Pennsylvania House Bill 416 (HB416) passed on November 12, 2025, and was signed into law under Act No. 45 of 2025. HB416 was signed as a budgetary compromise to balance fiscal responsibility and support the workforce through modernizing tax policy and implementing regulatory reforms. After a four-month budget stalemate, negotiators used two environmental bargaining chips: ending participation in the Regional Green House Gas Initiative (RGGI) and implementing streamlined plan approval and general permitting in the state. Each of these compromises were introduced as a way to improve developing industries in the commonwealth and resulted in a reduced environmental oversight Statewide.

RGGI is a cap-and-trade program designed to reduce greenhouse gas emissions from fossil-fuel-power plants in the Northeast and Mid-Atlantic. Pennsylvania previously was set to join RGGI, but implementation of the program was stayed pending legal challenges. Specifically on December 20, 2023, the Pennsylvania Commonwealth Court ruled RGGI a “tax” which could not be promulgated through Pennsylvania DEP rule making. An appeal of this decision was pending at the Pennsylvania State Supreme Court at the time Act No. 45 was passed formally ending the state’s participation in RGGI.

In addition to removing RGGI, Act No. 45 implements a reform to Pennsylvania’s Streamlining Permits for Economic Expansion and Development (SPEED) program, initially introduced in 2024. This program accelerates environmental permitting for businesses and projects seeking certain types of permits. Participation is voluntary, and there are additional fees to participate.

Under SPEED, businesses receive a more predictable timeline for permit decisions. If the Pennsylvania Department of Environmental Protection (PADEP) fails to meet the deadline, the permit is deemed approved. The following changes have been implemented to the SPEED program:

• New SPEED Program Permit Categories:
  • Storage Tank Site Specific Installation Permits Under 25 Pa. Code Chapter 245
  • Short-Term Construction Permits for Non-Coal Surface Mines Under 25 Pa. Code Chapter 77
  • Concentrated Animal Feeding Operations (CAFOs) Under 25 Pa. Code Chapter 92
  • These programs are in addition to the current SPEED Program Permit categories: minor source air quality plan approvals, earth disturbance permits, individual water obstruction and encroachment permits, dam safety permits, and oil and gas erosion and sediment control general permits.

• All Air Quality General Permits and General Plan Approvals will be deemed approved within 30 days under the following conditions:
  • PADEP notifies the applicant of any technical deficiencies withing 20 days of the application submission,
  • The applicant responds to all technical deficiencies within 25 days of the application submission,
  • PADEP may extend the permit review time period once, to a total of 35 days, with the consent of the applicant.
  • A list of available general permits can be found here

• Certain Water Quality National Pollution Discharge Elimination System (NPDES) permit renewals will be deemed approved within 60 days under the following conditions:
  • PADEP notifies the applicant of any technical deficiencies within 40 days of the application,
  • The applicant responds to all technical deficiencies within 50 days of the application submission,
  • PADEP may extend the permit review time period with prior agreement from the applicant.

The NPDES timelines above apply to the following general permit renewals: discharges of storm water associated with industrial activity (PAG-03), discharges of small-flow treatment facilities (PAG-04), discharges from petroleum product contaminated groundwater remediation systems (PAG-05), and wet weather overflow discharges from combined sewer systems (PAG-06).

The SPEED program and its recent revisions are designed to enable applicants to plan equipment installation, delivery, and project milestones more effectively while minimizing delays caused by environmental regulatory decisions. After the designated time frame passes, applicants no longer need to wait for a regulator’s decision. These reforms give applicants greater control and provide the opportunity to reduce regulators’ workload by implementing the qualified environmental professional system for the SPEED Program Permit Categories.

Trinity has extensive experience helping companies evaluate the appropriate environmental permitting path and requirements for projects in Pennsylvania. If you would like to discuss the impacts of Act No. 45 and how it may impact your facility, please contact either of Trinity’s Pennsylvania offices: Philadelphia at 610.280.3902 or Pittsburgh at 724.935.2611.