Stay Current: CEDRI and ERT Updates You Need to Know!

Stay up-to-date with the latest changes to the United States Environmental Protection Agency (U.S. EPA) Compliance and Emissions Data Reporting Interface (CEDRI) and the Electronic Reporting Tool (ERT). The following updates are important to keep in mind.

CEDRI Updates

• 40 CFR Part 63, Subpart NNNN (Surface Coating of Large Appliances): Updated §63.4121(c) Semiannual Compliance Report (v2.03). (May 7, 2025)
• 40 CFR Part 59, Subpart E (National Volatile Organic Compound Emission Standards for Aerosol Coatings): Implemented §59.509 and §59.511 Notifications and Reports Spreadsheet Template (v1.00). (April 8, 2025)
• 40 CFR Part 63, Subpart AAAA (Municipal Solid Waste Landfills): Updated §63.1981(l) Semiannual Report (v3.00). (March 19, 2025)
•  40 CFR Part 60, Subpart Kc (New Source Performance Standards for Volatile Organic Liquid Storage Vessels): Enabled Semi-annual Report Spreadsheet Template for §60.116c(c) (v1.00). (February 26, 2025)
• 40 CFR Part 60, Subpart XXa and Part 63 Subparts R and BBBBBB: Enabled a consolidated spreadsheet report for Standards of Performance for Bulk Gasoline Terminals, National Emission Standards for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations), and National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities (v1.00). (February 6, 2025)
• 40 CFR Part 60, Subpart Kc: Enabled an Initial Notification spreadsheet report for New Source Performance Standards: Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After October 4, 2023 (v1.00) in CEDRI. (February 6, 2025)
• 40 CFR Part 63, Subpart YYYY (NESHAP for Stationary Combustion Turbines): Updated Compliance Report Spreadsheet for §63.6150(a), (c), and (e) (v4.04). (February 3, 2025)
• 40 CFR Part 63 Subpart DDDDD (Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters): Updated Consolidated Semiannual Compliance Report for §63.7550(c) (v2.01). (January 13, 2025)

ERT Updates

ERTv7, originally released on March 12, 2024, was updated on May 23, 2025.

You can find the updated ERT Version 7 Program Files – May 23, 2025 on U.S. EPA’s official ERT webpage: https://www.epa.gov/electronic-reporting-air-emissions/electronic-reporting-tool-ert

This latest version includes the following revisions:

• Fixed bugs related to the completeness check.
• Addition of Method ASTM D6522 (Standard Test Method for Determination of Nitrogen Oxides, Carbon Monoxide, and Oxygen Concentrations in Emissions from Natural Gas-Fired Reciprocating Engines, Combustion Turbines, Boilers, and Process Heaters Using Portable Analyzers) and updated units of measure.
• Source Classification Codes (SCCs) have been updated.

The ERT User Manual v7 May 2025 (pdf) has been updated to reflect these changes.

Be sure to download the latest ERT version and consult the updated manual to ensure accurate and compliant reporting!

If you have any questions related to CEDRI or ERT or need help submitting electronic reports, please reach out to me at ashivkuamr@all4inc.com or 281-201-1239.

Heat Illness and Injury Prevention Rulemaking

Among all hazardous weather conditions in the United States (U.S.), heat accounts for the most death. According to Centers for Disease Control (CDC) and Prevention and California Code of Regulations (CCR), Title 8, Section 3396, excessive heat can lead to heat illnesses that include, but are not limited to, heat stroke, heat exhaustion, rhabdomyolysis, heat syncope, heat cramps, and heat rash. Common signs for these illnesses include confusion, lightheadedness, loss of consciousness, hot or dry skin, profuse sweating, high body temperature, weakness, or muscle aches. In addition to California, several other states with Occupational Safety and Health Administration (OSHA) approved state plans such as Washington, Oregon, Colorado, and Minnesota have implemented their own heat illness prevention standards based on their workforces and climates. These state-specific regulations aim to address gaps in the federal OSHA standards by requiring measures such as access to shade, hydration, rest breaks, and employee training to reduce the risk of heat exposure.

Workers are exposed to heat in both indoor and outdoor environments. High risk settings include construction sites, agricultural fields, warehouses, manufacturing plants, commercial kitchens, refineries, and foundries. Heat generating processes such as welding, smelting, baking, and running heavy machinery increase the risk. Enclosed or poorly ventilated spaces can also trap heat, raising exposure levels. Certain groups are more vulnerable, including new or unacclimatized workers, older adults, people with medical conditions, and those wearing protective gear that traps heat.

According to OSHA, from 2011 to 2022, 479 U.S. workers died from excessive heat in the workplace whether that be indoor or outdoor. It is estimated that there were 33,890 heat injuries resulting from work that caused workers to be away from work during those years.

Current Status of Federal the Federal Heat Standard

A Notice of Proposed Rulemaking (NPRM) for Heat Injury and Illness Prevention in Outdoor and Indoor Settings was published in the Federal Register on August 30, 2024. The proposed standard would apply to all employers in outdoor and indoor work in all general industry, construction, maritime, and agriculture sectors where OSHA has jurisdiction. This standard would require employers to create a plan to evaluate and control heat-related hazards. The plan must include the steps necessary to effectively protect employees from heat illnesses. Key proposed requirements include:

• Trigger temperatures: Protections begin at 80°F; enhanced measures at 90°F.
• Acclimatization: Gradual heat exposure for new or returning workers.
• Rest breaks: Required at specific intervals during high heat.
• Water access: Cool, potable water must be readily available.
• Cooldown areas: Shaded or climate-controlled rest spaces are required.
• Emergency response: Procedures for recognizing and responding to heat illness.
• Training: Required for all employees and supervisors on heat risks and prevention.
• Monitoring: Observe workers for signs of heat illness, during extreme heat or acclimatization periods.

