Operators with Wyoming facilities are starting 2026 amid ongoing state program expectations and federal policy shifts affecting air, water, waste, and annual reporting obligations. While some federal programs are being reconsidered or delayed, Wyoming operators still need strong internal documentation and consistent environmental data to meet state requirements and to stay prepared for future regulatory cycles. For a more detailed review, a recorded presentation on these topics is available On Demand: 2026 Annual Compliance Reporting and Hot Topics in Wyoming.
Wyoming Regulatory Hot Topics
WDEQ Priorities and Program Direction
The Wyoming Department of Environmental Quality’s (WDEQ) published priorities include further reductions of ozone precursors in the Upper Green River Basin, with the long‑term goal of supporting redesignation to attainment. WDEQ is also investing in modernizing IT systems to improve efficiency, transparency, and public access to regulatory information.
At the same time, stated challenges include adapting to federal regulatory changes, managing loss of institutional knowledge due to retirements/turnover, and maintaining timely permit issuance with limited staffing. Despite these pressures, WDEQ continues to report meaningful progress, including advancements in its Coal Combustion Residuals (CCR) primacy application, significant land reclamation achievements, closure of abandoned mine openings, reductions in emissions through its audit program, and implementation of an online system for electronic comments and records.
2026 WAQSR Updates on the Horizon
Wyoming Environmental Quality Council (EQC) will consider proposed changes across several Wyoming Air Quality Standards and Regulations (WAQSR) chapters. These discussions will focus on updating incorporation‑by‑reference provisions to include federal citations current as of July 1, 2025. Additional adjustments may arise following board review and stakeholder input. The public hearing will be in Pinedale on April 13, 2026.
Surface Water and WYPDES Rule Changes
Several important updates have been made to Wyoming surface water rules and Wyoming Pollutant Discharge Elimination System (WYPDES) general permits. The Mineral Mining General Permit (MMGP) now allows certain off‑site discharges from bentonite and clay operations when enhanced sampling and reporting requirements are met. A major modification to the permit took effect in October 2025, with additional restrictions and pre‑sampling requirements beginning in November 2027. Other general permits, including construction stormwater and MS4 permits, have been administratively renewed.
For Commercial Oilfield Waste Disposal Facilities (COWDFs), recent changes clarify freeboard design requirements, new notification requirements, updates to public participation applicability for certain modifications, and updates to water quality criteria.
Wildlife and Land‑Use Considerations
The state continues evaluating a new antelope migration corridor in southwestern Wyoming. A local working group is being assembled to participate in the designation process. Existing permits and developments will not be affected, but new state‑permitted activities on public lands within the corridor boundaries may require additional evaluation to minimize impacts. Private lands remain unaffected.
BLM Resource Management Planning
Bureau of Land Management (BLM) continues amendments to the Rock Springs Resource Management Plan (RMP), which covers several million acres of public lands and minerals in southwestern Wyoming. The agency initiated an amendment in late 2025 and closed public comments in December. Greater Sage Grouse land‑use plan updates have also been finalized, increasing protection in multiple western states, including Wyoming.
CCR State Permit Approval Expected
EPA has proposed approval of Wyoming’s state-run Coal Combustion Residuals (CCR) program. Following a public hearing held in October 2025, officials have expressed high confidence that Wyoming’s CCR permit program will be finalized in 2026, providing more local control over CCR regulation.
Wyoming Reporting Updates & Reminders
Annual and Periodic State Reporting
Wyoming operators face numerous routine reporting obligations, including:
- Title V semiannual reports and annual compliance certifications
- UGRB emission inventories
- Title V emission inventories
- Water discharge monitoring reports
- CEMS/COMS reports
- Well completion reports
- Stack testing summaries
- NSPS and NESHAP reports
- Other permit‑specific submittals
Current calendar year 2026 emissions will be required to be reported April 30, 2027 for the Minor Source Triennial Emission Inventory Reports.
Hazardous Waste Biennial Report (March 1)
All Large Quantity Generators (LQGs) must submit biennial hazardous waste reports in even numbered years covering activities for the prior calendar year. Reports must include generator identification details, off‑site shipment information, transporter data, waste descriptions, hazard classifications, reduction efforts, and certified signatures. All Small Quantity Generators (SQGs) and LQGs should already be registered in the e‑Manifest system.
