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October 2025

Not too late for Houston!

There’s still time to lock in your spot for McCoy’s Houston Refresher seminar, taking place November 18-19, 2025, at the South Shore Harbour Resort. Book your room with the McCoy rate of $140 before they fill up—rooms will be available through November 3, 2025! Over your stay, be sure to take advantage of the resort's premier spa, fitness center, and if you’re a golfer… access to the South Shore Harbour Country Club!

Refresher agenda
Houston registration

GHG reporting irrelevant?

The next in a long list of EPA’s deregulatory moves is to remove greenhouse gas reporting requirements for nearly all facilities except certain petroleum and natural gas system operators. The agency recently proposed these revisions, stating that such data collection is unnecessary since the CAA does not explicitly mandate it. While businesses could save millions by eliminating reporting, invaluable data will be lost that could be used by regulators and the regulated community to save billions. READ MORE

EPA deregulates spring air agenda

The Spring 2025 regulatory agenda is now available and EPA is planning reviews, revisions, and amendments to scores of CAA stationary source regulations. A critical aspect of the CAA is the periodic review of source category standards. While some of what is on the agenda is the typical review, many items are directly related to the current administration’s deregulatory efforts. READ MORE

Kick off 2026 with McCoy

The 2026 McCoy seminar schedule has arrived, and most classes are already open for registration! Start the year off with the January 20-22, 2026, .VIRTUAL 3-Day Clean Air Act Unraveled seminar, or plan ahead for the February 2-6, 2026, .VIRTUAL 5-Day RCRA seminar. Whether it’s RCRA, California Title 22, or the Clean Air Act, McCoy training will always keep you up to date and ready to go… whatever the new year brings!

McCoy’s full schedule

Spring RCRA deregulatory agenda drops

EPA’s Spring 2025 RCRA regulatory agenda shows few changes from the previous year. Notably, the agency has quietly removed the previous notices of proposed rulemaking for drum management/reconditioning and PFAS-related designations as CERCLA hazardous substances. Perhaps the most significant addition is the upcoming proposal to phase out paper manifests. READ MORE

The Miami ReefLine!

Miami Beach is making waves with the ReefLine, a groundbreaking 7–mile underwater sculpture park which doubles as a living reef. Designed to restore the Florida Reef Tract, the project transforms large-scale art sculptures into new marine habitats. Its first installation, “Concrete Coral”, by artist Leandro Elrich, features full-size 3D-printed concrete cars sunken deep beneath the waves. With many installations on the way, be sure to snorkel or boat out and see the reef for yourself!

ReefLine installations

Congress weakens air standards (again)

EPA finalized amendments to the rubber tire manufacturing NESHAP in November 2024, addressing HAP emissions from the rubber processing subcategory. [89 FR 94886] The amendments were a response to Louisiana Environmental Action Network v. EPA (U.S. Court of Appeals, D.C. Circuit; Docket No. 17-1257; April 21, 2020), which holds that EPA has an obligation to address unregulated emissions from a major source category when the agency conducts the 8-year technology review. Despite this legal mandate, Congress has once more intervened via the Congressional Review Act and passed a Joint Resolution of Disapproval [H. J. Res. 61], which was signed by the President on May 6, 2025. Thus, the 2024 amendments to Part 63, Subpart XXXX have been revoked and have no legal or enforceable effect. The agency will follow up with a final rule formally removing the now-obsolete provisions.

RCRA takes Vegas

This December 8-12, 2025, McCoy’s 5-Day RCRA in-person seminar takes over Las Vegas! Join us for five days of in-depth RCRA training at The Orleans Hotel, where we’ve reserved a limited block of rooms for just $45 per night. It’s the perfect chance to get guidance on the regs and enjoy everything Las Vegas has to offer. Reserve your spot today and make it a December to remember!

Class agenda

A river reborn

Once written off as too polluted, the long-forbidden Seine River in Paris has welcomed swimmers back for the first time in decades. Originally cleaned for the 2024 Olympics, its new public swimming areas are proof that even the most neglected waterways can be brought back to life.

Affirmative defense removed from PEPO NESHAP

Affirmative defense is a mechanism that allows a source to avoid civil penalties during judicial or administrative proceedings and typically applies within the context of malfunction events resulting in noncompliance with any applicable standard. In light of NRDC vs. EPA (U.S. Court of Appeals, D.C. Circuit; Docket No. 10-1371; April 18, 2014), which found such a mechanism to not be under the authority of EPA but rather the courts, EPA proposed removing the provisions from 18 NSPS and NESHAP rules in June 2024. [89 FR 52425] Effective September 2, 2025, the affirmative defense provision was removed from the polyether polyols production (PEPO) NESHAP of Part 63, Subpart PPP, and more removals from other standards will likely follow. [90 FR 42328] EPA will continue to evaluate possible violations on a case-by-case basis and determine whether an enforcement action is appropriate.

Fall .VIRTUAL RCRA

As the leaves turn and fall sets in, join us for our last .VIRTUAL 5-Day RCRA seminar of the year, November 3-7, 2025! During the live training, we’ll cover the RCRA essentials, the latest regulatory updates, and any questions that come up—just like an in-person seminar. And before class begins, course materials, including a course binder and the RCRA Unraveled and Reference publications, will be delivered right to your door, so you’ll be ready to end the year strong!

5-Day .VIRTUAL agenda
Full schedule

Pumpkins post-Halloween

After Halloween this year, give your pumpkin a better send-off than just tossing it in the trash. Compost it instead! Once the trick-or-treaters are all wrapped up, cut your pumpkin into small pieces, remove any decorations, and add it to your compost pile… your garden will thank you. No compost pile? Take it to a local farm or compost drop-off and keep your pumpkin from haunting the landfill!

2025–2026 Seminars

3-Day CAA Seminars
.VIRTUAL: January 20–22, 2026
.VIRTUAL: March 31–April 2, 2026

4-Day California Title 22-RCRA Seminars
.VIRTUAL: May 11–14, 2026

5-Day RCRA Seminars
.VIRTUAL: November 3–7, 2025
Las Vegas: December 8–12, 2025
.VIRTUAL: February 2–6, 2026
Virginia Beach: March 9–13, 2026
Denver: June 8–12, 2026
Lake Tahoe: August 17–21, 2026

2-Day RCRA Refreshers
Houston: November 18–19, 2025
.VIRTUAL: February 18–19, 2026

Visit mccoyseminars.com to register or call us at 303-526-2674.

If you have received this email in error or wish to remove your name from our subscriber list, you may unsubscribe here. You may also update your profile here. If you need to contact us directly about subscription or other issues, you may email us at mccoyreview@mccoyseminars.com or call us at 303-526-2674.

McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided in RCRA Review. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance in RCRA Review is general in nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.

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