Here’s the issue of McCoy Review you requested:

August 2025

Rejecting reason, EPA exacerbates climate change

On August 1, 2025, the new administration’s EPA proposed a “reconsideration” of the 2009 greenhouse gas (GHG) endangerment finding and a repeal of GHG emission standards. [90 FR 36288] The proposal rests on the most tenuous logic and concludes that GHGs don’t endanger public health and welfare and are not a driver of anthropogenic climate change. McCoy and Associates will write a detailed article on the proposal soon. Until then, if you would like to submit a comment on this short-sighted and ill-advised proposal, you may do so until September 15, 2025 via Docket ID No. EPA-HQ-OAR-2025-0194.

From McCoy’s editorial board:

For over forty years, McCoy’s mission has been to help industry and federal and state agencies manage air emissions and hazardous waste responsibly. Our commitment to help protect human health and the environment is resolute.

The potential repercussions from the current administration’s proposal to rescind the 2009 GHG endangerment finding ignore decades of evidence and a Supreme Court ruling affirming that GHGs are pollutants that can be regulated under the CAA. Pulling back on climate action now makes neither environmental nor economic sense.

For example, the strategic shift to produce US electric vehicles makes sense because EVs are cleaner and simpler to manufacture, and EVs are more energy efficient. Furthermore, the US must be equipped to compete with global competition or be left woefully behind. This proposal is poorly reasoned, and combined with separate defunding efforts, it sabotages US auto manufacturing and the practical effort to combat climate change at a time when the rest of the world is taking giant leaps ahead.

Therefore, we strongly disagree with the administration’s conclusion that GHGs do not endanger public health and welfare. It is our hope that industry will continue to take positive steps to reduce GHG emissions to protect their organization’s reputation, increase its competitive position, and to protect the health of our planet for future generations.

Not just RCRA

McCoy doesn’t just do 5-Day and 2-Day RCRA seminars anymore. Over the last few years, we’ve added the 3-Day Clean Air Act Unraveled seminar and 4-Day California Title 22-RCRA seminar to the McCoy curriculum… and this October, we’ve got both on the calendar! Join us for the .VIRTUAL Clean Air Act seminar October 21–23, 2025, or the .VIRTUAL California Title 22-RCRA seminar October 6–9, 2025. Same signature McCoy training—different sets of regs.

Clean Air Act agenda
California T22-RCRA agenda

Houston Refresher tune-up

Even the smoothest riding cars could use a tune-up now and again. Join McCoy in Houston this November 18–19, 2025, and keep your RCRA engine running smoothly throughout the year. Held at the South Shore Harbour Resort—reserve a room with the McCoy room rate of $140 per night while they last. We’ll catch you in Texas this November!

RCRA Refresher agenda

TSDF toolkit unlocked

To improve stakeholder access, EPA recently updated its Hazardous Waste TSDF Toolkit, a compendium of publicly available RCRA permitting resources. The toolkit includes permitting process flowcharts, training modules, Federal Register rulemaking notices, permit appeals, example permits, and links to state and federal resources. From the toolkit, hundreds of additional documents can be accessed, enabling regulatory agencies and facility operators to find what they need with just a few clicks. Meeting the obligations of having a full RCRA permit can be difficult, but at least navigating the resources has been made a little bit easier.

New modules for RCRA permits

EPA’s RCRA model permit is a guide to help permit writers draft and review RCRA permit conditions for incorporation into a RCRA hazardous waste permit. The model provides example language vetted by legal and enforcement experts, designed to reduce permit issuance time and promote consistency. The agency recently updated the RCRA model permit to include modules on general facility conditions, preparedness and prevention, and contingency plans. As discussed in a previous article, these modules help permit writers by standardizing the language associated with hazardous waste management permits.

Dazzling Las Vegas

McCoy’s final seminar of the year lands in the dazzling city of Las Vegas, this December 8–12, 2025! Join us for one or all five days of training and stay at The Orleans Hotel—where we’ve reserved a limited block of rooms for just $45.00 per night. And if these dates don’t fit your schedule, rest assured, McCoy has multiple .VIRTUAL classes to choose from. If you didn’t already know, our virtual classes are live with two presenters just like an in-person class.

