As the saying goes, “the only constant in life is change!” Some have described the changes thus far on the federal level as fast and furious. Since January, EPA has undergone significant changes to its organization and its regulatory agenda, including regulatory freezes, staff reductions, budget cuts, prohibitions on staff communications with external stakeholders, and ambitious deregulatory agendas. 

With new leadership, EPA has announced its intentions to reduce the size and scope of the agency as well as the impact of its regulatory actions. Specifically, the comprehensive deregulatory agenda has been accompanied by proposed organizational changes to EPA that affect its regulatory priorities and how they impact the metalcasting industry. With air regulations as a primary concern for metalcasters, recent developments within EPA’s Air Office could be critical for the industry. 

Shifting Priorities

Under EPA’s Air Office reorganization, the Office of Air Quality Planning and Standards (OAQPS) and the Office of Atmospheric Protection (OAP) would be abolished. OAQPS, which is currently responsible for approximately 80% of EPA’s air regulations, is being split into two new offices: the Office of Clean Air Programs (OCAP) and the Office of State Air Partnerships (OSAP). OCAP will implement the regulatory work required under the Clean Air Act (e.g., National Ambient Air Quality Standards (NAAQS) and National Emission Standards for Hazardous Air Pollutants (NESHAP)), and OSAP will handle approvals of state implementation plans and address air permitting issues (to support cooperative federalism efforts). The Climate Change Division, the Climate Protection Partnership, and other climate change functions currently housed in OAP will be eliminated, signaling a shift in priorities away from climate change initiatives.

With the reorganization, EPA will reassign current staff to new positions within the agency, but staff reductions are expected as some OAQPS personnel were offered a second round of buyouts and are likely to leave the agency. Of course, uncertainty remains as the changes are now subject to a temporary restraining order (TRO) sought by environmental and labor groups, which has been appealed to the U.S. Court of Appeals.

Even supporters of the air office reorganization have expressed concerns about the timing for the changes and how they may impact EPA’s ambitious deregulatory agenda. Keep in mind that even with the deregulatory push, EPA is a regulatory agency that will continue to issue regulations, many of which are required by statute. Furthermore, deregulatory actions take time, require staff to implement the agenda, and need budget resources to support the effort. Deregulation does not necessarily come easily.

With reduced staff, ambitious timetables, and slashed budgets, EPA is now in the process of drafting proposed rules that will be subject to the notice-and-comment process of the Administrative Procedure Act (APA). This includes proposals to revise or rescind greenhouse gas (GHG) rules, air toxic standards, and NAAQS such as the PM2.5 rule, as well as reconsidering the GHG endangerment finding. Issuing proposed rules by the end of 2025 would be considered a significant accomplishment for EPA. It is an incredible workload in an incredibly short timeframe for a stressed agency workforce.

All of this demonstrates the Trump administration’s ongoing tension between meaningful regulatory reform and dramatically reducing the size and scope of the agency. EPA has moved from its regulatory review and evaluation stage to implementing its ambitious deregulatory plan. The success of the agency reorganization and the deregulatory agenda will play out over the next six months as EPA works diligently to issue new proposed rules to support its historic deregulatory agenda and meet its statutory requirements.

Throughout this process, the metalcasting industry will be presented with many opportunities and challenges to shape the regulatory landscape that impacts foundry operations. AFS and its environmental committees will continue to position the industry for sustainable regulatory compliance and economic growth. AFS Members interested in participating in the AFS Air Quality Committee; Water, Waste & By-Products Management Committee; or Safety & Health Committee are encouraged to email Kim Perna to be added to the committee roster: kperna@afsinc.org.