Unlocking the Versatility of Power BI Desktop

In the digital age, businesses have a need to manage vast amounts of data from various sources. It is important to use this data to gain insights to assist strategic decision-making and support organizational growth. Achieving these goals often involves visualizing data, creating reports, and manipulating data models. Business Intelligence (BI) applications such as Power BI empower users to achieve those goals, making it important to understand their capabilities and master the use of them.

Understanding Power BI and Its Uses

Power BI is a set of applications designed for analysts, data scientists, and business users who want to present data purposefully. Uses of the application include report creation, data modeling/transformation, data analysis, and predictive analytics. When users understand how to navigate the application, they can utilize all of Power BI’s strengths and maximize its practical uses.

Strengths and Practical Uses

• Data Connectivity
  • Connects to extensive data sources including databases, cloud services, and individual files.
  • Imports data from various sources such as SQL Servers, Excel/CSV files, web browsers, and Azure.
• Data Transformation
  • Provides tools for cleaning and preparing data, such as manipulating data columns and creating conditional columns.
  • Features the Power Query, which enables users to transform data in a structured manner.
• Data Modeling
  • Allows users to create relationships between different data tables using the Model view and joining data sets.
  • Supports creation of calculated columns and measures using DAX (Data Analysis Expressions), Power BI’s primary formula and query language.
• Report Creation
  • Offers various visualization options including charts, graphs, maps, tables, matrices, etc.
  • Contains functionalities that allow users to populate visualization options and customize them according to color, fonts, and formatting.
  • Allows downloads of additional visual reports not included in PowerBI’s out of the box version.
• Report Interactivity
  • Enables dynamic data exploration through filters that can be placed on reports.
  • Supports highlighting and cross-filtering between different report visualizations.

Insights on Power BI’s Usability

To unlock the versatility of the Power BI application, there are a few insights to know while using it. First, using the application is a skill that will take time to master. There are a great number of online resources to aid users while learning how to use Power BI. Second, there are many ways to manipulate imported data. Users must be able to understand basic computing logic and harness critical thinking skills to solve problems. The computing language DAX is used to manipulate imported data and should be understood when creating variables or equations that pertain to a user’s project. Additionally, data modeling is a big aspect of connecting different data sets to generate reports. It requires time, effort, and patience to understand. Finally, there are a multitude of visualization templates for model data sets. Users can edit their reports through these visualizations, but only to the extent that the application allows. As a result, creative ideas for reports can be fulfilled, but users should be aware of each visualization’s limits. Fortunately, the ability to import new visuals gives more variety to users who may want to use different visualizations.

Example of Power BI Data Visualization

One Power BI project that ALL4’s digital solutions practice (DSP) worked on tracked environmental spills. The project was a good example of the practicality of Power BI, and how it could be used in other report design projects in the future. To demonstrate the use of Power BI to stakeholders at the outset of the project, an example table and dataset were created for an original report.

Below is the demo chart made to display the hypothetical cumulative volume and monthly volume of oil spills in 2024.

Data can be imported from many locations and in this example ALL4 manually created an Excel file and uploaded it into the Power BI application. Below is a snippet of the data that was uploaded locally.

The example data table is very simple, as it only shows the date and volume of spills, but it serves to illustrate how the application can be used to perform calculations and create a visual from a data set. The column Quantity (GAL) is used within the DAX calculations to find the volume of spills from the current year and previous five years. The calculation below shows how we pulled data to create a visualization.

In this formula, we take advantage of the DAX language to calculate the volume of spills there are in the year 2024. Rows 5 to 7 showcase how we pull the data from the ‘Spill Report,’ which is what we named the data pulled from the dataset example. In row 7, we created another calculation that uses columns such as Quantity, which is the sum spill volume for the year. All these calculations result in the blue line with the squares in the Reportable Spill chart.

This process highlights the creative capabilities of the Power BI application and its practical applications. With a solid understanding of how to navigate the software and utilize the DAX language, developers can craft interactive charts that effectively visualize data. Although mastering these processes and languages requires time and effort, ALL4 has extensive experience in delivering results with Power BI. We know how to use our expertise to efficiently develop data models and unlock the full creative potential of every visual report to help our clients make the most of their data and operate more efficiently.