The public comment period closed on January 14, 2025. Public comments are available for viewing in the Heat Injury and Illness Prevention rulemaking docket. OSHA will host an informal virtual public hearing on June 16, 2025, at 9:30 a.m. EDT. The hearing will let the public provide and give any comments regarding the proposed rule. The hearing will be available online on OSHA’s Heat Rulemaking webpage.

What’s Next?

If finalized, employers are required to develop, implement, and maintain a Heat Illness Prevention Plan (HIPP). Currently, OSHA relies on the General Duty Clause to cite employers for failing to adequately protect workers from heat-related hazards. Employers should consider reviewing their existing heat safety plans to ensure they incorporate the key elements OSHA recommends. If an employer can demonstrate that their plan includes these elements, it will be more difficult for OSHA to uphold a General Duty Clause violation.

ALL4 will continue to monitor this rulemaking and will publish updates as needed. ALL4 staff are trained and experienced in implementing health and safety regulatory requirements, including developing workplace safety procedures that incorporate federal, state, and local requirements, as well as developing training programs. If you have questions on this proposed rulemaking or need assistance in preparing a HIIP, please contact Victoria Sparks at vsparks@all4inc.com, Jessica Malberg at jmalberg@all4inc.com, or Ayoon Ahmad at aahmad@all4inc.com.

Change in NPDES Construction General Permit

Under the United States Clean Water Act (CWA), construction stormwater discharges into waters of the U.S. (WOTUS) must be authorized by a state or U.S. Environmental Protection Agency (U.S. EPA) National Pollutant Discharge Elimination System (NPDES) permit.

U.S. EPA Construction General Permit (CGP) under the NPDES program applies to states which do not have authority to issue their own NPDES permits and include Massachusetts, New Hampshire, New Mexico, the District of Columbia, and all U.S. territories (except for the U.S. Virgin Islands). Some states also model their own NPDES permits based on the U.S. EPA permits.

Changes to the GCP

On April 8, 2025, U.S. EPA finalized a modification to the 2022 CGP effective immediately for U.S. EPA Regions 2, 4, 5, 6, 7, 8, 9, and 10. For U.S. EPA Regions 1 (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont) and Region 3 (Delaware, District of Columbia, Maryland, Pennsylvania, Virginia, West Virginia), the modification’s effective date is pending. These regions require additional time to complete the Clean Water Act section 401(a)(2) process. The modification expanded the CGP scope to include construction projects in Lands of Exclusive Federal Jurisdictions (LEFJ), which are lands in the U.S. where the Federal Government maintains full jurisdiction. Not all federal lands are LEFJ and there is no master list of LEFJ because it is tracked by multiple agencies within the federal government and changes over time. LEFJ were not explicitly covered under the 2022 CGP, but U.S. EPA “finds the most effective way to provide such permit coverage is through a modification to the 2022 CGP” per the CGP 2022 Fact Sheet.

Not related but included in the modification, U.S. EPA is updating water quality-based limitations in light of the Supreme Court’s decision in San Francisco. The decision ruled that the CWA does not allow “NPDES permit requirements that condition permitholders’ compliance on whether receiving waters meet applicable water quality standards.” In accordance with this the new CGP added discharge water-based limitations and removed “generic narrative prohibition” of final water quality that was rejected by the courts. Per the CGP 2022 Fact Sheet the new GCP “Section 10…makes a conforming change to indicate that triggering conditions for corrective actions in Part 5.1.3 and limits on the use of treatment chemicals in Part 7.2.6 focus on conditions within the construction site’s discharge”. State specific implementation and timeline of removal of the “generic narrative prohibition” will vary by state.

What Can I Do

If you have a construction project located in LEFJ, assess whether the modified 2022 CGP applies to your activities. If you have a construction project which falls into a LEFJ and requires a CGP, ensure timely submission of the Notice of Intent (NOI) form to obtain coverage under the modified CGP.

If you need help determining the applicability of the CGP to your site or preparation and submittal of the NOI, please contact Evan Mia of ALL4 at emia@all4inc.com

Insights on Effective Environmental Programs

Recently, I had the opportunity to represent ALL4 at Mapistry’s Environmental Compliance Summit in Atlanta. Although I enjoyed each of the sessions, there were some particularly insightful takeaways I had from networking with some of the most effective environmental compliance program managers across a multitude of industries. Here are the four most impactful things I learned at the Summit:

Empowering Environmental Leaders

Most of the people in attendance at the Summit were part of environmental compliance organizations that are responsible for many facilities and media. With each person I spoke to, it was clear that they relied on large teams to execute specific responsibilities. One crucial ingredient to these strong teams is an effective leader. A common frustration that was voiced was the lack of time and resources available to focus on being a leader for their team. Instead, they often found themselves putting out fires or grinding through tedious tasks. During my panel, I was asked what I see work well in teams responsible for large environmental programs. The most consistent trait I see in large environmental programs is the presence of a true leader of the team. Someone who is ultimately accountable for the performance of the group but is empowered by his or her company to do so by providing adequate resources. This answer elicited a lot of head nods from the crowd and my fellow panel member (Mary Jo Press) even throwing in an “amen”!

