December 15, 2015
2016 Environmental Regulations Planning – A Look Ahead
POSTED BYJosiah Frey
As we approach the end of 2015 and consign it to the history books, our attention inevitably turns to what comes next in 2016. For many of us individually, this involves some thoughtful waxing and waning, but for most businesses the next steps are much more pragmatic. From a regulatory perspective, the first quarter of 2016 starts with a focus on filing annual Emergency Planning and Community Right-to Know Act (EPCRA) Tier II reports for facilities that use, produce, or store a Hazardous Chemical, or an Extremely Hazardous Substance (http://www.smithmanage.com/2015-epcra-tier-2-hazardous-chemical-inventory-reports/). Did you know that storing certain quantities of common compressed gases (oxygen, propane, natural gas, etc.) may require a facility to file an EPCRA Tier II report? EPCRA Tier II reports are due between January 1st and March 1st 2016.
Following EPCRA Tier II reporting in the early spring, many industrial facilities will need to begin submitting Semi-Annual Monitoring Reports (SAMR) to the Kentucky Division of Air Quality (DAQ), and semi-annual Discharge Monitoring Reports (DMRs) to the Kentucky Division of Water (DOW). Semi-Annual Monitoring Reports (SAMR) associated with many air permits, and Discharge Monitoring Reports (DMRs) associated with the General Industrial Stormwater Permit are due at the end of July. Patty Mason with SMG published a blog earlier this year that provides some good resources for permittees that have these reporting requirements (http://www.smithmanage.com/tis-the-reporting-season/).
Also, many businesses will want to keep up with developments on the EPA’s Clean Power Plan, which seeks to have each state submit a plan for compliance by June 30, 2016. The Clean Power Plan faces a legal challenge from twenty-four states, including Kentucky, and could be transformative for the electrical supply landscape (http://www.usatoday.com/story/news/politics/2015/10/23/24-states-file-legal-challenge-obamas-power-plan/74472236/). While the Clean Power Plan appears to be the most press-worthy regulation to be decided in 2016, the EPA’s new National Ambient Air Quality Regulations for Ozone (NAAQS) (http://www.smithmanage.com/new-ozone-air-quality-requirements/) and Stormwater Urban Runoff Rules (http://www.smithmanage.com/epa-to-update-stormwater-urban-runoff-rules/d) will also influence 2016 site development projects.
As you look ahead to 2016, if you have any questions about upcoming regulations or need help with your current reporting requirements, please contact me at firstname.lastname@example.org or 859-231-8936 x 115.