1 Rule Purpose
1.2 Revise and streamline the electronic reporting requirements of MATS
Comment 1: Commenters 20593, 20595, 20597, 20599, 20607, 20609, 20610 and 20612 supported EPA's efforts to streamline the MATS reporting requirements. Commenter 20595 supported the sole use of the XML format and ECMPS for MATS reporting. Commenters 20597, 20599, 20610 and 20612 supported the use of the ECMPS as the single reporting system, and agreed that EGU owners or operators would use one familiar electronic reporting system, instead of two separate systems, reducing their burden. The commenters noted that there are further revisions EPA should make. Commenters 20597, 20610 and 20612 stated there are duplicative and unnecessary reporting requirements that are a burden on reporters. Commenter 20610 stated that EPA can still make additional changes that will ease the proposed reporting burden while still providing adequate information to document substantial compliance with the regulations. Commenter 20609 stated there are unresolved issues and inconsistencies from prior rulemakings that have complications for compliance reporting that EPA will have to address in this rulemaking.
In response to EPA's statement regarding a reduction in the reporting burden through the use of a single system, commenter 20597 requested EPA to reduce the burden of the MATS reporting by the MATS reporting requirements by reporting all the data through the ECMPS Client Tool. The use of ECMPS will benefit both EPA and the industry while improving the quality of the reported emissions and performance stack test data. The commenter also noted that while the revisions may be intended to streamline the original reporting requirements, the revisions represent a substantial change to the way that MATS data are reported. In addition to addressing the existing reporting requirements, the proposal also includes three new appendices and new reporting requirements.
Commenter 20599 noted concerns with certain proposed amendments, particularly the timeline EPA has proposed for sources to begin following the new proposed data collection requirements and changes to the quarterly emissions and CEMS Performance Evaluation Reports.
Commenter 20610 supported the current practice of submitting test reports electronically within the interim reporting structure, and understood the EPA was making improvements to this system. The commenter said this proposal now suggests that this worthwhile and well-designed tool be burdened with many additional requirements beyond what is necessary to demonstrate compliance.
Response 1: The Agency acknowledges the support from commenters for use of the Emissions Collection and Monitoring Plan System (ECMPS) Client Tool as the sole means for electronic reporting. As described in later responses, the rule has been adjusted to account for many of the commenter's claims of duplicative and unnecessary reporting.  As the commenter notes, some reporting frequencies have been changed to quarterly to better mirror the requirements of the industry-requested ECMPS  Client Tool. As shown in later responses, the extension of quarterly PDF file submissions will continue through December 31, 2020. After that date, MATS electronic reporting via the ECMPS Client Tool will be required. As discussed in later responses, the Agency finds that there are no superfluous reporting requirements: each is necessary for compliance determination.

Comment 2: Commenter 20606 stated EPA has failed to work with state partners to coordinate any streamlining efforts so that EGU's would not be subject to multiple reporting regimes for the same information. The commenter stated that the Michigan Department of Environmental Quality-Air Quality Division (AQD) confirmed that EGUs would still be required to file hard copy reports based on the current AQD reporting structures and guidelines.
Response 2: The Agency finds the commenter's concerns misplaced: EPA has no ability to change unilaterally state, local, or tribal statutes which may contain separate reporting requirements. The Agency continues to work with other regulatory bodies, sharing the benefits of a single electronic reporting system. The commenter may find that messaging could be successful with its state, local, or tribal authority.

Comment 3: Commenter 20594 recommended that EPA clarify whether there are paper reporting requirements for MATS in addition to those proposed involving ECMPS. The commenter noted that the proposed rule goes on to discuss requirements for submittal of data in ECMPS, but it is silent on whether the proposed new reporting scheme replaces all paper reporting. The commenter said the rule also does not cover whether the ECMPS submittal will also go to the permitting authority (the state). The commenter recommended EPA should specify whether the new reporting scheme replaces all paper submittals and courtesy copies to EPA (Region and Headquarters) and to the permitting authorities.
Response 3: Use of the ECMPS Client Tool to submit a required MATS report or notification satisfies any requirement in Subpart A of Part 63 to submit that same report or notification to the EPA Regional or State Office, as described in section 63.10021(f). Once submitted to ECMPS, the electronic report will be available for EPA's central data exchange / compliance and emissions data reporting interface (CDX / CEDRI), where only the regulatory authorities and certifiers registered with CDX / CEDRI can view and download the electronic report.  After a 30 or 60 day processing period, the electronic report will be pushed to WebFIRE, where anyone can view and download the electronic report.  It is important to note that while federal reporting requirements are fulfilled when electronic reporting requirements are used, other, nonfederal regulatory authorities operating in accordance with their own statutory authorities may still require reporting via other media.
1.4 Reduce the reporting burden via the use of a single reporting system
Comment 1: Commenter 20612 disagreed that the proposal will have no significant impact on stakeholders. The commenter stated that the revisions represent a substantial change to the way that MATS data are reported, even though the intent was to streamline the original reporting requirements. The commenter noted the addition of three new appendices. The commenter urged the EPA to provide adequate time to allow changes to be implemented in a reasonable and orderly fashion that will ensure consistent and accurate reporting of the compliance data.
Response 1: The Agency maintains that in merging the separate electronic data reporting systems  -  which is being pursued at industry's request  -  the reporting requirements are shifted from 2 systems to 1 system.  Even though electronic monitoring submission frequency has been increased and provisions for PM, HCl, and HF CEMS, as well as PM CPMS, have been added, in order to align with using the industry-requested ECMPS Client Tool, the Agency finds the change yields an overall burden reduction in reporting and recordkeeping requirements. This annual burden reduction of about $4.2 million per year provides no significant impact on EGU owners or operators, as that reduction amounts to about one-tenth of one percent of projected net utility income for 2015 (see 81 FR 67070, September 29, 2016 and page 2-15, https://www3.epa.gov/ttn/atw/utility/mats_final_ria_v2.pdf).
Comment 2: Commenter 20612 stated that EPA has no basis for saying that the proposed MATS data elements that would be reported electronically for performance tests and CEMS performance evaluations remain unchanged. The commenter said the original requirement to submit data using the ERT is not synonymous with a requirement to provide all the data within the forms represented by all the data input screens in the ERT as EPA seems to be suggesting. It only means that a source would have to report the applicable required performance test data in the format that the ERT generates. The commenter suggested that the situation would be analogous to saying that an individual must report tax information using the forms provided by the Internal Revenue Service, allowing a source to report the data in the ERT that was required by the rule and that applied to their source under the original MATS. The commenter stated EPA needs to recognize that MATS sources were never required to report all the data within the ERT. Rather than just assume that it has to replicate some assemblage of ERT within Appendix E (or any new XML reporting format for stack test data), the EPA should be reflecting on how best to report the data: what data needs to be reported, what portion of that data is critically required in a numeric XML format, and what data is adequately or better addressed within a detailed stack test report that can be submitted electronically in a PDF (or equivalent) file.
Commenter 20602 said the proposal changes the reporting requirement from semiannual to quarterly. This would increase the burden significantly, doubling the annual reporting needed with little change in the flow of information, since the same information would be reported either way. The commenter suggested that the semiannual reporting criteria be maintained rather than switching to quarterly reporting.
Commenter 20606 stated the new reporting requirements significantly increase the amount of information industry has to report to the EPA, as well as the frequency at which such information is submitted (i.e., quarterly versus semi-annually). The commenter said this proposal's shift towards submittal in XML format presents new burdens on the affected sources that EPA has failed to adequately justify. The commenter identified the following information as being submitted in addition to what was required in the February 16, 2012 final rule.
 Hourly PM CEMS concentrations as mg/wscm, as well as mg/acm, and the temperature and pressure values used to convert from mg/acm to mg/wscm if the PM CEMS measures in units of mg/acm;
 Hourly PM emission rate in units of the applicable standard;
 The results of all PM CEMS daily Quality Assurance (QA) assessments; Hourly average output for PM CPMS or codes indicating that the CPMS was out-of-control, as well as percent monitor availability (PMA) information;
 30- or 90-boiler operating day (or group boiler operating day, for units participating in averaging plans) records for units employing CEMS or CPMS for compliance purposes or participating in an averaging plan;
 Summary records for any stack testing or 30- or 90-boiler operating day Low Emitting Electric Generating Units (LEE) test completed during each calendar quarter.
The commenter said this proposal will result in a decrease in staff time devoted to MATS reporting obligations as compared to the February 16, 2012 final rule. At best, the proposed rule entails just as much effort as that associated with the final rule. Although some level of efficiency may be gained in the submittal process by using a single EPA electronic reporting tool as opposed to multiple tools, the EPA has expanded the amount of information EGUs are required to submit electronically and added additional electronic summary records that were not initially required.
Commenter 20608 stated the proposed requirements represent a substantial improvement over the original MATS reporting requirements; but still contain significant amounts of areas where changes are needed to ease the burden of reporting. The commenter did not agree that this was a simple formatting change that will have "no significant impact on stakeholders." The commenter did not support using ECMPS as the single MATS reporting system instead of using the two reporting systems (ECMPS and ERT/CEDRI).
Commenter 20607 supported EPA's effort to streamline reporting, but stated some provisions in the proposed rule would increase the reporting burden on companies and state agencies, and should be amended in the final rule. The commenter said failure to do so would thwart EPA's attempt to simplify and facilitate reporting, as well as consume the cost savings gained by converting to a single reporting system.
Response 2: As mentioned earlier, while the rule increases some submission frequencies and includes provisions for new types of CEMS and CPMS in order to make the electronic reporting system consistent with the industry-requested use of the ECMPS Client Tool, the Agency determined an overall decrease in industry burden resulting from those changes. However, this annual reduction is very small  -  on the order of one-tenth of one percent  -  when compared to annual net income of the industry, so there is no significant change in industry reporting or recordkeeping burden.
While use of the Agency's Electronic Reporting Tool (ERT), which collects all relevant compliance information for emissions testing, was mandatory in the original promulgated rule, a separate XML schema that identifies components of relevant compliance information has been prepared - at industry's request  -  and is available for use in electronic reporting (see EPA-HQ-OAR-2009-0234-20586 at www.regulations.gov) . Use of the ERT remains a viable option for an EGU owner or operator to submit an emissions test, but its use is no longer mandatory.
As discussed in the proposal, this rule reduces reporting burden on industry by over $4.2 million per year while maintaining the burden on state, local, and tribal authorities (see 81 FR 67070, September 29, 2016).
2 Interim Reporting Period
2.1 Extension of interim PDF reporting process from April 16,2017 to December 31, 2017
Comment 1: Commenters 20594, 20596, 20597, 20599, 20600, 20607, 20609 and 20612 stated EPA has not allowed enough time to implement the proposed changes. The proposed rule would require sources to begin following the new proposed requirements for data collected starting on January 1, 2018. Sources and EPA will need more time to implement these changes. The proposed changes will require sources (and/or their software vendors) to make substantial changes to the data acquisition and handing system (DAHS) software that they use for MATS reporting. Programmers will need to interpret the regulations and reporting instructions to ensure that the DAHS software addresses the various reporting options that are allowed under the MATS rule and the different monitoring scenarios that might be used at numerous plants. The software vendors will need to make these changes while supporting the on-going reporting under the existing requirements, which may necessitate cumbersome parallel revisions to their reporting platforms. Iterative rounds of beta testing may be needed to ensure the proper performance of software. The beta testing will require interaction between the software vendors, utility personnel and, at times, EPA to identify and resolve issues prior to the date that actual reporting begins. Stack test companies will also need to develop spreadsheet and/or other tools to accommodate the proposed changes to the way performance test data are reported under Appendix E. All these tasks take time to do properly. Commenter 20595 added that the agency is requesting information on each data set of a RATA, 30-day averages, and other requirements that have not normally been part of the ECMPS software package or reporting requirements within ECMPS. Commenter 20594 stated concern that a shortened transition period would limit vendor availability, making it even harder to complete all of this work in the time frame proposed.
Commenters 20594, 20597, 20599, 20607, 20609 and 20612 noted that implementation of the changes is also predicated on the Agency both finalizing the rule changes and providing reporting instructions. Sources and software vendors cannot assume that the reporting requirements will stay the same between the proposed and final rules. In addition, EPA did not provide a draft of the reporting instructions for the proposed stack test data for the PM CEMS or HCl CEMS related reporting requirements, which further limits the degree of preparation that can be made prior to the release of final version (and associated reporting instructions). Since the requirements may change, the Agency will need time to develop draft reporting instructions once it finalizes the reporting requirements. And then, EPA will, likewise, need time implement the new requirements within ECMPS and the database systems that will ultimately receive the data.