Utilizing Technology to Increase Productivity

Being a technology company, Mapistry attracted environmental leaders that are passionate about using technology to their advantage. I’m only a decade into my career; however, during that relatively short period of time the use of technologies such as Mapistry has shifted from being a “nice-to-have” to being a necessity for any mature environmental program. One of the primary reasons for a lack of leadership in environmental programs is that the person who is supposed to be leading is spending the majority of their time hunting down operational data or combing through outdated calculation workbooks trying to figure out why they’ve been using a specific emissions factor for the past 20 years. If that statement resonates with you, it’s time to start evaluating technologies that can alleviate that pain.

ALL4 is a perfect partner to assist you in this journey. Implementing these technologies can be expensive, and almost all take a significant investment of time and resources. Additionally, the feeling that you must get it right the first time, or nobody will trust the product and be even more skeptical if you try to make changes, can be daunting. Selecting the correct technology for your situation and implementing it effectively the first time is critical for user-adoption and actual gains in efficiency. Partnering with a group like ALL4 can greatly increase your chances of these efforts being successful. Why? Because we have worked with a wide variety of these technologies, assisted many industries in implementing them, and best of all have no agenda to select a specific solution. If you are looking for a non-biased, expert opinion to evaluate these technologies, ALL4 is the group to call.

Transfer of Knowledge

Beyond increasing productivity, the other reason people at the Summit were evaluating technology solutions was to help solve the problem of transferring years of knowledge when teams experience turnover. Many of these environmental programs have calculation workbooks, applicability determinations, and compliance report templates that were all developed decades ago. This information has been passed along from environmental manager to environmental manager until nobody knows why decisions were made or the origin of certain data points. Employees move from company to company more frequently than ever, which makes it critical that these decisions are documented clearly for whoever is going to step in to lead the team next. If you find that your team is heavily reliant on the knowledge that is only present in the minds of your team, your environmental program is at risk.

Proactive Instead of Reactive

I learned that there is a common theme behind strong environmental programs: Being proactive rather than reactive. If your team members are frequently dealing with notices of violations (NOVs), tracking down paper records, or frantically trying to complete compliance activities and/or reports right before their deadlines, I’m here to tell you it doesn’t have to be this way. I have spoken to many program leaders, and some have accepted that this is the world of environmental compliance; however, many companies refuse to accept that fate and instead empower their leaders to utilize technologies effectively, automate task tracking and recordkeeping, and document key historical information for their current and future teams. This mindset allows those environmental management teams to focus on improving their program year after year rather than just trying to hold their head above water and avoid NOVs.

As ALL4’s Atlanta Office Leader, I am passionate about partnering with environmental program leaders who have or want to have proactive mindsets and contribute to the continued success and improvement of their programs. If you want to talk about how to start looking into the future toward a more proactive approach and brainstorm improvements to your program, reach out to me at  rbalaban@all4inc.com or 678-293-9427.

Update on U.S. EPA Deregulatory Agenda and New Annual Emissions Reporting Platform Coming to Kentucky: Live and In-Person from Madisonville, Kentucky on Friday May 16, 2025

When, Where, & What is the Environmental Practitioners’ Workshop:

ALL4 will present at the Environmental Practitioners’ Workshop hosted by the Kentucky Chapter of the Air & Waste Management Association (KY A&WMA) and the Kentuckiana Chapter of Hazardous Materials Managers (KCHMM) on Friday, May 16, 2025 at Madisonville Community College in Madisonville, Kentucky (event starts at 9:00 AM CDT).

The Environmental Practitioners’ Workshop is an ongoing series of workshops hosted by the KY A&WMA and KCHMM that gathers subject matter experts, regulators, and environmental professionals across the Commonwealth of Kentucky to learn, share ideas, and obtain professional development hour (PDH) credits.

Come to Madisonville to network with your regulators and environmental professionals to learn about the contemporaneous regulatory matters ongoing at the federal level and what that means in the Commonwealth of Kentucky.

In addition to ALL4’s presentation “U.S. EPA and Federal Air Regulatory Updates: 31 Flavors of Deregulation,” Commissioner Tony Hatton of the Kentucky Department of Environmental Protection (KDEP) will provide a Keynote Address along with personnel from the Kentucky Division for Air Quality, Division of Waste Management, and the Division of Water to host a regulator’s roundtable session.

What you can expect at ALL4’s Presentation:

Since his nomination, U.S. Environmental Protection Agency (U.S. EPA) Administrator Lee Zeldin has made big announcements for sweeping changes across numerous regulatory programs including “the largest deregulatory announcement in U.S. history.”

ALL4 will summarize and contextualize these proposed actions, detail the process U.S. EPA must undertake to implement its bold deregulatory agenda, and provide insight on how to stay engaged in this everchanging regulatory landscape.

In addition to the deregulatory changes announced by U.S. EPA, ALL4 will provide an update on proposed changes coming to the Kentucky Air Emissions Survey. KDEP is currently working with Windsor Solutions to bring online the State and Local Emissions Inventory System (SLEIS) to replace the Air Emissions Survey that has been in place for more than 20 years. Learn about anticipated challenges and best practices for reporting to SLEIS. ALL4 will share its experience helping regulated sources migrate to SLEIS in other jurisdictions including the migration to SLEIS in Jefferson County, Kentucky in 2020.

We hope to see you in Madisonville!

Please stop by and say hello if you are able to attend the workshop. If you can’t make this event and have any questions or concerns regarding your facility’s compliance strategies, especially in the Commonwealth of Kentucky, please contact Stewart McCollam at smccollam@all4inc.com.

