Compliance and Emissions Data 

Reporting Interface

Integrated Project Team

Guidance and Recommendations 

Document

Version: 1.0

Revision Date: September 26, 2013 
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Revision History

Version 

Number Description of Change ChangeEffective Date

Change

Entered By

0.1 Initial draft delivered to CEDRI

IPT

08/23/2013 EPA

0.2 Second draft delivered to IPT 

Participants

09/03/2013 EPA

1.0 IPT participant comments 

incorporated

09/26/2013 EPA
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Table of Contents

Revision History ............................................................................................................................................ ii

1 Introduction ..........................................................................................................................................1

1.1 CEDRI Background.........................................................................................................................1

2 IPT Objectives & Structure....................................................................................................................2

2.1 Objectives......................................................................................................................................2

2.2 Structure .......................................................................................................................................3

2.3 Reference Documents...................................................................................................................3

3 Summary of Findings.............................................................................................................................5

3.1 General Interest and Success Measures.......................................................................................5

3.2 Dataflow........................................................................................................................................5

3.2.1 Processing Time for State Review.........................................................................................6

3.3 Data Resubmission........................................................................................................................6

3.4 Data Requirements: ......................................................................................................................7

3.4.1 S/L/T Specific Data ................................................................................................................7

3.4.2 Report Identification.............................................................................................................8

3.5 Data Access...................................................................................................................................8

3.5.1 CEDRI versus WebFIRE Access ..............................................................................................9

3.5.2 Notifications..........................................................................................................................9

3.5.3 Review File Access...............................................................................................................10

3.5.4 Alternate ERT Formats........................................................................................................10

4 Guidance and Recommendations.......................................................................................................11
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1 Introduction

This document provides a summary of the information gathered through the Compliance and Emissions Data 

Reporting Interface (CEDRI) Integrated Project Team (IPT) and the guidance and recommendations derived from 

these inputs. The content in this document is based on input from the CEDRI IPT that was formed to address 

data submission, data resubmission, and data access requirements for eReporting under 40 Code of Federal 

Regulations (CFR) Part 60 and 63.

1.1 CEDRI Background

CEDRI is an application being created on the Environmental Protection Agency’s (EPA’s) Central Data Exchange 

(CDX) to collect electronic reports required under 40 CFR Parts 60 and 63 from regulated entities. CEDRI is 

undergoing a phased development approach. The first phase, already implemented, allows regulated entities to 

submit performance test and performance evaluation reports. The second phase of CEDRI, scheduled for release 

in the first quarter of fiscal year 2014, will allow regulated entities to submit certain air emissions data reports

(reports similar to semi-annual or excess emissions reports) in addition to performance test reports and 

evaluation reports. Notification of compliance status reports will be included in a later CEDRI release. The CEDRI 

application is being designed to transition the EPA to electronic reporting which will support improved data 

quality and facilitate review of reports. EPA is making CEDRI available to State, Local, and Tribal (S/L/T) agencies 

as an optional tool to assist them in receiving reports.

EPA’s goal is to implement a dual-reporting structure where air emissions reports will be sent to EPA and to the 

S/L/T agencies. Maintaining the present mode of reporting by regulated entities to S/L/T agencies is important. 

Therefore, sources are obligated to submit reports to EPA electronically via CEDRI, and to their S/L/T agency in 

the agency designated manner (paper or electronic reporting system). S/L/T agencies have the option to 

participate in EPA’s electronic reporting system. In addition, EPA plans to release the XML (eXtensible Markup 

Language) schema for their reporting tools so that S/L/T agencies currently with electronic reporting systems 

can modify their systems to be compatible with CEDRI.

The current plan is to use the Web-based Factor and Information Retrieval System (WebFIRE) as a repository for 

all files submitted to EPA through CEDRI. This includes performance test reports via the Electronic Reporting 

Tool (ERT), notification of compliance reports, and air emissions reports. WebFIRE is being modified to 

accommodate this expanded functionality.
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2 IPT Objectives & Structure

2.1 Objectives

The objectives of the CEDRI IPT were to gather requirements and ideas from S/L/T agencies on the data flow 

process within the CEDRI application. Areas of particular interest were the submittal and electronic report 

review process. Consequently, and as defined by the CEDRI IPT charter, the topics of discussion were limited to

data submission, data resubmission, and data access requirements of the CEDRI data flow. 