Commenters 20597, 20604, 20607, 20608, 20609, and 20612 disagreed that EPA will be able to finalize the rule by April 16, 2017. The commenters said that all stakeholders will need more than six months to get the program up and running. Commenters 20597, 20603, and 20608 urged the agency to carefully consider comments and not rush finalizing this rule by the date proposed.
Commenter 20612 stated that there are many changes that will need to be made, and suggested that EPA refer to the schedule of activities from when CAMD was implementing the new XML reporting requirements that were included in the original MATS rule. Commenter 20609 said the timeframe will need to include solicitation of feedback on the remaining reporting instructions, discussions to resolve rule ambiguities or inconsistencies, and EPA's revisions to the ECMPS Client Tool. The commenter added all stakeholders (EPA, EGUs, software vendors, and source testing companies) will need time to properly implement the new requirements, including time to resolve new questions that will arise during implementation. Commenter 20604 noted that MATS implementation took over two years from rule publication to the first quarterly reporting compliance requirement. Extra time was needed to address exceptions and special circumstances, via multiple schema, Client Tool, and Reporting Instruction version releases.
Commenters 20597, 20608, and 20609 urged EPA to ensure that the current transition period is long enough to prevent reversion to the 2012 reporting system while EPA completes this rulemaking, and to reconsider the amount of time it has proposed for implementation of the new requirements. Commenter 20593 requested that the Agency take specific action to delay the expiration of the interim reporting provisions under MATS and provide adequate time for implement reporting requirements in the final rule. The commenter said to ensure the work accomplished by the Agency and industry groups over that last four years are not undone by a timing technicality; the transitional reporting period deadline must be extended. Commenter 20600 noted that based on their experience with past revisions to electronic reporting requirements, they anticipate software development time will be at least six to eight months, followed by approximately three months for implementation and deployment to our customers.
Commenters 20597, 20608, and 20612 recommended the EPA extend the current interim reporting requirements and mandate the new reporting begin with the data collected eight quarters following the date when the final rule is published. Commenter 20612 disagreed that the transition can take place in six quarters. Commenter 20609 requested that EPA lengthen the implementation period to a minimum of 6 calendar quarters. The commenter suggested that the rule include a start time that is expressed as a number of full calendar quarters after the effective dates of the final rule, instead of January 1, 2018. Commenter 20593 said the Agency should issue a stand-alone, direct final rule to extend the interim reporting period in the rule to January 1, 2020. Commenter 20594 suggested that the transition date be delayed until the first quarter of 2019 with 2018 serving as an optional full-scale trial of the new software, which is similar to the 2008 roll-out of ECMPS. Commenter 20599 encouraged EPA to extend the timeframe for temporary use of PDF submissions in the ECMPS Client Tool to December 31, 2018. Commenter 20603 urged the EPA to extend the interim reporting requirements, providing for submittal of certain reports through ECMPS in PDF format, indefinitely until such time as the agency completes the rulemaking transitioning all reporting to ECMPS. Commenter 20596 supported extending the interim reporting process until January 1, 2020. This will allow time to complete the development of the final reporting process that includes all the necessary compliance reporting elements. The commenter recommended a phased in approach over the next three years (2017  -  2019). This phased in approach is similar to the successful process adopted by the Agency which was implemented back in the 2007-2008 timeline for the transition under the ARP from the old ascii file to the current XML EDR file format: 2017 will be used by the Agency to flush out the requirements, reporting instructions and schemas to complete the electronic reporting process; 2018 will be used by the DAS vendors to develop the appropriate software changes, perform internal testing and to implement beta testing of the software that they will need to develop; and, 2019 will be used to roll out the software by the software vendors to the end users and make whatever configuration changes necessary to the hundreds of software systems which are operating in the field to generate clean, complete and error free submissions of Monitoring Plan records, quality assurance test data and results, and the final hourly and summary records for the recorded emissions. The commenter also recommended an ECMPS beta period in 2019 where vendors and facilities can do trial submissions for testing purposes. Commenters 20597 and 20608 requested this be extended immediately until January 1, 2020, with a brief final rule that makes only that specific change. Once the interim reporting period is extended, EPA would then have more time to complete the other revisions in a second final rulemaking. Just as EPA initially indicated that it would issue these revisions as a direct final rule but later revised its approach when it deemed a proposed rule to be a better option, the Agency should now also modify its original planned deadline. Commenter 20600 requested extending the interim reporting provisions through at least 2018. Commenter 20607 said EPA should extend the deadline to January 1, 2020. Commenter 20604 suggested that EPA extend the compliance deadline to July 1, 2018 at the earliest. To attain this date, two fundamental activities must be accomplished: (1) This proposal must be published by the expiration of the interim reporting rule on 4/17/2017, and preferably earlier, and (2) EPA must publish final schema and ECMPS Reporting Instructions in a timely manner after finalizing this rule. The commenter requested that EPA commit to publishing a final schema with Reporting Instructions within four (4) months of the final rule signature date. This would allow DAHS vendors, along with the stack testers, eight (8) months to work with the final version of schema and reporting instructions, and give EPA eight months to release beta versions of Client Tool and resolve issues with beta xml submissions. The commenter said this is a more reasonable time frame for all parties concerned to achieve an orderly transition to the new reporting requirements. The suggested July 1, 2018 compliance date would need to be delayed accordingly if EPA is unable to meet the above timeline.
Commenters 20597, 20608, and 20612 noted that extending the interim reporting period will have no impact on either a source's obligation to comply with the MATS emissions limits or the requirement to conduct monitoring or testing to demonstrate such compliance nor will extending the interim reporting prohibit the EPA from using the reported data to assess compliance.
Response 1: EPA agrees that the proposed December 31, 2017 end date for the interim PDF reporting process did not allow enough time to finalize the rule and implement the new reporting requirements.  In view of this, as suggested by some commenters, on April 6, 2017, the Agency published an extension of the interim reporting process through June 30, 2018 (see 82 FR 16736, April 6, 2017).  New requirements include hourly reporting of PM CEMS and PM CPMS data and reporting of certification and QA tests of HCl CEMS using PS 18 and Procedure 6. Therefore, today's rule further extends the interim PDF reporting through December 31, 2020, to allow enough time for software programming and all of the other activities associated with implementation of the single data system initiative.
The rule's new deadline for ending interim PDF reporting  -  some 13 calendar quarters after publication  -  amply addresses the commenters suggested implementation dates for electronic reporting. Commenters suggested implementation dates ranged from 2 to 8 calendar quarters after publication of the final rule in order to allow sufficient time so that software can be developed and tested prior to the deadline.  The Agency notes that software developers have been able to start their efforts since September 2016, when the XML schema for performance tests was placed into the docket (see EPA-HQ-OAR-2009-0234-20586 at www.regulations.gov).
3 63.10011-Initial compliance with emission limits and work practice standards
Comment 1: Commenter 20612 stated §63.10011(e) was not revised as described in the preamble. The commenter believed the change described in the preamble is unnecessary, and they recommended that EPA not include such a change in the final rule.
Response 1: The rule corrects this inadvertent oversight.  The revisions to §63.10011(e) described in the preamble of the proposed rule have been finalized.
Comment 2: Commenter 20609 stated that the general provisions require reporting all reports to the delegated authority and the EPA regional office (unless EPA waives the requirement), and after a Title V permit has been issued, reporting the Notification of Compliance Status and performance test results to the appropriate permitting authority. The commenter argued that EPA has no basis to require EGUs that are reporting information directly to a central EPA reporting system to duplicate those reports in separate submissions to states and regions, and that they have access to the relevant information through the SMS. The commenter noted a few places in the proposal where EPA should address this issue. The commenter said EPA must make other revisions to make clear that such duplication is not required. Specifically, the commenter suggested EPA either amend Table 9 to make clear that the duplicative reporting in the general provisions is not applicable to Subpart UUUUU and/or by including in § 63.10011(f) a statement that: "Submission of a report using the ECMPS Client Tool satisfies any requirement under subpart A of this part to submit that report (or the information in that report) to the appropriate EPA Regional Office or State agency of a delegated authority." The commenter noted EPA did this in a similar issue with respect to written "excess emissions" reports under § 63.10(e)(3)(v). The commenter said if EPA does not do this, EPA must explain and solicit comment on its rationale for requiring duplicative reporting of this information and how it can be reconciled with the proposed electronic submission requirements in § 63.10031(b)(2) and (3).
Response 2: See the earlier response to Comment 3 of Section 1.2.
Comment 3: Commenter 20609 stated that some standardization is needed to harmonize deadlines for the quarterly emissions reports with quarterly reporting under Part 75. This will ensure EGUs have the full period of time intended under all programs. The commenter noted that EPA must address the potential that EPA Host System maintenance outage could adversely impact EGUs' ability to meet fixed reporting deadlines. EGUs are required to include MATS emissions information in the same quarterly report used to satisfy Part 75. The commenter noted EPA has not yet provided any option to submit MATS data separately. To ensure that EGUs are not forced to submit ARP and CSAPR quarterly emissions reports earlier than they would be required to under § 72.11, or to submit a report on a weekend or Holiday, the commenter suggested EPA revise the MATS rule to provide similar deadline extensions. To address Host System outages, the commenter requested that EPA provide in the rule explicit extension of the reporting deadline if the EPA Host System is offline and not available for submissions at any time on the day a report is due. Specifically, the commenter suggested the following (or similar) language to § 63.10011(f) (or some other appropriate provision) to provide similar instructions: "If the final date of any time period (or any deadline) for submission of a report using the ECMPS Client Tool falls on a weekend or a Federal holiday, the time period shall be extended to the next business day. Moreover, if the EPA Host System supporting ECMPS is offline and unavailable for submission of reports for any part of a day when a report would otherwise be due, the deadline for reporting is automatically extended by the number of days affected by the outage." The commenter said if the revision is not made, EPA explain and solicit comment on its rationale for not addressing EPA Host System outages and for imposing different deadlines under Part 75 and MATS for the same quarterly reports. EPA also must explain why such a provision is not appropriate for the new quarterly compliance reports submitted under § 63.10031(g).
Response 3: The final rule includes statements which extend the deadline for required submittals in two circumstances: (1) when a deadline falls on a Federal holiday or weekend; and (2) when the ECMPS host system is in outage on the deadline.  As described in the preamble, in the first case, the deadline is extended to the next working day.  In the second case, the deadline is extended to the first business day after the system outage.  See section 63.10021(f).
Comment 4: Commenter 20609 supported EPA's proposed clarification of the applicability of § 63.10011(g)(3). The commenter specifically agreed the clarification that it only applies to EGUs that rely on paragraph (2) of the startup definition is helpful. The commenter requested that EPA include the same clarifications in § 63.10021(h)(3) and (i), § 63.10031(i), and Table 8 Item 12. Because § 63.10031(c)(5) only applies to EGUs opting to use that definition, the provisions requiring compliance with that section should be identical. Although § 63.10031(c)(5) is clear in its applicability, inclusion of the qualification in some but not all of the relevant provisions that reference § 63.10031(c)(5) could cause confusion.
Response 4: The following sections of the rule have been amended to further clarify that these sections apply only to EGUs that are relying on paragraph (2) of the §63.10042 definition of startup: §63.10031(i); Table 3, Items 3 and 4; and Table 8, Item 12.
4 63.10021-Continuous compliance with EL, operating limits, and WPS
Comment 1: Commenter 20609 supported EPA's revision to replace the general reference to § 63.10031 in § 63.10011(g) and § 63.10021(h) with a more specific reference to § 63.10031(c)(5).
Response 1: The Agency appreciates the commenter's support regarding the revised language.

Comment 2: Commenter 20612 recommended the proposed revisions should clearly indicate that the electronic reporting requirements satisfy general Part 63 reporting requirements. The commenter provided an example stating a source that submits MATS stack test data via ECMPS would not still need to submit that same data to the state and EPA regional office under §63.13 unless specifically required by the state or regional offices to do so. The commenter recommended EPA clarify that submitting the files through ECMPS will meet the requirements to report the same information to the state/region in the general provisions of Part 63. Specifically, the commenter suggested that §63.10021(f) could read: "(f) You must submit the applicable reports and notifications required under §63.10031 (a) through (n) to the Administrator electronically, using EPA's Emissions Collection and Monitoring Plan System (ECMPS) Client Tool. Submission of a report using the ECMPS Client Tool satisfies any requirement under subpart A of this part to submit that report (or the information in that report) to the appropriate EPA Regional Office or State agency of a delegated authority. If the final date of any time period (or any deadline) for submission of a report using the ECMPS Client Tool falls on a weekend or a Federal holiday, the time period shall be extended to the next business day." The commenter said this change would be consistent with the current provisions in §63.10031(f)(5) and would allow sources to benefit from the paperwork reduction that is supposed to be an advantage of electronic reporting and avoid continuing to have to report hardcopy unnecessarily. States and other delegated authorities already have the right to request any report in hardcopy, if deemed necessary, under §63.10031(f)(5). The last sentence of the suggested language is consistent with federal agency practices.
