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Emerging Regulatory and Technical Topics
- While the new administration has been busy thinking about reviewing old regulations and pulling back any new regulations, the Clean Water Act (CWA) Hazardous Substances Facility Response Plan (FRP) rule is still here. With changing tides and reduced workforce at U.S. EPA, guidance anticipated around this rule and/or implementation dates may be delayed; ALL4 is tracking developments related to this rule and will keep our readers up to date as we learn more. ALL4 co-presented with NCASI on a webinar about the rule and a threshold screening tool NCASI has developed for their members.
- Hot off the presses, U.S. EPA announced on March 12 that they plan to revise the 2023 Waters of the United States (WOTUS) rule to align with the Supreme Court’s decision in Sackett v. Environmental Protection Agency. U.S. EPA stated that they plan to begin this review by obtaining input from stakeholders.
- Although the federal government is discontinuing all efforts around environmental justice (EJ), including removing tools like EJSCREEN from the U.S. EPA website, activities continue in various states. We are not likely to see further guidance around considering EJ in NSR permitting or how a cumulative impacts assessment is performed from U.S. EPA, but several states continue to develop and implement EJ policies and regulations and have their own screening tools. Before you permit your next project, make sure you understand your state’s EJ requirements and whether additional public outreach or air dispersion modeling is required for projects in or near EJ communities.
- Our last newsletter included a summary of the recent Lead and Copper Rule Revisions (LCRR) and Lead and Copper Rule Improvements (LCRI); with the change in administration came uncertainty around the future of LCRI. LCRI was approved within the CRA “lookback” period; Congressional Repeals have been proposed that would revoke LCRI and prevent a “substantially similar” rule. The repeal requires a majority vote in both the House and the Senate and signature by the President. The LCRI’s requirement for replacement of lead service lines (LSLs) by 2037 is undergoing litigation; U.S. EPA has asked the courts for time to decide whether to continue defending the rule in court.
- Addressing per- and polyfluoroalkyl substances (PFAS) was a big priority for the previous administration, with actions such as the establishment of federally-enforceable drinking water maximum contaminant levels (MCLs) for certain PFAS as well as a hazardous substance designation under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). There are still many PFAS concerns to address as well as pending rules at the federal level, but it is uncertain what actions the new administration will take. States, however, are moving along with their own actions, and we’ve updated what we know in a recent article.
- Speaking of state activity, check out our blog on actions states may take over the next four years regarding water quality if there is less regulatory activity at the federal level.
Industry News
- March 4, 2025 | AF&PA Responds to 25% Tariffs on Canada and Mexico Read more
- March 4, 2025 | Poly-Pak, Smurfit Westrock, TC Transcontinental add to 2025 packaging closures, layoffs Read more
- February 26, 2025 | ND Paper Announces Plans to Restart PM 25 at Biron Mill in Wisconsin Read more
- February 18, 2025 | Clearwater Paper eliminates 200 positions as part of cost-cutting plan Read more
- February 13, 2025 | Sylvamo to Invest $145 Million in South Carolina Paper Mill and Sheeting Plant Read more
- February 13, 2025 | International Paper to Close Red River Containerboard Mill, Along with Other Facilities Across US Read more
- February 12, 2025 | Pactiv Evergreen to close Michigan plant, cut 153 jobs Read more
- February 7, 2025 | Paperworkers’ Resource Council Workers Visit Capitol Hill to Discuss Policies Impacting Manufacturing Jobs, Local Communities and the Environment Read more
- February 5, 2025 | Total U.S. Boxboard Production Increased Five Percent in Q4 2024 Read more
- January 31, 2025 | Layoffs, closures announced by Dow, Orbis, Greif in January Read more
- January 31, 2025 | International Paper Completes Acquisition of DS Smith Read more
- January 28, 2025 | U.S. EPA fires science advisers Read more
- January 16, 2025 | Monadnock Paper Mills Earns Platinum Rating in EcoVadis Corporate Social Responsibility Assessment Read more
- December 4, 2024 | Green Bay Packaging Announces Major Investment to Modernize Arkansas Kraft Paper Mill Read more
Safety Corner
A January NIOSH policy update calls on employers to use “individual, qualitative fit testing” to assess the effectiveness of workers’ hearing protection devices. This policy is a revision to NIOSH’s June 1998 criteria document. “Advances in research and technology have made it possible to quickly check the attenuation that each worker receives from their preferred hearing protection devices at the worksite,” NIOSH says.
More info can be found on the American Industrial Hygiene Association’s (AIHA) website.
Reach out to Victoria Sparks, CSP at vsparks@all4inc.com for more info!
