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Forest Products Industry Newsletter – March 2026

Home / Forest Products Industry Newsletter – March 2026

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Emerging Regulatory and Technical Topics

  • On February 12, 2026, the United States Environmental Protection Agency (U.S. EPA) signed a rule to finalize the recission of the 2009 Endangerment Finding and greenhouse gas (GHG) vehicle standards. U.S. EPA is expected to finalize a rescission or significant revision to the GHG standards for electric generating units (EGUs) this year. It’s likely that these actions make it all the way to the Supreme Court of the United States for argument.
  • On February 24, 2026, U.S. EPA published proposed revisions to the Risk Management Program (RMP) rule titled “Common Sense Approach to Chemical Accident Prevention.” The proposed changes reduce regulatory burden by eliminating many of the updates in the 2024 final RMP rule revisions. You can find more information on the proposed changes in our recent blog. Comments on the proposed rule are due by April 10, 2026.
  • On February 25, 2026, U.S. EPA signed a rule to extend the GHG reporting deadline under 40 CFR Part 98 from March 31, 2026 to October 30, 2026. This final rule changes only the reporting deadline for annual GHG reports for reporting year 2025 in response to comments received on the proposed rescission of the Greenhouse Gas Reporting Program (GHGRP). U.S. EPA anticipates addressing the remainder of the 2025 proposed rule in one or more subsequent final actions, likely by July 2026.
  • We are seeing the emergence and refinement of state GHG reporting requirements. For example, we’re following emerging GHG reporting requirements in New York (see below) and California and tracking how other states’ reporting programs, like Washington, are affected by the proposed rescission of Part 98 – reach out to Louise Shaffer or Madison Jones for more information.
  • In February and March 2026, U.S. EPA published two proposals regarding the Clean Water Act (CWA) Facility Response Plan (FRP) rule that we’d been waiting on – one to request comments on certain changes to be made to the rule regarding applicability determination and implementation, and another to delay the compliance date for the rule by three years (from June 1, 2027 to June 1, 2030). The purpose of the delay is to allow time for U.S. EPA to “consider implementation and compliance assistance tools that regulated parties may be able to take advantage of when complying with the new requirements.” 30-day public comment periods on the two proposals end on March 20, 2026 and April 6, 2026, respectively. For more information, see our latest blog.
  • The 2021 U.S. EPA Multisector General Permit (MSGP) for stormwater discharges expired on February 28, 2026, and a renewed permit has not yet been issued. This permit directly applies in the limited areas where states do not have delegated authority for the National Pollutant Discharge Elimination System (NPDES), including Massachusetts, New Hampshire, New Mexico, and Washington DC, however many states that issue their own MSGPs model updates to their permits after U.S. EPA’s. U.S. EPA sent messages to facilities with active permit coverage under the 2021 permit and/or with in-progress Notices of Intent (NOIs) communicating that they would be “unable” to issue the renewed permit prior to the expiration of the 2021 permit. The 2021 permit will be administratively continued until a renewed permit is issued, meaning that permit coverage will continue for those with current coverage; however, facilities will not be able to obtain new coverage under the permit until the permit is renewed. In the interim, facilities will either need to obtain an individual stormwater permit from U.S. EPA or submit a No Exposure Certification (NEC), if eligible. We are hearing that it could be a year or more before the renewed permit is issued. ALL4 previously published a blog on the draft 2026 U.S. EPA MSGP which was put out for public comment in December 2024; following the change in administration, the public comment period was extended multiple times and concluded in May 2025.
  • We continue to follow Environmental Justice (EJ) policies and regulations at the state level. For example, Pennsylvania formalized its EJ Policy on January 3, 2026, and we are watching regulatory activity in Washington and Minnesota. Reach out to Joe Sabato for more information on state EJ activity.
  • U.S. EPA missed the February deadline to make designations under the recently lowered annual fine particulate National Ambient Air Quality Standard (NAAQS) of 9 µg/m3. The court has not yet ruled on whether U.S. EPA’s reconsideration of the 2020 NAAQS was legal. For now, we are under the lower NAAQS but stay tuned to see whether it’s permanent.
  • U.S. EPA recently proposed Step 1 of a two-step process that is expected to significantly revise or rescind the 2023 revisions to the Good Neighbor Plan for the 2015 ozone NAAQS. If finalized, Step 1 would approve many of the state implementation plans (SIPs) that were previously disapproved and formed much of the basis for the 2023 revisions, including emissions limits for certain paper mill boilers.
  • Did you have to prepare a four-factor analysis for the current Regional Haze Rule (RHR) planning period a few years ago? U.S. EPA recently extended the due date for SIPs for the 3rd RHR planning period from 2028 to 2031 while it works on rule changes to streamline the process for states. In states where air quality is ahead of the “glidepath” to natural conditions by 2064, this could mean less sources are selected for analysis this time around.
  • Thinking of installing a combustion turbine for cogeneration, maybe to replace an aging boiler? U.S. EPA finalized revisions to the combustion turbine nitrogen oxides (NOx) standards in 40 CFR Part 60 – see our blog for more information.

