2025 Look Ahead

Part 1

2025 Look Ahead // Colin McCall

Happy New Year to our colleagues, clients, and partners as we enter 2025. Each January, we are excited to outline observations and insights that will help with proactive planning around environmental, health, safety, and sustainability programs. As our readers see throughout the year, our consultants track regulatory and policy developments around the clock, but the calendar turning gives us a good opportunity to put some of the most critical items together in one place. We are also particularly excited to be releasing our annual Lookahead article for the first time as a global company, having added to our team with locations and consultants in Europe and Latin America. Here are a few things companies with operations in the U.S., Europe, and Latin America should consider and navigate in 2025:

1. This month the U.S. will see its third Federal administration change in the past eight years. Over the next six months the priorities of the new administration and how it will impact project permitting will come into greater focus. We expect most of the Federal regulatory activity to focus on Clean Air Act deadlines related to regulatory and ambient standard reviews that the United States Environmental Protection Agency (U.S. EPA) is required to perform rather than the development of entirely new regulation and policy. ALL4 will continue to track U.S. EPA’s priorities moving forward.
2. The outgoing U.S. EPA administration has been very busy with rulemaking over the past 12 months. The fine particulate (PM_2.5) ambient standard, Facility Response Plan (FRP) rulemaking, and Risk Management Plan (RMP) rulemaking, per- and polyfluoroalkyl substances (PFAS) developments, in addition to industry-specific regulatory updates (e.g., Chemical Industry Maximum Achievable Control Technology (MACT) standards), are a few examples of rules that will require compliance and capital planning in the coming months.
3. Although there is not likely to be much activity around Environmental Justice at the federal level in 2025, we anticipate regulatory and policy activity at the state and local levels in certain geographies and continued active involvement in environmental permitting processes from communities and environmental groups at both the national and local level. As a result, no permit renewal or construction permitting process should be viewed as routine, and connections with local regulatory agencies on what they are hearing from environmental groups and communities will be critical.
4. Sustainability regulatory and policy developments in the U.S. at the Federal level remain to be seen, but Europe’s Corporate Sustainability Reporting Directive (CSRD) will require disclosures and other activities of European-based companies and certain U.S.-based companies with operations in Europe. California legislation requires greenhouse gas (GHG) and climate risk disclosures. This regulatory and legislative activity will continue to increase the importance of generating auditable sustainability data using tools to create strong documentation and efficiencies around the preparation of that data.

Our consultants get a lot of energy from tracking these developments and helping their clients navigate them. I trust that you will feel that in these lookahead articles and hope you will reach out to us with questions and comments. We are looking forward to working together in the year ahead!

“Here We Go Again” – 2025 New Source Review Look Ahead // Roy Rakiewicz

The on-going New Source Review (NSR) saga continues into 2025, and likely beyond, with a new (old) administration. While ALL4 does not anticipate any consequential changes to the NSR program in 2025, there are a few clean-up issues that could be addressed in the short-term and a nugget from 2018 that may reappear. ALL4 can help you navigate changing policies and regulations and can help you make sense out of possible NSR regulatory revisions. Navigating NSR requirements can be challenging, especially in the midst of tightened National Ambient Air Quality Standards (NAAQS). ALL4 can help you develop a permitting strategy and timeline while working with you to successfully permit your project. We can also help you develop technical comments in support of or challenging proposed federal or state regulatory changes

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Impacts of Lowered PM_2.5 NAAQS to take Shape in 2025 and other NAAQS related Updates // Dan Dix

On February 7, 2024, the United States Environmental Protection Agency (U.S. EPA) finalized the particulate matter (PM) National Ambient Air Quality Standards (NAAQS) reconsideration process and lowered the annual PM less than 2.5 microns (PM_2.5) NAAQS from 12 micrograms per cubic meter (mg/m³) to 9 mg/m³. A change to any NAAQS triggers a regulatory process for implementation of the revised NAAQS that has a number of milestones starting at the promulgation date. There are several critical implementation milestones for the lowered annual PM_2.5 NAAQS occurring in 2025 that will provide more clarity on how the lowered annual PM_2.5 NAAQS may impact your operations, including an opportunity for the public to provide comments on the implementation process. 

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2025 Look Ahead: Occupational Health and Safety // Victoria Sparks

Looking back on 2024, the Occupational Safety and Health Administration (OSHA) proposed federal rules for heat safety and emergency response workers. Increased enforcement around Process Safety Management (PSM) programs, and updated recordkeeping and reporting requirements. As we look ahead to what 2025 will bring with the transition to a new administration, we can expect a move to scale back federal regulatory oversight on workplace safety issues, however OSHA will continue to play a vital role in ensuring workplace safety across industries. There will still be essential compliance requirements for OSHA-regulated facilities in 2025. Heading into 2025, OSHA is focusing on several key areas to enhance workplace safety that could result in the need to update your facility’s programs. 

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PFAS Expectations for 2025 // Kayla Nuschke

There was a lot of per- and polyfluoroalkyl substances (PFAS) related activity in 2024 and we are not expecting this to go away in 2025. Although we may see a reduction in priority status or available resources to pursue PFAS regulation under the incoming Trump administration, it’s undeniable that public scrutiny and concern around PFAS continues to grow. As such, we anticipate the overall push to continue to some degree. While PFAS regulations are popping up at all levels and under many regulatory programs, some key actions we’d like to highlight for 2025 are relating to water and chemical reporting. It will also be critical in 2025 and beyond to monitor PFAS regulations closely and understand what state regulations may also be in place that could affect your facility.

