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2014 NEI Plan

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EPA-454/R-19-008
July 2015
2014 NEI Plan
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Air Quality Assessment Division
Research Triangle Park, NC

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2014 NEI Plan
1 Introduction
The National Emissions Inventory (NEI) is a comprehensive and detailed estimate of annual total
air emissions of both criteria and hazardous air pollutants (HAPs) from all air emissions sources. The NEI
is prepared at least every three years by the U.S. EPA based primarily upon emissions estimates and
emissions model inputs provided by State, Local and Tribal (SLT) air agencies, and supplemented by data
developed by the EPA. The NEI is created to provide EPA, federal and state decision makers, the U.S.
public, and other countries the U.S.'s best and most complete estimates of criteria air pollutants (CAPs)
and hazardous air pollutant (HAP) emissions. The NEI is used by the EPA in support of evaluating National
Ambient Air Quality Standards (NAAQS), assessing interstate transport of air pollutants, air toxics
programs, and for international reporting. It is also used by state and local air agencies as a starting point
for State Implementation Plan (SIP) development, other federal agencies, researchers, and environmental
groups to understand sources of air pollution.
The NEI is created based on both regulatory and technical components. The Air Emissions
Reporting Rule (AERR) is the rule that requires states to submit emissions of CAP emissions and provides
the framework for voluntary submission of HAP emissions. The AERR requires agencies to report all
sources of emissions, except fires and biogenic sources. Open fire sources such as wildfires are
encouraged but not required. Sources are divided into large groups called "data categories": stationary
sources are "point" or "nonpoint" (county totals) and mobile sources are either onroad (cars and trucks
driven on roads) or nonroad (locomotives, aircraft, marine, off-road vehicles and nonroad equipment
such as lawn and garden equipment). The AERR specifies emissions thresholds above which states must
report stationary emissions as "point" sources with the remainder of the stationary emissions reported
as "nonpoint" sources.
Since the 2008 NEI, the Emissions Inventory System (EIS) has been the data system for collecting
and storing current and historical emissions inventory data. The AERR requires the submission of data
electronically to the EIS through the Central Data Exchange (CDX), and the EIS is used to receive and store
emissions data and to select the data to be included in the NEI. The EIS not only holds the emissions data,
it also provides all reporting codes, EIS quality assurance (QA) checks, and the Bridge Tool. The EIS also
includes agency organization profiles such as a list of agency staff and contact information who are
responsible for submitting or reviewing data. Lastly, the EIS provides feedback reports to agencies with
results of EIS QA checks on reported data as well as reports on facilities and emissions useful for
summarizing and reviewing agency data and the NEI.
Since the inception of the EIS, the EPA has worked to ensure that all changes to business
processes, codes, QA checks, etc., are provided to the SLT air agencies by June 1st of the year that the
submission window opens. For the 2014 inventory, this date is June 1, 2015. However, air agency
feedback indicated that this timeline did not give SLTs enough time to implement associated changes into
SLT data systems. In response to those comments, the EPA is posting changes by June 1st, 2014, one year
before the submission window opens (18 months before the data are due).
The NEI team staff are sensitive to the impact that these changes have on SLTs and are interested
in your comments. The NEI team will assist you wherever possible to implement any needed changes into
your system. While we try to minimize changes to the EIS, these improvements are intended to help EPA
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to create a more complete, accurate, and timely inventory, which is ultimately also in the best interest of
SLT agencies as well.
2 Schedule
The 2014 NEI Schedule is located at http://www.epa.gov/ttn/chief/net/2014inventorv.html. A
key change to this schedule from what was done for the 2011 NEI is that comments on the draft NEI will
not be permitted to include SLT agencies submitting wholesale replacement data. The previous approach
had the unintended effect of delaying the NEI release by many weeks and increasing EPA resource
requirements. SLT agencies will still be able to send data corrections during a QA period. Another
important change to the schedule is that a grace period for submission will extend through January 15th,
2016 to account for the challenges of meeting a December 31st deadline during the holiday season. Finally,
we are including a schedule for a second version of the 2014 NEI as well as the overlapping 2015 NEI
submissions, so that the EPA and SLT agencies can plan accordingly.
In the schedule, "release in EIS" means that the NEI selection has been made and the results have been
made public to all EIS users for use in reports. "Public release" refers to when the data are fully
transferred to the EPA website in various forms, including modeling files. The EPA makes every effort to
ensure that the data included on the website and the data in EIS use the same emissions.
2.1	What are the key 2014 NEI due dates for my agency?
January 15, 2016: Point, Nonpoint, Onroad, Nonroad and Event data are due.
June 10, 2016:	Corrections of 2014 Draft due for including in 2014 NEI vl.
February 3, 2017: Corrections of 2014 NEI vl due for including in 2014 NEI v2.
2.2	How will agencies make data corrections to the NEI data during the QA
period?