Conclusion

Given how important it is to manipulate and visualize vast amounts of data for most companies, BI applications are needed for success. By providing a user-friendly interface for data transformation, modeling, connectivity, and visualization, the application can be used across all diverse roles and skill levels within organizations. Power BI can be used to display company or division-wide data, compare performance, and provide real-time monitoring of a single process to identify trends, alert operators to potential issues, and flag upcoming failures or compliance risks. Once a Power BI dashboard is set up, it can be easy for users to navigate the visualization and apply desired filters to see the information they need. Applications like Power BI are useful for any project that has data as its focal point.

ALL4 is well-equipped to help develop customized BI dashboards for our clients. We have utilized Power BI internally for resourcing and on projects for data analysis and data visualization. Please reach out to Derrick Chen at dchen@all4inc.com to learn more about how we can help you better manage and visualize your data.

Thinking About Noise Levels from Your Project is a SOUND Decision

Sound and noise are often used interchangeably, but a deeper look into their definitions reveals that noise is any sound that is undesired or interferes with one’s hearing of something while sound is the sensation perceived by the sense of hearing. Sound is observed in nearly every environment ranging from the hum of the refrigerator in your house to the whine of a sports car engine, to wind turbine generators, to the power generation and cooling systems of a data center. We also hear sounds from birds chirping in the forest, leaves and other vegetation rustling in the wind, or wildlife running through the shrubs. Sounds are all around us and we rarely give sound a second thought until it becomes noise.

When planning a new project at your facility it’s easy to overlook how the project might sound until after the project is constructed and becomes noise. Coincidentally, once a project is operating and generating noise, you will find that it is much more difficult to mitigate that noise. In some extreme cases, ignoring the noise until a project is operational could potentially lead to lawsuits and litigation, which are a headache for everyone involved.

Noise regulations are intended to protect communities from excess noise levels. These regulations often differ from community to community and have the potential to be quite confusing or only provide a qualitative sound level limit for a project. Alternatively, some municipalities simply point to the regulations enforced by a larger governing body (such as a county or state). There is even the possibility that a local municipality does not have any noise regulations and simply requires that a project not become a nuisance.

So how can a project avoid becoming a headache for you and your neighbors? Here are a few things to consider:

• Start thinking of potential sound level impacts from your project early. This could include reviewing the local, county, and state noise-related codes to understand what the requirements are around noise levels.
• Ignore Listen to the noise. Take a moment before a project starts up to understand what the existing sound levels are at your site. This could be as simple as listening with your ears or measuring existing sound levels at a proposed site.
• Consider the sound levels from proposed equipment associated with your project. Often this can be done using predictive sound level modeling. Building a sound level model can simulate the expected project-only sound levels generated by a proposed facility. These are typically presented as “worst-case” sound levels where each piece of proposed equipment is operating simultaneously. Sound levels generated by a predictive model can be directly compared to the applicable noise level limits.
• Consider mitigation early on in the process. Predictive sound level modeling can also factor in the impact of different mitigation options. For example, what if the project used a better enclosure? What would happen if a noise source were relocated to a different part of the site?
• Once a project is up and running, post-construction noise monitoring can be used to confirm the results of the predictive sound level model with respect to relevant regulations.

Ignoring the noise in the beginning stages of a project may lead to headaches later on. ALL4 is here to help. We have experience reviewing noise requirements, can perform predictive sound level modeling, and can measure noise levels from your facility and your project. Feel like sounding off to us about your project’s noise impacts? We’re happy to listen. Reach out to TJ Savino at tsavino@all4inc.com or 508-251-9906 to discuss how we can help.

Gasoline Distribution Terminal Regulation Changes – Do You Need to Install a TOC CEMS or Update Your TOC Monitoring Strategy?

As mentioned in a previous ALL4 article, the United States Environmental Protection Agency (U.S. EPA) finalized updates on May 8, 2024 to the Gasoline Distribution Terminal Regulations. The Gasoline Distribution Terminal Regulations include 40 CFR Part 63, Subpart R (National Emission Standards for Gasoline Distribution Facilities [Bulk Gasoline Terminals and Pipeline Breakout Stations]) for major sources of hazardous air pollutants (HAP), 40 CFR Part 63, Subpart BBBBBB (National Emissions Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities) for area sources of HAPs, and 40 CFR Part 60, Subparts XX and XXa (Standards of Performance for Bulk Gasoline Terminals) for new, modified, and reconstructed facilities.

This article focuses on the changes in 40 CFR Part 63, Subpart R and 40 CFR Part 63, Subpart BBBBBB that require bulk gasoline terminals using vapor recovery systems to comply with a total organic carbon (TOC) concentration limit with a continuous emissions monitoring system (CEMS). These changes may require a facility to either install a TOC CEMS that was not previously required or make changes to the current monitoring strategy to comply with the new concentration limits. The compliance date related to these changes is May 8, 2027 (i.e., three years after the rule updates were finalized).