Response 2: See the earlier responses to comments 2 and 3 of section 3.
Comment 3: Commenter 20609 found error in the provision where Section 63.10021(e)(9) currently specifies reporting of the date in "hard copy" under § 63.10031(f)(5) until April 16, 2017. Section 63.10031(f)(5) is a provision that only applies to reports that are not the subject of other reporting requirements in paragraph (f). However, as noted above, § 63.10031(f)(4) explicitly requires that the semi-annual report, including the date of the last tune-up, be reported electronically. The commenter suspected the erroneous statement is in reference to requirement in § 63.10006(j) of the 2012 rule to report the "results" of boiler tune-ups within 60 days that was removed in the 2016 Technical Corrections Rule. The commenter said EPA proposes to revise § 63.10021(e)(9) to retain the requirement to report the date of the tune-up in PDF format as part of the semi-annual compliance report up until January 1, 2018 and thereafter to require reporting of the date in the quarterly compliance report under § 63.10031(g). The commenter supported this proposed revision, which would remove the current erroneous reference to hard copy reporting. Prior to finalization of this rule, EPA should acknowledge the error in § 63.10021(e)(9) so that delegated states will not be expecting such reports.
Commenter 20609 stated EPA proposes to specify additional detail regarding the substance of the reporting requirement in new Appendix E, sections 10.3 and 10.4. EPA proposes to require reporting of the both the "Date of Last Tune-up" and "Date of Last Burner Inspection." The commenter said this is in direct conflict with § 63.10021(e)(9) and § 63.10031(c)(4), both of which explicitly limit reporting with respect to tune-ups to the date of the optimization and testing in § 63.10021(e)(6) and (7). The commenter said if EPA wants EGUs to also report the date of the last "burner inspection," EPA must revise the other provisions to make the rule consistent. EPA also must explain what it means by "burner inspection" as that relates to the activities described in § 60.0021(e) and identify what date should be reported when the specified activities take place over several days. For example, EPA should specify whether the reported date includes inspection of the combustion controls, and whether it is limited to the initial inspection or includes inspections following repairs. In the draft reporting instructions posted to the docket, EPA explains the requirement as follows:
"Last Burner Inspection Date
Element name: LastBurnerInspectionDate
Report the completion date of the most recent burner inspection if it was not done in conjunction with the most recent boiler tune-up but instead was delayed until the next scheduled outage."
The commenter said the additional date EPA proposes be reported is the date of completion of some activity, EPA must say that in the rule. EPA cannot use reporting instructions to establish binding requirements.
Commenter 20611 stated EPA should clarify the date specified on §63.10021(e)(9) to start the reporting of the tune-up dates in the quarterly compliance report. On page 67071 of the proposed revised rule, EPA specifies that "Until January 1, 2018, report the dates of the initial and subsequent tune-up electronically, in PDF format, in your semi-annual compliance reports, as specified in §63.10031(f)(4) and (6)... After December 31, 2017, report the date of all tune-ups electronically in your quarterly compliance reports in accordance with 63.10031(g) and section 10 of Appendix E of this Subpart." The commenter suggested that the following revisions be made to this paragraph to more clearly align with EPA's intent regarding the start date of the quarterly MATS semi-annual report using ECMPS:
"Report the dates of the initial and subsequent tunes performed on or prior to December 31, 2017, electronically, in PDF format, in your semi-annual compliance reports, as specified in §63.10031(f)(4) and (6)... Report the dates of all tune-ups performed on or after January 1, 2018, electronically in your quarterly compliance reports in accordance with 63.10031(g) and section 10 of Appendix E of this Subpart."
Response 3:   Section 63.100021(e)(9) has been finalized as proposed, except that the words "Until January 1, 2018" have been replaced with "Prior to January 1, 2021, and the words "After December 31, 2017" have been replaced with "On and after January 1, 2021".   Therefore, prior to, January 1, 2021, tune-up dates must be submitted electronically in the semiannual compliance reports, and hardcopy submittals are required only when specifically requested by the Administrator.  This is consistent with §63.10031(f)(5), which states that the Administrator retains the right to require submittal of reports subject to paragraphs (f) introductory text and (f)(1) through (4) of this section (which includes the semiannual compliance reports) in paper format.   On and after January 1, 2021, the tune-up dates must be submitted electronically in the quarterly compliance reports.  Note, however, that requirements concerning quarterly compliance reports are under §63.10031(g), not (f)---therefore, the provision in §63.10031(f)(5) authorizing the Administrator to request hardcopy submittals is not applicable to the quarterly compliance reports.
EPA has withdrawn the proposed requirement in section 10.4 of Appendix E for affected EGUs to report the date of the last burner inspection.  The Agency agrees that §63.10021(e)(9) and §63.10031(c)(4) require only the date of the tune-up to be reported.  According to §63.10031(c)(4), the tune up date is the completion date of combustion optimization and measurement of the effluent CO, NOx and O2 concentrations [see §63.10021(e)(6) and (7)].
Comment 4: Commenter 20612 recommended §63.10021(h)(3) and §62.10031(i) should be revised to clearly indicate that the reporting only applies if Startup Definition 2 is used.
Commenter 20609 questioned the current purpose of the proposed clarifying revisions to § 63.10021(i). The commenter stated the provision does not impose any obligation that is not already covered in the proposed revisions to both § 63.10021(f) and § 63.10021(h)(3). The commenter quoted the text as promulgated in 2012, showing that § 63.10021(h) adequately addressed recordkeeping for startup and shutdown, and § 63.10021(i) adequately addressed reporting. To avoid confusion, the commenter requested that EPA remove and reserve § 63.10021(i). If EPA does intend to impose some additional obligation through that provision, EPA should explain what that is and provide opportunity for comment on it. If EPA removes § 63.10021(i), all of the reference to it in Table 3 should be changed to § 63.10021(h)(3), which is the more specific provision.
Commenter 20611 stated EPA should clarify that the emissions data recorded during startup and shutdown periods that should be included in the compliance reports as specified in the proposed §63.10011(g)(3) and §63.10021(h)(3) apply only to facilities that are relying on paragraph (2) of the definition of startup provided in §63.10042. The commenter also suggested EPA should revise §63.10021(h)(3) and §63.10021(i) to clarify the additional startup/shutdown reporting requirements only apply to facilities that are relying on paragraph (2) of the definition of startup provided in §63.10042 as is specified in the proposed §63.10011(g)(3). They should also indicate that the additional information required by §63.10031(c)(5) should be provided in PDF format as an attachment to the quarterly compliance report also as specified in the proposed §63.10011(g)(3).
Commenter 20602 stated EPA needs to provide clarity on requirements associated with use of startup definition (2). A number of provisions in the proposed revisions reference recordkeeping or reporting associated with the information in §63.10031 (c)(5). The requirements associated §63.10031 (c)(5) are only applicable if an affected unit chooses to use startup definition (2) found at 40 CFR 63.10042. The commenter said the revisions should make clear that the information required by §63.10031(c)(5) is only associated with units where startup definition (2) is being used. An example where this is done in the proposed revisions is the second sentence in §63.10011(g)(3). The commenter suggested that this also be clarified in the §63.10011(g)(3) third sentence: If you are relying on paragraph (2) of the definition of startup in § 63.10042, for startup and shutdown incidents that occur on or after January 1, 2018, you must provide the information referenced in§ 63.10031(c)(5) in PDF format as an attachment to the quarterly compliance reports, in accordance with§ 63.10031(i).
The commenter suggested that this also be clarified in the following sections of §63.10021:
 §63.10021(h)(3): You must report the emissions data recorded during startup and shutdown. If you are relying on paragraph (2) of the definition of startup in § 63.10042, for startup and shutdown incidents that occur on or prior to December 31, 2017, you must also report the supplementary information in§ 63.10031(c)(5) in the semiannual compliance report. If you are relying on paragraph (2) of the definition of startup in § 63 .10042, for startup and shutdown incidents that occur on and after January 1, 2018, the applicable information in§ 63.10031(c)(5) shall be provided quarterly, in PDF format, in accordance with §63.10031(i).
 §63.10021(i): If you are relying on paragraph (2) of the definition of startup in§ 63.10042, you must provide reports concerning activities and periods of startup and shutdown that occur on or prior to December 31, 2017, in accordance with§ 63.10031(c)(5), in the semiannual compliance report. If you are relying on paragraph (2) of the definition of startup in § 63 .10042, for startup and shutdown incidents that occur on and after January 1, 2018, the applicable information in§ 63.10031(c)(5) shall be provided quarterly, in PDF format, in accordance with §63.10031(i).
Response 4: Section 63.10021(i) of the rule has been revised to clarify that EGU owners or operators who choose to use paragraph 2 of the startup definition are to submit reports concerning activities and periods of startup and shutdown.  Regarding the other comments, see the response to comment 4 of section 3.
Comment 5: Commenter 20612 stated the use of the term "notifications and reports" when referencing electronic reporting within the rule may be confusing since not all notifications are submitted electronically (only the Notification of Compliance Status).
Response 5: The term "reports and notifications," not "notifications and reports," is used 3 times in the rule.  While the commenter is correct that the only specific notification mentioned in these 3 instances is the Notification of Compliance Status (NOCS), the EPA does not believe that using the plural of the term will cause confusion with regard to electronic reporting via the ECMPS Client Tool; however, the rule has been revised such that the "and" has been replaced with "or" in the instances of its use.
Comment 6: Commenter 20609 supported § 63.10011(g)(3), § 63.10021(h)(3) and (i), and § 63.10031(i) to require continued submission of all of the information in § 63.10031(c)(5) in PDF format, rather than XML format. The commenter states this information requested is the most transparent and user-friendly format under the circumstances. The commenter questioned the purpose of continuing to require submission of information in PDF format under (c)(5)(iii)-(v) that already has been reported in a quarterly emissions report in XML format. Under the current rule, all EGUs already are reporting hourly average concentration values for Hg and flow in XML format in quarterly emissions reports submitted to ECMPS, and flagging the hours that occur during startup and shutdown. The commenter said all EGUs with CEMS, sorbent trap monitoring systems, or PM CPMS already are or will be reporting this hourly information in XML format for all operating hours with quality assured data and identifying which hours are startup and shutdown. The commenter questioned why EPA would require that the same information be reported in the subsequent quarterly compliance report in PDF format simply because an EGU has opted to rely on paragraph (2) of the startup definition. To eliminate duplication and streamline reporting, the commenter said EPA should remove the requirements in § 63.10031(c)(5)(iii), (iv), and (v) to re-report in PDF format those startup and shutdown emissions-related values that already have been reported in XML format.
Response 6: The rule requires the additional information required for EGUs using paragraph (2) of the definition of startup must be provided along with the quarterly compliance reports, starting with the first quarter of 2021 report.  Until then, the information must be included in the semiannual compliance reports.  In all cases, the information must be reported in PDF format.
Note, however, that, consistent with the commenter's recommendation, the hourly CEMS readings during startup and shutdown described in §63.10031(c)(5)(iii), (iv), and (v) have not been carried over into the PDF reports that will be submitted on and after January 1, 2021; these paragraphs have been removed and reserved.  Startup and shutdown hours are flagged in the quarterly emissions reports, and the hourly CEMS readings, which are already required by section 63.10011(g)(2) to be collected and recorded, can be identified easily for auditing purposes.
5 63.10031-Reports to Submit
Comment 1: Commenter 20612 indicated that although §63.10031(c)(1) was not in the proposed rule revision it should be removed or revised   They believe the reference to §63.10(e)(3)(v) will be incorrect since the excess emission reporting requirements are will not be required (except for PM CPMS) after the target date year 2018.
Commenter 20612 also indicated that references to ERT and the ERT website in §63.10031(g) should be removed to reduce confusion regarding the use of ERT in MATS.
Response 1: : The final rule amends Table 9 to clarify that the excess emission reporting requirements of §63.10(e)(3)(v) and (vi) apply only through December 31, 2020, when the semiannual compliance reports are phased out.  On and after January 1, 2021, the 30- or 90- boiler operating day rolling averages must be reported for all CMS, including PM CPMS, and "deviations" must be reported in the quarterly compliance reports.
While references for mandatory use of the ERT have been removed from the rule, the ERT remains a viable tool for EGU owners or operators to create their XML schema and report their emissions test information.  Indeed, over 15,000 such schemas have been developed using the ERT and are posted in WebFIRE.

