April 2024 Steering Committee Session Recap

On April 11, 2024, Rudi Muenster met with members of the Steering Committee at the Duke Energy office in St. Petersburg, Florida, to discuss business development directives for the year ahead.

It was an action-packed day, with each team member bringing their perspective to the challenges and opportunities facing their organization and industry. Everyone rolled up their sleeves and tackled issues related to cyber security, challenges in staffing, major regulatory initiatives, and employee training. The group concluded the meeting by identifying and prioritizing various CEMLink6 development items in the backlog for the next 24 months. Team members provided valuable input on the timing of the release schedule and major features to be introduced, and they took the lead on writing functional development specifications.

The Steering Committee is a multidisciplinary advisory group of various industry members advising VIM on functional requirements associated with the CEMLink product. We’re eagerly seeking new team members from the pharmaceutical, pulp, and paper, and refining industries to join the team. Your unique perspectives and expertise will be invaluable.

For more information or to reach out to the Steering Committee with any questions, please send an email to steeringcommittee@vimtechnologies.com. To view existing Steering Committee members, visit www.vimtechnologies.com/steering-committee/.

Part 75 ECMPS Re-Engineering Update

On February 6, 2024, the EPA’s Clean Air Markets Division (CAMD) hosted a webinar to discuss modifications to the existing ECMPS 1.0 Client Tool to accommodate the Good Neighbor Rule and MATS Rule electronic reporting requirements that became effective January 1, 2024.  The deadline for implementing ECMPS 2.0 continues to be postponed indefinitely.  Indications are pointing to either a 2024 Q3 or 2025 Q1 implementation schedule, with 2025 the likely scenario.

The ECMPS 1.0 Client Tool MATS PDF Submit module will be modified to allow the submittal of XML, JSON, and PDF files and will be renamed accordingly.

CAMD stated that the release date for the stand-alone ECMPS Client Tool would follow the usual deployment schedule and take place around “mid-March.”  There were no personnel from EPA’s Office of Air Quality Planning and Standards (OAQPS) to clarify how certain reports would be formatted (XML vs. JSON vs. PDF).

The ECMPS 2.0 schema for the quarterly compliance report has not been finalized and the first report was anticipated to be in JSON format.  CAMD suggested that affected sources contact the delegated authority to obtain guidance on whether a PDF copy of the report could continue to be submitted in lieu of an XML or JSON.  The same confusion applies to the requirements to submit hourly PM CEMS data, hourly PM CPMS data, and 30/90-day rolling averages.  A recording of the webinar will be posted at https://www.epa.gov/power-sector/ecmps-re-engineering-effort but has not been loaded up yet.

All VIM Technologies customers running CEMLink6 who are subject to either the Good Neighbor Rule or the MATS Rule will require a CEMLink6 update before Q1 2024 reporting in April.  We are in the final phase of QC and will be prepared to release CEMLink6 Ver. 6.2.550 in late March.  This release will allow users to generate MATS quarterly compliance reports and PM CEMS quarterly emission reports in JSON format.

VIM recommends that MATS-affected sources contact their stack test contractors to ensure that they will provide the applicable required MATS stack test data elements specified in Sections 17 through 30 of Appendix E to the MATS Rule in XML format.  VIM is not planning to include a CEMLink6 module to generate XML files for MATS compliance tests for elements required in this section of the rule.

VIM Technologies will continue to stay on top of these changes and will provide an update when we know more.  In the meantime, please don’t hesitate to reach out to our COMPAS group (COMPAS@vimtechnologies.com) if you have any questions.

 

ECMPS 2.0 Start Date Postponed

UPDATE: ECMPS 2.0 Start Date Postponed

On November 15, 2023, the EPA’s Clean Air Markets Division (CAMD) hosted a webinar to discuss transitioning from ECMPS 1.0 (i.e., the ECMPS Client Tool) to the new web-based ECMPS 2.0 reporting platform. During the webinar, CAMD announced that ECMPS 2.0 would not be used to report quarterly QA and emissions files as initially scheduled for Q1 2024. Additionally, CAMD did not specify a new start date for ECMPS 2.0. The agency does not want to postpone the ECMPS 2.0 implementation date more than once, so they intend to conduct a thorough assessment of the status of the software platform before setting a new realistic start date. CAMD indicated that they hope to complete this assessment before the end of 2023. The webinar was recorded, and a copy will be posted to the ECMPS Re-engineering Effort website at https://www.epa.gov/power-sector/ecmps-re-engineering-effort

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EPA Administrator Signs Final Federal “Good Neighbor Plan” for the 2015 Ozone National Ambient Air Quality Standards

UPDATE: EPA Publishes Final Good Neighbor Plan In Federal Register

On June 5, 2023, EPA published the final Federal “Good Neighbor Plan” for the 2015 Ozone National Ambient Air Quality Standards in the Federal Register.  The rule effective date is August 4, 2023.  A copy of the Federal Register version of the final rule is available here.  Read below our previous News Post concerning the final rule.

