See the latest EHS federal and state regulatory updates due to COVID-19


With updates occurring every day regarding government responses to the COVID-19 impact on facility operations and EHS compliance, we are striving to bring you the most current information. We know that you depend on Trinity Consultants to be responsive to your business challenges and ongoing work. We will update this page as new information becomes available, so please check periodically for the latest guidance.

States with COVID-19 Specific Environmental Guidance
 

 

 

States
Federal UpdatesIllinoisMontanaRhode Island
AlabamaIndianaNebraskaSouth Carolina
AlaskaIowaNevadaSouth Dakota
ArizonaKansasNew HampshireTennessee
ArkansasKentuckyNew JerseyTexas
CaliforniaLouisianaNew MexicoUtah
ColoradoMaineNew YorkVermont
ConnecticutMarylandNorth CarolinaVirginia
DelawareMassachusettsNorth DakotaWashington
FloridaMichiganOhioWashington D.C.
GeorgiaMinnesotaOklahomaWest Virginia
HawaiiMississippiOregonWisconsin
IdahoMissouriPennsylvaniaWyoming
   Canada

Please consult your local Trinity Consultants office for more in-depth explanation, further support, and to answer any outstanding questions.

Federal Updates

EPA temporary policy in response to COVID-19 (does not apply to criminal violations or Superfund or RCRA corrective action enforcement matters):

  • Routine compliance monitoring and reporting: EPA will not expect to seek penalties for violations of routine compliance monitoring, integrity testing, sampling, laboratory analysis, training, and reporting or certification obligations in situations where the EPA agrees that COVID-19 was the cause of the noncompliance. The entity should document each situation and provide supporting documentation, upon request.
  • Trainings and certifications: If practical, sectors mandated to function with certified operators should maintain normal certification and training practices. If not practical due to the COVID-19 pandemic, it is more important to keep experienced, trained operators on the job, even if a training or certification is missed.
  • Signatures: If a submission to the EPA requires a “wet” signature of a responsible official, the EPA will accept a digital or other electronic signature. For enforcement purposes, the EPA also will accept emailed submissions even if a paper original is required.
  • Facility operations: All regulated entities should continue to manage and operate their facilities in a manner that is safe and protects the public and the environment. If a facility is a generator of hazardous waste and, due to the COVID-19 pandemic, is unable to transfer the waste off-site within the time periods required to maintain its generator status, the facility should continue to properly label and store such waste. EPA will treat such entities to be hazardous waste generators, and not treatment, storage and disposal facilities. The EPA will treat Very Small Quantity Generators and Small Quantity Generators as retaining that status, even if the amount of hazardous waste stored on site exceeds a regulatory volume threshold.
  • Reporting: Facilities should contact the appropriate implementing authority (EPA region, authorized state, or tribe) as quickly as possible if facility operations impacted by the COVID-19 pandemic may create an acute risk or an imminent threat to human health or the environment, or result in exceedances of enforceable limitations on emissions to air or discharges to water, or land.
    • The e-GGRT system will remain open for Annual GHG reporting submissions past the March 31 deadline.
    • No provisions for electronic submission of the 2019 Annual Compliance Certification (ACC). If possible, mail a hard copy and make a note of mail drop date. If unable to get to mailbox, mail the hard copy when you can and include a cover letter with explanation as to why the documents are late.
    • No changes to the TRI reporting deadline.
    • The TSCA CDR reporting window has been extended until Nov. 30
  • EPA Temporary Advisory for National Pollutant Discharge Elimination System (NPDES) Reporting in Response to COVID-19 Pandemic applies to NPDES reporting. NetDMR reports are still required even if incomplete data is available. Using the COVID-19 code option indicates the permittee believes the Temporary Policy applies to their routine monitoring or sampling noncompliance. The ICIS-NPDES data system will not automatically identify a DMR non-receipt violation if the COVID-19 code is used.

