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.

Reporting Requirements for RCRA Small Quantity Generators – First Deadline September 1, 2025

Small Quantity Generators (SQG) of hazardous waste under the Resource Conservation and Recovery Act (RCRA) historically do not have as many Federal reporting requirements as Large Quantity Generators (LQG). However, as part of the Generator Improvements Rule (GIR) published in 2016, there was an additional report required for SQGs – the United States Environmental Protection Agency (U.S. EPA) Form 8700-12 (Site Identification form, Site ID Form) which certifies their RCRA hazardous waste generator status. LQGs are required to submit this certification every two years as part of their Biennial Reporting requirements. Title 40 of the Code of Federal Regulations (CFR) Part 262.18(d)(1) details the requirements for SQGs to certify their generator status using the Site ID form by September 1, 2021, then recertify every four years thereafter (Quadrennial Report).

Note: If your state has not adopted or been authorized to implement the GIR, this would not apply to your facility.

This means that if your SQG facility submitted their certification in 2021, the next time you would need to resubmit is in 2025. There is one caveat: if the facility has submitted a Site ID form (8700-12) in full any time within the period before the deadline, the renotification requirement has been met. If you are not sure if your facility has completed the form, in full, since 2021, it is recommended to resubmit the full recertification to meet this regulatory requirement. As additional clarification, U.S. EPA provided a notice that explained the deadline schedule as quadrennially starting September 1, 2021; the submission during the period before the deadline does not change when the recertification is due.

As an example, if your facility, in a state that has adopted the GIR, completed a full Site ID form by September 1, 2021, and again on June 30, 2024, the deadline for that period is still September 1, 2025. The requirement for that period (2021-2025) would be satisfied but the Quadrennial Reporting period would not be different for your facility (i.e., your next deadline would remain as submission by September 1, 2029, not June 30, 2028). The next deadline would still be to satisfy the reporting period of 2025-2029.

How do I submit this report?

Many states have annual reports that some or all generators of hazardous wastes are required to submit. U.S. EPA may not recognize these annual reports as satisfactory to meet the requirements for the Quadrennial Report, especially if the state does not use the RCRAInfo reporting module. To satisfy the requirement, your facility would need to either: be located in a state that annually uses RCRAInfo’s full Site ID form submission to satisfy the annual reporting requirements, or submit, independently of the state submission, through RCRAInfo.

What is RCRAInfo?

As an SQG, you may not have signed up for a RCRAInfo account, or even known it was an option! If you do not have an account, setting one up is simple. Visit U.S. EPA’s website for a walkthrough video: https://rcrainfo.epa.gov/rcrainfo-help/videos/CreateRIAAccount/Create%20RIA%20Account.html

Or U.S. EPA’s landing page for RCRAInfo registration: https://www.epa.gov/e-manifest/e-manifest-user-registration#how_register

As of January 22, 2025, all LQGs and SQGs are required to hold a RCRAInfo account to maintain an e-Manifest profile (Site Manager or e-Manifest Certifier permission) for their facility. RCRAInfo acts as an electronic manifest repository, discrepancy, and exception report communication method, as well as the preferred avenue for submitting your Quadrennial Report. If you already have a Central Data Exchange (CDX) account for another Federal report, the login credentials are the same and you can add access to the RCRAInfo module through CDX.

If you aren’t sure if anyone has access to your facility in RCRAInfo, reaching out to the state will start that process:  https://rcrainfo.epa.gov/rcrainfoprod/action/public/public-site/state-contacts

You can also search for your facility and request access using your U.S. EPA ID number in the Facility Search after confirming or completing your RCRAInfo account access.

If you have any questions about Biennial or Quadrennial Reporting, Hazardous Waste Generator Compliance, or using RCRAInfo, reach out to Michelle Carter at mcarter@all4inc.com.