SCAQMD – Nitric Acid Tanks Rule

South Coast Air Quality Management (SCAQMD or District) Governing Board adopted Rule 1159.1 for the control of nitrogen oxides (NO_X) emissions from nitric acid units. Rule 1159.1 is expected to impact over 900 nitric acid units across nearly 250 facilities.

Background

Under California Assembly Bill 617 (AB 167), Air Districts designated as nonattainment for one or more air pollutants were required to adopt an expedited schedule by January 2021 for the implementation of Best Available Retrofit Control Technology (BARCT)¹ by December 31, 2023. As facilities begin to transition out of the Regional Clean Air Incentives Market (RECLAIM), SCAQMD identified the need for a command-and-control regulation to control NO_X emissions from nitric acid units in line with BARCT requirements.

Nitric acid units are typically found at metal finishing, precious metal reclamation, or expanded graphite foil production facilities. NO_X emissions are generated from the either a chemical reaction between the nitric acid and metals or from thermal decomposition of the nitric acid.

Nitric Acid Unit Requirements (Rule 1159.1(d)(1))

Nitric acid units vented to an air pollution control device (APCD) will be subject to the following requirements:

• Limit overall NO_X emissions from the combined nitric acid unit(s) vented to an APCD to 0.30 pounds per hour (lb/hr) [Rule 1159.1 (d)(1)(A)(i)]; or
• Achieve a 99% control efficiency [Rule 1159.1 (d)(1)(A)(ii)].

Facilities that elect to comply with the performance standards of Rule 1159.1(d)(1)(A)(i) or (ii) by operating an APCD that uses a scrubber solution are required to install and operate the following:

• A flowmeter to measure flowrate of scrubber solution across each stage of the APCD,
• A pH meter to measure pH of scrubber solution across each stage of the APCD, and
• A pressure differential measuring device to measure pressure drop across each stage of the APCD.

Facilities are required to monitor and record the parameters listed above at least once weekly.

Facilities that operate two or more APCD that elect to demonstrate compliance with the 0.30 lb/hr NO_X limit [Rule 1159.1 (d)(1)(A)(i)] must limit NO_X from all nitric acid units vented to an APCD across the facility to no more than 0.90 lb/hr, as demonstrated by a source test.

Alternative Compliance Pathways (Rule 1159.1(d)(2))

Facilities that operate nitric acid tanks not vented to an APCD can elect to comply with one of the following alternative compliance pathways:

• Limit NO_X emissions from all nitric acid units that are not vented to an APCD to 0.60 lb/hr, as demonstrated by a source test [Rule 1159.1 (d)(2)(A)]; or
• Demonstrate that nitric acid additions in no more than one of the past five calendar years, including the current calendar year, are less than the following [Rule 1159.1 (d)(2)(B)]:
  • 550 gallons adjusted to 68 weight percent per nitric acid unit per calendar year, and
  • 1,650 gallons adjusted to 68 weight percent for all nitric acid units electing to comply with Rule 1159.1 (d)(2)(B) per calendar year.

Facilities electing to comply with (d)(2)(A) must maintain specification sheet for each of the following:

• Product or part processed in the nitric acid unit specifying the precise concentration or maximum concentration of metal(s) present; and
• Processes conducted in the nitric acid unit specifying the type of metals processed, and the acceptable operating conditions for nitric acid concentration and processing time.

Facilities electing to comply with (d)(2)(B) must maintain the following records for at least five years:

• Record for each addition of nitric acid including
  • Date of addition,
  • Volume of the addition (in gallons),
  • Highest concentration of nitric acid based on the manufacturer’s safety data sheet or chemical analysis of a sample, and
  • Volume of addition adjusted to 68 percent by weight.

Source Testing

Prior to conducting a source test to demonstrate compliance with one of the pathways previously identified, facilities must submit a source test protocol to SCAQMD for approval. Source tests must be conducted no later than five calendar years from the last source test that demonstrated compliance with the requirements of Rule 1159.1. Final source test reports must be submitted within 120 days after the test was completed and no later than the applicable due dates listed in Table 1, Table 2, or paragraph (h)(5) of Rule 1159.1.

Labeling Requirements

By July 1, 2025, facilities with nitric acid units will need to label each unit with the tank name (or functionally equivalent identifier) and SCAQMD Application/Permit Number.² Cleaning tanks must also be labeled with “Rule 1159.1 Cleaning Tank”.

The implementation schedules for the various compliance pathways are summarized in the following tables.

What’s Next?

Rule 1159.1 is not a one-size-fits-all rule. Facilities have multiple pathways they can take to meet their compliance obligations. ALL4 can work with facilities to develop a roadmap to understand new regulatory requirements, plan for compliance, prepare emissions test plans, review emissions test data, obtain vendor quotes for new emissions control, and prepare permit applications to maximize operational flexibility. If you are interested in learning how this rule may affect your facility, please contact your ALL4 project manager or Michael McHale at 610.422.1131 or mmchale@all4inc.com.

¹Under Section 40406 of the California Health and Safety Code BARCT is defined as “an emission limitation that is based on the maximum degree of reduction achievable, taking into account environmental, energy, and economic impacts by each class or category of source.”

²Unless the nitric acid unit is subject to the labeling requirements of SCAQMD Rule1426 (f)(5) or Rule 1469 (g)(3).