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    Alabama

    • The Alabama Department of Environmental Management (ADEM) staff is working remotely 4 days each week and are coming into the office one day each week (on a rotation). They are still available via phone and email.
    • ADEM hopes facilities will be able to complete stack tests in a timely fashion. However, during this time, there will likely not be any enforcement actions due to late stack tests. Deviations are expected to be listed in standard reports (SMR, ACCs, etc).
    • Method 9 observers who couldn't re-certify due to the cancelled smoke school training may continue to conduct Method 9 observations until they are able to re-certify. Include situation as a write-up in the standard compliance reports.
    • ADEM expects reporting and renewal application deadlines to be maintained. A facility may request an extension prior to the due date if needed.
    • Facility inspections will be reduced over the coming weeks. Field office personnel are observing facilities from public access points during this time. They will only enter if a problem is suspected.
    • ADEM staff are still working through permit applications and writing permits as needed. However, your facility should plan for the slower processing speeds, and should submit any SIP applications as early as possible to ensure that construction timelines are maintained.
    • If you have more questions or would like our support, please contact the Alabama Trinity Consultants office.
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    Alaska

    • The Alaska Department of Environmental Conservation (DEC) asks that facilities continue to seek compliance with all permit conditions.
    • Until July 1, 2020, it is acceptable to continue performing tasks like monitoring even in the event of a certification lapse.
    • DEC doesn't have authority to delay stack testing requirements. Approval from EPA may be required.
    • If you have more questions or would like our support, please contact the Alaska Trinity Consultants office.
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    Arizona

    Arizona Department of Environmental Quality (ADEQ)

    • ADEQ is still accepting hard-copy applications.
    • At this time, ADEQ does not anticipate permit issuance timelines to be impacted significantly.
    • Any leniency offered by ADEQ would have to be determined on a case-by-case basis depending on the situation in which a compliance requirement cannot be met. At this time, the regulated community is expected to continue compliance with all applicable requirements.
    • ADEQ will accept compliance monitoring and reporting submissions via email if a facility is unable to provide an original. ADEQ will accept electronic and scanned signatures for submitted documents.
    • ADEQ will implement Executive Order 2020-17, which provides 6 months of deferment for required certification renewals, training, exams, and professional development hours (PDHs).
    • ADEQ will work with facilities to amend agreement schedules when appropriate.
    • Documenting will occur in the inspection report, by facility self-reporting, and/or in the notice of opportunity to correct.
    • Notices of violation will be issued with leadership approval for compliance issues that create impacts or imminent threats to human health or the environment. Formal enforcement and penalties will be reserved for the most severe non-compliance.
  • Maricopa County Air Quality Department (MCAQD)

    • MCAQD will continue to accept hard-copy applications; appointments are required at both intake locations.
    • MCAQD does not anticipate any impact to timelines. Currently, all permitting staff is either telecommuting or in the office. Therefore, communications could delay because of remotely work.
    • MCAQD expects all sources to continue to comply with the terms of their permits. Inspections will be conducted as usual.
  • Pima County Department of Environmental Quality (PDEQ)

    • PDEQ permitting procedures are not expected to be impacted, and timelines are not expected to be delayed.
    • Their staff anticipates being able to address questions and concerns as normal.
    • PDEQ will apply discretion regarding any leniency in compliance-related requirements.
  • Pinal County Air Quality Control Division (PCAQCD)

    • PCAQCD only accepts hard-copy applications as an official wet signature is required to process applications.
    • Permit issuance timeframes may be impacted slightly but not significantly given the staff's ability to work from home.
    • Leniency in compliance related requirements will be on a case-by-case basis from PCAQCD. A detailed description on why the facility cannot comply with the requirements would be required. Some additional requirements could be proposed in lieu of the ones that cannot be complied with after thorough review.
  • If you have more questions or would like our support, please contact the Arizona Trinity Consultants office.

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    Arkansas

    • Enforcement Discretion Guidance Issued. Leniency will be determined on a case-by-case basis. All regulatory deadlines are expected to be met. Regulated entities should email COVID19EE@adeq.state.ar.us with specific information related to enforcement discretion requests.
    • If you have more questions or would like our support, please contact the Arkansas Trinity Consultants office.
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    California

