A Presidential Exemption for the Coke Ovens Rules

ALL4 has covered the amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and Battery Stacks (PQBS) and Coke Oven Batteries (COB) at 40 CFR Part 63, Subparts CCCCC and L in previous articles. The United States Environmental Protection Agency (U.S. EPA) published final amendments to the NESHAP for Coke Ovens in the Federal Register on July 5, 2024 (Coke Ovens Rules). The revisions are a result of the Clean Air Act (CAA) mandated risk and technology review (RTR) for PQBS and the technology review for COB and they address previously unregulated hazardous air pollutants (HAPs) and HAP emissions sources. Approximately 70% of steel is made from metallurgical coke; the coke industry is therefore seen as vital to building and maintaining critical infrastructure and military readiness. On November 21, 2025, President Trump made a proclamation that provides “regulatory relief for certain stationary sources to promote American coke oven processing security” (Proclamation). The Proclamation made 11 facilities exempt from compliance with certain requirements of the Coke Ovens Rules for a period of two years beyond the relevant compliance dates.

The basis of this exemption relieves severe burdens on the coke production industry from compliance with standards premised on the application of emissions-control technologies that do not yet exist in a commercially demonstrated or cost-effective form. The timeline to implement testing and monitoring was deemed an unacceptable risk that threatened facility closures, production halts, and lasting harm to the domestic coke production industry that would lead to national security issues including substantially impacting the local and national economy.

Six of the 11 facilities received extensions for the following requirements of the Coke Ovens Rules:

• Fenceline monitoring, root cause and corrective action, and related reporting requirements;
• Limits on leaks from coke oven battery doors, lids, and offtakes and related reporting requirements; and
• New Maximum Achievable Control Technology (MACT) and work practice standards for coke oven pushing and battery stacks and related performance testing and reporting requirements.

The original compliance date for the fenceline monitoring and limits on leaks requirements was July 7, 2025. The Proclamation extends compliance with those requirements to July 7, 2027. Facilities may have started to implement monitoring or leak limit calculations but could have been experiencing issues implementing the required effort for each. The Proclamation was issued prior to the date that any reporting requirements were due to be submitted. Compliance with the MACT and work practice standards has been extended from July 7, 2027 to July 7, 2029.

Five of the 11 facilities received extensions (from July 7, 2027 to July 7, 2029) for the following requirements of the Coke Ovens Rules:

• MACT numeric emissions limits for existing sources;
• Opacity limits for bypass/waste heat stacks on existing sources;
• Initial performance test requirements; and
• Method 303A and daily pressure monitoring.

WHAT DOES THIS MEAN FOR MY FACILITY?

If you were one of the 11 facilities associated with this Proclamation, your facility now has an additional two years (or actually 19 months as the two-year extensions are retroactive from past compliance dates in some cases) to comply with the Coke Ovens Rules. This should be seen as extra time to plan your compliance approach and implement compliance strategies.

HOW CAN ALL4 HELP?

As your facility advances closer toward implementation of the Coke Ovens Rules, ALL4 can assist with MACT determinations, performance testing, monitoring assistance for opacity or pressure, and fenceline monitoring. We can also help with strategy around implementation of the many other requirements U.S. EPA has added to the NESHAP (e.g., new standards, electronic reporting, and removal of startup/shutdown/malfunction exemptions). For more information on the Coke Ovens MACT requirements please contact Dustin Snare at dsnare@all4inc.com / 610.422.1126. Please do not hesitate to reach out for assistance!