New York’s Mandatory GHG Reporting Rule is Active!

New York finalized its first mandatory greenhouse gas (GHG) reporting program under 6 NYCRR Part 253. This rule applies to facilities located in New York that emit over 10,000 MT CO2e annually, as well as certain listed source categories regardless of threshold. Calendar year 2026 will be the first reporting period, with the first GHG reports due June 10, 2027. While this rule incorporates elements of the Federal GHG reporting rule under 40 CFR Part 98, there are several key differences (including additional sources to be reported) that forest products facilities should understand:

  • Use of 20‑year global warming potentials (GWPs) for emissions reporting, which are generally higher than some of the 100‑year GWPs used under 40 CFR Part 98.
  • Reporting of GHG emissions from emergency generators.
  • Reporting of GHG emissions associated with refrigerant leaks.
  • Implementation of more stringent calibration requirements, including:
    • Completion of initial calibrations prior to the start of data collection (or submission of an extension request by July 1, 2026, if initial calibration is not feasible).
    • Retention of calibration records.
    • Adherence to minimum calibration intervals of every 36 months, or more frequently as specified in the rule.
  • Enhanced recordkeeping requirements, including documentation for wood residuals from primary timber processing. For all wood combusted onsite, the following information must be reported:
    • Bone‑dry mass received.
    • Supplier name.
    • Supplier physical address.
    • State in which the wood was sourced.
  • Facilities with an anaerobic digester or solid waste landfill reporting annual emissions exceeding 300,000 MT CO2e must also submit an Emissions Monitoring and Measurement Plan (EMMP) by September 1, 2026.

There is another category called “large emissions sources” that are facilities that emit over 25,000 MT CO2e. These large emissions sources have additional reporting requirements such as submission of a GHG Management Plan (GHGMP) and third-party verification of the data.

For more information, reach out to your ALL4 project manager.

Industry News

Below are some recent forest products industry headlines you might find interesting. On the ALL4 news front, we recently acquired two firms that expand our service offerings and geographic coverage. We now have staff who specialize in wetlands and endangered species regulatory permitting, biological studies, cultural resource services, and California Environmental Quality Act (CEQA)/National Environmental Policy Act (NEPA) document preparation. We’re also growing our noise/acoustics services through recent hires.