EPA inventory developers will work with SLT agency staff to provide feedback on their data and allow
corrections on a case by case basis. Corrections will be done similarly to what was done for the 2011 NEI
vl review during early 2014. SLT agencies will submit their corrections to the EIS "QA Environment" and
select "Request Assistance" on their clean feedback report. EPA staff then will review the corrections and
submit them to the Production Environment on the SLT's behalf. This same QA and correction procedure
will be used in developing the 2014 v2 as indicated in the schedule above.
2.3	Why has EPA eliminated wholesale data replacements?
EPA inventory developers do extensive QA on data received by the submission due date. Allowing
wholesale replacements or initial submissions long past the original due date causes EPA staff to run the
complete QA procedure on all of the data again. This process delays the NEI release, increases EPA's use
of resources, and does not have a greater benefit than the correction process that we described above.
This change places a lot of importance on the end of the submission grace period on January 15th. It is
very important that SLTs meet this deadline.
2.4	What best practices will help my agency meet the deadlines in this schedule?
In order to assist you in allocating your time and resources to complete this requirement, we are
including a suggested timeline for the facility, point and nonpoint data categories in Appendix 1. Also
included in Appendix 1 are suggested QA reports to run upon completion of your production
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submission. In order to take advantage of these reports, your data will need to have been submitted
early enough that you can check for data quality and make adjustments to your previously submitted
file.
3 General changes to the Ml p ess
This section provides some general changes to the 2014 NEI process that effect all or several data source
categories. The subsequent sections of this plan include additional information regarding sector-specific
changes.
3.1	AERR
While the AERR requirements result in a December 31, 2015 deadline for submitting the 2014 NEI
data, we understand the difficulties this presents to SLTs agency staff due to holiday schedules. Therefore,
we are proposing an additional two week grace period that will end on January 15, 2016.
The AERR is currently between a proposed and final rule. The EPA is working to finalize the AERR
by the end of June, 2014. In the meantime, states should review the proposed AERR for possible changes
that will be needed for their 2014 NEI submissions. Specifically, the EPA encourages air agencies to be
prepared to report lead emissions point sources as low as 0.5 tons per year of actual emissions.
Additionally, as was done for the 2011 NEI cycle, the EPA encourages air agencies that use MOVES and
NONROAD to report model inputs rather than emissions.
3.2	EIS Reporting Codes
1.	Control Measure Codes - see Appendix 2 for details. We are proposing that 26 control measure
codes be retired. The proposed list of these codes was posted to the CHIEF website in September,
2013 for SLT agency review. These changes will be implemented forthe 2013 and 2014 NEI cycles.
2.	SCC Changes - see Appendix 3 for details.
a.	Point - No retirements are proposed.
b.	Nonpoint - 139 SCCs are being proposed for retirement. These SCCs represent codes
which are seldom used by SLTs or can cause issues with double counting emissions.
c.	Events - Two SCCs are being considered for retirement.
d.	Onroad - Changes are expected for on-road SCCs to support MOVES 2014 approaches.
These SCC changes will be available in the summer of 2014; however, they do not effect
states that submit model inputs to meet their 2014 NEI requirements.
e.	Nonroad - No changes are proposed.
3.	Emission Methodology Codes - Event-specific codes have been added. These codes will only be
available to wildfire and prescribed fire SCCs (2810001000, 2811015000, and 2811020000) when
reporting emissions. The following codes are the only allowable Emission Calculation
Methodology Codes permitted in the Event Inventory for the above SCCs.
a.	40 - Emission Factor based on regional testing program
b.	41 - Emission Factor based on data available in peer reviewed literature
c.	42 - Emission Factor based on Fire Emission Production Simulator (FEPS)
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4. Pollutant Codes - Recent efforts to incorporate test data from regulations into EIS have resulted
in the need to revisit the current pollutant codes. The rule data require a more expansive list than
what is currently used in EIS and to allow for future selections to include these data, we may make
changes to the pollutant table. Discussions are currently underway on if these changes will effect
states submissions. More information will be available by the end of 2014, but we hope to provide
sooner to allow states to incorporate any changes into their instructions for facilities.
While the above are the extent of known retired and additional codes, new codes may be added later in
the year if deemed necessary. No codes will be retired after the publication of the final version of this
plan expected by mid-June, 2014.
3.3	Expected Pollutants
For some time, SLT agencies have requested that EPA provide a list of expected pollutants. For the 2014
NEI cycle, the EPA will provide such a list to be used for two purposes:
(1)	To help air agencies prioritize which data categories and pollutants should have the greatest focus
for QA given limited resources.
(2)	To allow EPA staff to provide better completeness feedback on SLT data submissions (see Section
3.5).
Although only CAPs are required under the AERR, HAPs are also critical to a complete the NEI, and so HAPs
will also be included in this list. Since we are gradually phasing in this process improvement to the NEI
program, this list is not intended to be a comprehensive list of all categories and pollutants. Rather, the
list will contain the minimally expected pollutants for key categories of importance in the 2014 NEI cycle.