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EPA Administrator Signs Proposed MATS Rule Revisions

On April 3, 2023, the EPA Administrator signed proposed revisions to Subpart UUUUU of 40 CFR Part 63, commonly known as the Mercury Air Toxics Standards (MATS) Rule.  The signed rule was submitted for publication in the Federal Register.  A copy of the unofficial internet version of the rule preamble is available here.  A redline/strikeout copy of the proposed rule is available here. Comments on the proposed rule must be received on or before sixty (60) days after the date of publication in the Federal Register.  EPA also intends to host a virtual public hearing on fifteen (15) days after publication in the Federal Register.  VIM Technologies (VIM) will post an official copy of this rule notification once it is published in the Federal Register.  A few key proposed revisions are outlined below.

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EPA Administrator Signs Final Testing Provisions for Air Emission Sources Rule

UPDATE (March 29, 2023)

Final Testing Provisions for Air Emission Sources Rule Published in Federal Register

The final “Testing Provisions for Air Emission Sources” rule was published in the Federal Register on March 29, 2023. The rule is effective on May 30, 2023. A copy of the final rule is available here

On March 7, 2023, the EPA Administrator signed the final “Testing Provisions for Air Emission Sources” rule and submitted it for publication in the Federal Register. The rule will become effective sixty (60) days after the date of publication in the Federal Register.
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ECMPS 2.0 Re-Engineering

Did You Know?

The Emission Collection and Monitoring Plan System (ECMPS) 2.0 web-based reporting platform is scheduled for mandatory reporting by Acid Rain Program, Cross-State Air Pollution Rule (CASPR), and Mercury Air Toxics Standards (MATS) Rule (Subpart UUUUU, 40 CFR Part 63) affected sources in 2024. More specifically, the Q1 2024 emissions and quality assurance (QA) files must be submitted via ECMPS 2.0 in JSON format by April 30, 2024, reporting deadline.Read more »

EPA Publishes Revisions to the Civil Monetary Penalty Inflation Adjustment Rule

On January 6, 2023, EPA published revisions to 40 CFR Part 19, Civil Monetary Penalty Inflation Adjustment Rule in the Federal Register.  The rule adjusts the maximum (and minimum) statutory civil monetary amounts for the statutes administered by EPA.  For the Clean Air Act, the rule increased penalties from $109,024 per day per violation to $117,468 per day per violation. The rule also increases the monetary penalty for Clean Water Act violations from $59,973 to $64,618. This highest statutory civil penalty tier applies to violations that occurred after November 2, 2015, where penalties are assessed on or after January 6, 2023.  A second monetary penalty tier applies to violations that occurred after November 2, 2015, where penalties are assessed on or after January 12, 2022, but before January 6, 2023.  The rule becomes effective on January 6, 2023. A copy of the rule is available here.

EPA Publishes Revisions to Greenhouse Gas Reporting Rule in Federal Register

NEW UPDATE:

On July 19, 2022, EPA extended the comment period on the proposed “Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule” from August 22 until October 6, 2022.  A copy of the Federal Register notice is available here.


On June 21, 2022, EPA published the proposed “Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule” (i.e., 40 CFR Part 98) in the Federal Register. A few selected proposed amendments are discussed below.Read more »

EPA Good Neighbor Plan

Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard Published in Federal Register

UPDATE:

On May 12, 2022, EPA extended the deadline to submit public comments on the proposed “Good Neighbor Plan” from June 6 until June 21, 2022. A copy of the Federal Register notice is available here.


On April 6, 2022, EPA published the proposed “Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard” in the Federal Register. EPA is proposing this rule under the “good neighbor” or “interstate transport” provision of the Clean Air Act (CAA or Act). The proposed rule, referred to by EPA as the Good Neighbor Plan, includes several key components discussed below.Read more »