  • March 11, 2026 | Sofidel Selects Its Inola Facility for $775 Million Tissue Capacity Expansion in the U.S. Read more
  • March 10, 2026 | Manufacturers nix the USDA’s Paper and Packaging Board Read more
  • March 10, 2026 | EPR for packaging laws: Dates to know Read more
  • March 9, 2026 | Georgia-Pacific Lebanon Tennessee Facility Recognized by the State for Workplace Safety Read more
  • March 4, 2026 | February closure announcements hit hundreds of North American packaging workers Read more
  • March 2, 2026 | Ahlstrom to Close Pulp Mill and Two Paper Machines at Mosinee Mill in Wisconsin Read more
  • March 2026 | Hardwood Fiber Solutions Can Unlock Greater Cost Competitiveness and a More Sustainable Future Read more
  • February 25, 2026 | International Paper further downsizing in South Carolina Read more
  • February 19, 2026 | South Carolina, Virginia score packaging manufacturing expansions Read more
  • February 18, 2026 | Domtar Begins Installation of New High-Speed Tissue Converting Line at Calhoun Mill Read more
  • January 29, 2026 | AF&PA Elects Domtar’s Steve Henry as Chair Read more
  • January 29, 2026 | International Paper to Create Two Independent Public Companies Read more
  • January 23, 2026 | International Paper Completes Sale of Global Cellulose Fibers Business to American Industrial Partners (AIP) Read more

Safety Corner

In March, the American Ladder Institute (ALI) celebrates the 10th National Ladder Safety Month, designed to raise awareness around ladder safety and decrease the number of ladder-related injuries and fatalities. Every year thousands of workplace injuries and hundreds of workplace fatalities occur from use of ladders. The US Bureau of Labor Statistics (BLS) reported 161 workplace fatalities and 22,710 workplace injuries related to ladders in 2020 alone.* ALI believes that many ladder safety incidents are preventable, and that through increased awareness and training, the number of ladder related incidents can decline. The ALI outlined the following schedule for ladder safety month:

  • Week One: Choosing the Right Ladder
  • Week Two: Check Before You Climb
  • Week Three: Set It Up Safely
  • Week Four: Climb Safely, Work Safely
  • Week Five: Safe Steps with Stepstools

With National Ladder Safety Month upon us, now is a great time to evaluate ladder safety in your workplace. Do you have an effective ladder safety program and training for your workplace? Utilize ladder safety month as a time to increase awareness and improve ladder safety at your workplace. Unsure where your organization stands in terms of ladder safety? ALL4 can help you evaluate your ladder safety program and take it to the next level.

*BLS [2022]. The Economics Daily. US Bureau of Labor Statistics. April 25, 2022

Recent Relevant ALL4 Webinars/Podcasts

We’ve reinvigorated our podcast series and thought you’d be interested in the following recent topics:

Stay tuned for an upcoming podcast with Tim Hunt, American Wood Council, as one of our guests. On the webinar front, look out for a Toxics Release Inventory (TRI) webinar and a NPDES webinar coming soon and listen to our recent webinar on the Refrigerant Rule updates if you need a refresher.

Upcoming ALL4 Events/Conferences

We’re looking forward to the NCASI annual conference in June and hope to see you there! In the meantime, we will be out and about at these events:

Training

Do you need professional development hours or have new environmental staff you need to train? Is training in your budget for 2026? If you have budget on a general assistance project with ALL4 you can also use it to register for training – reach out to your project manager for information and a client discount code. Here are some options:

  • WASTE 101 provides a foundational knowledge of various waste-related regulatory programs, with an emphasis on the Resource Conservation and Recovery Act (RCRA). The program covers the history of waste-related regulations and an overview of regulatory programs that impact industrial operations in various sectors, including forest products. You can register and listen to the recordings of our Fall 2025 sessions.
  • Air Quality 101 (AQ101) Training provides a comprehensive and foundational knowledge of the Clean Air Act (CAA) and its various regulatory programs.  The program covers the history of the CAA, NAAQS, and an overview of regulatory programs that impact industrial operations (e.g., New Source Performance Standards, Prevention of Significant Deterioration, air quality modeling, etc.).  The program also covers more focused topics that are encountered day to day by facility environmental personnel such as the basics of emissions testing and continuous emissions monitoring. Our Fall 2025 program is in progress now – you can listen to recordings of early sessions to catch up.
  • WATER101 provides a foundational knowledge of various water-related regulatory programs, with an emphasis on the Clean Water Act (CWA). The program covers the history of water-related regulations, water quality protections, and an overview of regulatory programs that impact industrial operations (wastewater permitting and discharge, stormwater permitting and discharge, contingency and response plans, and drinking water and water resources). The topics covered by WATER101 will be those encountered by environmental personnel in their real-world projects. Recordings of our Spring 2025 sessions are available now and we will offer this course again in 2026.