US Power Sector: Developments in 2025 So Far

Since our 2025 Power Sector Lookahead article was published, we’ve had time to see how the change in administration might impact the power sector and have also seen a couple of factors not related to the administration continue to develop. One factor that has not changed is the initiative to permit and build new electricity generating capacity as quickly as possible. As discussed in the Lookahead article, the push for more generating capacity is driven primarily to support the rapidly expanding data center sector, which itself is being driven by the proliferation of artificial intelligence (AI). Many of our clients are actively permitting new power generation facilities, primarily gas-fired, all across the country. With that, here are some of the things we’ve seen so far in 2025.

Executive Orders

On January 20, 2025, President Trump issued a flurry of executive orders (EO) related to power generation, starting with Declaring a National Energy Emergency in an EO intended to facilitate not only the construction of new generating power, but also improving the capacity of the national grid to carry that new power. The EO also instructed several agencies to identify all regulations that might hinder energy development for potential revocation where legally possible and included the use of emergency actions to bypass the Endangered Species Act. The general purpose of the EO was to ease and speed up the process of developing new power plants. The idea of an “energy emergency,” however, was seemingly contradicted by another EO issued the same day: Temporary Withdrawal of All Areas on the Outer Continental Shelf from Offshore Wind Leasing and Review of the Federal Government’s Leasing and Permitting Practices for Wind Projects that put a halt on offshore and onshore wind leasing. The EO also put a temporary halt to all ongoing permitting actions for offshore wind, which to date is still in place. While ALL4 is aware of several projects that are currently dead in the water (pun intended) due to this halt, those offshore wind projects that have already received their permits and are under construction appear to be continuing. Several other EO’s were issued to revoke most of the previous administration’s climate policies, including support for electric vehicles (EV) and grants for renewable energy projects. On April 8^th, the EO Reinvigorating America’s Beautiful Clean Coal Industry and Amending Executive Order 14241 was issued with the intent of promoting coal as an energy source and easing mining restrictions by categorizing coal officially as a “mineral” under the March 20^th executive order 14241, which authorized mining of critical minerals.

All the referenced EOs generally set the table for a deregulatory environment designed to further fast track power projects. It remains to be seen whether the ban on the new development of offshore wind remains in place given the need to get new capacity on the grid as quickly as possible. The EO regarding coal seems unlikely to have any real impact on the sector other than perhaps to increase coal exports, though it is possible that some coal-fired power plants currently scheduled to retire might remain operational for a bit longer. It is very unlikely that we’ll see significant (if any) new coal-fired generation permitted and constructed given the length of time required to bring a new coal-fired plant online and the unfavorable economics of such projects.

Regulatory Direction

With the new administration, we don’t expect any significant new regulatory requirements for the sector and in fact expect to see attempts to relax or remove existing regulations. This approach was signaled when U.S. Environmental Protection Agency Administrator Lee Zeldin announced the largest deregulatory action in U.S. history on March 12^th. For more on what has been referred to as the “31 flavors” because of the 31 items potentially targeted for review, see our 4 The Record article for a discussion of those actions that might impact the power sector.

Meanwhile, several updates on the regulatory actions that we discussed in the Lookahead article, and some new ones, include:

• The comment period for the updated Standards of Performance for New Stationary Sources (NSPS) for Stationary Combustion Turbines (Subpart KKKKa) has now closed and the comments are under consideration by U.S. EPA. Based on what we’ve heard, U.S. EPA seems to be in a more collaborative mood, and we anticipate that some of the proposed reduced nitrogen oxide (NO_X) emissions standards may be revised in the final rule due in November.
• Revisions to the National Emissions Standard for Hazardous Air Pollutants (NESHAP) for Stationary Combustion Turbines (Subpart YYYY) were expected to be proposed in mid-2025, although there is no sign of them at this point. Some possibilities could be a very minimalistic rule, or potentially even an attempt at delisting the NESHAP altogether, though that would almost certainly result in legal action.
• On April 15^th, after setting up an e-mail inbox for industry to request Presidential Exemptions from NESHAP that were made more stringent in 2024, U.S. EPA approved two-year compliance exemptions for 47 coal-fired power plants from the Mercury and Air Toxics Standards (MATS) rule, supporting the coal-related executive order.
• On May 2^nd, U.S. EPA sent proposals for two sets of repeals, the carbon standards repeal proposal and the MATS rule repeal proposal, to the White House Office of Management and Budget (OMB) for review. Although at this time the details of what is in those proposals are not available, we expect that the Part 60 greenhouse gas (GHG) standards for electric generating units will be repealed or substantially gutted and the 2024 revisions to the MATS rule will be rolled back.

Power Sector Impact

The overall impact of the EOs and deregulatory focus to the power sector is twofold; on the one hand, this administration will probably not be adding any meaningful new rules, and utilities that were concerned with having to comply with rules like MATS and the GHG rules have seen those fears, along with concerns related to new regulations the previous administration might have brought forth, relaxed. On the other hand, the EOs may in fact slow new capacity growth in the U.S. — new gas-fired power is already being brought online as fast as the supply chain can keep up, but the limitations on new wind power may slow its deployment, without an obvious alternative to take up that slack.

The effects of the change in administration aside, ALL4 continues to see several fast-track programs bring new gas-fired power generating facilities online, including the PJM regional transmission organization (RTO)’s Reliability Resource Initiative, and Midcontinent Independent System Operator (MISO)’s similar proposed Expedited Resource Adequacy Study (ERAS) program for its region. These fast-track programs are tempered by the fact that the large turbine vendors in the U.S. are currently backlogged on combustion turbine orders for two or more years, with no relief in sight. The supply chain concerns are further exacerbated by cost concerns associated with general confusion about the administration’s tariff program and their associated international trade issues. Regardless, utilities, power developers, and data center developers are expected to continue to permit and construct facilities as fast as the permitting process and supply chain for equipment will let them.