The IPT sought to answer the questions listed in Exhibit 2-1.

Exhibit 2-1 CEDRI IPT Questions

Category Topic

Data Flow Information submitted via CEDRI into the CROMERR CDX archive will not be 

immediately entered into the WebFIRE database. What is an appropriate 

period of time to have reported data available in the WebFIRE database? 30 

days? More than 30 days?

a. Performance Test Reports (ERT reports)

b. Air Emissions Data Reports/Continuous Emissions Monitor data 

summaries

c. Notification of Compliance Status Reports

Data Resubmission Should data, resubmitted to correct previously submitted data, follow the 

same process as data entered for the first time?

Data Requirements Do the empty fields [memo fields] and the ability to attach PDF documents

to the Air Emissions Data Reports templates adequately accommodate the 

need for sources to submit information not required by the Federal rules? 

The goal of this feature is to allow sources to meet both Federal and State or 

Local requirements in the same electronic submittal package.

Reports being submitted are identified in CEDRI by the Code of Federal 

Regulations citation to where the report is required to be submitted. Is this 

adequate for State/Local/Tribal (S/L/T) agencies’ purposes?

Data Access How would S/L/T prefer to access this data? We presume agencies would 

like immediate access to the data submitted to CEDRI.

a. Using a user restricted interface in CEDRI or by setting up an 

automatic system to view the data via the Exchange Network. 

b. Through a user restricted interface in WebFIRE.

How do we identify the reviewers to notify when reports are received by the 

CROMERR CDX archive?

EPA wants to provide a universal output format other than Microsoft Access 

for use by S/L/T agencies to review the data found in the ERT performance 

test reports. 

a. What alternatives should EPA consider for release at the same time 

CEDRI undergoes its next update? (i.e. XML Schema data dictionary 

definitions)
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2.2 Structure

The CEDRI IPT was composed of the following representatives from EPA, state, and local agencies. 

Exhibit 2-2 CEDRI IPT Participants

Participant Name State or Organization

Colin Boswell U.S. EPA, OAQPS

Mike Ciolek U.S. EPA, OAQPS

Robert Schell U.S. EPA, OAQPS

Gerri Garwood U.S. EPA, OAQPS

Bernard McKee North Carolina Dept. of Environment and Natural Resources

Nathan Wilkes U.S. EPA, OIC

Christy Monk Alabama Dept. of Environmental Management

Erica Engel-Ishida Ohio Environmental Protection Agency

Heather Sessing Oklahoma Dept. of Environmental Quality

Mike Ahern Ohio Environmental Protection Agency

Janell White Linn County, Iowa

Jason Swift U.S. EPA, OECA

Jim Hodina Linn County, Iowa

Kevin Vuilleumier U.S. EPA, Region V

Ray Walters New Hampshire Dept. of Environmental Services

Rob Lischinsky U.S. EPA, OECA

Ron Evans U.S. EPA, OAR

Haley Stowe U.S. EPA Region 7

Jim Pennington Florida Dept. of Environmental Protection

IPT meetings were held every 2 weeks between May 14, 2013 and September 10, 2013. A total of 8 meetings 

were conducted. The meetings were conducted via on-line conference call.

Prior to the IPT sessions, a questionnaire was distributed to the IPT participants. Questionnaire results are 

summarized in the spreadsheet and the PowerPoint presentation made part of this document by reference. The 

spreadsheet and presentation were used during the IPT meetings to guide and facilitate discussions.

2.3 Reference Documents

The documents listed below were used by the CEDRI IPT:

1. CEDRI IPT Questionnaire 05012013.docx

2. CEDRI IPT Questionnaire Summary 05202013.xlsx

3. CEDRI IPT Meeting Minutes 05142013_Final.docx

4. CEDRI IPT Meeting Minutes 05282013_Final.docx

5. CEDRI IPT Meeting Minutes 06112013_Final.docx

6. CEDRI IPT Meeting Minutes 06252013_Final.docx

7. CEDRI IPT Meeting Minutes 07092013_Final.docx
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8. CEDRI IPT Meeting Minutes 07232013_Final.docx

9. CEDRI IPT Meeting Minutes 08062013_Final.docx
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3 Summary of Findings

Report findings are organized by question groups as established in the objectives in the IPT Charter document. 