5.1 (a)-Submit each report in the applicable section
Comment 1: Commenter 20609 supported EPA's proposal to reflect the requirement to comply with the electronic reporting requirements of Appendix B, when HCl or HF is monitored continuously, in a new paragraph § 63.10031(a)(2).
Response 1: The Agency acknowledges and appreciates the commenter's support regarding this matter.
Comment 2: Commenter 20609 stated that owners and operators and responsible officials should be able to designate an "agent" to make submissions on his/her behalf and that this authorization should be reflected in the rule. The commenter noted that under the ARP and CSAPR EPA developed rules to allow those who are otherwise required to "submit" reports to authorize "agents" to perform that task on their behalf. See 40 C.F.R. § 72.26. Under those rules, a submitter is legally bound by the actions of his/her agent. The commenter provided additional background details and examples supporting why this terminology is necessary.
Response 2:  In the final rule, statements have been added to Appendices A through E, allowing the required reports and notifications to be submitted by an authorized agent of the EGU owner or operator.  See sections <IP_ADDRESS>, 11.5.5, <IP_ADDRESS>, 3.2.6, and 1.0 of Appendices A, B, C, D, and E, respectively.
Comment 3: Commenter 20611 stated that EPA should clarify if the compliance certification statement currently provided with each quarterly report submitted via ECMPS under Part 75 satisfies the certification statement requirements specified in § 63.10031(a)(5)(E).
Response 3: The certification statement for Part 75 submissions (found at 40 CFR 72.21(a)(2)) is not identical to the statement found in §63.10031(a)(5)(iii)(E) and elsewhere in the MATS rule (see Appendix A, section <IP_ADDRESS> and Appendix B section 11.5.4).  Therefore, for coal-fired Acid Rain Program EGUs that elect to comply with MATS by monitoring SO2 emission rate as a surrogate for HCl, separate certification statements are required for Part 75 and MATS when the quarterly emissions reports are submitted.
Comment 4: Commenters 20612 and 20609 expressed opposition to proposed three (3) significant figures reporting requirements and both commenters provided a number of germane references, examples, and background details as to why they are in opposition.
Commenter 20612 stated that the three significant figures reporting requirement in the MATS rule is fundamentally flawed and that a number of "extra" digits might be associated with an electrical or even digital output does not mean that those digits necessarily reflect the actual precision of the measurement. The commenter stated that taken literally, the requirement to report significant digits is equivalent to applying a new precision standard and EPA should correct the MATS reporting requirements that currently state a certain number of significant figures should be reported and instead prescribe that the data be reported to the same level of precision as the emission limit. The commenter stated that If EPA fails to correct the errant three significant figure reporting requirement, sources may decide that EPA meant something other than the conventional meaning of significant figures when it used the term or that one simply does not have to comply with the reporting "requirement" based on the principle of ad impossibilia nemo tentur and that the technical dilemma creates a situation of uncertainty that results in the potential of inconsistent reporting from source-to-source.
Commenter 20609 stated that in § 63.10031(a)(5)(C), EPA proposes to require reporting of hourly SO2 emission rates "rounded to 3 significant figures and expressed in scientific notation." Id. Although EPA already has included such a requirement in its ECMPS Reporting Instructions [ECMPS Reporting Instructions  -  Emissions at 74, 76 (Sept. 14, 2016)], the MATS rule does not appear to require reporting of these SO2 values to ECMPS at all, let alone to three significant figures. And, EPA's reporting instruction do not provide any citation to the rule as support for the instruction. The commenter stated that although it does not object to a requirement to report hourly SO2 emission rates, it does object to a requirement to report to three significant figures.
Commenter 20609 stated that EPA should not add a new requirement for SO2 because that represents a greater number of significant figures and greater level of precision than the SO2 emission standards require and would conflict with Part 75 reporting requirements. If recording and reporting of SO2 to the nearest tenth is good enough for the ARP and CSAPR, it should be sufficient to support the emission limitations in Subpart UUUUU, which were developed using data reported under those other programs (see ICR Supporting Statement, Part B, at 37, EPA-HQ-OAR-2009-0234-0062).
Response 4:  The EPA reviewed the comments, and in order to reduce confusion, has revised the rounding policy for the rule.  The EPA believes no one is unable to round Hg, HCl, HF, PM, or SO2 emission rates to the precision of the applicable emission standards, by retaining one leading non-zero digit and one decimal place, expressing the result in scientific notation (e.g. 1.5E-2):  this is what the rule requires. The pollutant concentration values for Hg, HCl, HF must also be reported this way; however, in order to remain consistent with existing sulfur dioxide reporting requirements from other programs, SO2 concentration values (in ppm) must be reported to the precision required by Part 75, i.e., to the nearest 0.1 ppm.  Use conventional rounding, i.e., if the first digit to the right of the first decimal place is 5 or greater, increase the number in the first decimal place by one digit; if the first digit to the right of the first decimal place is 4 or less, leave the number in the first decimal place unchanged.
Comment 5: Commenters 20594 and 20597 expressed opposition to the proposed reporting requirements that PM and SO2 should be "rounded to 3 significant figures, and expressed in scientific notation." (§§ 63.10031(a)(5)(iii)(C) and Appendix C <IP_ADDRESS>). Both commenters provided a number of germane references, examples, and background details as to why they are in opposition.
Commenter 20594 stated that the requirement to report MATS compliance data in scientific notification to the third decimal point is incompatible with CEMS configuration, departs for longstanding reporting practices, and will lead to inconsistent reporting detail among sources. The commenter stated that this is a substantive change in MATS compliance and it disagrees with this approach for the following 3 reasons:
  (1) Reporting to three significant figures departs from EPA's historical practice of requiring sources to report compliance data to the same number of decimal places as the standard in place. The commenter referenced a consent decree it entered into with the EPA which it stated reflects this longstanding practice. "...Performance standards, emissions limits, and other quantitative standards set by or under this Consent Decree must be met to the number of significant digits in which the standard or limit is expressed...[Commenter] shall report data to the number of significant digits in which the standard or limit is expressed."
  (2) For all other parameters that are reported through ECMPS, a number of decimal places is specified, not a number of significant figures. Five separate tables in the ECMPS reporting instructions are dedicated to clarifying the number of decimal places that should be used for reporting emissions data. The commenter stated that it cannot identify, nor EPA has provided an explanation for why MATS requires a different standard of data reporting that departs from the standard used for other Clean Air Act regulations and Clean Air Act enforcement tools, such as consent decrees. Sources always have the option of voluntarily reporting to a higher level of precision.
  (3) Reporting to three significant figures will lead to sources reporting inconsistent detail. In particular, low emitters would need to report values that greatly exceed any reasonable degree of measurement precision. It is obvious that the precision of instrumentation is not the same regardless of the actual emission value, so it is unclear why EPA would require reporting to the same level of precision regardless of the emission level. In addition to requiring inconsistent reporting obligations among sources, the Proposed Rule could subject low emitters to reporting results that are well below the precision of the instrument itself and are therefore inaccurate or misleading at best. Any reference to significant figures should be relative to the precision of the standard.
Commenter 20597 stated that EPA should correct the MATS reporting requirements that currently state a certain number of significant figures should be reported and instead prescribe that the data be reported to the same level of precision as the emission limit.
Response 5:  See the response to the previous comment.
Comment 6: Commenter 20595 stated that the proposed changes in §§63.10031 (a)(1),(2), and (5) would clarify the electronic reporting requirements for the Hg, HCI, HF, SO2, and auxiliary CMS and that these changes appear to be in addition to that required by other programs (i.e., Part 75, ARP, and CSAPR) where the SO2, flow, CO2 and moisture CEMS are being used. In those programs, the reporting of quarterly QA and the amounts of data required for submittals of RATAs go well beyond what has historically been required. The agency has been silent regarding whether the submittal of RATA results should follow that same submittal schedule. The commenter recommended that the RATA reports and the excessive data elements be included into the uniform schedule and that the agency specifically address the change from the 45-day reporting requirement.
Commenter 20595 stated that Appendix 9 [sic] should address that § 63.10(e)(3) be excluded since the reporting requirements will follow Subpart UUUUU.
Response 6:  The Agency understands these comments to be seeking clarification whether CEMS data and quality assurance checks obtained for and performed in accordance with other programs can be used for MATS.  As mentioned earlier, section 10031(a)(5)(iii)(E) of MATS already allows use of SO2 data; the rule and its appendices also already allow the use of part 75 instrumentation and procedures for flow, moisture, and diluent data collection (see, for example, 63.10005(h)(3)(i)(A) and (B), 63.10010(c), section 5.3 of Appendix A, and section 5.3 of Appendix B); the Agency believes no additional clarification is warranted.

Comment 7: Commenter 20602 stated that since the MATS rule primarily affects coal-fired EGUs, a majority, if not all, affected units are already subject to the ARP. The commenter suggested that to simplify the requirements under proposed § 63.10031(a)(5), that the rule provide one set of conditions to specify what additional information must be submitted for those units that are already subject to ARP reporting requirements and another set of conditions for those units that are not subject to ARP requirements.
Response 7:  The commenter's suggestion has not been incorporated.  Regardless of whether or not an EGU is in the Acid Rain Program, the same requirements for SO2 reporting apply. Paragraph (a)(5) of §63.10031 clearly states that, ".... you must use the ECMPS Client Tool to submit the following information to EPA (except where it is already required to be reported or has been previously provided under the Acid Rain Program....)."  Coal-fired Acid Rain Program EGUs that are subject to MATS and elect to monitor SO2 as a surrogate for HCl already meet most of the requirements of §63.10031(a)(5). However, the requirement to report an hourly data stream in units of the MATS emission limit is required only by MATS, and the certification statement in §63.10031(a)(5)(iii)(E) is different from the standard Part 75 certification statement (see Response 3 in this section, above).  In addition, Appendix E to MATS requires corresponding Reference Method 6C data to be reported for each run of each RATA of the SO2 monitor. The Agency believes that the provisions of 63.10031(a)(5) and Appendix E are sufficiently clear and that there is no need to revise the rule text to provide two sets of SO2 reporting conditions, i.e., one for Part 75 and one for MATS, as suggested by the commenter.
Comment 8: Commenter 20611 stated that EPA should revise §63.10031(a)(3) to specify that the electronic reporting of hourly PM CEMS emissions data shall begin with the later of: The first operating hour on or after January 1, 2018 or the first operating hour after completion of the initial PM CEMS correlation test on or after January 1, 2018.
Commenter 20611 stated that EPA should revise §63.10031(a)(4) to specify that the electronic reporting of hourly PM CPMS emissions data shall begin with the later of: The first operating hour on or after January 1, 2018 or the first operating hour after completion of the initial performance stack test that establishes the operating limit for the PM CPMS conducted on or after January 1, 2018.
Response 8: Table 8 incorporates the commenter's recommendations, except that the January 1, 2018 date is replaced with January 1, 2021.
5.2 (b)-Compliance reports
Comment 1: Commenter 20611 stated that EPA should revise § 63.10031(b)(1) to specify that the first compliance report should cover the period ending on June 30 or December 31, whichever date is the first date that occurs at least 180 days after the compliance date that is specified for your affected facility in §63.9984, or if applicable, the extended compliance date approved under §63.6(i)(4).
Response 1: The commenter's recommendation has been incorporated into the rule.  Revised §63.10031(b)(1) now recognizes that some affected EGUs may have received approval of extended compliance dates under 63.6(i)(4).  Existing sections 63.10000(n) and 63.10005(a)(2) of the rule already acknowledge the possibility that compliance date extensions may be granted in a similar fashion.
5.2.1 Semiannually to quarterly
Comment 1: Commenter 20595 stated that based on the proposed changes to §63.10031 (b)(5), the current option to follow alternate submission schedules for semiannual compliance reports to coordinate with Title V Semi-annual deviation reporting requirements would be removed, which would lead to additional work being required for modifying Title V Permits. The agency has included several reporting elements of the MATS program into the uniform submission schedule and proposes changing that schedule to quarterly. In some cases, Title V Permits have been amended or modified to allow the alternative semi-annual report submittal schedule. The commenter expressed concern as this proposed change will require another modification to reverse the amendment to the Title V permit where facilities and permitting authorities have worked to get the reporting schedules for semi-annual reports on the same schedule for both Title V and MATS.
Response 1:  In keeping with industry's request to use the ECMPS Client Tool, submissions should be made on a consistent basis.  As the ECMPS Client Tool requires quarterly submissions, MATS electronic reporting requirements have been adjusted to its submission requirements, i.e., from semiannual to quarterly submissions.  In addition, a consistent reporting basis is important, for without one, it would be virtually impossible to track compliance with these reporting requirements if there were a multitude of custom reporting schedules.
