These changes will require DAS (DAHS) vendors to update software and will affect ECMPS reporting starting with Q2 2019 submissions. Draft Instructions are available.
Beginning with 2nd quarter 2019, CAMD’s ECMPS* will require the System and Component IDs to be reported for all missing data periods. These new requirements will also apply to any re-submission of old data.
There are several good reasons for requiring the IDs to be reported. It will simplify the tracking of operating hours and required QA and should reduce inaccurate errors and messages from ECMPS. This is because all times and activities should now be tied to the correct systems and components without the breaks previously caused by missing data periods.
ESC and all other DAS (DAHS) vendors will have to alter our software to accommodate this change. For ESC, it is a normal part of working with the always-changing requirements of air compliance reporting. We have completed much of the the basic work, based on previously published information.
Draft Instructions are now available from the ECMPS Support Reporting Documentation page. We and our customers have questions which we have submitted to EPA. These questions relate to differences between what was previously published and what is in the draft, and also to applicability. We will update this article when we have a response.
There will also be a vendor technical Q&A session on May 7th, held in conjunction with the EPRI CEM User Group 2019 event, which we will attend. Once we have that information we can review, finalize and test the changes in time for our regular quarterly release in June.
If your DAS vendor hasn’t contacted you yet to let you know about this change, then you should contact them and ask about the status of their updates. EPA has an action item for all ECMPS users to work with their vendors to make sure the changes are in place for Q2 reporting. Previous instructions specifically indicate not to report these IDs during periods of missing data, so re-submission of historical data could be especially problematic, depending on how your systems store this data.
Failure to report the IDs will generate an Informational Message during Q2 reporting, giving everyone a little bit of a grace period to report correctly. However, EPA could change this to a Critical Level 1 error as early as Q3, based on what they have published.
EPA will monitor the number of instances resulting in this Informational Message and will change this error message from Informational to Critical Level 1 in the future based on that information.
For more details, see the ECMPS News https://ecmps.blogspot.com/
*The Emissions Collection and Monitoring Plan System (ECMPS) is part of a larger effort by the Clean Air Markets Division of the EPA to reengineer the processes and data systems that are used to collect data for cap and trade emissions reduction programs. - from Introduction to ECMPS
Current customers may contact the ESC Support Team with questions, contact support.
If you are not yet a customer, we will still be happy to answer questions about the ESC DAS and our response to the new ECMPS reporting requirements, contact us here.
ESC Staff Published: 4/12/2019 1:13:57 PM
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