The reporting of all criteria pollutants for all data source categories is required by the AERR, and this list
does not supersede that requirement. Rather, it will help provide air agencies a way to prioritize the data
categories and pollutants in accordance with EPA priorities. Air agencies should continue to report all
pollutants as they have done for prior NEI cycles and in accordance with the AERR, using this list as a way
to help prioritize limited resources.
If your agency only submits CAPs, EPA staff will add estimates of HAPs to these categories (where
specified) in the absence of your agency's HAP data. Your data submittal will not be considered
"incomplete" if you do not voluntarily report HAP emissions, but it will be augmented with EPA estimates
of HAPs from this list using EPA data augmentation procedures.
The list of expected pollutants should be available on the CHIEF website by the beginning of September,
2014 for point, nonpoint and event data categories. Onroad and nonroad expected pollutants are the
CAPs and HAPs generated by the MOVES 2014 and the National Mobile Inventory Model (NMIM).
3.4	EIS QA Checks
The following QA changes are being proposed for the 2014 NEI cycle.
1. Add six additional critical QA checks for particulate matter (PM) emissions values. These
checks are being added to reduce the assumptions that the EPA must make when using SLT
agency PM data and to lessen the need for EPA's PM augmentation procedures. The net effect
of these changes will be increased use of SLT data and better overall data quality. If PM10-FIL
and PM10-PRI are submitted, then PM10-PRI must be greater than or equal to PM10-FIL
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a.	If PM25-FIL and PM25-PRI are submitted, then PM25-PRI must be greater than or
equal to PM25-FIL
b.	If PM10-PRI and PM-CON are submitted, then PM10-PRI must be greater than or
equal to PMCON
c.	If PM25-PRI and PM-CON are submitted, then PM25-PRI must be greater than or
equal to PM-CON
d.	If PM10-FIL and PM25-FIL are submitted, then PM10-FIL must be greater than or
equal to PM25-FIL (QA check 835)
e.	If PM10-PRI and PM25-PRI are submitted, then PM10-PRI must be greater than or
equal to PM25-PRI (QA check 832)
2.	Add two additional warning QA checks for particulate matter (PM) emissions values. To
ensure air agency data passes these QA checks, we suggest that agency QA procedures ensure
PM data combinations are "equal" within a > 1 ton tolerance.
a.	If PM10-FIL, PMCON and PM10-PRI are submitted, PM10-FIL + PM-CON must equal
PM10-PRI If PM25-FIL, PM-CON and PM25-PRI are submitted, PM25-FIL + PM=CON
must equal PM25-PRI
b.	Update Criticality - QA Check 192, Consistency of Release Point Exit Gas Flow Rate
and Velocity will be upgraded from a warning to critical. This check will only apply if
the stack diameter, exit gas flow rate and exit gas velocity are reported together.
3.	Delete two QA checks for PM emissions values (also planned for the 2013 NEI submission
period). These are no longer needed with the added checks listed above.
a.	QA Check 836 - If PM2.5 is reported, must have PM10
b.	QA Check 837 - If there is a PM25 control pollutant there must be a PM10 control
pollutant
4.	Add QA checks to compare agency-submitted data to values in new protected point source
data fields (Critical). For the 2011 NEI cycle the site latitude and longitude fields could be
locked by EPA after verifying values. For the 2014 NEI cycle, the following additional point
source fields can be locked after verification and some data values in these fields may be
locked when SLT agencies submit updates to their facility inventories.
a)
FIPS State & County Code
b)
Tribal Code
c)
Facility Name
d)
Location Address
e)
Locality Name
f)
Locality State
g)
Locality ZIP
These checks will not cause an error to be reported if the data value being submitted is the same
as the protected data value. These checks are also only run on production submissions; therefore,
the errors will not be included in feedback from the QA environment. We are applying this same
process to latitude and longitude protected data, which should reduce the number of messages
under the "protected data" tab of your feedback reports. Only the data in the protected field will
be rejected and other data will be accepted into EIS. When locked data do in fact need to be
revised (an actual revision), SLT agency staff should contact NEI staff to resolve the discrepancy.
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This change will go into effect starting with the 2013 submission period and continuing for the
2014 NEI and beyond.
5.	Update emission ranges check (Warning) - In the past, the emission range check gave the
submitter many false positives in the warning section of feedback report. The underlying
ranges have been updated for the 2014 NEI cycle, and this check should produce more
realistic results.
The remaining changes pertain only to fires in both the Nonpoint and Event data categories:
6.	Check for valid Emission Calculation Method Code (Critical) - When reporting emissions for
SCCs 2810001000, 2811015000, and 2811020000 in the Event Inventory, data submitted will
be required to use either Emissions Calculation Method Code 40 - Emission Factor based on
Regional Testing Program; 41 - Emission Factor based on data available peer reviewed
literature; or, 42 - Emission Factor based on Fire Emission Production Simulator (FEPS).
7.	Check for present Event Staging Code (Critical) - Event Staging Code has been raised to a
"critical" check, making this data field required.