For each question group, a brief discussion of the question topic is first presented summarizing IPT viewpoints 

and considerations. The summary is then distilled into “Consensus Findings” for each question in the question 

group.

3.1 General Interest and Success Measures

A poll of the general level of interest of IPT participants in pursuing some form of electronic reporting had 67% 

interested and 33% unsure. No participants stated that they had no interest in pursuing electronic reporting. 

With respect to utilizing EPA’s electronic reporting program (using the CEDRI application to receive and review 

reports), 43% were interested, 14% were not interested, and 43% were not sure. Respondents cited the fact that 

they were already pursuing their own electronic reporting initiatives as the reason for not being interested. The

conclusion reached is that key factors for adopting EPA’s electronic reporting program are: the system should be 

able to accept data collected by the S/L/T agencies, and that the data exchange is centralized and efficient.

Two overarching principles that emerged from the IPT as fundamental to the CEDRI implementation are:

1. Identification of valid submissions:

a. A goal of the system should be to determine that the data submission is complete prior to state 

review and then only make quality-assured data available for public review. This could be 

accomplished by acknowledging that submissions may have not yet been reviewed; though the 

S/L/T agencies would need the ability to remove the flags once reviewed. 

b. S/L/T agencies all observe best practices to identify whether or not a submission has been 

reviewed, regardless of the type of submission (Air Emissions Report or ERT Performance 

Reports). Therefore, the ability to mark or flag a report should be given to all reporting types. 

2. Incorporating current S/L/T procedures:

a. With all requirements and decisions, the intent is to maintain current processes and procedures 

implemented by sources and S/L/T agencies. There is the possibility that a state may not review 

a report for a long time, due to existing framework that S/L/T agencies have for viewing tests and 

recording results.

b. S/L/T agencies want a way to tie their own reporting/reviewing flows into the data being collected, 

reviewed, and published in CEDRI. 

c. S/L/T agencies have the desire to minimize duplicated work/effort. Some S/L/T agencies keep 

information on reports and reviews in their own state system. 

d. All state parties desire a mechanism for easy transferability between review files 

uploaded/created with state-specific procedures and the state review file component of CEDRI.

3.2 Dataflow

The assumption was made that S/L/T agencies would like access to report submissions as soon as they are 

received by CEDRI and have sufficient time to review and process reports before they are made available to the 
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public through WebFIRE. The amount of time necessary for S/L/T agencies to review reports is addressed in the 

dataflow question group.

3.2.1 Processing Time for State Review

The period of time that submitted reports should be made available to S/L/T agencies to review and process was 

found to vary by state, report type and also report complexity. The standard among the S/L/T agencies is that 

reports (stack test reports) are required to be submitted within 30 to 60 days after the end of each quarter, and 

the S/L/T agencies then allow 30 to 60 days for the review and processing of the submitted reports.

State processing time will vary by report since the time it takes to review reports depends on the type of test, 

the source, the quality of the data, and the presentation of the data in the final report. 

Submitted reports that are released to WebFIRE for public access should indicate if the report has undergone 

state level review. This indicator may potentially be worked into the quality rating for the emission factor data. 

There is not a desire however to prevent the release of the report to WebFIRE if a state level review has not 

occurred.

Consensus findings: 

The processing periods for all reporting types will begin on the date the report is submitted. The following 

consensus was reached regarding submission processing periods:

1. ERT Performance Test Reports – The typical review period for ERT Performance Test Reports was 

determined to be 120 days. This is the consistent time S/L/T’s are given to enter data associated with 

their review of Performance Test Reports into the Air Facility System (AFS).

2. Air Emissions Reports - A shorter review process is typical for Air Emissions Reports than for ERT 

Performance Test Reports. IPT participants suggested a processing period of 30 days to be sufficient. 