    California Air Resources Board (CARB)
    • All regulation deadlines still in effect.
    • For California GHG Mandatory Reporting Program, CARB is currently encouraging reporters and verifiers to postpone required site visits (not to exceed the regulatory deadline of August 10, 2020) as needed to comply with state and local shelter in place ordinances and to ensure the safety of site staff and verifiers.
      • Approaching close to the August 10 deadline, if there are still travel restrictions or any other specific concerns or limitations that might affect the ability to complete the site visit and meet regulatory deadlines, reach out to CARB at ghgverify@arb.ca.gov.
    • For California Low Carbon Fuel Standard (LCFS) Program, CARB is currently working case by case to determine how to handle individual company policies and directives as they relate to the regulatory requirements for site visits. CARB recommends you reach out to LCFSVerify@arb.ca.gov.
  • Bay Area Air Quality Management District (BAAQMD)

    • Essential functions of the Air District, including air quality monitoring and forecasting, the enforcement of air quality regulations, and response to air quality complaints, will continue.
    • All other Air District functions are being handled remotely until further notice.
    • Resolution of air quality complaints will continue to occur 24/7 by calling (800) 334-6367.
    • Visit the  BAAQMD website for more details.
  • Sacramento Metropolitan Air Quality Management District (SMAQMD)

    • Sac Metro Air District continues to provide essential services, including permit processing, responding to public complaints, the asbestos program, and air quality monitoring.
    • The District is open for business, but the office will be closed to the public until further notice.
    • To contact The District, call or email during business hours.
    • Visit the District's website for more details.
  • Department of Toxic Substance Control (DTSC)

    • DTSC will continue to provide essential services during the COVID-19 outbreak. 
  • California Unified Program Agency (CUPA)

    • The Unified Program state agencies will provide guidance for both regulated businesses and CUPAs, and post it on the CalEPA and other state agencies websites, beginning next week.
    • State agencies are closely collaborating to ensure the guidance is provided as soon as possible. 
    • CalEPA has postponed all current CUPA performance evaluations. 
    • CUPA managers should maintain regular communications with CalEPA regarding the impacts on their local Unified Program implementation.
    • Please refer to the CUPA website for more information.
  • State Water Resources Control Board (SWRCB)

    • Non-essential file reviews are postponed and essential file reviews are by appointment only.
    • Some Water Board meetings have been cancelled, while some are just postponed.
    • The Water Boards are continuing day-to-day work protecting public health, safety, and the environment.
    • They are conducting Board Meetings solely via remote presence by video and teleconference. Members of the public will be able to listen to and watch the meeting and comment if desired.
    • Please follow the SWRCB website or subscribe to an applicable Lyris list for your area of interest for further updates.
  • South Coast Air Quality Management District (SCAQMD)
    • Annual Emissions report deadline is extended to April 17, 2020 at 5pm.
    • Permitting process expedited for businesses helping with the COVID-19 response. Email PermitServicesOnline@aqmd.gov for assistance in filing applications for new/modified equipment. Include “COVID-19 Permit” in the subject line.
    • A regulatory advisory document was released and is retroactive to March 12 and extends until May 11. In summary:
      • If deadline is within this period, facility can request extension of 60 days.
      • If deadline has already passed (and was after March 12), facility needs to request extension by Wednesday, April 22. Extension will be for 60 days from previous deadline.
      • Applies to deadlines, including:
        • RATA, RAA, CGA, tune-ups, etc.
        • Quarterly and annual reports for various rules, including: Rule 1118, 1143, 1150.1, 1173, 1176.
        • RECLAIM QCER (paper and electronic reports)
      • Does not apply to:
        • Title V deviation forms (500-N)
        • Annual emissions report (AER), due April 17
      • ATIR/HRA/etc. will be handled on a case-by-case basis.
  • San Joaquin Valley Air Pollution Control District (SVJAPCD)

  • If you have more questions or would like our support, please contact the California Trinity Consultants office.