8.	Check for valid Event Staging Code (Critical) - Event Staging Code will be limited to reporting
combinations of Flaming (F) and Smoldering (S); S and Both (B); F and B; or F, S and B for the
same reporting period. The reporting of a single staging code will be rejected, e.g. Report
only flaming without either smoldering or both will reject the flaming record for that reporting
period.
9.	Ensure Activity values are reported (Critical) - For all SCCs with a Tier 3 description of
Agricultural Fires, the following EIS fields will now be required: Calculation Parameter Type
Code (I), Calculation Parameter Value (number of acres burned), Calculation Parameter Unit
of Measure (Acre), and Calculation Material Code (Ill-Fire). See Appendix 4 for specific SCCs.
3.5 EPA Completeness Feedback
As was the case for the 2011 NEI, the 2014 NEI data will be the foundation for key EPA regulatory and
other analyses. Due to the importance of this inventory, the EPA will again provide completeness reports.
New to the 2014 NEI cycle, the completeness reports will be available through the EIS Gateways to SLT
agency staff and the EPA regional offices. Allowing SLT agency staff to run these reports themselves will
provide SLTs with the greatest possible time to address any incomplete findings. SLT agencies will only be
able to see completeness reports for their own agency and delegated agencies. With the release of the
2014 NEI version 1, letters based on the final completeness reports will also be provided to state and local
Air Directors.
Additionally, the EPA has added additional completeness criteria for the 2014 NEI cycle. These
completeness checks will be based on the following criteria:
Point:
1.	Check that all facilities with an operating status of OP (Operating) have been reported. This
will be done using the Agency Submission History Report available on the EIS Gateway.
2.	Percent of completeness based on SCC/expected CAPs. Voluntary HAP data submission will
be noted, though lack of HAP data will not count against a completeness percentage. These
checks will be available via a completeness report function on the EIS Gateway.
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Nonpoint:
1.	Completion of a nonpoint survey (see Section 5.4.1).
a. This survey will include the request for total point activity data at the county level for
Industrial/Commercial/lnstitutional (ICI) combustion sources for each fuel type. We
expect that these data will allow us to improve our point/nonpoint reconciliation
process for boilers. We hope that this approach will reduce burden on SLT agencies
to report point source total activities rather than perform the ICI combustion
reconciliation themselves. This approach is an experiment for the 2014 NEI cycle.
2.	Percent of completeness based on SCC/expected CAPs. Voluntary HAP data submission (or
acceptance of EPA data) will be noted, though lack of HAP data will not count against a
completeness percentage. These checks will be available via a completeness report function
on the EIS Gateway.
Onroad/Nonroad:
1. Completeness is based on an agency either submitting inputs or accepting EPA estimates.
Events:
1. Completeness is based on an agency either submitting inputs or accepting EPA estimates.
Additional efforts to provide fire activity data from state forestry programs will be noted.
The table below provides an example feedback table that would be compiled from the EIS completeness
reports and included in the letter to the Air Directors. Ongoing work to resolve the details on the final
feedback letter may change this example.
Data Category
Status
Percent
Complete1
Voluntary
HAP level2
What to do
Point sources
75% of facilities reported
60%
Modest
Report remaining facilities or
indicate facility shutdowns.
Reporting all expected criteria
pollutants for reported SCCs or
correct SCCs.
Nonpoint sources
Survey submitted,
Data partly complete
80%
High
Report remaining expected
criteria pollutants for SCCs
reported. Report expected SCCs
as indicated in nonpoint survey.
Onroad mobile
sources
Inputs not provided
0%
No data
Submit model inputs or accept
EPA inputs/emissions.
Nonroad equipment
sources
Inputs not provided
0%
No data
Submit model inputs or accept
EPA inputs/emissions.
Events
Inputs provided
EPA data accepted
100%
High

1	Based on expected SCC/pollutant combinations for pollutants required by the Air Emissions Reporting Rule.
2	Level as compared to all other agencies submitting data. High = Submitted and highly complete; Modest = Between 40% and
70% expected HAPs provided for SCCs reported; Low = few SCCs reported with HAPs or less than 70% of expected HAPs for
SCCs reported; No data = no HAP data or model inputs were reported.
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4 Point sources
4.1	Overview
Air agency point source data are the predominant source of point source data in the NEI. Point source
reporting includes both the "facility inventory" and "emissions" as separate reporting steps, each with
their own set of tables defined for electronic reporting. The following subsections provide a road map to
the requirements from the AERR and the best practices for submitted data. Additional subsections
provide specific information on point-source specific practices for the 2014 NEI, including how the EPA
intends to use emission factors from the Mercury and Air Toxics Standards (MATS) and an emission
factors compendium.
As in past NEI cycles, the EPA intends to augment state point source emissions when needed. In past
cycles, the augmentation has included PM augmentation, HAP augmentation (factors to ratio HAPsfrom
CAPs), chromium speciation, and including emissions from TRI.
