether the EPA had received any feedback from 

state agencies. The EPA clarified that it has been working with states for the last 

few years on electronic reporting and recently provided a webinar and 

participated in a conference call with state and local agencies. The feedback from 

states has been mixed to this point, but the state and local agencies are still 

considering different elements of the proposed rule.
• The EPA mentioned that as part of the E-Enterprise program, a collaborative 

effort between the EPA and state agencies, the EPA is developing a scoping study 

on data integration for its different reporting systems.

• The EPA mentioned the possibility of development of a web-based ERT, as 

proposed in the preamble of the rule.

• The EPA clarified that the system will be designed with the ability to import data 

from spreadsheets.

• The representatives stated that the EPA should include industry and state 

representatives on its team for development of the electronic reporting system.

• The EPA reminded attendees to please submit comments formally.

Discussion on this topic ended, and the meeting then moved to the next agenda item.
Appendix A

List of Attendees
The following people were present for the meeting in Research Triangle Park:

EPA/OAR/OAQPS

Michael Ciolek 

Gerri Garwood

Steffan Johnson

Theresa Lowe

Barrett Parker

Ketan Patel

Bob Schell

Chevron

Amy Lincoln

ExxonMobil 

Dawna Allen

Sherri Scott

FCA

Sandy Walker

Ford

Duane Johnson

GE

Roy Belden

John Oldi

Georgia Pacific

Maria Zufall

GM

Kim Essenmacher

Rusty Helm

Teri Kline

Paul Zavala

International Paper

Jeff Shumaker

Katten Muchin Rosenman LLP

Shannon Broome

Chuck Knauss

Bob Morehouse

Toyota

Eric Anderson

Becky Bright