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    Colorado

  • NSR permit applications and fees are to be mailed, not submitted online.
  • Late submittals of compliance reports will be considered on a case-by-case basis.
  • Submission of Discharge Monitoring Reports (DMRs) is still required. Include a cover letter that outlines the circumstances that are resulting in requirements not being met.
    • If you can't collect or analyze samples: Complete report to the best of your ability and write “Pandemic Incident” on paper DMRs or enter a no data indicator (NODI) code if using NetDMR to submit report.
    • If you can collect or analyze some, but not all, samples: Any collected data should be reported on the DMR. Note the actual frequency that the discharge was monitored.
    • If constricted to using non-EPA approved methods of sampling and analysis: Report all relevant data on the DMR and include a comment that identifies specific methodology used.
  • As of April 30, 2020, the Division is temporarily allowing electronic submission of APENs and construction permit applications via email. However, submission of applications on hard copy forms is still the Division's preference. This email address will be deactivated at some point when the COVID-19 restrictions are relaxed, and applicants will be required to resume the traditional process requiring a wet signature on hard copy documents. The Division may require a wet signature at a later date; you will be contacted if this becomes necessary. The applicant must pre-pay the appropriate APEN/application fee via credit card prior to sending the email containing the APEN(S) and permit application. Your email should contain the following documents as attachments:
    1. Make appropriate payment for the appropriate number of APENs and any associated general permit registration fees via credit card. Call 303-692-3158 to make payment.
    2. The APEN(s) you are submitting;
    3. A copy of your Credit Card Transaction Receipt you received after you contacted the Division by phone and had the Division process your credit card payment. Applications will be rejected if they do not include this receipt;
    4. A cover letter explaining your application (not required, but recommended);
    5. All required forms and information needed for your complete application (appropriate application forms, emission calculations, regulatory review, etc.). See Application Completeness Checklists;
    6. Any additional information to support your application;
    7. Email these documents to the following address: cdphe_apcd_ssp_application@state.co.us
  • If you have more questions or would like our support, please contact the Colorado Trinity Consultants office.
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    Connecticut

    • Late or incomplete compliance documentation will be assessed on a case-by-case basis for the 9.0 seasonal Reid Vapor Pressure (RVP) state requirement that begins on May 1, 2020.
    • All documents should be submitted electronically.
    • 1st Quarter CEM reports submission deadline has been extended to June 1, 2020. No other reporting deadlines have been extended at this time.
    • Title V and general permit to limit potential to emit (GPLPE) compliance reports should be submitted using the EMIT online reporting tool.
    • All other compliance reports may be submitted to deep.cacu@ct.gov.
    • If you have more questions or would like our support, please contact the Connecticut Trinity Consultants office.
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    Delaware

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    Florida

    • Emissions Inventory reporting deadline extended to May 1, 2020.
    • Title V fee payment deadline extended to May 1, 2020.
    • If you have more questions or would like our support, please contact the Florida Trinity Consultants office.
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    Georgia

    • Environmental Protection Division (EPD) personnel are working remotely, however at least one staff member will be at the office to accept packages and mail.
    • No separate enforcement discretion policy will be issued. EPD will apply the discretion framework described in the EPA Memo to state-only programs as well as federal programs.
    • All regulated entities should continue to meet all federal and state environmental requirements.
    • EPD reserves the right to set a different termination date for the policies expressed in the EPA Memo for state enforcement.
    • If you have more questions or would like our support, please contact the Georgia Trinity Consultants office.
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    Hawaii

    • Clean Air Branch (CAB) staff are currently teleworking.
    • In-person meetings and walk-in service have been suspended. Please call (808) 586-4200 or email cab.general@doh.hawaii.gov for assistance.
    • Documents can be mailed in or left in the drop box setup in the front of the CAB office.
    • If you have more questions or would like our support, please contact the Hawaii Trinity Consultants office.
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    Idaho

    • If unable to renew certifications, the permittee should continue to conduct monitoring with expired certifications/calibrations. Document expiration during the monitoring and obtain certification at next possible date.
    • Please refer to The Idaho Department of Environmental Quality (DEQ) response to the COVID-19 pandemic for more information.
    • If you have more questions or would like our support, please contact the Idaho Trinity Consultants office.
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    Illinois

    • No official extension on reporting deadlines have been granted. Illinois EPA will use “enforcement discretion” on late reports that include a cover letter with a valid explanation detailing COVID-19 as the hinderance.
    • The Illinois EPA mail room is still open to accept hard copy submittals. No general email addresses have been created (to date) for submitting permit applications, Annual Emission Reports, or Annual Compliance Certifications.
    • Limited agency staff are still going to the office and other staff are working from home. Permit applications are being received, reviewed, and issued.
    • If you have more questions or would like our support, please contact the Illinois Trinity Consultants office.
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    Indiana