4.2	AERR requirements
Please refer to 40 CFR Part 51, Subpart A for the point source submission requirements. Key
requirements for your attention include:
•	The data fields required by the AERR are provided in Table 2a to Appendix A of the AERR. While
EIS does not enforce the reporting of all required data fields, air agencies are legally obligated
to report the required fields. The field definitions are provided in Section 51.50 of the AERR.
•	The point source reporting thresholds specified as part of Section 51.50 definition of point
sources. The emissions thresholds are specified as "potential to emit" emissions and are lower
for sources within nonattainment area boundaries for ozone, PMio, and CO nonattainment
areas. As noted above, the proposed AERR revision was to lower the reporting threshold for
lead, though the EPA has received a number of comments on this proposal. The EPA encourages
states to be prepared to submit to EPA at least those sources as low as 0.5 tons/year of actual
lead emissions.
•	Obtain the latest reporting codes from EIS prior to compiling point source data. In particular for
the 2014 NEI cycle, some codes have changes (see Section 3.2).
4.3	Point source best practices
The EPA encourages the use of the following best practices when submitting emissions of point sources.
•	Collecting data from facilities:
o Require or request that facilities use test data to estimate emissions for their processes.
Where test data are not available, require or request facilities use the provided emission
factors compendium when estimating their emissions (see Section 4.4) in lieu of Webfire
factors where noted.
o Require that facilities use the latest EIS reporting codes. Download these as described
above and make them available to your facilities,
o For HAPs, encourage facilities to compare their HAP submissions to what has been
submitted to TRI. While the EPA prefers the HAP emissions for the NEI because it is at a
more detailed process level, the facility-level TRI data and the NEI data should sum to
the same values.
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•	Building your inventory:
o Use consistent identification codes from one year to the next (e.g., facility, unit, release
point, and process identifiers). This prevents the creation of duplicate facilities or sub-
facility records, which reduces subsequent steps needed to remove such duplicates. If
needed, work with your information technology department to update your data
system to make these changes,
o Provide control information whenever possible, making sure that it is complete. The
control data are required by the AERR (when controls are present), and the EPA uses the
control data to assess future possible controls as a demonstration of whether and how
future NAAQS can be attained,
o Use the expected pollutants list (see Section 3.3) to help prioritize your efforts and QA.
•	Reporting best practices:
o Plan to start your submission process at least 4-8 weeks prior to the deadline,
accounting for time away from the office for holidays,
o Submit the facility inventory data for only those facilities or parts of facilities that have
changed since the previous time the facility inventory data were provided,
o Make sure to also submit updates to the "Operating Code" for facilities that are no
longer operating or no longer required to report as point sources. This will impact your
completeness report since facilities which have a Facility Site Status Code of OP
(Operating) that have not submitted emissions will be counted as incomplete,
o Submit data to the EIS QA Environment prior to submitting data the Production
Environment. Make sure your feedback reports are clean prior to submitting to the
Production Environment,
o QA your data after submission to Production (see Appendix 1)
o Run the completeness report and update your submission to meet or exceed all
completeness criteria.
4.4	Point sources emission factor compendium
The EPA will make available an Emission Factor Compendium for 2014. The compendium will be a listing
of all site or unit specific emission factors, or average SCC-based emission factors that are not currently
available in WebFIRE. We expect to have this posted by October 2014.
4.5	Mercury and Air Toxics Standard (MATS) Data
For the 2014 NEI the EPA will make available via the CHIEF web site the average emission factors
developed from the MATs testing done for several HAPs at electric generating units (EGUs). We will also
make available our assignment of those bin-average emission factors to each of the EGUs covered by the
MATs rule for consideration by the SLTs in their review for the best estimation method available for their
facilities. The MATS testing was performed in 2010 and covered mercury, lead, several other metals, and
HCI and HF acid gases. The assignments of the averaged emission factors to individual units was reviewed
and revised by the EPA for the 2011 NEI, based on controls believed to be in place at that time.
The EPA encourages SLTs to review whether the MATs-based emission factors are still applicable to the
units in their jurisdiction, and to use those emission factors unless they have more recent site-specific
data on which to base an emissions estimate. The EPA believes the MATs-based emission factors are
more representative of emissions from these units than the published AP-42 emission factors or metal
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content equations. The EPA will make estimates of these units emissions based upon the MATs emission
factors and reported heat inputs for 2014. These estimates will be compared to the SLT-reported values
to identify any large discrepancies which may need resolution.
Please indicate your review and evaluation of the most current emission factor materials for these units
by using the emissions calculation method code "9" if you are using one of these bin-average emission
factors. The EPA will interpret emission calculation method code "8" (USEPA Emission Factor) to mean
that you are using the outdated published AP-42 emission factor for these units. Whether you use the
MATS emission factor or your own site-specific assessment, please also fill in the emission factor field and
its associated numerator and denominator fields.
5 Nonpoint sources
5.1	Overview
Air agency nonpoint source data is an important source of data in the NEl, particularly for those
nonpoint categories that have overlap with point sources. These important categories include fuel
combustion categories, industrial solvents, residential wood combustion, and agricultural emissions
sources. The EPA provides a large number of spreadsheets and database tools to help SLT agencies
calculate their nonpoint emissions, and these tools provide fallback data for the EPA to use in many
cases. The following subsections provide a road map to the requirements from the AERR and the best
practices for submitted data. Additional subsections provide specific information on an updated
nonpoint-source specific process using a category survey for the 2014 NEI.