Recent Relevant Podcasts/Webinars
- There have been several Executive Orders (EOs) issued by President Trump since he took office in January. The first of these were discussed in a recent podcast. The effect of these has been that comment periods have been extended for several regulatory actions published late in the Biden Administration and that any new federal regulatory activity is temporarily frozen. President Trump also issued an EO on February 19 instructing agencies to develop a list of existing regulations that could be targeted for repeal if they meet any of a list of criteria defined as inconsistent with administration policy and directing agencies to use enforcement discretion on those rules in the meantime. Subscribe to our 4 the Record newsletter for updates on regulatory activity.
- ALL4 hosted a Navigating NPDES Permitting: Key Strategies and Best Practices webinar on February 12, 2025 and published an accompanying ICYMI blog. Reach out to Lizzie Smith at lsmith@all4inc.com with any questions or for more information!
- In our webinar on February 26, we reviewed the California climate disclosure legislation applicability. These regulations currently apply to companies doing business in California, which means they do not need to be incorporated, headquartered or physically located in the state. Have questions? The recording is now available.
Upcoming Events
Conferences
- Louisiana Environmental Conference & Trade Fair in Lafayette, LA – March 19-21
- Kentucky Environmental Conference in Lexington, KY (ALL4’s Scott Kirkpatrick is presenting on CWA Hazardous Substances FRP Rule) – March 26-27
- Amy Marshall is presenting at the American Bar Association’s Spring Conference on Environmental Law in Philadelphia, PA on March 28
- CAPCA Spring in Asheville, NC (ALL4’s Amy Marshall and Steven Moore are presenting an air emissions tools workshop and Daryl Whitt is presenting on sustainability hot topics) – April 9-11
- Tennessee Environmental Network Show of the South in Chattanooga, TN – May 14-16
- TCC EHS Seminar & Industry Tradeshow in Galveston, TX (ALL4’s Cody Fridley is presenting on CWA Hazardous Substances FRP Rule) – June 2-5
- Environmental Trade Fair and Conference in San Antonio, TX – June 3-4
Training
- We are offering our second round of WATER101 this Spring, kicking off April 17!
- Our 12-session AQ101 program starts up again April 22.
- ALL4 can develop customized EHS training programs for your staff – reach out to Lindsey Kroos for information!
Click here for a list of ALL4 conferences, webinars, trainings, and other events.
Upcoming Regulatory Deadlines
You may have noticed that the U.S. EPA’s website for submittal of Greenhouse Gas Reports required by 40 CFR Part 98, e–GGRT, is not available. Although reports are typically due at the end of March, we expect U.S. EPA will issue a reporting extension since the website is not functional. Other upcoming regulatory deadlines to be aware of include quarterly air compliance reports and possibly state air emissions inventory submittals. The comments on the proposed updates to the NSPS for stationary combustion turbines will be due in April.
Tips & Tricks
Our recent reporting blog offered several tips and reminders about 2024 reporting. For example:
- Reminder that 2024 was a leap year
- Reminder that Global Warming Potentials in 40 CFR Part 98 were updated
- Reminder to send your Title V annual compliance certification to both your state or local permitting agency and to the EPA regional office
- Reminder to know what reporting mechanism is required (paper or online submittal)
- Reminder to check for the latest reporting template if your report must be submitted via CEDRI
- Reminder to check your air emissions inventory submittal and your TRI submittal for consistency
Solutions Spotlight
Digital solutions using mobile devices can streamline forest product organizations’ environmental compliance and inspection completion once the capability is implemented. The most immediate impact is the increase in quality and efficiency of inspections because data collection happens directly at the site of inspection, rather than noting information using a clipboard and transferring it later to a digital system. This frees up the technician to record any findings or non-compliance issues in the field and remediate any glaring deficiencies right away. Applications often allow the user to take a picture of any items observed and attach it directly to the inspection or observation. Mobile incident reporting can also allow for earlier and more accurate reporting of incident information. Digital mobile applications, used to collect information on environmental incidents such as spills, can trigger automatic email notifications to stakeholders such as corporate Environmental, Heath, and Safety. Finally, standard data collection into a centralized compliance data hub improves the ability of engineers to analyze trends and identify repeat issues in a comprehensive way. ALL4’s Digital Solutions Practice can assist your organization with identifying and implementing suitable mobile applications. Reach out for more information or to have a conversation about how we might be able to help!
In this time when we are uncertain as to the path that U.S. EPA will take on several issues and what actions it has the resources to undertake, stay tuned for ALL4 regulatory updates in our weekly newsletter, 4 the Record. Please reach out if you have any questions or suggestions for our next quarterly Forest Products newsletter.
Thanks,
Amy Marshall, Air Quality Practice Director