In the response to comments for this regulatory action U.S. EPA indicated that they are requiring “CEMS for all rules, including NESHAP Subpart BBBBBB, because a CEMS can directly assess compliance with the emission limit and the design and operating parameters cannot provide this direct assessment.” U.S. EPA also indicated that to account for periods of CEMS outages they also provided an “alternative to CEMS that could be used for limited periods of CEMS outages, but not one that could be used indefinitely as an ongoing alternative to a CEMS.” Although there are still alternatives allowed within the updated rules they are only temporary (i.e., up to 240 hours per calendar year) and a CEMS is the primary method for compliance.

If your facility is impacted by these changes to 40 CFR Part 63, Subpart R or 40 CFR Part 63, Subpart BBBBBB, and a TOC CEMS is required on your vapor recovery system, here are some things to consider and steps to take as the compliance date approaches:

1) Evaluate your current compliance method in comparison to new/revised requirements to determine if new monitoring approaches (or changes to existing monitoring) are needed.

1. We recommend you complete this step as soon as possible. If there are changes to the current monitoring strategy or a new CEMS needs to be purchased and installed, there are timing considerations to make sure everything is in place by the compliance date.

2) If you do not currently have a TOC CEMS and need to install one, you will need to consider the following:

1. Procurement process considerations
   1. Can the proposed CEMS meet the applicable Performance Specification?
   2. Are there any state-specific CEMS specifications that need to be met?
   3. Is there a data acquisition and handling system (DAHS) in place to meet recordkeeping and reporting requirements or will one need to be implemented?
   4. How will the data systems work together at the facility?
   5. Are the data systems robust enough to alert you when data is trending toward non-compliance?
   6. What are the lead times for the equipment needed?
2. Installation requirements and considerations
   1. Is the CEMS being installed in a location that meets the applicable Performance Specification?
   2. Where will all the equipment be placed (e.g., shelter, reference gas bottles, etc.)?
   3. Is there an accessible power source?
   4. What infrastructure is available for data communications?
3. Initial certification and performance evaluation test considerations
   1. Schedule third party vendors (as needed) to complete the required testing and ensure protocols and notifications are completed on time.
   2. Plan the testing so the CEMS performance evaluation is completed prior to the compliance date.

3) Ensure a quality assurance/quality control (QA/QC) plan is in place that addresses the TOC CEMS (may need to develop a plan or update an existing plan).

4) Evaluate reporting requirements and ensure processes are in place to accurately report CEMS compliance (downtime and excess emissions).

5) Evaluate how alternative monitoring may be used during periods of CEMS outages and ensure those monitoring systems and data collection processes are in place.

6) Ensure you will be able to meet the required ongoing QA/QC requirements.

1. What is the facility’s workflow for completing the QA/QC on the TOC CEMS?
2. Do you need additional staff or contract support?

ALL4 has a team of continuous monitoring system experts that can help you implement and improve monitoring systems, analyze your data, and maintain compliance with applicable requirements. If you have questions about how the updates in the Gasoline Distribution Terminal Regulations impact your monitoring requirements or need help navigating the CEMS implementation process, please reach out to me at mstroup@all4inc.com.

Happy World WATER Day: ALL4 Water Services

Happy (Early) World Water Day! World Water Day is an annual United Nations observance on March 22 that began in 1993 to highlight the importance of fresh water. As ALL4’s Water Lead, I thought World Water Day was the perfect opportunity to update our clients on ALL4’s rapidly growing Water Services and how our services contribute to the protection of water resources!

Industrial Wastewater Permitting and Compliance

ALL4 supports our clients with all manner of industrial wastewater permitting and compliance including National Pollutant Discharge and Elimination System (NPDES) modification and renewal permitting (if you missed our webinar, check out the recording or our blog), renewal and modification permitting for indirect dischargers [Significant Industrial User/Significant Industrial Discharge/Categorical Industrial User (SIU/SID/CIU)], reasonable potential and antidegradation analyses, sampling, and compliance reporting. Need help with an upcoming modification or renewal application? Having trouble understanding the “why” behind onerous permit requirements or upcoming changes to discharge regulations? Not sure if a change planned at your facility requires wastewater permitting? One of our experts can help!