Tier II Chemical Inventory Reporting (March 1)
Wyoming Tier II reports are submitted through the Wyoming Homeland Security Tier II portal and distributed to the local LEPC and fire department. Facilities should be aware of updated hazard categories under OSHA’s 2024 Hazard Communication Standard that take effect for the RY2026 reports due in 2027, significantly expanding the number of hazard classifications. Early review of updated SDSs is highly recommended.
Refrigerant Management and Chronic Leaker Report (March 1)
The EPA’s Refrigerant Management Rule continues to require reporting for regulated appliances containing at least 50 pounds of Class I or II ODS if leaks exceed 125% of full charge in a year. Beginning in 2027, the reporting requirement expands to include HFC systems >15 pounds with global warming potential above 53, for leaks occurring in 2026.
Federal Updates Snapshot
EPA Enforcement Declines and Focus Shifts
EPA enforcement activity has dropped significantly in the past year, with only a single compliance advisory released in 2025 and historically low levels of litigation. Current priorities focus on imminent public health risks, illegal HFC imports, and select waste‑related concerns. Enforcement tied to methane emissions, environmental justice, or expanded oversight has been deemphasized by the current EPA administration.
Federal Deregulatory Efforts Intensify
EPA has initiated more than 30 deregulatory actions impacting oil and gas standards, electric power rules, wastewater effluent guidelines, and GHG reporting programs. Several methane rule compliance dates, originally set under NSPS OOOOb and OOOOc, have already been delayed until 2027 or later.
GHG Reporting and the Endangerment Finding Under Review
The federal GHG Reporting Program may be significantly scaled back. A 2025 proposal would eliminate reporting for nearly all source categories after reporting year 2024 and suspend Subpart W reporting until 2034. Additionally, EPA announced on February 12, 2026 a final rule that rescinds the 2009 GHG Endangerment Finding, a move that fundamentally affects greenhouse gas regulation nationwide. Litigation is virtually guaranteed on this action.
PM2.5 Standard and Modeling Impacts
The EPA has announced plans to revert the annual PM2.5 National Ambient Air Quality Standard (NAAQS) from 9.0 µg/m³ back to 12 µg/m³. Until rulemaking or legal action occurs, the stricter standard remains in effect, which increases the complexity of air dispersion modeling and may extend permitting timelines for particulate‑emitting projects.
Affirmative Defense Reinstated
A 2025 court ruling reinstated the Clean Air Act’s emergency affirmative defense for Title V facilities, allowing a defense against penalties for certain emergency‑related exceedances. Strong documentation and consistent recordkeeping are essential to support the defense.
PFAS Regulatory Activity
While many federal programs face rollback, PFAS or “forever chemicals” regulation remains an area of ongoing development. TRI reporting thresholds now cover more than 200 PFAS, CERCLA continues to classify PFOA and PFOS as hazardous substances, and stormwater and wastewater programs are incorporating new PFAS monitoring requirements. Drinking water rules have narrowed their scope but extended compliance timelines, reducing immediate burdens while maintaining long‑term expectations.
HFC Management Rule Now in Effect
Under 40 CFR Part 84, hydrofluorocarbons (HFCs) and refrigerant substitutes with global warming potential above 53 are now regulated with a January 1, 2026 effective date for most requirements. The rule is similar to the requirements for ODS appliances under 40 CFR Part 82, Subpart F, with some differences, including a lower capacity threshold of 15 pounds for leak repair requirements. For more information on refrigerant management, see our Refrigerant Management Services (ODS and HFC) webpage.
Key Takeaways
Wyoming’s 2026 regulatory environment remains stable, with some minor state‑specific developments in permitting, water quality, waste programs, and land‑use planning intersecting with rapidly shifting federal priorities. Although some federal requirements may be delayed or reconsidered, core compliance obligations remain in effect, and Wyoming facilities must continue to meet annual reporting, emissions inventory, and operational monitoring requirements. Early planning, consistent data management, and strong internal documentation will be essential for navigating the year ahead and preparing for future regulatory changes.
Resources
- To stay current on our Wyoming reporting requirements, download a copy of the Wyoming annual reporting compliance calendar.
- For a copy of our slide deck from our recent presentation on 2026 Annual Compliance Reporting and Hot Topics in Wyoming reach out to Zoe Stone.
- For support with your upcoming reporting requirements or questions on regulatory changes in Wyoming, reach out to Austin Buley with the Trinity’s Wyoming office.
