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Non-EGU Point Workgroup

Collaborative Wiki Main Page

Inventory Collaborative Google Drive Link

Non-EGU Point Workgroup Charge


Co-leads: Tammy Manning (North Carolina), Caroline Farkas (EPA)

Anna Wood (Alabama), Brian Sullins (Alabama), Ben Cordes (Kentucky), Chad Wilbanks (South Carolina), Craig Henrikson (Montana), Deb Basnight (Georgia), Richard McDonald (Georgia), Hannah Ashenafi (Maryland), Jay Koch (Indiana), Jon Loftus (Wisconsin), Ken Newkirk (New York), Laura Stevens (New York), John Barnes (New York), Ken Santlal (Massachusetts), Kotur Narasimhan (Virginia), Thomas Foster (Virginia), Adam Lewis (New Jersey), Lynn Deahl (Kansas), Mike Maleski (Ohio), James Smith (Tennessee), Ron Thomas (Texas), Doug Boyer (Texas), Roslyn Higgin (New Mexico), Scott Hanks (Utah), Peter Verschoor (Utah), Vanessa Crandell-Beck (Alaska), Molly Birnbaum (Alaska), Wendy Jacobs (Connecticut), Steve Potter (Connecticut), Bryan Oshinski (Pennsylvania), Sylvia Vanderspek (California), Stephanie Huber (California), Ron Ryan (EPA), Brian Keaveny (EPA), Eric Svingen (EPA), Jenny Liljegren (EPA), Joseph Jakuta (OTC), Michael Leslie (EPA)

Non-EGU Point Committee Meetings

Held the 3rd Tuesday of the month at 2:00 p.m. Eastern.

July 17, 2018


CT, NY, NJ, VA, AL, NC, WI, OH, TX, OK, KS, AK, Ron Ryan (EPA), Caroline Farkas (EPA)


  • Roll Call
  • Wiki notes and files posted
  • Projections
    • Closures post-2016
    • State’s own growth and control factors
    • Corn Ethanol plants
    • Industrial Sources - update to AEO 2018
    • Review of growth and control factor method changes


Wiki notes and files posted


  • Closures post-2016
    • If your state has units that will be closing and need to be accounted for in the 2023 and 2028 projected platforms, you can submit that data to Caroline or Tammy.
    • Caroline is sending around an email today (July 17) providing an example of the recently-updated closure packet. It has also been uploaded to this workgroup's google drive (CLOSURES_EIS_2011NEIv1_sep2013_converted_06may2018_v0.csv)
    • Deadline for submitting these closing units to Caroline or Tammy is 8/31/2018
  • State's own growth and control factors
    • Tammy (NC) explained that due to the way NC handles Boiler MACT controls, they would like to submit their own growth and controls for these units.
    • EPA is happy to accept state growth and control factors from a state in CoST control or projection packet form
    • WI mentioned they would need to also submit some of their own growth and control factors for certain units
    • The workgroup said it would be helpful to have examples of growth and control packets to work from
    • If you follow the link to:, the zip file called “” contains many examples of Projection and Control packets.
      • For example, unzipping the folder and going into the ptnonipm folder, and further into the Step 1 folder will provide several examples of these packets.
      • A reminder that the exception to this is the Closure packet format which has been updated and is referenced above.
    • A deadline for these submission is TBD, but the sooner the better
  • Corn Ethanol Plants
    • This topic was tabled for another call
  • Industrial Sources - update to AEO 2018
    • From the Technical Support Document of the previous projection platform: "In response to comments about EPA's no-growth and previous approaches, the EPA developed industrial sector activity-based growth factors.
    • The most recent version used AEO 2017 projected growth for the growth factors.
    • LADCO and MARAMA submitted their own detailed activity-based projection factors for industrial sources in their states
    • We will be updating the growth factors for non-LADCO/MARAMA states using the AEO 2018.
    • If a state has their own growth/controls they would like to submit for industrial sources, they are welcome to and those will be included in the platform projections.
    • A deadline for these submissions is TBD
  • Review of growth and control factor method changes
    • NC asked if the states would have an opportunity to review any updated/changed growth and control methods/packets
    • We definitely will encourage review of any updated or changed methods.
    • Caroline asked if workgroup members would prefer this occur as the changes happen (i.e., as soon as they are finished, send them along to the workgroup to review) or for there to be a formal review period post-beta but before version 1.
      • NC stated that it depended on the amount of material. If there is a lot to review, more time would be helpful but if it is only a small amount of material, perhaps it would be more efficient to do it all at once.
      • If there are any other opinions on this, please let Caroline or Tammy know.
    • NC asked if EPA's review of projection methods would include possibly out-of-date control packets
      • We plan to step through each control packet and decide if the units are already in compliance (and therefore the control packet is no longer needed). If you know of a particular control that is now out-of-date and should not be considered for the new platform, please let Caroline or Tammy know so we can flag it in our review.