Industrial Stormwater Permitting and Compliance

ALL4 supports clients with industrial stormwater coverage from state or United States Environmental Protection Agency (U.S. EPA) multi-sector general permits (MSGP) or individual stormwater permit coverage, including:

• Notice of Intent (NOI)/Note of Termination (NOT)
• Stormwater Pollution Prevention Plan (SWPPP) development and updates
• Sampling
• Inspections
• Compliance reporting
• Training
• Evaluation of water quality trends

ALL4 can also evaluate and support with no exposure certifications (NEC) or no potential to discharge evaluations for applicable states. ALL4 tracks general permit renewals at the state level and keeps our clients and readers up to date on changes. Check out our Lookahead blog on resiliency planning in stormwater permits at the U.S. EPA and state level.

Wastewater Design, Operation, and Troubleshooting

The acquisition of our Boston office in 2024 brought expertise with wastewater treatment system design, operation, and troubleshooting! The Boston office supports clients with design solutions to mitigate compliance concerns, upgrade aging systems, or accommodate production changes. They also provide training courses for Massachusetts Wastewater Operator exam preparation and Training Contact Hours (TCHs). ALL4 is excited to be able to offer these services to our clients.

Water Resources

Not only does ALL4 help clients protect water from a permitting and compliance perspective, we also harness the power of water through the design and permitting of water control infrastructure. Whether it be stormwater modeling to support the design of stormwater management control, hydraulic modeling for streambank restoration, or inspection and redesign of regulated dams, ALL4 has Professional Engineers and Geologists on staff who can support various Water Resources projects.

Drinking Water Support

ALL4’s rapidly expanding water services area allows us to support clients with public water supply permitting, water system sampling and reporting, and public water system emergency response plan preparation. And if you’re unsure of the Lead and Copper Rule requirements (or are a bit tardy with submittal), we can help with that too!

Water Support Services

Other water-related services ALL4 can support our clients with include:

• Spill Prevention, Control, and Countermeasure (SPCC) Plans
• Facility Response Plans (FRP) – including the new Clean Water Act (CWA) Hazardous Substances FRP
• Best Management Practices (BMP) plans
• State-required contingency plans
• Laboratory Quality Assurance/Quality Control (QA/QC) and Standard Operating Procedure (SOP) review
• U.S. Army Corps of Engineers permitting
• Compliance auditing

As ALL4’s Water Lead, I am thrilled to see the growth in water service offerings over the past several years – and we aren’t done growing! Not sure who to reach out to about your water needs or want to discuss our current water services? Reach our Water Team at water@all4inc.com and we will connect you with one of our 100+ water practitioners!

Phases of a Digital Solutions Project

A project to select, configure, and implement a new digital tool can be a long and complex process. A general understanding of the process of implementing these projects can help staff that do not have an IT background (such as environmental or health and safety personnel helping to support selection and implementation of a software tool) understand the steps of the process. This article describes a general or best practice approach to digital solution projects. For specific cases, there may be good reasons to deviate from these steps or approach them in a different order.

1) Determine Need – Being able to clearly define the need for a new software tool is the first step. Some examples could include replacing an existing system that can no longer be supported or lacks key features or implementing an entirely new tool where no robust digital solution currently exists. When the need is not replacing an existing system, clearly understanding what goals you are trying to achieve and what business processes the software should support is key. For example, the goal could be to streamline a manual process that is prone to errors – you might determine that this software should support an environmental compliance calendar, including routine tasks and alerting someone when a due date is approaching or if a task deadline is missed.

2) Define Requirements – Requirements are more granular and specific statements of what the software should do. Requirements are important because if the system design and configuration meets the requirements, then the project is considered successful by IT standards. Requirements form the basis of robust system selection, as systems that cannot meet critical requirement should not be selected for a project. Here are a few tips for defining strong software requirements:

• Work with a variety of stakeholders – not just IT, administrators, or end users; make sure all stakeholders are represented in the requirements gathering team.

• Select the correct-sized group – if groups are too small they may miss requirements while groups that are too large may struggle to reach consensus and agree on requirements.

• Include IT for security/integration requirements – Company IT groups often have security requirements for all software. A system should not be selected that cannot support security requirements. If the system will integrate with other software, IT groups often build and manage these integrations and may have requirements around standard protocols the software should support.

Not following these best practices can result in unplanned costs due to missed requirements!

3) System Selection – Once requirements exist for the project, with each labeled as “must have” or “nice to have,” it is time to start developing a request for proposal.