Comment 2: Commenter 20607 expressed support for EPA's proposal to consolidate reports that originally were required to be submitted separately on different time tables into quarterly compliance reports. Commenter stated this change would eliminate the need for companies to track different reporting deadlines, thus reporting would be greatly simplified, as well as more efficient and cost-effective.
Commenter 20607 also expressed support for the proposed compliance deadline for quarterly compliance reports of 60 days after the end of each calendar quarter. Commenter stated that this 60-day period is necessary for companies to compile stack test data. A shorter time period would not allow sufficient time to obtain and verify results prior to submittal to EPA. This is especially important for PM and HCl stack testing, the results of which require additional time for laboratory analysis.
Commenter 20607 stated that it urges EPA to extend this 60-day period to the submittal of emissions files and quality QA file data. As proposed, this information must be submitted within 30 days after the end of each quarter. This is not sufficient time for data to be collected and reports to be generated. PM and HCl CEMS rely on periodic stack tests for QA. This additional QA testing must be included in the quarterly reports to validate the CEMS results. A 30-day reporting deadline is insufficient to allow companies to perform these QA tests and collect results, particularly when the performance testing is conducted near the end of the calendar quarter. In those situations, it is possible that the test results will not be finalized until after the 30-day submittal period has ended. In addition to affording the time necessary to perform QA tests, extending the deadline to 60 days would align the deadlines for all quarterly reports, decreasing the administrative burden and increasing the overall efficiency of reporting.
Response 2:  EPA appreciates the supportive comments regarding the 60-day period after the end of each quarter in which to submit the results of stack tests performed to demonstrate compliance.  As requested by the commenter, the rule provides a similar extension for submitting the results of HCl and HF monitor RATAs and PM CEMS performance evaluations (RRAs, RCAs, and correlation tests).  For these continuous monitoring system (CMS) performance evaluations, the results may be submitted up to 60 days after the test completion date.
Comment 3: Commenter 20612 supported the changes to replace the semi-annual reports with the quarterly compliance reports. They also agree, it is absolutely necessary to maintain the 60-day reporting deadline to ensure that testers and sources have adequate time to analyze, review and certify the quality of the emissions data being reported.
Commenter 20609 generally supported the consolidation of reporting using ECMPS however for each activity involving use of a reference test method  -  i.e., a quarterly performance test or LEE test  -  EPA proposes to require submission of detailed information about the reference method used.  Most of this detailed data will be electronically reported using XML and the remainder using PDF.  This commenter was concerned about the number of details in the proposed reporting changes.
Response 3: The Agency appreciates the commenters' support for quarterly submission of electronic reporting using the ECMPS Client Tool, along with limited PDF file submission. As mentioned earlier, switching to the industry-requested, sole use of the ECMPS Client Tool necessitated some revisions to the existing reporting requirements; however, even with those changes, the overall industry burden decreases by about $4.2 million per year.
5.3 (c) -CEMS units of measure
Comment 1: Commenter 20597 stated that EPA is proposing that sources that correlate PM CEMS in terms of actual conditions (mg/acm vs. mg/scm) would be required to report hourly PM concentrations in both mg/acm and mg/scm and to report hourly temperature and pressure values as well. The commenter recommended that all PM CEMS, regardless of the type, only be required to report hourly mg/scm values. This approach will simplify the reporting and make the reported data more consistent from unit-to-unit.
Commenter 20607 stated that EPA proposes to require that hourly PM concentrations be reported in both mg/acm and mg/scm. This would require companies to calculate PM emissions using both metrics and report the same data to EPA twice. The commenter recommended that companies be allowed to choose which metric to use when reporting hourly PM concentrations. This approach would simplify and streamline reporting.
Response 1: The rule now requires PM concentrations to be reported in the units of measure that are consistent with the units of measure used for the PM CEMS correlation, rather than requiring reporting PM concentrations in both actual and standard units of measure. This approach is consistent with provisions in Performance Specification 11 (40 CFR part 60, Appendix B) that require one to"...convert the reference method results to units consistent with the conditions of your PM CEMS measurements." Given that measurement units differ among PM CEMS, the rule requires hourly PM concentrations to be recorded and reported in units of measure that are consistent with the PM CEMS correlation (see Appendix C, section 3.2.2).  Moreover, section <IP_ADDRESS> of Appendix C is consistent with this approach, requiring the reference method readings and the PM CEMS responses obtained in the RRAs and RCAs to be reported in the same units of measure as the PM CEMS correlation curve. For example, if the PM CEMS measures in units of mg/acm and the concentrations used to derive the correlation curve are in those same units, then the hourly PM concentrations must be recorded and reported in mg/acm.
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All PM concentrations must ultimately be converted to standard conditions, in order to calculate the PM emission rates (lb/mmBtu or lb/MWh).  However, the procedures that are followed and/or the equations that are used for the conversions are not necessarily the same for all PM monitoring technologies.  In view of this complicating factor, section <IP_ADDRESS>.2 of Appendix C requires the hard copy portion of the monitoring plan to include an explanation of how the PM concentrations are measured and how they are converted to the units of the applicable emissions limit; in addition, the equation(s) used for the conversions must be documented.
Comment 2: Commenter 20609 provided a summary of the change to 40 C.F.R. § 63.10031(c)(5)(iii) indicating that EPA proposes changing the phrase "use CEMS to demonstrate compliance with numerical limits" to "use CEMS for compliance purposes." EPA also proposes changing the units for reporting flow values from "standard cubic meters" to "standard or actual cubic feet per hour." This commenter then objects to the change to "use CEMS for compliance purposes" because EPA removing the language adopted in the 2016 Technical Corrections Rule and going back to the language promulgated in 2014 without stating the reason for this change. The commenter requested EPA explain the proposed change so they may adequately provide comments. Commenter 20609 agreed with the change in units of measure to "standard or actual cubic feet per hour" because the revisions would better align with the existing Part 75 requirements.
Commenter 20609 also indicated that § 63.10031(c) "the compliance report" should be revised to be consistent with the terminology of § 63.10031(b)(5) "the semi-annual compliance report" or add time limiting language to make the rule consistent. If EPA does not do that, the requirement in § 63.10031(c)(1) to comply with excess emissions reporting under § 63.10(e) would continue to apply contrary to EPA's express intent.
Response 2: The commenter's concern is moot, for, as mentioned earlier, §§63.10031(c)(5)(iii) through (v) of the rule have been removed and reserved.  Hourly CEMS values recorded during startup and shutdown are flagged in the electronic emissions reports and are easily identified for auditing purposes.  Therefore, for owners or operators of EGUs electing to use paragraph (2) of the startup definition, it is unnecessary to report these same values in the semiannual compliance report.
The word "semiannual" has been inserted into the introductory text of paragraph (c), as well as into paragraph (b), to address the commenter's concern.

5.4 (d)-Excess emissions and monitor downtime for semiannual and quarterly compliance reports
Comment 1: Commenter 20612 stated that §63.10031(d)(2)(iv) should be revised to indicate that the emergency bypass reporting requirements only apply to LEE units.
Response 1: Specific emergency bypass reporting requirements associated with EGUs with LEE status already exist in §63.10031(c)(6), and those requirements have been revised to show the link to section 10.3 of Appendix E; moreover, upon consideration of the comment, §§63.10031(d)(1), (2), and (3) have been replaced by a general requirement for owners or operators of EGUs that use CMS to report excess emissions and monitoring system downtime according to §63.10(e)(3)(v) and (vi) in their compliance reports (see §63.10031(d)).  Submission of those reports is on a semiannual basis through December 31, 2020; however, starting on January 1, 2021, after the semiannual compliance reports are phased out and replaced with quarterly compliance reports under §63.10031(g), reporting of 30- and 90- boiler operating day rolling averages for all parameters that are continuously monitored is required and any "deviations" that occur in the quarter must also be reported.
Comment 2: Commenter 20612 stated that §63.10031(e)(1) and (2) cause confusion around which reporting requirements apply for the semiannual compliance reports before 2018 and which apply to the reporting requirements for quarterly compliance reports following 2018. Since these requirements are clearly explained in other parts of the rule, these sections should be removed.
Response 2:  EPA agrees with the commenter that proposed paragraphs (e)(1) and (e)(2) of §63.10031 are superfluous, and they have been withdrawn.
Comment 3: Commenter 20609 stated that as an initial matter, the purpose of proposed § 63.10031(d)(2) is not clear. Current § 63.10031(d)(1) establishes semi-annual "excess emissions" and "monitoring system performance" reporting requirements consistent with the general provisions that will end on January 1, 2018 and be replaced by new XML reporting requirements. In other instances where EPA has proposed to replace the current semi-annual reporting requirements with XML reporting requirements in 2018, EPA has reflected the requirements in the data elements in new Appendix E and simply required reporting of them under § 63.10031(g). It is not clear why EPA believes it necessary to address future "excess emissions" reporting both in § 63.10031(d)(2) and in Appendix E. EPA should adopt a consistent approach. If EPA does not change its approach, it must address the following issues with its proposed language. Commenter 20609 stated that EPA provides an exception to the "excess emissions" reporting requirement for EGUs that elect to demonstrate compliance using a PM CPMS [Proposed § 6310031(d)(3) and (k)]. The purpose and scope of this exception are unclear. With respect to scope, if read literally, the use of a PM CPMS would subject an EGU to PDF reporting of excess emissions and monitor evaluation information for all emission limitation and monitoring systems. UARG assumes that EPA only means such EGUs would continue existing excess emissions and monitoring system evaluation reporting with respect to their PM CPMS and its associated operating limit, and not with respect to other emission limitations or CMS. EPA should add language stating as much.
Commenter 20609 stated that the manner of reporting and the relationship between § 63.10031(d)(2) and the new data elements in Appendix E are unclear. Appendix E data elements clearly must be reported in XML format. Proposed App. E section 1.0. Section 63.10031(d)(2) is silent on the format for reporting. Because most of the information in § 63.10031(d)(2) appears to also be covered in proposed Appendix E, the commenter assumes EPA intends it to be reported in XML format consistent with Appendix E. But the two parts of the rule are not consistent. For example, Appendix E covers exceedances of emission limits and operating limits in sections 12.1.1 and 12.1.2, but labels them "deviations" from an "emission limitation" (see proposed section "12.1.1 Emission limit exceeded"), not "excess emissions." As a result, it is not clear from the rule whether compliance with Appendix E satisfies § 63.10031(d)(2). EPA should not require excess emissions to be reported both as "excess emissions" and "deviations." It should be enough to report once under § 63.10031(g) and Appendix E.
Response 3: The comments are moot, for as mentioned earlier, upon consideration of the comments, §§ 63.10031(d)(1), (2), and (3) have been removed from the rule.
Comment 4: Commenter 20609 stated that the requirements for malfunction reporting are inconsistent. Current § 63.10031(g) only requires reporting of "malfunctions." EPA proposes to revise the "malfunction" reporting in proposed § 63.10031(d)(2)(iv) to include "emergency bypasses." Under the current rule, and proposed Appendix E section 13, "emergency bypass" events are reported only by EGUs with LEE status in order to implement the emergency bypass exceptions in § 63.10000(c)(1)(i)(C)(2). EPA also proposes separate data elements for malfunction reporting in Appendix E section 11.0. At a minimum, to avoid confusion and for consistency, EPA should remove the reference to "emergency bypass events" in § 63.100031(d)(2)(iv).
Commenter 20609 stated that moreover, EPA should not require the reporting of malfunctions under both § 63.10031(d)(2) and Appendix E. It should be enough to report once under § 63.10031(g) and Appendix E.
Response 4: As mentioned earlier, the reference to emergency bypass events has been removed from paragraph (d) of §63.10031.  Emergency bypass incidents are addressed in Section 10.3 of Appendix E, which makes it clear that these incidents apply only to certain coal-fired EGUs that are using the LEE compliance option.
The rule continues to require reporting of process and control equipment malfunctions in the semiannual compliance reports until those reports are phased out (the final report covers the fourth quarter of 2020).  However, to avoid inadvertently removing the requirement to report malfunctions in the semiannual reports, that requirement has been moved from §63.10031(g) to a new section, §63.10031(c)(10).  New paragraph (g) of §63.10031 requires quarterly compliance reports to replace the semiannual reports, starting in the first quarter of 2021; the quarterly compliance reports retain the requirement to report malfunctions.