June 19, 2018


Steve Potter (CT), NY, MD, Anna Wood (AL), Tammy Manning (NC), WI, Mike Maleski (OH), TX, Craig Henrikson (MT), Molly Birnbaum (AK), Tom Moore (WESTAR), Ron Ryan (EPA), Alison Eyth (EPA), Caroline Farkas (EPA)


  • Roll Call
  • Final Point Inventory Ready
  • Review and QA
  • Non-EGU Projections


Final Point Inventory Ready

Review and Quality Assurance

  • QA is an important part of the modeling platform process. Caroline provided some examples of how EPA performs QA (with inventory comparisons and county-level maps)
  • For this application, we have already had rounds of QA. Note that HAPs are now included, many of which were not in the draft.
  • If you submitted important changes, you may wish to confirm that they came through as expected. If you need to see more detailed information that facility level, you can use the EIS interface or review the data in the SMOKE files.
  • Please let Caroline know by the end of July if something looks amiss in your state that you think needs to be corrected prior to the beta version. This may include EGU/non-EGU splits or units that may have moved from non-EGU point to nonpoint (or vice-versa).

Non-EGU Projections

  • NESHAP RTR for Petroleum refineries needs to be reviewed. It has an effective date of 2016. The main questions are: Has this already been accounted for in 2016 submissions? Does it still need to be accounted for in 2014 carry-over data?
  • CISWI units NSPS has an effective year of 2018. This will need to be accounted for in projections. Lee Tooly of EPA completed a deep dive of this rule and the impacted units. Caroline will put them into a projection packet according to SCC.
  • Lee Tooly began some work on consent decrees. Caroline will review the work and report back on the next call. This may be a consideration as we move forward on emission projections.
  • Caroline asked workgroup members to email with any ideas/topics they feel the workgroup should work on for emission projections as we transition from the 2016 base case to the 2023/2028 projection cases.

April 17, 2018


Joe Jakuta (OTC), Steve Potter (CT), NY, NJ, KY, AL, Tammy Manning (NC), OH, WI, OK, TX, MT, Deb Basnight (GA), Ken Santlal (MA), Kotur Narasimhan (VA), Molly Birnbaum (AK), Caroline Farkas (EPA), Alison Eyth (EPA), Ron Ryan (EPA), Tom Moore (WESTAR)


  • Welcome and Roll Call
  • Aircraft Call Recap
  • 2016 Point Flat File
    • Description of files available
    • State-specific – Alison Eyth
    • What we need from the Workgroup
  • How to submit corrections – Ron Ryan
  • 2016 vs. 2014 analysis – Caroline Farkas
  • Questions?


Aircraft Call Recap

  • Held small subgroup call on April 4
    • Laurel Drive spoke about the process for compiling the 2014 aircraft emissions and the changes for 2017
    • The group has suggested using the 2017 aircraft emissions for the 2016v1 platform as they will be estimated using the new FAA model
    • See the slides on the Google Drive for more information