    • Submit a completed, signed hard copy and scanned copy of your air pollution permit. Email scanned copy to airpermitapps@idem.in.gov.
    • State issued licenses are being automatically extended.
    • Requirements of regulated entities to follow the terms in permits, to submit reports, conduct and report on sampling, and other activities, have not been suspended. Additional guidance can be found here.
    • Air Compliance reports should be emailed to AirCompl@idem.IN.gov.
    • Annual Compliance Certifications should be emailed to mailto:AnnualComplCert@idem.IN.gov.
    • If you have more questions or would like our support, please contact the Indiana Trinity Consultants office.
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    Iowa

    • Iowa Department of Natural Resources (IDNR) issued a compliance and enforcement protocol in effect through April 30, 2020.
    • Method 9 Certifications that are valid as of March 1, 2020, will be considered valid for up to six months after April 30.
    • 2019 minor source emission inventories (MSEI) are being accepted through June 15, 2020.
    • If you have more questions or would like our support, please contact the Iowa Trinity Consultants office.
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    Kansas

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    Kentucky

    Kentucky Department of Environmental Protection (DEP)

    • A grace period is granted for Method 9 certifications until July 1, 2020, relevant for certifications that expire on or after March 1, 2020.
    • A grace period is granted until July 1, 2020 for required proof of training for accreditation renewals on licenses that expired after January 1, 2020.
    • Drinking water renewal late fees waived through August 31, 2020 on renewals that are due on June 30, 2020.
  • Louisville Metro Air Pollution Control District (LMAPCD) - For Sources in Jefferson County Only

    • Emissions Inventory Reporting deadline is extended to May 15, 2020.
    • Annual Compliance Certification submittal deadline is extended to May 15, 2020.
  • If you have more questions or would like our support, please contact the Kentucky Trinity Consultants office.

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    Louisiana

    • Refineries may continue to sell gasoline with a Reid Vapor Pressure (RVP) of 13.5 until May 1, 2020.
    • Annual Emission Inventory deadline is extended to May 30, 2020.
    • Reporting deadlines are extended 30 days, if the facility doesn't have appropriate personnel.
    • No extension is granted for emergency reporting for Title IV or Title V of the Clean Air Act, or under the PSD program.
    • Semi-annual monitoring and deviation reports deadline is extended to May 1, 2020.
    • Annual compliance certifications deadlines extended to May 1, 2020.
    • If you have more questions or would like our support, please contact the Louisiana Trinity Consultants office.
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    Maine

    • The Maine Department of Environmental Protection (DEP) offices located in Augusta, Presque Isle, Bangor and Portland are closed to the public until further notice.
    • DEP reception areas in each location will remain open for members of the public who wish to drop off paper documents and applications. Staff is also available via phone and email.
    • No extensions have been granted for any reporting or compliance obligations
    • Questions or requests regarding noncompliance should be directed to Eric Kennedy at eric.kennedy@maine.gov or (207) 287-5412
    • DEP will not enforce any violations of the federal summer gasoline and RFG requirements from May 1, 2020 through May 20, 2020. Reach out to David Madore at david.madore@maine.gov or (207) 287-7674.
    • If you have more questions or would like our support, please contact the Maine Trinity Consultants office.
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    Maryland

    • Maryland Department of the Environment (MDE) personnel are working remotely.
    • Air permit applications can now be submitted electronically.
    • To request extensions on emissions and compliance reports, email your MDE air quality inspector. Flexibility will be granted on a case-by-case basis.
    • Emissions and compliance reports can be submitted via hard copy or emailed to your MDE air quality inspector and copied to Daniel Davis at Daniel.Davis@maryland.gov
    • If you have more questions or would like our support, please contact the Maryland Trinity Consultants office.
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    Massachusetts

    • 2019 Source Registration deadline is extended by 60 days.
    • Greenhouse Gas Reporting deadline is extended by 60 days.
    • The Massachusetts Department of Environmental Protection (MassDEP) has suspended state permitting deadlines and extended validity of state permits.
    • If you have more questions or would like our support, please contact the Massachusetts Trinity Consultants office.
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    Michigan