As in past NEI cycles, the EPA intends to augment state nonpoint source emissions when needed, using
the nonpoint spreadsheets and databases. In past cycles, the augmentation has also included PM
augmentation, HAP augmentation (factors to ratio HAPs from CAPs), chromium speciation.
5.2	AERR requirements
Please refer to 40 CFR Part 51, Subpart A for the nonpoint source submission requirements. Key
requirements for your attention include:
•	The data fields required by the AERR are provided in Table 2b to Appendix A. While EIS does
not enforce the reporting of all required data fields, air agencies are legally obligated to report
the required fields. The field definitions are provided in Section 51.50 of the AERR.
•	Obtain the latest reporting codes from EIS prior to compiling nonpoint source data. In particular
for the 2014 NEI cycle, some codes have changes (see Section 3.2).
5.3	Nonpoint source best practices
The EPA encourages the use of the following best practices when submitting emissions of nonpoint
sources.
•	EPA's nonpoint emissions tools:
o We encourage SLT agency staff to participate in the review and development of the
nonpoint emissions spreadsheets and databases. During 2014 and 2015, the EPA will be
convening workgroups focused on prioritizing which tools need to be updated and get
community collaboration for improving the tools for use in the 2014 NEI.
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o After the tools are released, the EPA encourages states to use the tools to estimate their
emissions. Alternatively, if no changes are needed to these EPA defaults, SLT air
agencies can indicate to EPA (through the survey response, see Section 5.4.1) their
interest in accepting the EPA defaults as their NEI emissions estimate.
•	Provide an accurate and timely nonpoint survey response.
•	Building your inventory:
o Provide control information whenever possible, making sure that it is complete. The
control program data are required by the AERR (when control programs are present),
and EPA uses the control data to assess future possible controls as a demonstration of
whether and how future NAAQS can be attained,
o Use the expected pollutants list (see Section 3.3) to help prioritize your efforts and QA.
o Use the information provided to EPA in the 2014 nonpoint survey (see Section 5.4.1) to
make sure to report those categories that you indicated you have in your state,
o Focus on categories that require point/nonpoint reconciliation since the EPA cannot do
this reconciliation without state input. These efforts will help prevent missing emissions
or double counting of emissions.
•	Reporting best practices:
o Plan to start your submission process at least 4-8 weeks prior to the deadline,
accounting for time away from the office for holidays,
o Submit data to the EIS QA Environment prior to submitting data the Production
Environment. Make sure your feedback reports are clean prior to submitting to the
Production Environment,
o QA your data after submission to Production (Appendix 1)
o Run the completeness report and update your submission to meet or exceed all
completeness criteria.
5.4 Nonpoint process changes for 2014
Two process changes are planned for nonpoint sources in 2014:
5.4.1 Nonpoint category survey
Similar to our process for 2011, we plan on gathering information from states on their nonpoint
estimates through a survey that is to be provided prior to the SLT agencies submitting emissions
data. Because each state has their own universe of sources and inventory development approaches,
each state reports nonpoint estimates a little differently. The survey will gather information specifically
for your state regarding which source categories are covered by point, nonpoint or both, and about
where point source reconciliation needs to be done to nonpoint activity. The survey allows us to
determine what it means when a SCC is missing from a state's data. It could mean the state accepts EPA
data, that those sources/processes are not present in a state, or that the state uses different SCCs than
the default EPA approach. In past inventory cycles, we have taken an approach of either contacting
states individually (after their submissions arrive), or we have made assumptions. We believe that this
new process for 2014 of gathering this information for all states early, consistently, and
comprehensively will both greatly streamline the process and allow for better EPA QA of incoming state
data.
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5.4.2 Delayed data submission for some data categories
For nonpoint emissions, EPA staff recognizes that activity data for the current inventory year is
often not available until after the NEI submission period closes. To reduce the burden on SLT agencies,
we propose the following:
1.	For those sectors where 2014 activity data are available prior to the submission deadline,
submit your nonpoint data or accept EPA data by the January 15, 2016 deadline.
2.	For those sectors where 2014 activity data are not expected to be available by the close of
the 2014 vl corrections window (in February of 2017), submit nonpoint data using the most
recently available activity data or accept EPA data by the January 15, 2016 deadline. EPA
estimates will consist of data which has been pulled forward from 2011 NEI v2.
3.	For those sectors where 2014 activity data will become available after the submission
window closes on January 15, 2016, SLTs may wait to estimate and submit these categories
using the newer activity data. These data would be submitted during the 2014 version 1
corrections period between July 1, 2016 and February 3, 2017. In this category, EPA will use
estimates which consist of data that has been pulled forward from 2011 NEI v2 for the 2014
NEI vl.