ALL4 will continue to track regulatory and technical developments related to the power sector in this period of rapid growth. ALL4 has significant power sector experience related to siting, permitting, and compliance for electricity-generating facilities combined with established working relationships with relevant industry organizations, numerous state agencies, and U.S. EPA. ALL4 provides a full range of environmental health and safety (EHS) and data services to our clients to help them meet their permitting, monitoring, testing, recordkeeping, and reporting challenges. If you’d like to learn more about our capabilities in the power sector, please contact Rich Hamel or your ALL4 project manager.

GHG Compliance in New York: Understanding the CLCPA and Future Reporting Mandates

New York State has long positioned itself as a national leader in the fight against climate change, with some of the most ambitious greenhouse gas (GHG) reduction goals in the United States. Under the Climate Leadership and Community Protection Act (CLCPA) implemented in 2020, New York set GHG reduction targets while transitioning towards a carbon-neutral economy. The challenge of meeting the GHG reduction targets has been supported by new, emerging regulations to strengthen emissions monitoring and corporate accountability, including the soon-to-be-finalized 6 NYCRR Part 253 and the proposed Senate Bill S3456.

What is the Current Climate Regulatory Landscape in New York?

In 2019, the Climate Leadership and Community Protection Act (CLCPA) was officially signed into law in New York State. The CLCPA establishes some of the most aggressive and legally binding climate and clean energy targets in the United States. The CLCPA mandates a state-wide reduction in GHG emissions by 40% by 2030 and 85% reduction by 2050, both relative to 1990 levels. Furthermore, it commits to 100% zero emissions electricity production by 2040, economy-wide net-zero emissions by 2050, and even includes stipulations to direct 35% of the benefits from the state climate and energy programs to disadvantaged communities. These state-wide GHG reduction targets are codified in 6 NYCRR Part 496.

A key aspect of the CLCPA’s implementation is its direct influence on the permitting process for facilities across the state. The New York State Department of Environmental Conservation (NYSDEC) issued DAR-21: The Climate Leadership and Community Protection Act and Air Permit Applications, a policy document requiring applicants for new Air State Facility (ASF) and Title V permits, as well as permit renewals and modifications, to develop and submit a CLCPA analysis as part of their permit applications. The analysis requires applicants to quantify direct GHG emissions from new or modified sources, as well as upstream and downstream emissions attributable to proposed projects.

What are the Upcoming Climate Regulations? 6 NYCRR Part 253

As part of New York’s continued efforts to gather air pollution data and implement the CLCPA, NYSDEC (Department) is establishing a mandatory GHG reporting program (Reporting Program), which would require certain GHG emitters to report their emissions to the Department. The Reporting Program would be codified in 6 NYCRR Part 253. Under this regulation, facilities in specific industry sectors that have exceeded an emissions threshold of 10,000 metric tons of carbon dioxide equivalent (MT CO₂e) in any year since 2023 will be required to track GHG emissions and disclose emissions records to the Department as of January 1, 2026. Additionally, facilities exceeding an annual emissions threshold of 25,000 MT CO₂e will be designated as “Large Emission Sources” subject to more stringent reporting and verification requirements than sources emitting 10,000 MT CO₂e.

The public comment period for 6 NYCRR Part 253 is currently underway, with adoption expected later this year. The finalization of this regulation will enable New York to attain a more comprehensive, facility-specific GHG emissions database, which will be critical to tracking the state’s progress towards meeting its CLCPA targets.

Corporate-Level Accountability: Senate Bill S3456

In support of the goals of the CLCPA, New York has also proposed the Climate Corporate Data Accountability Act (CCDAA), formally introduced in the state Senate as Senate bill S3456. Whereas 6 NYCRR Part 253 addresses reporting at the facility-level, the CCDAA has a broader, corporate-level focus – the proposed bill mandates that large businesses with over $1 billion in revenue operating in New York disclose their full annual GHG inventories, which includes the following:

• Scope 1 emissions – This encompasses emissions generated from sources directly owned or controlled by a business.
• Scope 2 emissions – These are emissions produced indirectly by a business entity, specifically from the generation of purchased energy.
• Scope 3 emissions – Scope 3 emissions refer to other indirect sources of emissions produced from a business’s value chain, which encompass upstream and downstream activities such as suppliers and customers.

If this Senate bill is passed, then the applicable businesses would need to report Scope 1 and 2 emissions by 2027 using 2026 data and report Scope 3 emissions by 2028 using 2027 data. Key features of the proposed legislation also include the creation of a public emissions reporting platform and the imposition of large penalties of up to $100,000 per day, with a maximum of $500,000 per reporting year for companies that willfully fail to comply. At present, the CCDAA is still under consideration in the state Senate. If passed, this bill would be a large step in corporate accountability towards emissions generation and would incentivize mitigation strategies and expansion of carbon neutral technologies.

How to Prepare

With more rigorous reporting requirements looming, facilities should begin to review their climate strategies and current reporting policies. For facilities applicable to either CCDAA or 6 NYCRR Part 253, it is best to begin implementing or assuring that systems are in place to reliably monitor and track GHG emissions with high accuracy. For large corporations with over $1 billion in revenue, they should begin assessing their capabilities in tracking Scope 1, 2, and 3 emissions, in preparation for the potential enactment of the CCDAA. This may include identification of data gaps and engagement with suppliers and others within their value chain.