ALL4 can develop customized EHS training programs for your staff – reach out to Lindsey Kroos for information!

 

Upcoming Regulatory Deadlines

Do you have electronic reports due soon? Be sure to check the U.S. EPA Compliance and Emissions Data Reporting Interface (CEDRI) templates and the Electronic Reporting Tool (ERT) for updates.

  • The 40 CFR Part 98 GHG reporting deadline has been extended from March 31, 2026 to October 30, 2026.
  • RMP proposal comments are due April 10, 2026.
  • Quarterly compliance reports, if applicable to your site, are due in April.
  • Check your air permit to see when your annual compliance certification is due. Need a better compliance tool? We can help.
  • Check your state’s requirements to see if you have an annual emissions inventory due in 2026 and when. Does your emissions inventory need a refresh? We can help.

Reporting Tips & Tricks

With Tier II and Resource Conservation and Recovery Act (RCRA) biennial hazardous waste reporting in the rear-view mirror, the Toxics Release Inventory (TRI) is next on the list.  TRI requires the use of “best readily available information” for compiling the threshold determinations for reporting. TRI does not require additional monitoring or measurement beyond what other laws/regulations require or are part of routine plant operations. Some tips for data collection are:

  • Check for new safety data sheets and the latest site-specific sampling information.
  • Do not use non-site-specific emissions factors or calculations if more accurate, representative data is available (e.g., sampling).
  • Where site-specific data is not readily available, use reasonable estimates. Reasonable estimates can be based on published emissions factors, emissions factors from other sites in your company, material balance calculations, or engineering calculations.
  • Just because you were over or under a threshold last year, doesn’t mean you will be this year.

Reach out if you need assistance preparing your threshold calculations and TRI report.

Solutions Spotlight

Dealing with Odor Issues can Stink

Odor from industrial facilities can be a challenging issue to characterize and address. An individual’s perception of odorous emissions is subjective, fleeting, and affected by their sensitivity to the specific compound or compounds.  There are even instances where the odor threshold of a compound may be less than the level of detection of the methods used to measure its presence. While not specifically regulated at the federal level, many state and local air permitting  authorities include prohibitions of odorous emissions within their air regulations, usually targeting “nuisance” odors.  Many municipalities include environmental performance provisions within their zoning ordinances, which typically prohibit odorous emissions as a nuisance.

Even after the imposition of regulations to limit emissions hazardous air pollutants (HAP),  odor  complaints remain a difficult issue for forest products facilities because what communities experience is not always what routine compliance monitoring is designed to measure. Even when operations are permitted and operating within emissions limits, odors can still trigger complaints, regulatory scrutiny, and reputational risk. The challenge is that odor events rarely originate from a single obvious source. Instead, they may result from a shifting mix of gases, condensable organic vapors, and, in some cases, fine particulate or aerosol droplets that can carry odorous compounds. Because odor events are often intermittent and influenced by process conditions, control device performance, weather, and material handling practices, identifying the true source – and therefore the appropriate mitigation strategies – can be difficult.

ALL4 helps facilities move beyond guesswork by applying a structured approach that combines odor fingerprinting, targeted monitoring, and process evaluation. By identifying the specific odorous species present and linking them back to facility operations, we can evaluate capture systems and control performance to pinpoint practical improvements. The result is a clearer understanding of odor drivers and targeted solutions that reduce complaints while keeping operations running efficiently. Reach out if you’d like to learn more.

In this time where there is a steady stream of regulatory and deregulatory news, stay tuned for ALL4 updates in our weekly newsletter, 4 The Record. Please reach out if you have any questions or suggestions for our next quarterly Forest Products newsletter.

Thanks,

Amy Marshall, Air Quality Practice Director

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