5.5.2 On and after January 1, 2018 compliance based on 63.10031 (g), (i), (k)
Comment 1: Commenter 20611 stated that EPA should revise §63.10031(e)(2)(iii) to specify that new EGUs starting operation on or after January 1, 2018 or EGUs with extended compliance dates approved under §63.6(i)(4) should submit their initial Notification of Compliance Status in accordance with paragraph (h) of §63.10031. It is our understanding that no additional NOCS are required to be submitted for any subsequent tests performed under the MATS rule for existing EGUs with compliance date of April 16, 2015. The results of these tests were being submitted in the semi-annual compliance reports prior to December 31, 2017 and will be submitted in the quarterly compliance reports after January 1, 2018.
Response 1: The rule clarifies in §63.10030(e) and in Table 9 that Notifications of Compliance Status are required only for the initial compliance demonstration.  Sections 63.10000(n) and 63.10005(a)(2) recognize the possibility that compliance date extensions may be given.
5.6 (f)-Interim period PDF reports
Comment 1: Commenter 20612 supported the change from semi-annual to quarterly reporting and maintains that the 60 day reporting deadline must be maintained to provide sufficient time for testers and sources to complete analysis and reporting.
Commenter 20612 supported submitting detailed performance test report electronically as PDF files but indicates the proposed changes would be simpler if EPA removes the proposed list of requirements for the PDF stack tests reports required under Table 8 and Section 22 of Appendix E and simply references the stack test requirements included in the recently finalized revisions to §60.8(f) and §63.7(g). Without this change, the difference between the content lists will introduce inconsistency between rules.
Response 1: The Agency appreciates the support for quarterly reporting and, as mentioned elsewhere, the rule was adjusted to allow a 60 day reporting deadline for tests performed to demonstrate compliance. The Agency finds that a sole submission of detailed performance test reports via a PDF file would not constitute electronic reporting as described in the Agency's E-Reporting Policy for Regulations. As that policy states  -  and as is provided via the XML schema for this rule  -  electronic reporting is a system in which an electronic tool guides the regulated entity through the reporting process and which has some data quality checks; electronic reporting is not simply submitting a copy of a document, such as a performance test report, to the Agency. In addition, the Agency notes that the XML schema contains rule-specific information to be reported; this information would not be collected if EGU owners or operators were to report just the requirements of the NSPS and NESHAP general provisions, as suggested by the commenter.  Therefore, the changes regarding only PDF file reporting for just the items in the NSPS and NESHAP general provisions are not in the rule.
5.6.2 CEMS or CPMS must submit quarterly within 60 days
Comment 1: Commenter 20595 stated that the proposed revisions to § 63.10031(f)(2) would require quarterly reporting of all 30- (or 90-) boiler operating day rolling average emission rates for units monitoring Hg, HCI, HF, and/or SO2 emissions, and for units using emissions averaging, starting with a report covering the first quarter of 2018. The agency identifies that this reporting is in place of exception reporting. As such, the agency will need to change the software generally utilized for hourly data submittals to handle a daily value. This change needs to be factored into the timing of completing the changes to ECMPS and allow time for DAHS software providers to make changes to their software to make this reporting successful for the reporting period beginning January 1, 2018.
Response 1: The Agency finds the commenter's concerns misplaced, as ECMPS software will only collect hourly average data from continuous monitoring systems; it will not calculate, or be used as the means of affirmation for  compliance with, the 30- or 90-boiler operating day rolling averages.  Those boiler operating day rolling averages are to be reported in the quarterly compliance reports, and compliance assessment is to be performed by regulatory authorities such as inspectors or auditors.  As an aside, the commenter apparently misunderstands the way in which the rolling average is to be calculated; it is not the average of 30 or 90 "daily" values, but it is the arithmetic average of all of the valid hourly emission rates recorded during the 30- or 90-  boiler operating day period.
5.6.3 Submittal of PDF
Comment 1: Commenter 20595 stated that in §63.10031(g) through (I) and Table 8, Item 8, the agency identifies that ECMPS will be designated the exclusive data system for reporting. While the data elements are excessive in some situations, the commenter stated that it generally agrees that the sole use of ECMPS and the XML format is preferable.
Commenter 20595 stated that the proposed revisions should clearly indicate that the electronic reporting requirements satisfy general Part 63 reporting requirements (e.g., sources that submit MATS stack test data via ECMPS would not still need to submit that same data to the state and EPA regional office under §63.13 unless specifically required by the state or regional offices to do so). EPA needs to clarify that submitting the files through ECMPS will meet the Part 63 general provision requirements to report the same information to the state/region. The commenter stated that it believes that §63.10031 (f)(5) implicitly allows the existing electronic reporting required under §63.10031(f)(1) through (4) to satisfy the reporting requirements under the Part 63 general requirements. But, the new electronic provisions are introduced in other sections (§63.10031(g) through (I)). The proposed rule should be revised to ensure that the new electronic reporting provisions will satisfy the general provisions to submit such data to state and EPA regional offices (and to make such a statement in a clearer, explicit way). For example, §63.10021(f) could be revised to read:
"(f) You must submit the applicable reports and notifications required under §63.10031 (a) through (n) to the Administrator electronically, using EPA's Emissions Collection and Monitoring Plan System (ECMPS) Client Tool. Submission of a report using the ECMPS Client Tool satisfies any requirement under subpart A of this part to submit that report (or the information in that report) to the appropriate EPA Regional Office or State agency of a delegated authority. If the final date of any time period (or any deadline) for submission of a report using the ECMPS Client Tool falls on a weekend or a Federal holiday, the time period shall be extended to the next business day."
Commenter 20595 stated that this change would be consistent with the current provisions §63.10031(f)(5) and would allow sources to benefit from the paperwork reduction that is supposed to be an advantage of electronic reporting and avoid continuing to have to report hardcopy unnecessarily. States and other delegated authorities already have the right to request any report in hardcopy, if deemed necessary, under §63.10031(f)(5).
Response 1: The Agency disagrees that the reporting requirements associated with performance (stack) testing of the original rule or those associated with HCl or PM CEMS or PM CPMS of the proposed rule are "excessive in some situations;" each data element required to be reported (and identified by a separate XML tag) is necessary to determine compliance with a component of the test method, performance specification, or quality assurance or control procedure. With regard to the other comments, see the response to comment 3 of section 1.2 and the response to comment 3 of section 3.
Comment 2: Commenter 20609 stated that references to Notification of Compliance Status ("NOCS") for initial and subsequent compliance demonstrations are confusing since there are no requirements for any NOCS except the initial NOCS.  Currently Section 63.10011(e) reads: "(e) You must submit a Notification of Compliance Status containing the results of the initial compliance demonstration, in accordance with §63.10030(e)."
Commenter 20609 provided that Section 63.10030(e) currently reads: "(e) When you are required to conduct an initial compliance demonstration as specified in §63.10011(a), you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii)."  They further stated that "language in §63.10031(e)(7) and § 63.9(h)(2)(ii) of the general provisions appear to conflict with those provisions".
Commenter 20609 provided alternate changes to address these issues:
"EPA should make the following additional changes to ensure that the rule is internally consistent:
  :: Remove and reserve § 63.10030(e)(7)(i), which duplicates current § 63.10031(c)(7); and
  :: In Table 9, under § 63.9, add a note that the reference in (h)(2)(ii) to submission of a NOCS following "completion of any subsequent required performance test" does not apply."
Response 2: The Agency agrees that section §63.10030(e)(7)(i) is duplicative; that section has been removed from the rule and reserved.  Table 9 and §63.10030(e) in the rule have been revised to clarify that Notifications of Compliance Status are required only for initial compliance demonstrations.

5.7 (g)-Quarterly compliance reporting
Comment 1: Commenter 20609 stated that EPA proposes to significantly expand the information that must be reported for all tests involving reference methods, including RRAs and RCAs for PM CEMS and even if EPA finalizes some or all of the proposed requirements, EPA must reconsider the timing of some of the required submissions.
Commenter 20609 stated that under the current rule, RATA, RRA, and RCA test reports are not required to be submitted until 60 days after completion of the test [40 C.F.R. § 63.10031(f)(1)]. EPA proposes to revise that to require submission no later than with the "relevant quarterly emissions report." [Proposed App. C section 7.2.4; see also Table 8 Items 13 and 14, App. E sections 14.3, 15.2-3]. The commenter stated that if EPA finalizes that requirement, the amount of time between completion of the tests and the electronic reporting requirement would vary based on when the test was conducted. For a test conducted early in a calendar quarter, the revised deadline would provide more time than the current rule. The commenter stated that it does not object to that and agrees that EGUs should be allowed to submit the information earlier, just as EPA has proposed. However, for tests conducted late in the quarter, the rule could require reporting of data as little as 30 days after completion of the test.
Commenter 20609 stated that thirty (30) days may not be adequate for RRAs and RCA conducted on PM CEMS. RRAs and RCAs are much more involved than a typical RATA. They involve isokinetic sampling and require laboratory analysis that might take several weeks for an outside laboratory to process. Once the results are obtained, they need to be integrated with the other stack testing measurements to calculate the final PM emission rates that are provided to the owner/operator. The owner or operator then has to perform the requisite comparison to determine if the test was passed. Requiring completion of that in 30 days is not reasonable, and EPA has provided no rationale for changing the deadline. To the contrary, with respect to performance tests, which also require the processing of laboratory results, EPA acknowledges that 60 days (not 30 days) is a reasonable time period. 81 Fed. Reg. at 67,065. The commenter stated that as a result, rather than require submission of RRAs and RCA results with the quarterly emissions report, EPA should require their inclusion in the quarterly compliance report, which does not have to be reported until 60 days after the end of the quarter.
Response 1: The commenter's suggestion to include RRA and RCA results  in the quarterly compliance reports has not been incorporated.  Instead, the final rule allows up to 60 days after the test completion date for the results of RRAs and RCAs to be submitted.  The quarterly PM emissions data reports must still be submitted within 30 days after the end of each quarter.
To the extent practicable, the RRA and RCA results should be submitted prior to or concurrent with the relevant quarterly emissions report.  However, when this is not possible (e.g., for tests done near the end of the quarter), the emissions data may be assigned a "provisional" status, pending receipt of the test results.  If the RCA or RRA is successful, then, when the test results are submitted electronically, the status of the "provisional" data changes to "quality-assured" and no further action is required.  If the test is not successful, then, when the results are submitted, data with the provisional status must be invalidated until a subsequent test of the same type is successful; in this case, resubmission of the affected quarterly emissions report(s) is required.
Comment 2: Commenter 20609 stated that there are two issues with EPA's proposal to replace current § 63.10031(g) with a provision requiring submission of new quarterly compliance reports starting with the first calendar quarter of 2018. The commenter stated that first, the new proposed language contains a typographical error. The reference in the proposed revised section to "appendix B" is a typographical error. It should refer to "appendix E."
Commenter 206090 stated that secondly, the revision would remove the requirement to report certain malfunction events in semi-annual reports for the period up until December 31, 2017. If EPA wants such information to be reported, EPA needs to include it somewhere else. The commenter suggests that it could be added to the other requirements for semi-annual reports in § 63.10031(c) as a new subsection (c)(10).
Response 2: The rule now corrects the typographical error.  Also, upon consideration, the recommendation to relocate existing paragraph (g) of §63.10031 as a new paragraph (c)(10) has been incorporated in the rule.  The Agency agrees that without the relocation, the revisions to §63.10031(g) would have inadvertently removed the requirement to report malfunctions in the semiannual compliance reports.
5.7.2 Due within 60 days after the quarter
Comment 1: Commenter 20594 stated concern that the proposed rule puts new quarterly reporting obligations in place that are inconsistent with existing MATS reporting time periods. The proposed rule includes a new requirement to report and certify hourly PM CEMS data on a quarterly basis that is not in harmony with the current MATS reporting scheme. 81 Fed. Reg. at 67064. Presently, MATS requires that sources submit quarterly PM CEMS reports without hourly data. The source must submit relative accuracy test audit data or other quality assurance data (RCA and RRA data) within 60 days after the date of completing the test [§ 63.10031(f)]. Since the reference methods used to conduct these tests are wet chemistry methods (as opposed to instrumental analyzer test methods), sources must wait on the test results during this 60-day period after the testing date. A certification problem arises if a source is waiting to receive testing results, but a quarterly report becomes due. The source would be forced to certify PM CEMS data as "true accurate and complete" prior to receiving the testing results that verify the data is indeed accurate and quality assured. The Proposed Rule does not provide a solution for this gap in timing created by the new requirement to submit hourly PM CEMS data through ECMPS.
Commenter 20594 stated that it recommends revision to this reporting scheme and offered the following actions EPA could take to remedy this disconnect:
:: Exclude hourly PM CEMS emissions data from quarterly reporting.
:: Allow PM CEMS hourly emissions data to be submitted within 60 days after the end of the calendar quarter.