We intend that this third change will alleviate the need for SLTs to create and submit a nonpoint
data file simply to meet the January 15, 2016 deadline, when SLT agency staff know they will have newer
activity data in time for the 2014 v2 inventory.
6 Mobile sources
6.1	Overview
Mobile sources are sources of pollution caused by vehicles transporting goods or people (e.g., highway
vehicles, aircraft, rail, and marine vessels) and other nonroad engines and equipment, such as lawn and
garden equipment, construction equipment, engines used in recreational activities, and portable
industrial, commercial, and agricultural engines.
The EPA creates a comprehensive set of mobile source emissions data for criteria, hazardous air
pollutants, and greenhouse gasses for all states, Puerto Rico, and U.S. Virgin Islands as a starting point of
the NEI. The EPA uses models to estimate emissions for most of the mobile source categories. The EPA
encourages SLT agencies to submit model inputs where applicable, rather than emissions, so that the
EPA can use those inputs if the mobile models are updated and for consistent future year mobile source
projections.
6.2	AERR requirements
[This section on hold pending the AERR final rule]
6.3	Mobile source best practices
The EPA encourages the following best practices when submitting onroad/nonroad mobile data:
• Look for and follow posted directions on how to submit mobile inputs. Inputs are strongly
encouraged over emissions submittals.
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• Submit both the required input data, and any supplemental documentation, to help support and
explain your input information. The EPA will provide instructions regarding how to provide any
supplemental documentation prior to the June 2015 opening of the EIS submission window.
6.4 On road process changes for 2014
The EPA expects to use MOVES 2014 for the 2014 NEI for both onroad and nonroad emissions. To
accommodate new model output information, the SCCs will be changed and expanded to include new
categories such as new fuel types (like ethanol and electricity) and new emissions processes (like
extended idling). For the NEI, we anticipate aggregating these new, expanded SCCs to include fewer
SCCs in the NEI database or for reported emissions. The EPA is still working through details about these
new SCCs and expect that the approach will become public in the fall of 2014 with the release of the
2011 NEI version 2.
Collection of inputs, rather than emissions, is strongly preferred in order to provide EPA the ability to
run varying model scenarios and future projections from the same input basis. Model input data
collection will be similar to the process used for 2008 and 2011 NEIs. The EPA is interested in comments
on the current MOVES input process in planning improvements for the 2014 NEI cycle.
6.1	Nonroad equipment process changes
With the incorporation of NONROAD into MOVES 2014, the EPA has not yet decided the input format
that will be used. One option is that the NMIM input format could be used. Another option is that we
could require states to use the updated MOVES 2014 input format, and incorporate the submittal of
those inputs into the existing process for submitting MOVES 2014 inputs. The EPA is interested in
comments from the SLT agencies on this issue, which can be provided as part of the comments on this
plan. We intend to provide the reporting format requirements no later than January of 2015.
6.2	Commercial marine vessels changes
As with the 2008 and 2011 NEIs, the EPA will post shape-fraction files to aid agencies that have CMV
emissions at the county-level and wish to allocate them to shapes based on EPA's values. If SLTs have
more detail than EPA's shapes, they may contact us to update the shape files to include new ones.
7 Events
7.1 Overview
As proposed, the revised AERR does not require SLT agencies to report emissions from wildfire or
prescribed burning sources. These sources are reported as events to EIS. Thus, for the purposes of this
plan, the approaches described here assume use of the event format and voluntary participation from
SLT agencies to help EPA to create the most accurate inventory of these sources.
Air agency EVENT (day-specific emissions from wildfire and prescribed burning sources) data is an
important source of data in the NEI, as many pollutants such as PM, VOCs and numerous HAPs are
emitted in significant amounts by the large fires. For EVENTS, the EPA provides a default dataset that
covers the entire U.S. States should carefully check these emissions and strongly consider accepting
them before making a decision to submit emissions on their own. The EPA prefers to use consistent
methods and pollutants where possible, so working with EPA to have the best estimates possible and
then accepting EPA's estimates are an ideal approach. After review of EPA's final EVENT emissions (after
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provision of activity data), if an Agency deems it absolutely necessary to submit emissions, then care
must be exercised to keep the pollutant coverage the same as what EPA estimates using its methods.
7.2	Event process changes
For the 2014 NEI process, we expect the following items to be new/changed from the 2011 NEI process:
•	Those Agencies that decide to submit data, must submit smoldering and flaming emissions (the
sum represents what has been required in the past (see Section 3.4). The smoldering and
flaming components individually are important for many activities including use of data for
climate assessments, because the PM2.5 chemical makeup is different for the smoldering vs. the
flaming component.
•	We will include lead (Pb) as a pollutant from these large fires in the 2014 NEI. Agencies that
decide to submit actual emissions data should also plan on submitting Pb emissions. An
emissions factor and procedure for estimating Pb emissions from PM2.5 fractions will be
provided by the EPA as needed.
