On September 18, 2025, Administrator Lee Zeldin issued a policy memorandum entitled “ New Source Review Program ‘Reactivation Policy .’”  In the policy, Mr. Zeldin confirmed that the EPA would follow the Third Circuit’s decision in Port Hamilton Refining & Transp. v. U.S. EPA , will apply that decision nationwide, will not apply the “major modification” aspect of the policy to a facility that only restarts, but will apply to restarts that involve a physical change or change i

EPA recently issued a reminder regarding its e-Manifest Third Final Rule , published July 26, 2024. The rule finalizes a major shift: several manifest-related reports must be submitted electronically through the e-Manifest system starting December 1, 2025 . Below is a quick breakdown: 1. Exception Reports — Biggest Change for Generators Beginning December 1, 2025 , Large Quantity Generators (LQGs)  and Small Quantity Generators (SQGs)  must submit Exception Reports electronic

On September 15, 2025, EPA Administrator Lee Zeldin issued a memorandum, " EPA Policy on Enforceability and Use of the Actual-to-Projected-Actual Applicability Test in Determining Major Modification Applicability in New Source Review Preconstruction Permitting: Reinstatement of 2017 Memorandum ," (2025 Memo) which reinstated Administrator Pruitt's December 7, 2017 memorandum " New Source Review Preconstruction Permitting Requirements: Enforceability and Use of the Actual-to-P