2024 Look Ahead
Posted: January 9th, 2024
Authors: Colin M. Dan D. Michael L. Scott K. Teck L. Aditya S.
Part 1
2024 Look Ahead // Colin McCall
Hello to all of our clients, partners, and colleagues as we enter 2024. We are very grateful for the time and work together in 2023 and look forward to another great year ahead. We are particularly excited amongst the ALL4 team to continue the growth of our existing Practices and Geographies and to continue to serve as a strategic partner for our clients in 2024. The year ahead will see changes to navigate in all facets of our business:
- Regulatory changes in environmental lanes will require significant compliance and permitting preparation and planning. The pending fine particulate National Ambient Air Quality Standard has the potential to change the way we view future capital spending and strategies at major facilities as just one example. Another example: the proposed Facility Response Plan regulation that will add to the stored chemicals that we need to evaluate and plans to prepare.
- The manner in which we evaluate carbon emissions and the expectations around carbon will continue to shift. We are awaiting the first nationwide carbon disclosure rulemaking from the Securities and Exchange Commission. With that will come increased expectations around the auditability and traceability of emissions data to go from “compliance grade” to “financial grade”. The companies that evolve and utilize digital tools best fit for their operations will be the most successful in this area.
- Environmental Justice (EJ) policy will continue to develop in a patchwork fashion across a variety of states and regulatory agencies. We will closely monitor these developments and continue to encourage a strong connection between industry and state regulatory agencies to work together in addressing the public stakeholder requirements in the permitting processes that they undertake.
- Building upon EJ policy, the broader involvement and activity of the public as a stakeholder in the permitting process for industrial clients will continue to increase. New grants are being awarded to local environmental groups routinely for the installation of public ambient monitoring networks in a variety of locations as just one example of increased public stakeholder involvement. Companies will be well served to continue to enhance their public outreach and education programs to increase the depth of relationships with neighbors.
Layer these developments atop a presidential election year and there will be no shortage of regulatory and policy developments to stay connected on. We hope that the Look Ahead topics and articles for 2024 are a helpful start in navigating these changes. Every year I am reminded of the pride I have for our team and their insights, and I hope that you will enjoy reading these updates from them.
PM2.5 NAAQS Lookahead: Revision of the Annual Standard is Imminent // Dan Dix
The proposed lowering of the annual particulate matter less than 2.5 microns (PM2.5) National Ambient Air Quality Standard (NAAQS) from 12 micrograms per cubic meter (µg/m3) to a level between 9 µg/m3 and 10 µg/m3 is in the final stages of being finalized and has been at the White House Office of Management and Budget (OMB) since September 22, 2023. At the beginning of 2024, the U.S. EPA filed a motion to extend abeyance of a lawsuit related to the PM2.5 reconsideration process and as a result ALL4 currently expects a finalized PM2.5 NAAQS rule in mid-February 2024.
2024 Look Ahead: Battery Safety and Compliance // Michael Liebert
The Inflation Reduction Act (IRA) of 2022 set aside over $360 Billion for climate and clean energy projects. That’s billion with a B! This influx of funding caused an immediate impact on the battery industry in the United States (U.S.), from production to disposal and reuse. Lithium-Ion batteries are a critical ingredient in the transition to a sustainable energy future for the U.S. as they are used both in electric vehicles (EVs) and for storing energy created by solar and wind. As lithium-ion batteries become more important and prevalent in today’s current and future economy, new requirements and changes to current requirements continue to arise affecting producers, transporters, and recyclers. ALL4 has its finger on the pulse of all aspects of battery management and has put together the “ALL4 Path to Lithium-Ion Battery Safety and Compliance”.
Continue reading about Battery Safety and Compliance
TSCA Look Ahead for 2024 // Scott Kirkpatrick
We saw regular activity around the Toxic Substances Control Act (TSCA) in 2023 and we expect even higher activity levels in 2024. The once every four-year Chemical Data Reporting (CDR) window opens June 1, 2024. The information allows U.S. EPA to understand the types, amounts, end uses, and possible exposure routes for chemicals in commerce. This allows U.S. EPA to collect data to support chemical prioritization, risk assessment, and risk management activities which has ramped up in recent years. Proposed Risk Management Rules were proposed for four chemicals in 2023. The public comment period for the prioritization of five new chemicals was opened December 18, 2023. It is important to collect good quality data for the CDR and get involved in the prioritization and risk evaluation of chemicals critical to your facility through public comment.
Future of AI in Environmental Work // Aditya Shivkumar & Teck Lee
Whether the hype over Artificial Intelligence (AI) has you feeling empowered, enthused, overwhelmed, or concerned, the fact is that AI is changing (and will continue to change) the way we develop permit applications, demonstrate compliance, and review data. This blog explores the pivotal roles of Machine Learning (ML), Natural Language Processing (NLP), Robotic Process Automation (RPA), and Image Recognition in revolutionizing environmental compliance, health and safety, air quality, and Environmental, Social, and Governance (ESG) work. ML forecasts operational and compliance issues, NLP extracts insights from textual data, RPA streamlines ESG and compliance reporting, and Image Recognition transforms everything from health and safety to environmental compliance. The application of AI promises to support more efficient and informed decisions, fostering more sustainably developed solutions.