    • Regulated entities are expected to maintain compliance with environmental regulations and permit.
    • To request regulatory flexibility for unavoidable noncompliance directly due to the COVID-19 emergency, email EGLE-EnforcementDiscretion@mi.gov. In response to those requests, EGLE may extend reporting deadlines, waive late fees, or otherwise exercise enforcement discretion.
    • If you have more questions or would like our support, please contact the Michigan Trinity Consultants office.
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    Minnesota

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    Mississippi

    • April smoke school cancelled, and next smoke school is scheduled for October 2020.
    • Report permit/regulatory requirement deviations to Mississippi Department of Environmental Quality (MDEQ) contacts.
    • Permit renewal deadlines extended by 90 days from the date that MDEQ withdraws the guidance.
    • NOV and Agreed Order compliance dates can be extended.
    • MDEQ will extend the current requirements for certifications and CEUs as applicable.
    • MDEQ has provided links for electronic submittals for permits and renewals:
      • OPC Air and Water Pollution Control permit applications should be submitted here.
      • Notices of Intent (NOIs) for coverage under Air and/or Water General Permits and associated supporting documents should be submitted here.
      • Solid Waste, Waste Tire, Beneficial Use Determination, Underground Injection Control and Hazardous Waste permit applications and associated supporting documents should be submitted to the following email address: WasteSubmittals@mdeq.ms.gov.
    • If you have more questions or would like our support, please contact the Mississippi Trinity Consultants office.
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    Missouri

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    Montana

    • The Montana Department of Environmental Quality (DEQ) staff are working remotely.
    • DEQ prefers that all applications be submitted electronically via email or electronic file transfer.
    • DEQ is trying to keep all application timelines the same.
    • DEQ has issued compliance and enforcement discretion guidance. DEQ will consider enforcement discretion on a case-by-case basis.
    • If you have more questions or would like our support, please contact the Montana Trinity Consultants office.
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    Nebraska

    • No extensions have granted made for regulatory deadlines. Enforcement discretion will be used if a facility is able to provide a valid reason for not meeting the deadline.
    • In-person meetings are cancelled. Pre-application meetings being held via conference call.
    • The NDEE, City of Omaha and City of Lincoln have developed COVID-19 information webpages at the links below:
    • If you have more questions or would like our support, please contact the Nebraska Trinity Consultants office.
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    Nevada

    Clark County Department of Air Quality (DAQ)

    • DAQ continues to provide essential services, including permit processing.
    • DAQ is open for business, but the office will be closed to the public until further notice.
    • Visit DAQ's website for details on DAQ's interim operations.
  • Nevada Division of Environmental Protection (NDEP)

    • Emissions Inventory reporting deadline extended to May 1, 2020.
    • NDEP continues to provide essential services, including permit processing.
    • NDEP is open for business, but the office will be closed to the public until further notice.
    • Visit NDEP's website for more information.
    • NDEP has issued the following guidance regarding Method 9 (visible emission) certifications: “If you have held a valid [Method 9] certification within the last 6-months and otherwise would have completed the re-certification, but could not because of smoke school closures, you can and should continue to perform Method 9's as required by your permit. But, we ask that you note on the form when your certification expired and that your certification has expired due to COVID-19.”
  • Washoe County Air Quality Management District (AQMD)

    • WCAQMD is open for business, but the office is accessible to the public by appointment only.
    • Businesses impacted by COVID-19 can apply to defer payment of their annual air permit renewal fee. More information and the Fee Deferral Application can be found here.
  • If you have more questions or would like our support, please contact the Nevada Trinity Consultants office.

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    New Hampshire

    • Any documents needing to be submitted can be emailed or mailed to the New Hampshire Department of Environmental Services (NHDES) office. You may also use the drop box located at the offices during normal business hours.
    • No extension has been granted for the annual air emmisions inventory reporting deadline.
    • If you have more questions or would like our support, please contact the New Hampshire Trinity Consultants office.
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    New Jersey

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    New Mexico

    • Electronic pre-submittals of permitting actions are now available. There is a very specific process to submit successfully. Please reach out to Trinity for dedicated help. Hard copy applications are also being accepted. Electronic payments are not being accepted - paper checks are required.
    • New Mexico cannot perform remote notarizations. Notarization obtained through an online service is acceptable at this time.
    • Permitting actions that are submitted electronically without being notarized will cause the permit filing fee to be non-refundable. If the action is not properly notarized, it will be denied.
    • If you have more questions or would like our support, please contact the New Mexico Trinity Consultants office.
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    New York