How ALL4 Can Help

ALL4 can provide GHG reporting, tracking, and mitigation services to organizations that may be subject to these regulations. ALL4 can assist in developing a GHG monitoring plan, developing GHG emissions inventories including Scopes 1, 2, and 3, as well as developing strategies to reduce emissions and carbon footprint. For inquiries about how the proposed New York legislation may impact your facility or organization, contact Josh Jose at jjose@all4inc.com or your ALL4 project manager.

May is Electrical Safety Month: Are You Powering Up the Right Way?

Each May, National Electrical Safety Month serves as a powerful reminder of how essential electrical safety is—not just at home, but in workplaces across every industry. From arc flash hazards to improper lockout/tagout (LOTO) procedures, electrical incidents are consistently among the top causes of workplace injuries and fatalities. Yet many of these incidents are preventable through proactive assessment, employee training, and program development.

Why Electrical Safety Demands Attention

According to the Occupational Safety and Health Administration (OSHA), electrical hazards cause more than 300 fatalities and 4,000 injuries each year in the workplace. These aren’t just statistics—they represent lives changed and operations disrupted. Whether it’s a manufacturing facility, a construction site, or a laboratory, electrical safety should be built into the very foundation of your health and safety culture.

Workplace environments often involve complex electrical systems and equipment that evolve over time. Without a structured program in place, hazards can go unnoticed—until it’s too late.

OSHA and NFPA 70E: The Compliance Foundation

At the core of electrical safety are key regulatory and consensus standards:

• OSHA’s General Industry Electrical Standards (29 CFR 1910 Subpart S) and Construction Standards (29 CFR 1926 Subpart K) provide baseline requirements for electrical installations, grounding, personal protective equipment (PPE), and safe work practices.
  •  National Fire Protection Association (NFPA) 70E, Standard for Electrical Safety in the Workplace, complements OSHA by providing detailed guidance on electrical risk assessments, arc flash analysis, shock protection boundaries, and the selection of appropriate PPE.
  • Lockout/Tagout (29 CFR 1910.147) remains one of the most cited OSHA standards every year. Improper control of hazardous energy leads to countless preventable injuries and fatalities—not just electrical shock or arc flash, but crushing, cutting, or mechanical movement from unexpected startup.

LOTO procedures are foundational for assuring that equipment is properly isolated before maintenance or servicing work is performed. This includes verifying zero energy state, proper application of locks and tags, and employee training on roles and responsibilities.

Key Pillars of a Strong Electrical Safety Program

Whether you’re looking to strengthen your program or simply reassess existing practices, consider these core focus areas:

1. Assessment

• Conduct arc flash and shock risk assessments to identify where hazards exist.
  • Review electrical system labeling, single-line diagrams, and panel access.
  • Evaluate work practices, maintenance procedures, non-routine task processes, and LOTO programs to identify compliance gaps.

2. Training

• Provide role-based electrical safety training for both qualified and unqualified workers, also referred to as ‘Authorized’ and ‘Affected’ personnel.
  • Train employees on hazard recognition, energized work permits, PPE use, and proper LOTO steps.
  • Reinforce training through refresher courses, real-world scenarios, and toolbox talks.

3. Program Development

• Develop or update written electrical safety and LOTO programs that align with OSHA and NFPA 70E.
  • Include procedures for equipment-specific energy control, periodic inspections, and authorization of employees.
  • Establish internal auditing processes to monitor both LOTO implementation and electrical safety practices overall.

A Proactive Approach = A Safer Workplace

Electrical safety is more than compliance—it’s about building a culture where workers are empowered to speak up, identify hazards, and take safe actions every day. The most effective programs are proactive, sustainable, and continuously improving.

This Electrical Safety Month, it’s a great time to ask:

• Are your employees trained and confident in their roles?
• When was your last risk assessment or program review?
• Are your LOTO procedures accurate and actively used?
• When was your last evaluation of authorized personnel and periodic equipment inspection?

If you’re thinking about strengthening your electrical safety foundation, consider working with a trusted partner who understands the regulatory requirements and practical realities of your operations. Whether it’s performing a gap assessment, developing documentation, or facilitating training, ALL4 is available to help you build and sustain a safer workplace.  For more information and to see how ALL4 can assist you, contact Brian Godfrey, Managing Consultant at bgodfrey@all4inc.com.

How Pennsylvania’s Industrial Sector Can Benefit from RISE PA

Pennsylvania’s industrial sector is at the center of a new opportunity to secure funding, modernize operations, and drive meaningful greenhouse gas (GHG) reductions. The Reducing Industrial Sector Emissions in Pennsylvania (RISE PA) program, launched in early 2025, is designed to accelerate industrial decarbonization across the state – a sector responsible for about 30% of statewide GHG emissions.

What is RISE PA?

The RISE PA program is designed to accelerate decarbonization across Pennsylvania’s most energy- and emissions-intensive industries. The program provides financial support for projects that reduce emissions while advancing operational improvements and technological innovation. Major goals of the program include the creation of high-quality jobs within the energy sector and the improvement of air quality across the state, with increased focus on low-income areas. The initiative is funded through both federal and state resources, in part through the U.S. Environmental Protection Agency’s (U.S. EPA) Climate Reduction Grants under the Inflation Reduction Act of 2022. This is still in effect with the current federal funding changes.