2016 Point Flat File

  • The 2016 alpha flat file is now available for review to the workgroup
  • The presentation has links to these files
  • EPA has separated the flat files into State-based files (one for each State) to make the files smaller and the review process easier for States
  • What does EPA need from the workgroup?
    • Please review your State’s 2016 point alpha inventory
      • Are there any sources that are in a different sector than they should be?
      • Are the EGUs/non-EGUs correctly divided? Oil & Gas?
      • Any other irregularities you might see
  • Steve Potter mentioned that some of CT’s sources that were nonpoint sources in 2014 are considered point sources in 2016 because of rule changes. This is mostly a nonpoint issue because they need to be removed from the nonpoint inventory to avoid double counting. We will be covering this during the nonpoint workgroup call next week. If you have a similar situation, please let us know.
  • A question was asked about how ptoilgas is divided out from non-EGU point. Alison said that this happens by NAICS code and includes both production and distribution sources
    • Tom Moore and Jeff Vukovich will be working with their workgroup to make sure the sources that have been put into that sector are correct

How to Submit Corrections

  • If you find an issue with emissions in the 2016 point alpha file, Ron Ryan is who to contact
    • Email and he will open a submittal window in EIS for you
      • Corrections can be submitted manually in EIS source by source or for several sources using an XML batch file with the corrections (not a complete resubmittal, just the edits)
      • Corrections are due by May 31
  • If you find an issue with the subsector a source is assigned to, closures, or location of a source, Caroline Farkas is who to contact
    • Email with the information about the source and the correction needed
  • If you are unsure of who to contact, please email Caroline Farkas or Tammy Manning and we can help

2016 vs. 2014 Analysis

  • On a previous call, the following questions have been asked about the 2016 point submittals:
    • How many point sources were submitted with 2016 emission submittals?
    • What percentage of the total non-EGU emissions do these sources represent?
  • Ron Ryan had given some preliminary information that of 63,000 non-airport facilities in 2014v2 NEI, about 22,000 were reported for 2016 by 48 states (KY and MA missing), DC, PR, 20 locals and 2 tribes
  • Caroline analyzed the point alpha flat file to determine the percentage of emissions the 2016 submittals represented of the total non-EGU emissions.

March 20, 2018


CT, NY, PA, Tammy Manning (NC), AL, GA, OH, WI, NM, TX, KS, Caroline Farkas (EPA)


  • Welcome
    • Roll Call
  • QA Comparison File and 2016 Point Update
  • 2014v2 Emission Totals by Subsector
  • Growth and Controls data (2011)


Aircraft Subgroup

  • An interest call about an aircraft subgroup will meet Wednesday, April 4, 2018 at 2pm EDT. Email Caroline if you would like to be added to the meeting invitation.

QA Comparison File and 2016 Point Update

  • Tammy reviewed the file Ron Ryan sent out to states. A few people mentioned not receiving it, probably because another representative at the state has worked on it - send an email to Caroline and she will ask Ron if he can send it along.
  • Questions from General Collaborative Update meeting:
    • How many states submitted point sources for 2016?
      • 48 states (KY and MA missing), DC, PR, 20 locals, and 2 tribes submitted at least one facility. Out of approx. 63,000 non-airport facilities in 2014v2 NEI, about 22,000 of those were reported for 2016.
      • We plan to do an analysis of the percentage of emissions these 22,000 facilities represent when the 2016 point flat file is ready.
  • Update on 2016 Flat File Progress
    • How do members want to see the data? (e.g., non-EGU point separated? Pt_oilgas not separate out? Whole Point file?)
      • Members would like to see both the entire Point file and the non-EGU Point separated file.
    • As a note, the non-EGU and EGU facilities are separated using the IPM_YN column. If an entry appears in this column, it is separated out as an EGU.
  • If you want to see your states' submitted data before the 2016 flat file is ready, follow the instructions in the tutorial to create a flat file in EIS from the submitted data: Flatfile Generation Tutorial.

2014v2 Emission Totals by Subsector

  • Caroline reviewed the graph of subsector totals for CAPS with the group. This is available on the google drive, or can be requested via email if you do not have access.

2011 Growth and Control comparisons

  • Caroline reviewed the ftp links that members can use to see how growth and controls factors projected emissions from 2011 to 2023 and 2028. This will be most helpful for projections after we set the base case.


Projection and Control packets: and

  • If you have issues accessing any of the data covered today, contact Caroline or Tammy.