• Target group of likely vendors – creating an RFP and responding to one takes significant time for both the company sending and reviewing the RFP and the vendor responding to it. For efficiency, it is best to target specific vendors that are likely to be able to meet the requirements. To identify this group, you could contact a consultant familiar with digital tools such as ALL4’s Digital Solutions Practice or review impartial third parties’ descriptions of different software capabilities.

• Format requirements to maximize success – Asking if something can be done in a configurable, off the shelf solution may cause a software vendor to say yes, but it can only be done with significant effort and customization, which may prove costly. This type of question and its answer are often misleading to the team selecting software. There are ways to write and format RFP questions to receive more helpful data from vendor responses.

• Have vendors demonstrate tool capabilities – Giving vendors a script they must follow when they demo their tools allows you to compare systems more evenly because they are all showing the same set of features. It also avoids the software vendor demonstrating only the strengths of their tool.

4) Design – After the software system is selected, detailed design begins. This takes the requirements that were previously designed and translates them into features and a configuration using the tools and features of the selected software. New requirements may also be uncovered during this process. Any gaps or situations where the requirements cannot be directly met by software features or configuration should be addressed with a gap closure or workaround.

5) Configuration – Depending on the level of configurability of the software and how close the requirements aligned with the tool out of the box, this can be very minimal or very involved.

6) Load Your Content (if applicable) – This step can be minimal for certain types of tools (for example, event reporting) or a very high effort for others (environmental compliance tasking based on regulatory requirements or air emissions calculations).

7) User Acceptance Testing – This step involves testing of configuration and content to confirm everything works as expected, followed by configuration and content adjustments to correct anything found to be defective. User Acceptance Testing (or UAT) is the user’s chance to validate that the delivered product meets the project requirements.

8) Go Live– In order to prepare for Go Live, configuration and content must be put into the digital tool’s production environment, where end users will access it. Users must be given user accounts and any features such as Single Sign On must be turned on. Once all of these tasks have happened, the system is live.

9) Training of End Users – Once the tool is ready for end users, clear communication and training is needed to ensure that end users start using the tool. Although this step happens at the end of the process and can be overlooked, it is critical to increase user adoption of a tool that the company may have spent years selecting, configuring, and preparing to use.

10) Ongoing Maintenance and Support – This could take the form of periodic enhancements, such as adding new fields or reports, or evergreening system content to reflect new regulations, updated permits, etc. It could also take the form of updating system integrations as the software the systems are integrated with change to keep data moving in and out of the system.

The ALL4 Digital Solutions team has experience supporting every step of this process from determining a need to ongoing maintenance and support. We have helped clients implement tools from simple compliance calendars or data dashboards to comprehensive multimedia environmental and safety information and compliance management systems. If you want to learn more about how digital tools can fulfill your information or compliance management needs and what tools might best meet your requirements, please contact Julie Taccino at jtaccino@all4inc.com or 281-201-1247.

Waters of the United States Reconsidered

he United States Environmental Protection Agency (U.S. EPA), in a press release on March 12, 2025, announced the decision to review the definition of “waters of the United States” (WOTUS) with the U.S. Army Corps of Engineers (USACE). The U.S. EPA and USACE (Agencies) have been granted authority via the Clean Water Act (CWA) to define WOTUS in U.S. regulations because the CWA does not provide a definition for WOTUS. The CWA instead provides approved jurisdictional determinations and delegates authority to the Agencies to define WOTUS in regulations.

In the press release U.S. EPA stated that the review will “be guided by the Supreme Court’s decision in Sackett v. Environmental Protection Agency (Sackett), which stated that the Clean Water Act’s use of ‘waters’ encompasses only those relatively permanent, standing or continuously flowing bodies of water forming streams, oceans, rivers and lakes. The Sackett decision also clarified that wetlands would only be covered when having a continuous surface connection to waterbodies that are ‘waters of the United States’ in their own right.” As part of the press release, U.S. EPA provided a pre-publication notice to be used as initial guidance for providing recommendations to the Agencies on the definition of WOTUS. The official version of the document will be provided via the Federal Register and Regulations.gov in Docket No. EPA-HQ-OW-2025-0093 upon publication, and the pre-publication version will be removed.

The Supreme Court provided guidance for jurisdiction over adjacent wetlands in Sackett as a two-part test in order to provide consistency in determining the scope of ‘adjacent wetlands’ and ‘continuous surface connection’. The two-part test includes the following:

1. The adjacent body of water must be a WOTUS, or a relatively permanent body of water connected to a traditional navigable water; and
2. The ‘wetland’ (33 CFR 328.3(c) and 40 CFR 120.2(c)) must have a continuous surface connection to a requisite covered water, making it difficult to determine where the water ends and wetland begins.