For companies operating in manufacturing, materials production, and heavy industry, RISE PA brings both new opportunities and new expectations. Pennsylvania’s Department of Environmental Protection (DEP) is now accepting applications for both medium and large-scale award tracks, with applications due in August 2025.

Who is Eligible for RISE PA Funding?

The RISE PA program focuses on funding projects that achieve direct, verifiable reductions in industrial emissions, including both greenhouse gases and criteria pollutants such as nitrogen oxides and particulate matter. There are three different pools of funding depending on the size of the project, which are Small Scale, Medium-Scale, and Large-Scale award tracks. Eligible applicants include owners or operators of industrial facilities that produce process emissions, such as cement, steel, aluminum, chemical, and semiconductor manufacturing. Eligibility also extends to owners or operators of active or abandoned coal mines, coal processing operations, and natural gas or oil production, transmission, and distribution systems.

Under the program guidelines, an owner of an industrial facility will qualify under the following North American Industry Classification System (NAICS) codes qualify for the Medium- and Large-Scale award tracks:

• NAICS code 11: Agriculture, forestry, fishing, and hunting
• NAICS code 21: Mining, including oil, power generation, and gas extraction
• NAICS code 23: Construction
• NAICS codes 31-33: Manufacturing

The following GHG reduction projects are eligible for the RISE PA Program:

• Electrification technologies (electric heat pumps or zero carbon process heating)
• Industrial process emissions technologies and waste reduction technologies
• Energy efficiency technologies (combined heat and power systems, waste heat recovery, smart energy management systems, etc.)
• Fugitive emissions reduction technologies such as regenerative thermal oxidizers and air ventilation
• Fuel switching technologies
• On-site renewable energy technologies
• Carbon capture, utilization, and storage (CCUS)
• Other technologies that reduce GHG emissions, as determined by RISE PA

In addition, Energy-as-a-Service companies, Sustainability-as-a-Service companies, landlords of industrial facilities, and other service providers may also be eligible, provided the project is conducted at a qualifying industrial facility and all application requirements are met. The program is particularly interested in high-impact projects that demonstrate scalability, replicability, or technological innovation.

What Funding is Available Through RISE PA?

Grant awards are expected to range from $25,000 to $5 million per project, depending on the size, scope, and potential impact of the proposed activities. There is no fixed limit on the number of RISE PA grants awarded; instead, the total awarded depends on available funding and the quality of applications received. RISE PA is a reimbursement grant program, which means the grantee will pay upfront and then provide costs to the state to invoice for reimbursement from RISE PA. The grant awards are summarized in Table 1 below. In most cases, applicants will be required to provide a cost-share contribution, meaning that the company must invest its own resources alongside the grant funding. The specific matching requirement may vary based on the project category, but demonstrating a financial commitment will strengthen an application’s competitiveness.

Projects must be able to begin shortly after receiving the award notification and should show clear progress toward emissions reductions within a two-to-three-year implementation period. The project must also be completed before April 2029. This requirement emphasizes the program’s focus on immediate action and achievable near-term results, rather than projects that remain in planning stages for extended periods. Companies seeking to participate will need to prepare a well-defined scope of work, a detailed budget, and credible emissions reduction projections that align with RISE PA’s goals.

What is the Application Process?

Applying for RISE PA is a multi-stage process that requires careful planning and preparation. Companies should start by identifying eligible emissions-reduction opportunities within their operations. Once a potential project is identified, they need to conduct a baseline emissions assessment to quantify current emissions and establish a point of comparison for the proposed reductions.

After completing the baseline assessment, companies must use their findings to develop a technical proposal. This proposal should detail the project design, the technologies or strategies to be implemented, the expected emissions reductions, and the overall benefits of the project. It should include both a technical narrative and a financial proposal component. The financial proposal must outline the total project costs, the requested grant amount, any necessary cost-sharing sources and amounts, and a clear project timeline. Additionally, it must describe how the project will be managed to ensure timely and successful execution.

Applications will be evaluated based on several key criteria, including projected emissions reductions, cost-effectiveness, technical merit, innovation potential, scalability, and the applicant’s readiness to execute the project execution promptly. All applications must be submitted by August 29, 2025, and companies are encouraged to start their preparations immediately to meet this deadline.

Why Should Companies Act Now?

The opportunity to secure RISE PA funding is significant, but the timeline is tight. Companies interested in applying must act quickly to define their projects, assess their current status, develop strong proposals, and coordinate internally to meet the August 2025 submittal deadline. Delaying action could result in missed funding opportunities or rushed applications that are less competitive.

In addition to the immediate funding benefits, participating in RISE PA offers long-term advantages. Successful projects can lower operating costs, enhance energy security, improve environmental, social, and governance (ESG) profiles, and strengthen compliance readiness in anticipation of future regulatory changes. Companies that take action now will lead the way in shaping a lower-carbon industrial future for Pennsylvania.

Helping Companies Succeed with RISE PA

At ALL4, we assist companies in maximizing the new RISE PA funding opportunity. Our team collaborates closely with our clients to identify eligible projects, calculate baseline emissions, prepare strong applications, and assure the project is set up for success. Whether you’re already planning decarbonization efforts or just starting, we will guide you through the entire process, helping to secure funding and make meaningful progress towards your sustainability goals.

If you’re interested in discovering how ALL4 can support your RISE PA application and overall decarbonization strategy, please contact Cambre Codington at ccodington@all4inc.com.