February 20, 2018


Wendy Jacobs (CT), Steve Potter (CT), NY, Kotur Narasimhan (VA), PA, AL, Tammy Manning (NC), WI, Mike Maleski (OH), TX, NM, MT, AK, Ron Ryan (EPA), Caroline Farkas (EPA)


  • Welcome
    • Roll Call
  • Review/Answer Questions from last Call
  • Aircraft subgroup
  • Upcoming data being sent, what else would be helpful?
  • Action Items


Review/Answer Questions from last call

  • Specification Spreadsheet wording could be improved and the example spreadsheet may not be the most appropriate format/example for point source work. It is an agriculture spreadsheet.
    • This has been raised by a few people in other groups too and is being considered

  • Why does the charge have the group projection to 2028 first, rather than 2023?
    • This appears to have been a typo in the example charge given. It will be updated to include 2023. We will be working on projections to both years.

  • How is the group going to get data/input on data from SLTs that are not participating on work group call? How to fill in data not submitted by SLTs for 2016? 2014v2 projected to 2016? Ask SLTs to submit all collected data to EIS even if not required by AERR? Other options?
    • We just had submissions from states in mid-January for Calendar year 2016 emissions from S/L/Ts which included CAP emissions from Type A sources. However, Ron Ryan stated that most states report Type B source annually even though these sources are only required to report triennially. If we have missing data, we would grab the reported data from the most recent triennial (in this case 2014) NEI and use it to gap fill.  NC reports Type B sources annually. 

  • How to treat small power generators, i.e., peaking units? Will these units be included in non-EGU Point?
    • There was much discussion on this topic including ERTAC and IPM model uses and definitions.  EIS identifies these sources based on the IPM model and these sources are found in the IPM NEEDS file. Whichever units are identified as EGU-generators will be in the EGU group. At EPA, if a unit is modeled by IPM, then it is an EGU. IPM NEEDS file contains Municipal Waste Combustors (MWC).

Additional Notes from Ron Ryan

  • A review and comparisons file of the S/L/Ts 2016 point submittals as sent out to all S/L/Ts on Tues 2/20, just after the call. S/L/ts are asked to review for possible edits needed and get any edits into their EIS datasets by May 15 at the latest.

  • There is already a “draft” 2016 point inventory of sorts available in EIS for any EIS user’s access. It contains only the S/L/T 2016 point submittals, with no EPA augmentation or gap-filling for smaller facilities from 2014 NEI. It can be viewed, summarized, or filtered from EIS by using dataset name = “2016RAS”, which means “Responsible Agency Selection” – only what the Responsible S/L/T Agency for each facility submitted is included. The completeness of this RAS draft will vary from State-to-State depending on whether each S/L/T submitted all or most of their facilities or whether they only submitted the very largest emitters that are required for the non-triennial NEI years.

  • We are targeting March 15 to have a more complete “draft” 2016 point inventory available in EIS. This draft will include EPA PM Augmentation (largely just summing S/L/T-reported filterable and condensible PM pieces) and using the 2014 NEI to gap-fill for any smaller, non-reported 2016 facilities that are still shown as “operating”. It will also include EPA augmentations where needed for HAPs : 2016 TRI data, HAP Augmentation, and Chromium speciation. Note that we do not expect any S/L/T edits of their submitted data to necessarily be available for that March 15 draft. We do not expect this to impact the utility of the March 15 draft, because the 2016 S/L/T submittals seem to be exceptionally clean, especially for criteria pollutants.

  • We are targeting July 1 to have the final 2016 point inventory available in EIS.

Aircraft Subgroup

  • No volunteer yet to lead subgroup. Some discussion about whether this subgroup is needed or if the whole group should work on these sources.  Suggested to group that aircraft subgroup is needed and some members have indicated interest in working on this subgroup.  Caroline will talk to some of the interested members and management about the subgroup.

  • CY2017 draft should be ready by mid-summer.  Most of work would be focused on projections.

Upcoming data being sent

  • Caroline will be gathering and sending out current data about existing growth and controls used for projections from EPA. She will also compile a summary/plot of emission totals by subsector.

  • Ron is sending a draft out to states today of 2016 EIS emissions.

  • For closures, a list of facilities/sources marked for shutdown can be obtained as a report from EIS.