The Agencies are aware that during periods of drought, low tide, or interruptions to surface connections, the determination of where a ‘wetland’ begins, and ends is not always clear. As a result, the Agencies will provide additional guidance on a case-by-case basis in the future.

Next Steps and Ways to Get Involved

As part of this announcement, the Agencies have provided information on how to provide feedback on the definition of WOTUS as part of a 30-day recommendation public docket and at least six listening sessions.

Stakeholder Feedback Opportunities

Written recommendations are being considered for feedback by the Agencies for the following scopes, as the designations for each scope have varied throughout the different regulatory rulings since the implementation of the CWA:

• “Relatively permanent” waters and to what features this phrase applies
• “Continuous surface connection” and to which features this phrase applies
• Jurisdictional ditches

Upon publication of the finalized document of the notice in the Federal Register, written recommendations must be received on or before 30 days after the date of publication.

Public Listening Sessions

In late March through April 2025, the Agencies will provide web-based and in-person conferences for persons or organizations to provide verbal recommendations during the sessions and will be limited in time. Registration information will be provided on U.S. EPA’s Public Outreach and Stakeholder Engagement Activities page once available. The Agencies anticipate holding the following listening sessions:

• Two sessions for stakeholders
• One session for States
• One session for Tribes
• One session for agricultural stakeholders
• One for environmental and conservational stakeholders.

The listening sessions will be recorded and posted to U.S. EPA’s Public Outreach and Stakeholder Engagement activities page, as was done previously for the 2023 Sackett ruling.

If you have any questions or would like assistance in evaluating how your individual permits may be impacted regarding the reconsideration of the WOTUS under the CWA, please reach out to me at cnagel@all4inc.com. ALL4 will continue to track updates to additional guidance or rulemaking regarding the definition of WOTUS, as the determinations may impact future permitting decisions with regard to wetlands as part of WOTUS

PFAS: State-by-State Regulatory Update (March 2025 Revision)

Welcome back to the 2025 edition of the ALL4 state-by-state per- and polyfluoroalkyl substances (PFAS) update. A lot has changed over the past year in both the federal and state regulatory landscape. The U.S. Environmental Protection Agency (U.S. EPA) has put forth several federally enforceable PFAS requirements, and states have been matching stride by either incorporating the federal requirements by reference or introducing their own more stringent versions. With proposed legislation and other PFAS news popping up daily, ALL4 is here to help keep track of everything. Note that the information presented here was current as of March 6, 2025.

Note that if you are interested in more frequent PFAS regulatory information for specific states or environmental programs, ALL4 offers a monthly PFAS regulatory tracker to our clients.

First, to level-set, several key PFAS regulations currently at the federal level are presented below in Table 1.

Table 1
Summary of Key Federal PFAS Regulations

The following maps provide a high-level summary of what the individual states within the U.S. are currently doing in terms of water (e.g., drinking water, surface water, groundwater, wastewater, biosolids/sludge), air, and other PFAS-related regulations (e.g., AFFF, waste, cleanup, consumer goods). This does not include any litigation, consent orders, action plans/task forces, or investigative sampling.

The color key is as follows:

WATER REGULATIONS

Several highlights of state PFAS water regulations are presented below in Table 2.

Table 2
State Water Regulation Highlights

AIR REGULATIONS

Several highlights of state PFAS air regulations are presented below in Table 3.

Table 3
State Air Regulation Highlights

OTHER REGULATIONS

Several highlights of other state PFAS regulations are presented below in Table 4.

Table 4
State Other Regulation Highlights

ALL4 continues to track the regulatory movements and maintains an internal database of current state PFAS activity. ALL4 also offers a monthly PFAS regulatory tracker to our clients. If you have any questions or would like any additional information, please reach out to Kayla Nuschke at knuschke@all4inc.com or your project manager to discuss how ALL4 can support.

Supreme Court Limits Clean Water Act

The Clean Water Act (CWA) gives the U.S. Environmental Protection Agency (U.S. EPA) the authority to impose requirements on facilities that wish to discharge “pollutants” into the waters of the United States. These requirements are in the form of National Pollutant Discharge Elimination System (NPDES) Permits and consist of requirements including effluent limits, sampling requirements, pollution prevention plans, and more. On October 16, 2024 the Supreme Court argued the authority of NPDES permits to prescribe “end-result” requirements, which “do not spell out what a permittee must do or refrain from doing but instead make a permittee responsible for the quality of the water in the body of water into which the permittee discharges.”

