Regulatory Updates from EFO Conference Air Quality Panel 2025

Environmental Consulting

10/23/2025

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Trinity marked its 20^th attendance at the Environmental Federation of Oklahoma’s (EFO) 34^th Annual Meeting and Trade Show on October 13 – 15, 2025. 340 industry professionals, regulators, and consultants attended this year’s conference, which focuses on the latest technologies and developments in the environmental, safety, and natural and cultural resources communities. This year’s theme, Dazed and Confused, was fitting for the quickly evolving 2025 regulatory landscape! The Air Quality Panel was held on the 15^th with presentations from the Oklahoma Department of Environmental Quality (DEQ), Trinity Consultants, and various other panelists.

Lee Warden, Permitting and Engineering Group Manager at DEQ, provided status updates on various projects within the air program. The Air Quality Division is taking volunteers for participation in the pilot expedited permitting program. This program will focus on high-priority applications such as Prevention of Significant Deterioration (PSD) and other major source construction permits, Applicability Determinations, and tier determinations for Title V permit minor modifications. A pre-application meeting will be required between the permittee and DEQ, and regular meetings will be scheduled to maintain progress. Standard rates for expedited permitting during the pilot program are given in the table below. Reach out to the Air Quality Division if you are interested in participating in the pilot program.

Permit Type	Application Fee	Expedited Surcharge	Total Fees
PSD Construction (greenfield)	$7,500	$15,000	$22,500
PSD Construction (existing)	$5,000	$15,000	$20,000
Tier II Construction (greenfield)	$7,500	$12,000	$19,500
Tier II Construction (existing)	$5,000	$12,000	$17,000
Applicability Determination	$500	$5,000	$5,500
Tier Determination for Minor Mod	$5,000	$5,000	$10,000

Additionally, the General Permit for Nonmetallic Minerals Processing Facilities (GP-NMPF) and the General Permit for Oil & Gas Facilities (GP-OGF) will be updated in the coming months. The revised GP-NMPF has been drafted and is being reviewed by industry groups prior to public review. The revised GP-OGF is currently being updated following substantial public comments on Revision 3 earlier this year. Expected notable updates include a revision of the engine testing policy to include large uncontrolled lean-burn engines that have historically been exempt as well as language addressing the delays of NSPS OOOOb implementation. The revised document is expected to be sent to industry groups by the end of 2025 with public review starting in early 2026. You can view all permits available for public review and submit comments on DEQ’s website.

Jeremy Jewell, Director of Quality at Trinity Consultants, outlined the major shift in EPA policy regarding the Regional Haze Program. While the program has the greatest potential to impact air regulations in all sectors across the country, Trump’s EPA is focused on restructuring the program to reduce energy costs for Americans. Much of this restructuring involves the realignment of existing and proposed State Implementation Plans (SIPs) to clarify that controls are only “reasonable” if they are necessary to ensure conformance with the rule’s haze index glidepath, an approach that previous administrations did not take. Oklahoma’s SIP is expected to be approved following the end of the current government shutdown.

One panelist summarized regulatory changes and associated impacts under the Trump administration. Topics included the proposed repeal of the Greenhouse Gas Reporting Program (GHGRP), NSPS OOOOb/c compliance deadline extensions, GHG emissions standards for fossil fuel-fired power plants, and the “Reactivation Policy” for NSR-affected idle equipment. Additionally, the Title V Affirmative Defense argument has been re-allowed for consideration to avoid civil penalties due to excess emissions events as determined by SSM Litigation Group v. EPA (2025). EPA is expected to prioritize clearing SIP backlog and revising the official interpretation of “begin actual construction” for NSR regulations.

Another panelist gave an overview of the differences between mandatory GHG reporting and comprehensive sustainability programs. Despite the GHGRP facing rescindment, they emphasized the benefits of maintaining a robust sustainability program to increase stakeholder engagement, potential for future investments, and operational efficiency on top of preparing for any future regulations should the GHGRP be reinstated or similar programs come online. For more information, read Trinity’s approach to sustainability in the midst of regulatory change and explore Trinity’s ESG and sustainability service offerings.

The conference closed following an illustration of the current administration’s commitment to cooperative federalism regarding SIP and Tribal Implementation Plan (TIP) resolutions in contrast to the previous administration. You can find information about approved SIPs and TIPs on EPA’s website.

Trinity has been a member of EFO for over 20 years to better serve Oklahoma businesses. The Environmental Federation of Oklahoma, Inc. is a 501(c)(6) environmental nonprofit organization providing Oklahoma companies with a voice in the formulation and implementation of state and federal environmental laws, regulations and policies. For more information about the presentations at the 2025 conference and future events, see EFO’s website.

Have questions on how these updates affect your business? Reach out to Trinity’s Tulsa Office to discuss strategies and next steps!

Trinity provides the environmental compliance expertise we need to keep our business flowing. The amount of collaboration between us has established a high level of trust. Trinity is always looking out for our best interest.

Brent Jensen/Frazier

Manufacturing Director of EHS and HR