MEMORANDUM

TO: Docket EPA

- HQ

- OAR

- 2009

- 0174

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

DATE: May 2 6 , 2015

SUBJECT: Summary of Meeting with Air Permitting Forum Representatives on May 2 0 , 2015

On May 20 , 2015 at 8 :30 a .m., the EPA held a meeting with member s of the Air Permitting Forum

. A list of attendees is included a s Attachment A to this memo. The first hour of the meeting covered topics related to electronic reporting , monitoring, and emissions factors. During t his 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 Fo rum 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 availa ble 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
Cl earinghouse 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 toelectronic reporting in a responsible way, i.e. beta testing, shakedown period, etc. Good, reliable information se rves 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 rep resentatives 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 representat ives 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 note d 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 men tioned 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 AttendeesThe 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

Che v r on Amy Lincoln

ExxonMobil
Dawna Allen Sherri Scott

FC A 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