Vegas registration
McCoy full schedule

Proper planning limits disaster debris

Disaster debris, whether caused by natural forces like wildfires or human-made events such as chemical spills, poses serious challenges for communities. Left unmanaged, such debris can deplete limited landfill space, sap local government budgets, and endanger public health and the environment. Communities will benefit from reviewing EPA’s newly updated disaster debris mitigation and planning resources and preparing for emergencies before they occur. READ MORE

Methane fees 10 years out

The waste emissions charge (WEC) rule, which impacted the oil and natural gas industry, was rescinded in March 2025 via a Joint Resolution of Disapproval [H. J. Res. 35], as discussed in a previous article. With the passage of The One Big Beautiful Bill Act (BBB), the legal dichotomy between the WEC rule’s mandate from CAA Section 136(c) [42 U.S.C. Sections 7436(c)] and Congress’s repeal of 40 CFR Part 99 is closer to being resolved. BBB Section 60012(b), which amends 42 U.S.C. Section 7436(g), pushes the application of the WEC fees to the beginning of 2034, with payment required in 2035. Despite the delayed implementation of the WEC fees, oil and natural gas facilities must still comply with the greenhouse gas reporting provisions of Part 98, Subpart W, where applicable.

Fall 5-Day RCRA!

Summer’s winding down and fall plans are already filling up fast. Beat the rush and sign up for one of McCoy’s .VIRTUAL 5-Day RCRA seminars taking place this September 15–19 or November 3–7, 2025. And before class starts, we’ll ship course materials right to your door—including McCoy’s RCRA Unraveled and Reference publications, plus a detailed course notes binder… you’ll have everything you need well ahead of time. Register before your fall plans fill up!

5-Day agenda
McCoy full schedule

EPA makes OSWI NSPS changes

EPA recently made changes to the new source performance standards and emission guidelines for other solid waste incinerators (OSWIs). Effective August 29, 2025, these amendments finalize applicability and definitional changes, introduce new subcategories of regulated units, eliminate the startup, shutdown, and malfunction exemption, and strengthen emission limits. However, pyrolysis and gasification, a long-standing issue for plastics recycling, were not addressed in the rule. The agency estimates these changes will reduce industry costs by $12 million annually. READ MORE

Multiple NESHAP deadlines extended

Part 63, Subpart FFFFF contains emission limits for sinter plants, blast furnaces, and basic oxygen process furnaces, while Part 63, Subpart L contains emission limits for coke oven batteries. On July 3 and July 8, 2025, EPA issued two interim final rules extending compliance deadlines for the integrated iron and steel manufacturing NESHAP and the coke oven battery NESHAP. [90 FR 29485 and 90 FR 29997] These actions revise the Subpart FFFFF 2025 and 2026 compliance dates to April 3, 2027 and the Subpart L 2025 and 2026 compliance dates to July 5, 2027. While the old compliance dates have been revised, all other aspects of the agency’s April 3, 2024 iron and steel rule [89 FR 23294] and July 5, 2024 coke oven battery rule [89 FR 55684] remain in effect.

Compliance pushed for oil and natural gas

EPA’s March 2024 oil and natural gas rule strengthened emission control requirements in Part 60, Subparts OOOO, OOOOa, OOOOb, and OOOOc, as discussed in a previous article. [89 FR 16823] On July 31, 2025, the agency promulgated an interim final rule to extend deadlines within the oil and natural gas NSPS and emission guidelines. [90 FR 35966] The compliance deadline for issues such as enclosed combustion device performance testing, legally and practicably enforceable emission limits, and implementing the super-emitter program has been extended to January 22, 2027. This interim final rule is effective on July 31, 2025 unless negative comments on any of the final provisions are received by September 2, 2025. Comments on the rule may be submitted via Docket ID No EPA-HQ-OAR-2025-0162.

A fine feathered evening

After Tuesday’s RCRA seminar wrapped up at the Sheraton Denver West Hotel, we gathered across the hall for a special evening with the HawkQuest team. Master falconer Kin Quitugua introduced us to a Bald Eagle, Peregrine Falcon, Harris Hawk, Great Horned Owl, and Screech Owl.

One of the most memorable moments came when the Harris hawk soared just a few inches over the audience’s heads! Between the raptors, Kin’s stories, and great company, it was a night to remember.

Check out the video from this year’s Food and Feather’s event here!

2025–2026 Seminars

3-Day CAA Seminars
.VIRTUAL: October 21–23, 2025
.VIRTUAL: January 20–22, 2026
.VIRTUAL: March 31–April 2, 2026

4-Day California Title 22-RCRA Seminars
.VIRTUAL: October 6–9, 2025
.VIRTUAL: May 11–14, 2026

5-Day RCRA Seminars
Lake Tahoe: August 18–22, 2025
.VIRTUAL: September 15–19, 2025
.VIRTUAL: November 3–7, 2025
Las Vegas: December 8–12, 2025
.VIRTUAL: February 2–6, 2026
Virginia Beach: March 9–13, 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.

Select another issue of McCoy Review...