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2025 Look Ahead ESG & Sustainability // Connie Prostko-Bell

In the Sustainability and ESG spaces, 2025 will see the parallel drivers of regulatory obligation and market requirements accelerate both domestically in the US and abroad. These drivers will also compel a significant “back-to-basics” movement focusing on resource consumption optimization and conservation and material recovery and reuse to secure domestic supply.

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Part 2

Looking Ahead – Air Toxics Regulatory Activity // Amy Marshall

The last few years have seen a flurry of revisions to air toxics regulations, due primarily to a court case referred to as “LEAN” where the court determined that the U.S. Environmental Protection Agency (EPA) should have set more comprehensive emissions standards when it first promulgated many of its rules under 40 CFR Part 63. U.S. EPA has been revising National Emission Standards for Hazardous Air Pollutants (NESHAP) to include additional hazardous air pollutants (HAPs) and additional emissions sources. More stringent requirements have also been added to the NESHAP for some source categories due to an update in the risk value for ethylene oxide. Sectors affected by significant rule changes include coke ovens, iron and steel, tire manufacturing, lime manufacturing, and chemicals. The recent changes often include not only new emissions standards but also more stringent monitoring requirements, including fenceline monitoring. U.S. EPA is obligated to review their NESHAP on a certain schedule, so even without decisions like LEAN, the work never ends. What might be coming in 2025?

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2025 Lookahead: Resiliency Planning in Stormwater // Lizzie Smith

U.S. EPA defines “resilience” as “the ability to prepare for, withstand, and successfully recover from a disaster.” In 2021, U.S. EPA renewed its National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity, and the renewed permit included requiring subject facilities to consider implementing structural improvements, enhanced/resilient pollution prevention measures, and other mitigation measures to minimize impacts of stormwater discharges from major storm events such as hurricanes, storm surge, extreme precipitation, and flood events (i.e., more extreme weather as a function of climate change). Subject facilities were required to document any such existing control measures in their Stormwater Pollution Prevention Plan (SWPPP) and to consider additional measures. While the U.S. EPA MSGP applies only in areas and classes of discharge that are outside of the scope of a state’s NPDES program authorization (see Appendix C to the MSGP for a list), in 2024, states renewing their own MSGPs have adopted similar requirements, and we expect this trend to continue into 2025.

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U.S. Power Sector: Looking Ahead to 2025 // Rich Hamel

The power sector in the United States is poised to change significantly in the next 25 years. The rate of power generation has remained relatively flat over the past 20 years, largely due to the wide scale deployment of residential rooftop solar panels and widespread improvements in energy efficiency, and since 2019, the U.S. has produced more electricity than it has consumed. This relatively static need for capacity has eased the process of retiring older fossil fuel plants and replacing them with newer, more efficient plants and renewable energy generation. In fact, by 2023, the contribution of renewables of all types to the US power mix was more than the contribution from coal-fired power generation or nuclear power generation.

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Environmental Justice Lookahead: Rollback of Environmental Justice at the Federal Level is Here // Joe Sabato

With the Trump administration taking over on Monday January 20, 2025, Donald Trump fulfilled campaign promises to begin rolling back environmental justice (EJ) requirements on Day 1. Trump signed an executive order entitled “Initial Rescissions of Harmful Executive Orders and Actions”, where among other actions, Biden’s Executive Order 14096 (Revitalizing Our Nation’s Commitment to Environmental Justice for All) was rescinded. Additionally, in a separate executive order (Ending Radical and Wasteful Government DEI Program and Preferencing), Trump took further action to eliminate EJ programs.

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Part 3

Chemicals and Ethylene Oxide Lookahead // Philip Crawford

Continuing the momentum of the past several years as the United States Environmental Protection Agency (U.S. EPA) is conducting its required periodic reviews of air rules, 2025 promises to bring additional changes to regulations for the chemical industry, including users of ethylene oxide (EtO). This article mainly covers updates to three major chemicals air rules for the Synthetic Organic Chemical Manufacturing Industry, Polyether Polyols Production, and Chemical Manufacturing Area Sources, but multiple other rules affecting industry are also covered, including an outlook for Toxics Substance Control Act updates in 2025…

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Looking Ahead – Fenceline Monitoring // Kyle Hunt

In 2024, the U.S. Environmental Protection Agency (U.S. EPA) finalized new fenceline monitoring requirements associated with amendments to Standards of Performance for New Stationary Sources (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) associated with the following source categories…

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2025 Look Ahead – Data Centers // Sharon Sadler

Data centers can get a bad rap – large buildings near residential areas, consuming power, drawing water, creating an inescapable hum. No industry is perfect. But what else? Data centers generate large tax  revenues for localities (and in Loudoun County, VA, for example, thereby reduce the tax burden on residents), their owners give back to the communities and invest in the alternative energy industry to help solve concerns around power, and if you use the internet, drive an electric car, make plans using a smart phone – you need them; the “cloud” lives inside of data centers. As Artificial Intelligence (AI) expands, we’re only going to need them more, and the U.S. government agrees. During his last week in office, former President Biden signed an Executive Order (EO) committing Federal support to ensure American leadership in AI, which includes facilitating the construction of data centers through several measures, catalyzing clean energy generation, and creating partnerships. During his first week in office, President Trump highlighted strategic partnerships and billions of dollars in AI infrastructure investment.

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Clean Water Act Facility Response Planning for Hazardous Substances // Matt Dabrowski

As we start 2025 it is important to note that we are moving closer to the compliance deadline of the United States Environmental Protection Agency’s (U.S. EPA) Clean Water Act (CWA) Hazardous Substances Facility Response Plans (FRP) regulation under 40 CFR 118. Think of this rule as more advanced Spill Prevention, Control and Countermeasure (SPCC) for chemicals…

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