What is the time line for testing and implementing the process? Will there be a transition period during which both the current and new processes can be used?
At the request of EPA, a number of comments were submitted after the February 17, 2005, ECMPS stakeholder meeting regarding the planned implementation schedule for the new process. We asked for comments to help us justify the schedule and changes we must request from the Office of Management and Budget (OMB) in order to alter our budget. The comments received were universal in their call for two things; (1) more time was needed for sources to load and test the new process and systems at their facilities, and (2) time was needed to transition from the old process to the new process before the required implementation date. The schedule as outlined at previous meetings called for development to take place in 2005, testing of the new process and systems in 2006, and implementation by all sources for the 1st quarter 2007 reporting period. This schedule, EPA was told, did not allow enough time for testing and provided no time to transition from the old process to the ECMPS process. The ECMPS
