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On April 22^nd, 2025, EPA’s Clean Air and Power Division (CAPD) provided a status update on the ECMPS 2.0 re-engineering effort. The blog post can be found here.

The key takeaway from the message is the delay for ECMPS 2.0 implementation until at least Q1 2026 (from Q3 2025). This announcement didn’t take us by surprise considering the beta testing environment has been unavailable for 9 of the last 10 months!

If you haven’t already done so, we strongly encourage you to get set up with CDX and CBS test accounts and start playing around with the new ECMPS 2.0 web-based client tool. EPA created a quick start guide that will walk you through setting up your test accounts in all applications (CBS, CDX and Login.gov). It also describes the various roles and responsibilities within CDX and what to expect during the official migration expected sometime next year.  To get a copy of the startup guide click here or visit the re-engineering page at https://www.epa.gov/power-sector/ecmps-re-engineering-effort.

We are excited to hear that ECMPS 2.0 beta environment is back on-line, but most importantly to hear that it’s been backfilled with historical MP, QA, and EM data through Q3 2024. The ECMPS 2.0 tool, even when it was on-line, was relatively unusable due to out-of-date records in monitoring plans and the divergence of data between production and beta systems. Any JSON files that were produced by a DAHS likely contained outdated monitoring plan information that weren’t present in the beta system.

Some other good news is that there was no mention of any JSON schema updates. This means that any CEMLink6 DAHS systems running 6.2.620 or greater are equipped with the tools they need to start playing around in the beta environment. If you’re unsure the version you’re running or need help getting your DAHS updated, please contact our support group at support@vimtechnologies.com or call us 1-866-484-6435 and follow the prompts for support.

Unfortunately, one area where EPA is digging in their heels, is regarding Contractor Access. This is a topic we have been very vocal about to both EPA and industry for the last 3 years. This is a feature that’s available in CBS and the current stand-alone ECMPS 1.0 Client Tool and one that the vendors (DAHS, Consultants and Stack testers) rely on to access key information. Without an equivalent feature in ECMPS 2.0, industry will be forced to add a significant number of preparer agents under the sponsor (original DR or ADR) to get the support they need.  It’s imperative that industry press EPA on this subject because it will pose a significant burden to you as it’s currently architected.

VIM will continue to stay abreast of the ECMPS 2.0 developments and update this blog as relevant information becomes available. Please contact our COMPAS group at compas@vimtechnologies.com for more information concerning the ECMPS 2.0 implementation or any questions you may have.

On Tuesday, April 8, 2025, the President issued a Presidential Proclamation exempting specified stationary sources, listed in Annex I of the Proclamation, from compliance with the “National Emissions Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review” (89 Federal Register 38508) (the “Rule”).  A copy of the Proclamation and Annex I list is available HERE.  As specified in the Proclamation, the President’s exemption extends the compliance deadline for two (2) years beyond the Rule’s current compliance date (i.e., for the period beginning July 8, 2027 through July 8, 2029).  During the 2-year exemption period, the coal-fired sources listed in Annex I are subject to the compliance requirements that they are currently subject to under the Mercury and Air Toxics Standards (MATS) as the MATS Rule existed before the “RTR” MATS Rule (89 Federal Register 38508).

Facilities listed in Annex I must maintain compliance with the pre-RTR MATS standards. Monitoring, reporting, and quality assurance programs should continue to follow the requirements in place before the 2024 RTR amendments.  Affected sources not listed in Annex I must comply with the RTR MATS Rule requirements effective July 8, 2027.  It is unclear if MATS affected sources not listed in Annex I can request a similar Presential exemption.

While the exemption provides temporary relief to some sources, facilities should continue preparing for eventual compliance with the RTR MATS Rule.  Proactive planning and system readiness are essential for long-term compliance.

For more information or to schedule a compliance consultation, please contact VIM Technologies, Inc. (VIM).  VIM remains committed to being a trusted partner in environmental compliance, helping clients navigate regulatory changes with confidence and precision.

Stay tuned to the VIM Technologies News section for ongoing updates and expert insights on air compliance regulations.