Closed jsvine closed 1 year ago
Ah, the blank reasons are less of a mystery — they almost all either:
SubmissionType=F
, which represent first-time submissions — hence, no need to provide a code.Ah, and some more clarity: SubmissionType=C
submissions disappear entirely after 2009. So it makes sense that the C
reasons would also disappear. But now the question is why C-type submissions were deprecated. Asking the EPA about this.
Year | F | R | C |
---|---|---|---|
1999 | 14308 | 283 | 1846 |
2000 | 761 | 451 | 1041 |
2001 | 323 | 542 | 988 |
2002 | 330 | 831 | 1010 |
2003 | 334 | 747 | 471 |
2004 | 471 | 10335 | 1174 |
2005 | 324 | 1527 | 956 |
2006 | 350 | 1140 | 1116 |
2007 | 271 | 1132 | 1624 |
2008 | 355 | 1298 | 953 |
2009 | 305 | 7930 | 350 |
2010 | 224 | 2022 | |
2011 | 252 | 1555 | |
2012 | 285 | 1644 | |
2013 | 275 | 1793 | |
2014 | 322 | 6679 | |
2015 | 281 | 2064 | |
2016 | 247 | 2159 | |
2017 | 264 | 1755 | |
2018 | 245 | 1922 | |
2019 | 222 | 5202 | |
2020 | 187 | 2063 | |
2021 | 157 | 2053 | |
2022 | 25 | 299 |
(Note: Year is based on PostmarkDate
, or ReceiptDate
for a handful of the submissions that are missing the former.)
Getting closer to a clearer picture! Via email, the EPA provides an explanation that lines up neatly with what we're seeing in the data:
RMPeSubmit started in 2009. Before that RMPSubmit 2004 was used. First time submissions, corrections, and resubmissions were all submitted on diskettes or CDs so each one was submitted independently. Now with RMP*eSubmit a correction is not a full submission and is a change made to an already existing first time submission or resubmission.
I've now added a section related to that in the documentation draft: "Understanding corrections to RMP submissions"
There still remains, at least for me, some aspects of this that require clarification. For instance: How are pre-2009 corrections reflected in the _ChangeHistory
tables? And how is it that some pre-2009 changes in the _ChangeHistory
tables do not appear to be accompanied by a correction-type RMP submission?
I have received some helpful clarification from the EPA, and updated the relevant section of the documentation to reflect that. The short version is: Even in the earlier era, submitters could make minor corrections online (although only to Section 1 of the RMP) via a utility called "WebRC". This does appear to explain the phenomenon re. pre-2009 changes raised in the comment directly above.
The
tblS1Facilities
table contains aRMPSubmissionReasonCode
field, with corresponding lookup tabletlkpSubmissionReasonCodes
. Looking at the frequency (# of submissions) of each code by year (see table below), a couple of questions in need of clarification:C0_
codes used only between 2004–2009 (with a few minor exceptions)?(None)
column below.) Are submissions supposed to be able to submit an RMP with a reason code?~ (see comment below)Here's the table — note that you may have to scroll horizontally to see all columns:
Count of RMP submissions with each
RMPSubmissionReasonCode
byRecieptDate
year.