3. Notification Reports – Since the CEDRI application will be collecting only the semi-annual Notification 

Reports, the review process will be much shorter than for ERT Performance Test Reports. 30 days was 

determined to be an appropriate period of time. 

3.3 Data Resubmission

The data resubmission question group addressed the handling of report resubmissions that incorporate S/L/T 

review comments. In the event a report must be re-submitted, the IPT agreed that the re-submissions should 

follow the same process as the initial report and be subject to the original processing period. On average 25% of 

submitted reports require resubmittal to correct anomalies. Some S/L/T agencies experience higher rates (33%-

50%) that may reach as high as 67% for some reporting types.

Suggestions for handling resubmitted reports that did not garner group consensus, but should be considered in 

the application include:

 The ability to mark resubmissions as ‘Ready to Release’ was suggested as a way to allow a resubmitted 

report to be released to WebFIRE at the completion of the review. The same approach may be applied 

to initial submissions as well.
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 Incorporating metadata that describes the reasons for resubmission, version chronology, resubmission 

timestamp, AFS ‘Pass/Fail’ results, and whether the review was conducted on paper or electronically. 

Consensus was not reached regarding whether both reports should be made publicly available through

WebFIRE. 

Those in favor of publishing both reports reasoned that:

 Some re-submissions may be due to serious problems or heavily invalid data/calculations and should be 

treated as a whole new test. 

 Since WebFIRE is a public repository, both reports should be publicly available. 

 If both reports are published, the re-submission must be distinguished, so as not to be duplicative.

Those who argued that only the final report should be published reasoned that:

 Some re-submissions are corrections to calculations or results that use the original field data. These 

should be treated as revisions to the original report, and indicated as such, instead of a completely new 

test. 

 The original reports should not be stored in WebFIRE but still be available upon request. 

 Only final reports should be published if there is a penalty for supplying incorrect information. 

Consensus findings: 

The following consensus was reached regarding report resubmission:

1. Reports that are resubmitted should undergo the same processing period as the superseded submission.

2. Notifications sent to reviewers should indicate that the report is a resubmission.

3. Notifications should also provide traceability to the superseded report and contact information of the 

individual submitting the report.

4. An electronic records trail should be maintained for resubmitted reports.

3.4 Data Requirements:

The data requirements question group is intended to determine how best to address the following S/L/T

reporting requirements:

 How to capture additional S/L/T data beyond that required by federal regulation.

 How to identify, or reference, the reports that are received by CEDRI and are available for S/L/T review. 

3.4.1 S/L/T Specific Data 

The data required by state, local, and tribal agencies varies by S/L/T. The ability to add comments and attach 

PDF files to reports submitted through CEDRI will accommodate many S/L/T agencies’ reporting requirements, 

but not all. Furthermore, since the reporting frequency required by the S/L/T agencies does not necessarily 

correspond with the required federal reporting frequency, report submission dates need to be time-stamped for 

compliance evaluation purposes.
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Interest was expressed by some S/L/T agencies in having CEDRI accommodate S/L/T specific data elements 

directly in the reporting forms. This type of functionality will require considerably more elaboration and is 

outside the scope of this IPT. The general requirement though is noted for future consideration.

The use of memo fields and the ability to attach PDF files is necessary, but may not be sufficient for capturing 

quality assurance checks and data calculations. 

Consensus findings: 

The following consensus was reached regarding S/L/T specific data requirements:

1. Report submission date/time must be captured so S/L/T agencies may determine reporting compliance.

2. Memo fields and file attachments are necessary for capturing S/L/T specific information, but may not be 

sufficient for capturing all S/L/T specific data. Further analysis is required to develop an approach for 

collecting quality assurance checks, data calculations, and other S/L/T specific data elements.

3.4.2 Report Identification

Allowing the source facility to apply a descriptive label to the reports being submitted was determined to be an 

important feature and would facilitate execution of report searches. The common practice is to label reports 

(stack test) by year, quarter, and facility, and having separate metadata for reporting period would further 

enhance report searching capabilities.