March 2025 Ruling

On March 5^th, 2025 the Supreme Court ruled in a 5-4 decision that the CWA does not have authority to impose narrative “end result” requirements referencing effect on the quality of the waters that receive it rather than the nature of the discharge itself, and it is the U.S. EPA’s responsibility and expertise to determine what limits discharging facilities must meet. The case at hand for this decision involved the City of San Francisco’s Combined Sewer Overflow (CSO) NPDES permit, which prohibits discharges that “cause or contribute to a violation of any applicable water quality standard.”

The dissenting justices argued that since the CWA allows U.S. EPA to impose “any more stringent limitation that is necessary to meet . . . or required to implement any applicable water quality standard” that any requirement based on the receiving water body is plainly just a limitation on discharge.

The final 5-4 ruling will restrict U.S. EPA’s ability to create limitation in NPDES Permits based on receiving body and will put the burden on U.S. EPA to determine what facility specific limitation would need to be met.

What This Means

U.S. EPA will be forced to remove “end-result” requirements from their NPDES Permits but could impose other requirements which would compensate for this loss. This could include more stringent effluent discharge limits, or more frequent testing and reporting requirements.

The following states and territories have not been granted NPDES permitting authority, meaning the U.S. EPA directly administers NPDES permits in these states, and therefore is directly affected by U.S. EPA issued NPDES permits.

• Massachusetts
• New Hampshire
• New Mexico
• District of Columbia

While the other 47 states must still comply with the Supreme Court’s ruling of the CWA, since each state issues its own NPDES permits the language, methods, and requirements in each state NPDES permits will differ.

What Can You Do?

Keep an eye out for newly issued NPDES from the U.S. EPA or your facility’s governing state agency. If you want to discuss your facilities permitting NPDES strategy ALL4 is ready to help, please reach out to Evan Mia at emia@all4inc.com.

Colorado Adopts Final Revisions to Regulation Number 7 to Reduce Greenhouse Gas Emissions from Midstream Segment Fuel Combustion

In response to a directive to reduce greenhouse gas (GHG) emissions from the midstream segment oil and gas operations, Colorado’s Air Quality Control Commission (Commission) adopted final revisions to its Air Regulation Number 7. These revisions focus on regulating emissions from midstream fuel combustion equipment (MFCE) used in the oil and gas midstream sector, a critical component of the state’s industrial activities.

The oil and gas midstream segment in Colorado is defined in Regulation No. 7 as the oil and natural gas compression segment and the natural gas processing segment upstream of the natural gas transmission and storage segment. As of February 14, 2025, each midstream company is required to participate in this midstream segment emissions reduction program to reduce greenhouse gas emissions from MFCE in Colorado.

Key Revisions to Regulation Number 7

The revisions to Colorado’s Air Regulation Number 7, adopted on December 20, 2024, introduce a series of new measures aimed at reducing greenhouse gas emissions from MFCE. These changes follow several years of work by the Midstream Steering Committee, which was established to identify and propose standards that would contribute to achieving the required 20% reduction in carbon dioxide equivalent (CO₂-e) emissions over the 2015 baseline. Here are some of the key provisions in the revised regulation:

1) Establishment of both Midstream Segment and Company-Specific Caps: The commission adopted a segment cap of 3,930,220 metric tons of CO₂-e, which will be achieved through compliance with company-specific emissions caps by December 31, 2030. The company-specific emissions caps are allocated based on 2021 emissions and consider the following additional criteria:

• Proportion of emissions that occur in disproportionately impacted community locations.
• Recognition of electrification projects completed between January 1, 2016 and summer 2022.
• Size of midstream operator.

Because company-specific emissions caps were established, companies have the flexibility to implement reductions at the facilities they choose. However, they are expected to prioritize reductions at sites that are located in disproportionately impacted communities, where possible.

2) New Annual Reporting: Under the revised Air Regulation Number 7, oil and gas midstream operators will need to prepare and submit an annual report by June 30 of each year starting on June 30, 2025. Required information in the report is included, but not limited to the following:

• Company information, identification of each midstream segment facility, and whether the facility is located in a disproportionately impacted community or is part of the front range prioritization area (FRPA).
• Total annual GHG emissions in metric tons of CO₂-e from all MFCE owned or operated by the midstream company.
• Information on project plans to achieve the company-specific cap, including completed projects.
• Documentation of credits generated and retired in the GHG crediting and tracking trading system.