:: Exclude hourly PM CEMS data from certification by revising the certification language.
Response 1: Upon consideration of the comments, the rule maintains hourly PM CEMS emissions data and does not revise the certification language; however, the rule allows PM CEMS RATA data to be submitted in provisional status up to 60 days after the end of the quarter. More specifically, appendix C of the rule requires quarterly reporting of hourly PM CEMS data.  The quarterly emissions reports are due within 30 days after the end of each calendar quarter.    However, to address the commenter's concern about submission of the RRA and RCA results, the rule text in section 7.2.4 of Appendix C reads as follows:  "...Submit the results of the QA test (i.e., RCA or RRA) or, if applicable, a new PM CEMS correlation test, either prior to or concurrent with the relevant quarterly electronic emissions report.  If this is not possible, you have up to 60 days after the test completion date to submit the test results; in this case, you may claim provisional status for the emissions data affected by the QA test or correlation, starting from the date and hour in which the test was completed and continuing until the date and hour in which the test results are submitted.  For an RRA or RCA, if the applicable audit specifications are met, the status of the emissions data in the relevant time period changes from provisional to quality-assured, and no further action is required. For a successful correlation test, apply the correlation equation retrospectively to the raw data to change the provisional status of the data to quality-assured, and resubmit the affected emissions report(s).  However, if the applicable performance specifications are not met, the provisional data must be invalidated, and resubmission of the affected quarterly emission report(s) is required.  For a failed RRA or RCA, you must take corrective actions and proceed in accordance with the applicable requirements found in sections 10.5 through 10.7 of Procedure 2 until a successful QA test report is submitted. If a correlation test is unsuccessful, you may not report quality-assured data from the PM CEMS until the results of a subsequent correlation test show that the specifications in section 13.0 of PS11 are met."
Comment 2: Commenter 20611 stated that EPA should revise §63.10031(g) to specify that the quarterly electronic compliance reports are due "no later than 30 days after the end of each calendar quarter."
Response 2: As mentioned earlier, the rule requires compliance reports described in §63.10031(g) to be submitted within 60, not 30, days after the end of each calendar quarter.  The extra time is needed to receive the results of certain stack tests (i.e., HCl and PM tests) that are performed near the end of a calendar quarter and require laboratory analysis of the collected samples.
5.9 (i)-Startup and shutdown incidents
Comment 1: Commenter 20612 stated that EPA should not require the data in §63.10020(e), which is referenced in §63.10031(c)(5), to be submitted in XML format. The commenter objected to the requirement to report the startup data, but said there is no practical or meaningful way to make data more "user-friendly." Given the nature of the information required, the data are better suited as a recordkeeping requirement.
Commenter 20612 stated that if the Agency retains the reporting requirement, a PDF rather than XML format should be used. Trying to report the information in XML format would be difficult because this would cover many additional process parameters and potential configurations of those controls. In contrast to the burden of putting the information in numeric form, there would be little benefit to providing the data in XML since there are few, if any, meaningful checks that could be performed. Given the transient nature of the parameters during startup, screening the data electronically would not only be cumbersome but likely a fruitless effort. The commenter stated that given these factors (and the effort required of the Agency alone to develop XML formats for such data, much less the burden of sources to report the data in XML), PDF reporting would be adequate.
Commenter 20612 stated that EPA published the monitoring and reporting requirements in §63.10020(e) and §63.10030(e)(8) as part of the final startup/shutdown reconsideration rule without having proposed such language or making any indication that it was considering such requirements. The proposal of reopening the comment period for reconsideration of the startup/shutdown (SU/SD) provisions only included requests for additional information or comments on four specific issues: 1) the use of default diluent gas cap during SU/SD, 2) how to calculate SU/SD emissions for affected units sharing a common stack, 3) the use of a default electrical output value for calculating SU/SD emissions when the load is zero, and 4) the results of technical analyses the Agency conducted, which it believed "could support defining the end of startup at coal-fired EGUs as occurring at 25 percent of nameplate capacity plus 3 hours or the start of electricity generation plus 6 hours, whichever comes first."
Commenter 20612 stated that the requirements that EPA included in §63.10020(e) for sources to monitor (and report such information under §63.10031(c)(5)) could not reasonably be considered a logical extension of any of these four requests; and, therefore, the public was denied the opportunity to comment upon the requirements as required under CAA §307(d)(5). The Agency should, therefore, remove these unlawfully added provisions, which the commenter said provide little benefit in terms of documenting application of the startup work practice standards for sources using Paragraph 2 of the MATS Startup definition, making the question of how to report such information moot.
Response 1: In the rule, the additional information required for owners or operators of EGUs using paragraph (2) of the definition of startup must be provided along with the quarterly compliance reports, starting in the first quarter of 2021.  Until then, the information must be included in the semiannual compliance reports.  In all cases, the information must be reported in a PDF file.
The Agency disagrees that the data required when an EGU owner or operator chooses to use paragraph 2 of the definition of startup are not suitable for collection and submission via an XML format.  Those data are numeric values, as opposed to text, and are thus well suited for collection via XML format.  Nevertheless, the requirement in §63.10031(i) to report the information quarterly in a PDF file has been finalized, as proposed.
The Agency finds the commenter's suggestion that the monitoring and reporting requirements associated with the optional use of paragraph 2 of the definition of startup misplaced, as such comments are beyond the scope of this rule.  In any event, such comments should have been mentioned as part of startup and shutdown reconsideration rulemaking.  In point of fact, few EGU owners or operators have reported using paragraph 2 of the definition of startup (as shown in a recent review, only 20 of 570 EGU owners or operators who reported rely on paragraph 2 of the definition of startup); other EGU owners or operators who choose to continue to use paragraph 1 of the definition of startup are not required to provide such information.  Therefore, EGU owners or operators should consider all implications of their startup definition choice, including reporting and recordkeeping activity, before deciding on an approach.
Note, however, that, consistent with the commenter's recommendation, the hourly CEMS readings during startup and shutdown described in §63.10031(c)(5)(iii), (iv), and (v) have not been carried over into the PDF reports that will be submitted on and after January 1, 2021; these paragraphs have been removed from the rule and reserved.  Startup and shutdown hours are flagged in the quarterly emissions reports, so the hourly CEMS readings for these hours can be identified easily for auditing purposes.
Comment 2: Commenter 20609 stated that in § 63.10011(g)(3), § 63.10021(h)(3) and (i), and § 63.10031(i), EPA proposes to require continued submission of all of the information in § 63.10031(c)(5) in PDF format, rather than XML format like the rest of the compliance report, but solicits comment on whether a more transparent format should be required. 81 Fed. Reg. at 67,066. The commenter stated that it supports the use of PDF format to report the information in (c)(5)(i) and (ii), at least initially, and believes that for the type of information requested it is the most transparent and user-friendly format under the circumstances. Because this information is by its nature unique to the reporting source, XML format may not be sufficiently flexible to accommodate differences in details and there may be little benefit to compiling the information in a single database.
Commenter 20609 stated that it questions the purpose of continuing to require submission of information in PDF format under (c)(5)(iii)-(v) that already has been reported in a quarterly emissions report in XML format. Under the current rule, all EGUs already are reporting hourly average concentration values for Hg and flow in XML format in quarterly emissions reports submitted to ECMPS, and flagging the hours that occur during startup and shutdown. 40 C.F.R. Part 63, Subpart UUUUU, App. A sections <IP_ADDRESS>, <IP_ADDRESS>, <IP_ADDRESS>, 7.2.5. Similar requirements apply for HCl CEMS. Id. App. B. EGUs that use SO2 as a surrogate also are reporting hourly SO2 values in quarterly ECMPS emissions reports, and would continue to do so under the proposed rule. 40 C.F.R. § 75.57(c) and Proposed § 63.10031(5).
Commenter 20609 stated that under this proposal, EGUs using PM CEMS or PM CPMS would similarly begin reporting hourly PM values on January 1, 2018. Proposed App. C sections <IP_ADDRESS>, <IP_ADDRESS>, <IP_ADDRESS>, and App. D sections <IP_ADDRESS>, <IP_ADDRESS>, 3.2.4. Given that all EGUs with CEMS, sorbent trap monitoring systems, or PM CPMS already are or will be reporting this hourly information in XML format for all operating hours with quality assured data and identifying which hours are startup and shutdown, the commenter stated that it does not understand why EPA would require that the same information be reported in the subsequent quarterly compliance report in PDF format simply because an EGU has opted to rely on paragraph (2) of the startup definition. In light of the purpose of this rulemaking  -  i.e., to eliminate duplication and streamline reporting  -  EPA should remove the requirements in § 63.10031(c)(5)(iii), (iv), and (v) to re-report in PDF format those startup and shutdown emissions-related values that already have been reported in XML format.
Response 2: As mentioned earlier, consistent with the commenter's recommendation, the hourly CMS readings during startup and shutdown described in §63.10031(c)(5)(iii), (iv), and (v), which are required to be included in the semiannual compliance reports, have not been carried over into the PDF reports that will be submitted on and after January 1, 2021; these paragraphs have been removed from the rule and reserved.  Startup and shutdown hours are flagged in the quarterly emissions reports, and the hourly CEMS readings for these hours can easily be identified for auditing purposes.
Comment 3: Commenter 20595 stated if an EGU relies on paragraph (2) of the definition of startup given in §63.10042, the information in §63.10020(e), which is referenced in §63.10031(c)(5), would be reported quarterly in PDF format, as an attachment to the compliance report. The EPA specifically solicited comment on whether this information should be made more transparent and user-friendly. The EPA requested comment on possible techniques to achieve those ends, e.g., by requiring the data to be submitted in XML format. The commenter stated that while it does not utilize paragraph 2 of the definition of start-up, reporting this information appears to be better if handled as a PDF file.
Commenter 20607 supported EPA's proposal to require EGUs relying on paragraph (2) of the definition of startup to report the information required by § 63.10020(e) quarterly in PDF format, as an attachment to the compliance report. The commenter stated that this would continue the current practice of submitting this information in PDF format. Requiring this information to be submitted in XML format would force companies to change the methods by which they collect and report this data; specifically, companies would need to input data into a software application to convert it to XML format prior to submittal. Such a change in practice would be time-consuming and expensive, and would make reporting more burdensome without providing any benefit.
Response 3: As no commenter suggested approaches other than submission of the information in §63.10020(e) in a PDF file, the rule maintains this requirement.
Comment 4: Commenters 20602 and 20611 stated that a number of provisions in the proposed revisions reference recordkeeping or reporting associated with the information in §63.10031(c)(5) are only applicable if an affected unit chooses to use startup definition (2) found at §63.10042.
Commenter 20602 stated that these revisions should make clear that the information required by §63.10031(c)(5) is only associated with units where startup definition (2) is being used. An example where this is done in the proposed revisions is the second sentence in §63.10011(g)(3). The commenter suggested that this be clarified in the relevant areas of the proposed revisions including §63.10031(I). The commenter provided the following suggested changes to §63.10031(I):  "If you are relying on paragraph (2) of the definition of startup in§ 63.10042, for startup and shutdown incidents that occur on or prior to December 31, 2017, you must include the information in§ 63.10031(c)(5) in PDF format, in the semiannual compliance report. If you are relying on paragraph (2) of the definition of startup in § 63.10042, for startup and shutdown event(s) that occur on or after January 1, 2018, you must use the ECMPS Client Tool to submit this information in PDF format, as an attachment to each quarterly compliance report starting with the report for the first calendar quarter of 2018. The applicable data elements in paragraphs (f)(6)(i) through (xii) of this section must be entered into ECMPS with each startup and shutdown report."
Commenter 20611 also stated EPA should revise §63.10031(i) to clarify the startup/shutdown reporting requirements only apply to facilities that are relying on paragraph (2) of the definition of startup provided in §63.10042.
Response 4: As suggested by commenters, the rule, at §63.10031(i), clarifies that the information required to be reported under §63.10031(c)(5) and §63.10020(e) applies only to EGUs that are relying on paragraph 2 in the definition of startup.
5.11 (k)-PM CPMS submit excess emissions summary report in PDF quarterly after January 1, 2018
Comment 1: Commenter 20609 indicated that EGUs utilizing PM CPMS have an exception to excess emission reporting in § 6310031(d)(3) and (k) however the proposed purpose and scope of the exception is unclear.  This commenter said that "the use of a PM CPMS would subject an EGU to PDF reporting of excess emissions and monitor evaluation information for all emission limitation and monitoring systems."   Commenter 20609 assumed that EGUs using PM CPMS would continue existing excess emissions and monitoring system evaluation reporting with respect to their PM CPMS and its associated operating limit, and not with respect to other emission limitations or CMS.  The commenter indicated that this reporting method should be better stated.