Reference to the CFR citation, although not typically used by S/L/T, was seen as potentially useful so that cross 

referencing may be performed. The Army Corps of Engineers maintains a citation cross-walk service for statutes 

in the Clean Air Act which may be utilized to provide cross reference between S/L/T citations and federal 

citations. 

Consensus findings: 

The following consensus was reached regarding the use of CFR citations to identify reports:

1. The CFR citation is of limited use to S/L/T agencies as permit citations and other S/L/T citations are used 

to identify required reports.

2. Further analysis is required to determine access to and the potential for utilizing the Army Corps of 

Engineers cross-walk service. 

3.5 Data Access

The ability for S/L/T agencies to access report submissions may be provided through CEDRI, WebFIRE or both.

The public may only access reports through WebFIRE and only after the S/L/T agency processing period has 

elapsed and the reports are transferred from CEDRI.

The data access question group addressed the following elements of data access:

 Which system should S/L/T agencies use to access reports before they are made publicly available?

 How should submission notifications be routed to S/L/T reviewers?
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 Should the S/L/T review results be stored with the report submission and should they be available for 

public access?

 What are the preferred alternate formats for ERT Performance Report submissions?

3.5.1 CEDRI versus WebFIRE Access

The IPT participants did not have a preference between CEDRI and WebFIRE for accessing reports. Whichever 

system is used, however, must allow access to S/L/T agencies prior to the reports being made publically 

available.

Consensus findings: 

The following consensus was reached regarding the system used by S/L/T agencies for accessing report 

submissions:

1. Although there was not a preference between CEDRI and WebFIRE, the consensus was that public 

access must be restricted until S/L/T agencies have a sufficient amount of time to complete review. 

3.5.2 Notifications

The need for notifying S/L/T reviewers that a report has been submitted through CEDRI and is available for 

review and processing is understood to be necessary to streamline the electronic reporting process. Email alerts 

are intended to be used as the mechanism to notify individuals registered as S/L/T Reviewers that a report has 

been submitted by a facility within their S/L/T of interest. 

Although CEDRI does not restrict the number of users who may register in the “State Reviewer” role and does 

not restrict the number of S/L/T agencies any given reviewer may register to access, alerts are typically not 

configurable at the level of granularity necessary to fully support S/L/T review operations. Although the criteria 

used to assign reports for review varies among the S/L/T agencies, a few criteria emerged that were common. 

Common criteria used to assign and route reports for review include facility and type of report (Stack Test, 

Emissions, etc.). Other less common criteria were also identified such as whether the facility is under an 

enforcement action or the industry sector to which the facility operates (NAICS code). 

Registration for the “State Reviewer” role will utilize the closed registration process in CDX, meaning the CDX 

support staff will initiate the registration process and the registrant will complete the process. Within the closed 

registration process reviewers may be registered to review reports from multiple S/L/T agencies.

Consensus findings:

The following consensus was reached regarding notification of submissions:

1. An email alert and a message in the CDX Inbox would be the best way to notify reviewers that a report 

has been submitted and is available for review and processing. 

2. It is feasible for S/L/T agencies to identify the personnel who will be conducting reviews. This will 

facilitate the closed registration process. 

3. Providing notification of submissions based on report type and/or facility to specific reviewers is a 

desirable feature. 
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4. Facilities should be identified by both the Facility Registry System (FRS) and the Air Facility System (AFS)

1

numbers as AFS number is the identifier most commonly used at the state/local/tribal level. FRS 

number is not commonly used. 

3.5.3 Review File Access

The ability to include review files with a submitted report was generally agreed to be a necessary feature. A

standardized review file template to minimize the variability in review comments was also thought to be a 

necessary feature. Inclusion of S/L/T specific requirements was stated as necessary by some participants. To 

accommodate both standardization and S/L/T specific requirements, a baseline template with the ability to 

attach additional material was determined to be sufficient to meet review requirements.

It was agreed that review files should be stored along with the submitted reports and be available for public 

viewing.

Consensus findings: 

The following consensus was reached regarding S/L/T review comments:

1. S/L/T review comments should be retained and stored with the report submission.

2. S/L/T review comments should be made publicly accessible.

3. A standardized review file template should be developed.

4. The ability to attach S/L/T specific review files to a report submission (or to a standardized review file 

template) should be supported. 