Action Items

  • If you want to be on the aircraft subgroup and have not told us, please email Caroline or Tammy.

  • Review data sent out in the coming weeks and be ready to discuss in March.

January 29, 2018


CT, MA, NY, NJ, PA, VA, Joseph Jakuta (OTC), NC, AL, GA, OH, WI, Eric Svingen (EPA R5), TX, KS, MT, CA, AK, Ron Ryan (EPA), Jenny Lijegren (EPA), Brian Keaveny (EPA), Caroline Farkas (EPA)


  • Welcome
    • Co-chair Introductions
    • Roll Call
  • Introduction to overall Collaborative Workgroup effort
  • Introduction to non-EGU Point Workgroup
    • Charge
    • Subgroups
  • Administrative Items
    • Recurring Meetings
    • Google Drive
    • Wiki
    • Action Item
  • Questions?


Introduction to overall Collaborative Workgroup effort

  • Overall goals of this workgroup are to collaboratively generate the data files necessary to develop the 2016 Emission Modeling Platform. Create a projection methodology for future years 2023 and 2028 to augment the needs of SLTs. There are 10 groups working on this effort and the work will be accomplished in three phases;
    • Determine the appropriateness of the 2016alpha inventory developed by EPA and suggest improvements.
    • Develop 2016beta and projection methodology to 2028.
    • Finalize 2016v1 with projections to 2023 and 2028
  • For those SLTs that cannot access GoogleDrive at work, files have been copied to Wiki. Another strategy for file sharing may have to be implemented depending on file size.

Introduction to non-EGU Point Workgroup

  • Introduced group to Point Non-EGU WorkGroup Charge. The whole process should be approximately one year. As the group works through items in charge, the specification sheet needs to be completed.
  • Charge workgroup organization: there will be two sub-groups established to target specific data issues;
    • Projection-discuss and develop projection methodology for 2023 and 2028.
    • Aircraft-discuss and develop how to handle aircraft in point non-egu inventory
  • Initial data file, draft 2016alpha, should be available the first or second week of February. Ron Ryan says that 2014v2 point source data has been completed and is available in EIS.

Administrative Items

  • Recurring Meeting: 3rd Tuesday at 1400 EST. Next meeting will be February 20.
  • Google Drive
  • Wiki
    • For those who cannot access Google Drive, smaller files will be posted on Wiki when possible

Action Items

  • Members of work group read over charge and provide comments if you have any.
  • Caroline will work on Google Drive access issue.
  • Let co-chairs know if you have an interest in participating on sub-groups or if you would like to lead one of the subgroups.

Questions and Comments from Meeting

  • How is the group going to get data/input on data from SLTs that are not participating on work group call?
  • Specification Spreadsheet wording could be improved and the example spreadsheet may not be the most appropriate format/example for point source work. It is an agriculture spreadsheet.
    • There are field in EIS that are used when submitting data, could these be used for documentation?
  • How to fill in data not submitted by SLTs for 2016? 2014v2 projected to 2016? Ask SLTs to submit all collected data to EIS even if not required by AERR? Other options?
  • What about point subtraction? How will we avoid double counting?
  • Use trending methodology to generate projections?
  • Aircraft in 2016alpha? Or grown from 2014v2? It was noted that states may only submit partial inventories for 2016 aircraft.
  • Format for final deliverable data files=Smoke input files.
  • Will SPECIATE be used to augment 2016alpha? Sent email to Madeleine Strum
  • What do you see as the main use for the products of this workgroup?
    • Main use of 2016 Emission Modeling Platform would be PM and Ozone modeling. May be able to incorporate work by MARAMA on EMF.
  • How to treat small power generators, i.e. peaking units? Will these units be included in non-EGU point? There are identifiers for these units and could be used to flag units in SMOLE files. Northeast has been working on a similar issue and may have guidance.
    • Ron Ryan noted that many of these go into an IPM file but some do exist in non-EGU file. How will we identify these units?
    • May be determined by overall project coordinators Alison and Zac.
  • Why does the charge have the group projecting to 2028 first rather than 2023?

Next Call: February 20, 2018 at 2pm EST