•	Agencies should make it clear to the EPA that the activity data they are submitting is a complete
set for both prescribed and wild fires. In that way, the EPA will ensure no other default data is
brought into the process of estimating emissions for the SLTs in question if such a note is
included as part of the activity data submission. EPA will add more details on this to the plan at
a later time.
•	We encourage states to send in activity data beginning in January, 2015 so that we can start
incorporating that data into estimating emissions for a draft version of the EVENTS inventory,
which we expect will be released by the summer of 2015. The EPA will post instructions on this
process on the 2014 website in December, 2014. We encourage states to submit activity data
by March 30, 2015. Those agencies which cannot meet this deadline can send in their data
during the comment period on the draft version from July 1, 2015 through October 30, 2015.
We strongly encourage all agencies to review and comment on the draft EVENTS NEI that we expect
to post in the summer of 2015. This includes review and use of the activity data submitted by
various agencies.
7.3	Event source best practices
•	Submit activity data so that the EPA does not have to use default data to identify and estimate
emissions from fires occurring in your domain. Important parameters include acres burned, fire
perimeters, fuel loading, and fuel consumption; however, acres burned is the most important
activity data to submit. The EPA relies on the default methods from satellite detections without
more specific data. The importance of submitting activity data is especially true for prescribed
fires, because the EPA methods have a more difficult problem in identifying which fires are
prescribed fires for appropriately estimating the emissions. At this time, we expect that activity
data for the 2014 NEI fires will simply be submitted via email to Tesh Rao
(rao.venkatesh@epa.gov), and the EPA will provide directions if those plans change.
•	Review draft NEI for EVENTS soon after it is available. Ensure that submitted activity data were
used appropriately. Provide comments in the comment time period specified by the EPA.
•	If an Agency decides to submit actual emissions (EPA discourages this process for EVENTS),
provide documentation on the methods as much as possible either via comment fields in EIS or
via an email to Tesh Rao at rao.venkatesh@epa.gov. Also, if an Agency submits emissions,
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ensure that the pollutant coverage is the same as what the EPA estimates using its methods. If
Emission Factors are needed, please contact the EPA. If you do decide to submit emissions,
o Submit data to the EIS QA Environment prior to submitting data the Production
Environment. Make sure your feedback reports are clean prior to submitting to the
Production Environment,
o Use the new (expected) comparison report as an additional QA step (see Section 8.3)
• Please plan on reviewing the draft estimates that will be provided by EPA and submitting
appropriate comments. In addition, please work with EPA to submit and review your activity
data as EPA processes them into emissions.
3 EIS Gateway, Reports, ar^ I
8.1	Staging Tables
In order to assist you in resolving Bridge Tool errors, we will be building queries into the staging tables
that will identify widows and orphans, which may be preventing your data from converting to the required
XML format. We will also be working on updating the Bridge Tool error messages to be more informative.
The Bridge Tool updates will be posted by March of 2015 to allow time for data conversions in advance of
the 2014 NEI submission window opening.
For users of Windsor Solutions' inventory management product "SLEIS", we are adapting the Bridge Tool
to convert the XML export files from SLEIS into the staging tables without prior manual manipulation. Past
versions of the Bridge Tool could not convert the XML to the staging table format.
8.2	Submissions - EIS Multitfaread Approach
In an effort to prevent a backlog of submissions during peak periods, the EPA plans to create a
"multithread" approach to the submission process within the EIS. This multithread approach will establish
two submission threads, with each thread being a separate data processing pathway. With the new
approach, the EIS will automatically move files larger than a pre-assigned file size limit to another thread,
allowing smaller files to be processed simultaneously. Currently, larger files must be completely processed
before the smaller files will be processed. This change will be in the EIS software, so the only differences
users will notice is faster response times.
8.3	Reports
A new EIS report is being designed and will be available in time for improving the 2014 NEI process (it may
be available as soon as December 2014). The new report will be a comparison report that will allow you
to compare any number of datasets against a single, user-specific base dataset. This could be used, for
example, to compare point emissions in the NEI 2011 v2 against your agency submitted data for 2014. An
additional example would be to compare your submitted data against the TRI data so that you can see
what facilities have reported to TRI and what is being reported by your agency. The comparison reports
will provide an absolute difference, percent difference and ratio between the baseline data value and the
comparison value for each dataset being compared. We encourage SLT air agencies to take advantage of
this report after having made your submission as an additional QAtool.
In addition, another report will be available for assessing whether your submissions have met the 2014
NEI completeness criteria. The use of this completeness report is described in Section 3.5.
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9
The EPA has created this plan to assist SLT agencies with their own planning needs for the 2014 NEI
cycle. Please direct comments on this plan to Sally Dombrowski at dombrowski.sally@epa.gov. The EPA
recognizes that SLT air agency staff will have many questions, ideas, and improvements that we have
not addressed here, and your comments will help us improve this plan and the 2014 NEI process.
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United States	Office of Air Quality Planning and Standards	Publication No. EPA-454/R-19-008
Environmental Protection	Air Quality Assessment Division	July 2015
Agency	Research Triangle Park, NC

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