3) Emissions Reduction Credits for Early Action: Operators who exceed the prescribed emissions reduction targets or adopt advanced clean technologies before they are required to do so may earn emissions reduction credits. These credits can either be retired by the company or sold to other companies, providing a financial incentive for early and voluntary actions to reduce emissions. The ability to generate credits begins in 2028 for emissions reporting year 2027. In order for a midstream company to generate credits for a particular vintage year pursuant to Section VII., the midstream company must submit the annual report required in Section V.A.1. by March 31 of the reporting year in which they want to participate in the GHG credit market.

Who is Impacted and When?

The new revisions to Air Regulation Number 7 will have a substantial impact on the midstream oil and gas industry in Colorado. It applies to all midstream companies operating MFCE in the midstream segment. The requirement to participate in the midstream segment emissions reduction program began on February 14, 2025, and initial annual reports are due on June 30, 2025. The ability to generate emissions credits begins in 2028 and final compliance with the company-specific cap is required by December 31, 2030.

Colorado’s Climate Goals

The revisions to Air Regulation Number 7 are a result of Colorado’s broader climate strategy. The state has set goals to reduce its greenhouse gas emissions, with a target of cutting emissions by 50% by 2030 compared to 2005 levels. The three-year planning process aimed at reducing emissions of GHG from MFCE began as a directive that was added to Regulation No. 22 in December 2021 and subsequently moved to Regulation No. 7 in April 2023.

The new requirements are part of a larger effort that includes transitioning to renewable energy sources, improving energy efficiency, and promoting sustainable practices across industries. The revisions to Air Regulation Number 7 signal a continued trend toward more aggressive environmental policies in Colorado. As the state moves toward its 2030 climate targets, more regulations may be introduced to further reduce emissions across all sectors. Oil and gas companies in the midstream sector will need to adapt to a rapidly changing regulatory landscape.

ALL4 has extensive experience with GHG emissions inventories and helping companies plan for and execute GHG emissions reductions. If you or your facility is unsure of where to start with GHG reporting due in June, contact Noel Attwood at 281-201-1240 or nattwood@all4inc.com.

U.S. EPA Clarifies “Modification” as it Relates to NSPS Subpart XXa

The United States Environmental Protection Agency (U.S. EPA) has clarified what constitutes a “modification” in response to questions received regarding the Standards of Performance for Bulk Gasoline Terminals that Commenced Construction, Modification, or Reconstruction After June 10, 2022 under 40 Code of Federal Regulations (CFR) part 60, subpart XXa (NSPS XXa). The industry and its partners had voiced concerns about the potential that routine activities could be considered modifications and trigger applicability of NSPS XXa.

The final rule was published on May 8, 2024, and became effective July 8, 2024. If an existing facility makes a change that meets the definition of a modification following the effective date of NSPS XXa, it is required to meet the requirements of NSPS XXa. Definitions for terms used in 40 CFR part 60 are found in subpart A under 40 CFR §60.2,  and the term “modification” is defined as “any physical change in, or change in the method of operation of, an existing facility which increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not previously emitted.” Modification is discussed further in 40 CFR 60.14, which excludes items such as routine maintenance, repair, and replacement of equipment in the source category, increases in production without a capital expenditure, an increase in hours of operation, and the relocation or change in ownership of an existing facility.

U.S. EPA’s clarification states that minor equipment changes that do not result in an increase in the emission rate of volatile organic compounds (VOC) or that are considered routine maintenance, repair, and replacement of equipment are not considered modifications under 40 CFR 60.14. Examples of changes that U.S. EPA would not considered modifications under NSPS XXa include: adding piping, valves, or pumps that are needed to improve emissions control or for operational flexibility that are not anticipated to increase site/facility VOC emissions; temporary installation of piping and equipment needed to perform maintenance or repair activities for storage vessels, loading racks, and vapor collection and processing systems; and/or addition of piping components needed for safety or mechanical integrity purposes (e.g., low point bleeds, sampling, pressure relief, and isolation valves).

U.S. EPA also notes that although NSPS XXa does not currently contain specific provisions that prevent minor equipment changes from being considered modifications (e.g., if no capital expenditure is made), they recently granted reconsideration on this issue. Stay tuned for updates on changes and clarifications to this and other U.S. EPA rules. If you need help evaluating a project for regulatory applicability, please reach out to Troy Gayer or your ALL4 project manager.