Response 1: The proposed requirement for PM CPMS to continue the excess emissions report information in §63.10(e)(3)(v) and (vi) after the semiannual compliance reports are phased out has been removed from the rule.  Owners or operators of EGUs that use PM CPMS are required in Appendix D to report the hourly PM CPMS response values, percent monitoring availability (PMA), the 30- boiler operating day rolling averages, and deviations from the operating limit in the quarterly compliance reports.
7 Table 3-WPS
Comment 1: Commenter 20609 opposed proposes to revise three separate items in Table 3 to add language regarding reporting that mirrors the language in § 63.10011(g)(3) and § 63.10021(h)(3). The commenter said the proposed revision of Item 3(a)(1) to require reporting of the information in § 63.10031(c)(5) is incorrect. Section 63.10031(c)(5) is only applicable to EGUs that opt to rely on paragraph (2) of the definition of startup and Item (a)(1) addresses only paragraph (1) of that definition. The commenter also said the proposed addition of the language to Item 3(d) is incorrect with respect to EGUs that have not elected to rely on the alternative startup definition. Moreover, for EGUs that have elected to rely on paragraph (2) of the definition of startup, the proposed new language is redundant because Items 3(a)(1), 3(d), and 4 already require compliance with § 63.10011(g), § 63.10021(i), and § 63.10031, all of which EPA already has proposed to revise to include the same instructions regarding semi-annual and quarterly compliance reports. The commenter said if EPA does add the language to Item 3(d) or 4, EPA must include the qualifier that it only applies to EGUs that elect to rely on paragraph (2) of the definition of startup. EPA also would have to modify the language in Item 4 to refer to "shutdown" instead of "startup," because Item 4 only addresses shutdown periods. The commenter suggested that EPA should abandon these proposed unnecessary and confusing revisions.
Commenter 20611 stated EPA should make clarifications associated with startup definition (2). The commenter noted a number of provisions in the proposed revisions reference recordkeeping or reporting associated with the information in §63.10031(c)(5). The requirements associated §63.10031 (c)(5) are only applicable if an affected unit chooses to use startup definition (2) found at 40 CFR 63.10042. The revisions should make clear that the information required by §63.1003l(c)(5) is only associated with units where startup definition (2) is being used. An example where this is done in the proposed revisions is the second sentence in §63.1001 l(g)(3). The commenter suggested that this be clarified in the following areas of the proposed Table 3:
 Table 3, paragraph 3(a)(1): The proposed revision to this paragraph relates to §63.10031(c)(5). Since §63 .10031(c)(5) is only applicable to units that rely on paragraph (2) of the definition of startup, there should be no reference to §63.10031(c)(5) in this section of the table.
 Table 3 paragraph 3.(d): * * * If you are relying on paragraph (2) of the definition of startup in § 63.10042, you must report the applicable information in§ 63.10031(c)(5) concerning startup periods that occur on or prior to December 31, 2017 in PDF format in the semiannual compliance report. If you are relying on paragraph (2) of the definition of startup in§ 63.10042, for startup periods that occur on or after January 1, 2018, you must provide that information quarterly, in PDF format, according to§ 63.10031(i).
 Table 3 paragraph 4: ***If you are relying on paragraph (2) of the definition of startup in§ 63.10042, you must report the applicable information in§ 63.1003 l(c)(S) concerning startup shutdown periods that occur on or prior to December 31, 2017 in PDF format in the semiannual compliance report. If you are relying on paragraph (2) of the definition of startup in § 63.10042, for startup shutdown periods that occur on or after January 1, 2018, you must provide that information quarterly, in PDF format, according to § 63.10031 (i).
Response 1: The Agency agrees with the suggestions to clarify and correct Table 3. The rule now clarifies in Table 3 that the requirement to report the information in §63.10031(c)(5) applies only to owners or operators of EGUs that elect to use paragraph (2) of the definition of startup in §63.10042.  The rule also corrects paragraph 4 of Table 3, replacing the word "startup" with the word "shutdown", where appropriate.
8 Table 8-Reporting Requirements
Comment 1: Commenter 20612 stated the requirement in Table 8 to report pre-2018 PS-11 correlation test results should be revised to allow at least 60 days to report for any test that may occur late in 2017. The commenter suggested the revised version should read: "if, prior to January 1, 2018*, you have begun using a certified PM CEMS to demonstrate compliance with this subpart, you must use the ECMPS Client Tool to submit a PDF report of the existing PS 11 correlation test of the PM CEMS, no later than December 31, 2017* or 60 days after the completion of the PS-11 correlation test, whichever is later." The commenter noted with an asterisk that these data correspond to whatever date the new XLM reporting provisions would become effective.
Commenter 20597 stated the requirement to report pre-2018 PS-11 correlation test results should be revised to allow at least 60 days to report for any test that may occur late in 2017. The revised requirement should only require the current PS-11 correlation test of the PM CEMS be reported.
Response 1: In response to the commenters' suggestions, the rule requires PDF test reports of PM CEMS correlations completed prior to the effective date of the rule to be submitted no later than 60 days after the effective date of the rule.   For correlations completed on or after the effective date of the rule but prior to January 1, 2021, a PDF test report must be submitted within 60 days after the date on which the test is completed.  For correlations completed on or after January 1, 2021, the test data and results must be submitted along with supporting reference method data, electronically, in XML format, as required under section 7.2.4 of Appendix C and the applicable sections of Appendix E.
Comment 2: Commenter 20609 did not object to the proposed requirement in Table 8 Item 8 for EGUs that elect to demonstrate compliance using a CMS to report rolling average emission rates and related information for all parameters. The commenter suggested with respect Hg, EPA's proposed language does not recognize the option for EGUs that are not participating in a group averaging plan, including EGUs with LEE status, to comply with a 90-boiler operating day average for Hg. The commenter suggested that EPA needs to provide language in Table 8 Item 8 and Appendix E that reflects the availability of the option for EGUs, including those with LEE status, that are not participating in a group averaging plan under § 63.10009. Specifically, Table 8 Item 8 should read: "Starting in the first quarter of 2018, all 30- day rolling averages for all parameters (including Hg, HCl, HF, and/or SO2), or 90-day rolling averages for Hg, must be reported in XML format in the quarterly compliance reports described in § 63.10031(g)." The commenter referenced the revisions made to Table 2 in the 2016 Technical Corrections Rule supporting the 90-day average option. The commenter also added although EPA did not make similar conforming amendments to § 63.10005(a)(2), (d)(3), and (h)(3), which still refer to the 90-boiler operating day averaging only in reference to "certain coal-fired existing EGUs that use emission averaging for Hg," those provisions cannot override Table 5 and the other provisions that explicitly authorize the option. As a result, EPA should take this opportunity to make conforming revisions to those sections as well.
Response 2: Upon consideration of the comments, the rule contains language similar to that suggested by the commenter in Table 8, Item 8, recognizing that owners or operators of EGUs that are not in emissions averaging plans may elect to comply with the applicable Hg emission limit on a 90- boiler operating day rolling average basis.  Regarding the conforming amendments to §63.10005(a)(2), (d)(3), and (h)(3), the words "certain coal-fired existing EGUs that use emission averaging for Hg" appear only in paragraph (a)(2), not in (d)(3) or (h)(3).  These words have been removed from paragraph (a)(2) of the rule.
Comment 3: Commenter 20612 supported submitting detailed performance test report electronically as PDF files, but suggested EPA remove its proposed list of requirements for the PDF stack tests reports required under Table 8 and Section 22 of Appendix E and simply reference the stack test requirements included in the recently finalized revisions to §60.8(f) and §63.7(g). The commenter said there will be inconsistency between rules if this is not done. The commenter said EPA should revise Table 8 and Section 22 simply to reference the report requirements in §63.7(g), rather than creating a separate list in the MATS Rule, which could introduce inconsistency between rules. The proposed list in §63.7(g) is far more comprehensive than the one included in the MATS revisions and, since EPA has indicated that the revisions to §63.7(g) were made to "ensure that emissions test reporting includes all data necessary to assess and assure the quality of the reported emissions data," the reports will certainly include everything that is needed. The commenter provided an example of how the rule could be changed as follows: "14. For each test described in section 14 of Appendix E to this subpart, a detailed test report in PDF format that meets the requirements of §63.7(g)."
Commenter 20597 stated EPA should remove its proposed list of requirements for the PDF stack tests reports required under Table 8 and Section 22 of Appendix E and simply reference the stack test requirements included in the proposed revisions. Otherwise, the difference between the content lists will introduce inconsistency between rules.
Response 3: As mentioned earlier, the Agency disagrees with the commenters' suggestions to limit the list of items to be reported from performance tests to just those items contained in the NSPS and NESHAP general provisions. The Agency finds that there will be no inconsistency between rules.  The information that is required to be provided in a test report includes not only the information required by 40 CFR §60.8 (g) and §63.7(g) [the general provisions], but also additional information required by this specific subpart.  The required data are needed to replicate the calculations and QA the emissions that have been submitted in order for regulatory authorities to be able to assess compliance with the test methods, performance specifications, or quality assurance procedures.  The rule is unchanged; the submitted report will consist of an XML tags that contain the necessary data elements along with and pdf files containing supporting data, as necessary.
9 Table 9-Applicability of General Provisions to Subpart UUUUU
Comment 1: Commenter 20609 said EPA proposes only one minor change to Table 9 to provide an exception to the applicability of § 63.10(c)(7), which establishes "recordkeeping" requirements for excess emissions, to state that it only applies to EGUs that elect to use PM CPMS. The commenter questioned why the Agency has chosen to provide an exception for recordkeeping, and has not provided any exceptions for reporting. The commenter stated that starting January 1, 2018, EGUs should be exempted from the above listed reporting requirements. That should be made clear in Table 9 and, to cover the possibility that there are other reporting provisions that would duplicate information already reported to ECMPS, by new language in § 63.10011(f).
Commenter 20595 stated the proposed amendments would require all of the 30- (or 90-) boiler operating day rolling averages or WAERs to be included in the quarterly reports. Some excess emissions and monitor availability information would still be included in the compliance reports. Since this information is in place of the excess emission report identified in 63.10(e)(3), the commenter suggested the agency should revise the Table 9 to show that 63.10(e)(3) is not applicable to MATS.
Response 1: Table 9 of the rule has been revised to make it clear that the excess emissions and monitoring system performance recordkeeping and reporting requirements for CMS in §63.10(c)(7) and (c)(8) and §63.10(e)(3)(v) and (vi) apply through December 31, 2020, when the semiannual compliance reports are phased out.  Starting with January 1, 2021, 30- and 90- boiler operating day rolling averages and any deviations (as defined in §63.10042) must be reported for all CMS, in the quarterly compliance reports as described in §63.10031(g).
Comment 2: Commenter 20609 stated that the general provisions require reporting all reports to the delegated authority and the EPA regional office (unless EPA waives the requirement), and after a Title V permit has been issued, reporting the Notification of Compliance Status and performance test results to the appropriate permitting authority. The commenter argued that EPA has no basis to require EGUs that are reporting information directly to a central EPA reporting system to duplicate those reports in separate submissions to states and regions, and that they have access to the relevant information through the SMS. The commenter noted a few places in the proposal where EPA should address this issue. The commenter said EPA must make other revisions to make clear that such duplication is not required. Specifically, the commenter suggested EPA either amend Table 9 to make clear that the duplicative reporting in the general provisions is not applicable to Subpart UUUUU and/or by including in § 63.10011(f) a statement that: "Submission of a report using the ECMPS Client Tool satisfies any requirement under subpart A of this part to submit that report (or the information in that report) to the appropriate EPA Regional Office or State agency of a delegated authority." The commenter noted EPA did this in a similar issue with respect to written "excess emissions" reports under § 63.10(e)(3)(v). The commenter said if EPA does not do this, EPA must explain and solicit comment on its rationale for requiring duplicative reporting of this information and how it can be reconciled with the proposed electronic submission requirements in § 63.10031(b)(2) and (3).
Commenter 20608 stated the proposed revisions should clearly indicate that the electronic reporting requirements satisfy general Part 63 reporting requirements (e.g., a source that submits MATS stack test data via ECMPS would not still need to submit that same data to the state and EPA regional office under 63.13 unless specifically required by the state or regional office to do so). EPA needs to clarify that submitting the files through ECMPS will meet the requirements to report the same information to the state/region in the general provisions of Part 63.
Response 2: See the response to comment 3 of section 1.2.
10 Appendix A-Hg. Monitoring Provisions
Comment 1: Commenter 20609 supported the clarifications EPA proposed for Appendix A.
Response 1: The Agency appreciates the commenter's support for the clarifications.