3.5.4 Alternate ERT Formats

The ERT, used to report stack test results, is the collection mechanism used by the current CEDRI application and 

will be used by the new CEDRI application. It is understood that alternate formats may be more efficient and 

preferred by S/L/T agencies.

IPT consensus was that the current Microsoft Access Database did not provide transparency in the underlying 

equations which made it difficult to audit calculations. Use of an Excel spreadsheet was suggested as a means of 

making the equations more transparent. Excel however, was thought to provide less security, thereby allowing 

potential manipulation of the underlying equations.

HTML5 was also suggested as an implementation approach to support both on-line and off-line completion of 

reports.

Defining and publishing an XML schema was seen as a necessary element regardless of implementation 

approach. A published schema allows testing companies to configure their test programs to produce output 

reports in a compliant format and supports quality assurance checks on the data contained in the reports. EPA 

should focus on defining the data required rather than on trying to develop a system that satisfies all industry 

participants. Furthermore, EPA is actively pursuing a web-based ERT. 

 

1 AFS is scheduled to be replaced by ICIS-Air in September 2014. Therefore, any reference to AFS should assume reference 

to ICIS-Air Program ID after implementation. 
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Consensus findings: 

The following consensus was reached regarding alternatives to the ERT:

1. An XML schema with business rules should be published that defines required data elements.

2. S/L/T agencies and other third parties may develop their own systems to produce compliant test report 

data.

4 Guidance and Recommendations

IPT consensus findings are summarized by question group in Exhibit 4-1. These findings will be used by EPA to 

develop the functional requirements for the CEDRI application.

Exhibit 4-1 CEDRI IPT Consensus Findings Summary

Question Group Topic Finding

Data Flow Processing Time 1. ERT Performance Reports – The typical review 

period for ERT Performance Reports was 

determined to be 120 days.

2. Air Emissions Reports - IPT participants 

suggested a processing period of 30 days to 

be sufficient. 

3. Notification Reports – 30 days was 

determined to be an appropriate period of 

time. 

Data Resubmission Data Resubmission 1. Reports that are resubmitted should undergo 

the same processing period as the 

superseded submission.

2. Notifications sent to reviewers should 

indicate the report is a resubmission.

3. Notifications should provide traceability to 

the superseded report and contact 

information of the individual submitting the 

report.

4. An electronic records trail should be 

maintained for resubmitted reports.

Data Requirements S/L/T Specific Data 1. Report submission date/time must be 

captured so S/L/T agencies may determine 

reporting compliance.

2. Memo fields and file attachments are 

necessary for capturing S/L/T specific 

information, but may not be sufficient for 

capturing all S/L/T specific data.
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Question Group Topic Finding

Report Identification 1. The CFR citation is of limited use to S/L/T 

agencies as permit citations and other S/L/T 

citations are used to identify required 

reports.

Data Access CEDRI/WebFIRE 1. Although there was not a preference 

between CEDRI and WebFIRE, the consensus 

was that public access must be restricted to 

all reporting types until S/L/T review is 

complete.

Notifications 1. An email alert and a message in the CDX 

Inbox would be the best way to notify 

reviewers that a report has been submitted 

and is available for review and processing. 

2. It is feasible for S/L/T agencies to identify the 

personnel who will be conducting reviews. 

This will facilitate the closed registration 

process. 

3. Providing notification of submission based on 

report type and/or facility to specific 

reviewers is a desirable feature. 

4. Facilities should be identified by both FRS and 

AFS number as AFS number is the identifier 

most commonly used at the state/local level.

FRS number is not commonly used.

Review File Access 1. State review comments should be retained 

and stored with the report submission.

2. State review comments should be made 

publicly accessible.

3. A standardized review file template should be 

developed.

4. The ability to attach S/L/T specific review files 

to a report submission (or to a standardized 

review file template) should be supported. 

ERT Alternatives 1. An XML schema should be published that 

defines required data elements.

2. Industry can develop the systems to produce 

compliant test report data.