    • The Annual Emission Statement (AES) deadline may be extended on a case-by-case basis. Submit extension requests to Air.Inventory@dec.ny.gov.
    • The NY State Department of Environmental Conservation (NYSDEC) appears to be handling requests and enforcement discretion questions on a case-by-case basis.
    • NYSDEC has issued a Waste and Recyclables Essential Services Statement
    • Public hearing meetings regarding proposed regulations, in-person meetings, and other similar gatherings have been postponed or cancelled.
    • If you have more questions or would like our support, please contact the New York Trinity Consultants office.
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    North Carolina

    • DEQ office locations are limiting public access to appointments only. Requests are preferred to be handled via phone or email.
    • Annual emission inventory reporting deadline remains on June 30, 2020.
    • The North Carolina Department of Environment & Natural Resources (NCDENR) will consider regulation flexibility requests and work with facilities that supply proper documentation.
    • If you have more questions or would like our support, please contact the North Carolina Trinity Consultants office.
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    North Dakota

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    Ohio

    • No automatic extensions will be granted on regulatory deadlines.
    • To submit waiver requests related to enforcement discretion, submit a web form here.
    • Hard copy applications or compliance documents should be submitted via email to the agency representative for that county and the associated manager.
    • Required stack testing may proceed without agency witnesses.
    • If you have more questions or would like our support, please contact the Ohio Trinity Consultants office.
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    Oklahoma

    • The Oklahoma Department of Environmental Quality (DEQ) is receiving and distributing mail. Documents will be reviewed and acted on as normal but response times may be slower.
    • All permit conditions and compliance schedules should continue to be met. Communicate non-compliance issues with DEQ staff through email or program-specific reporting telephone numbers.
    • Email permit applications, annual reporting, semiannual reporting, and questions to the appropriate Air Quality Department contacts. Fee payments can be completed via mail, phone, or fax using check, money order, or credit card.
    • Lead Based Paint license and certification expiration date of March 31, 2020 is extended until further notice.
    • Renovation, Repair & Painting (RRP) certification expiration date of March 17, 2020 or later is extended until further notice.
    • Water and wastewater operator certification license renewal, training, and fees deadline of July 1, 2020 is extended through September 30, 2020.
    • State laboratory remains open but a call should be made before sending samples.
    • If you have more questions or would like our support, please contact the Oklahoma Trinity Consultants office.
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    Oregon

    • No extensions have been granted for regulation deadlines.
    • The Oregon Department of Environmental Quality (DEQ) will continue to exercise reasonable enforcement discretion within its authority when deciding whether to pursue potential violations caused by pandemic-related disruptions.
    • Facility inspections delayed until April 14, 2020 on facilities that don't present an immediate risk to public health or the environment.
    • If you have more questions or would like our support, please contact the Oregon Trinity Consultants office.
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    Pennsylvania

    • The Pennsylvania Department of Environmental Protection (DEP) staff are currently working remotely and prioritizing field inspections and complaints that are critical to public health and safety.
    • To request temporary suspension of regulatory requirements and/or permit conditions, fill out this form. Facilities must list each regulatory obligation they are seeking temporary suspension of along with the reasoning for the request. They must also identify any risks to the public health and environment, if temporary suspension is granted by the DEP. Submit the completed form to RA-EPCOVID19SuspReq@pa.gov.
    • DEP will continue to receive, and process permit applications, but final decisions may be delayed.
    • DEP regional offices have requested email notifications regarding submittals of applications as staff will not be present for delivery signatures.
    • Storage Tank inspection, upgrade, repair and testing activities performed by DEP-certified tank handling companies may continue.
    • Third-party inspection activities required by storage tank regulations to identify storage tank system and component failures may continue.
    • Installation of storage tank systems at life-sustaining businesses by DEP-certified tank handling companies may continue.
    • Removal of storage tank systems should be limited in scope where removal is necessary for subsequent tank installation or to protect human health and the environment.
    • In-person work at a business site is only to be performed on the most limited basis possible to deliver the services or goods.
    • All of 25 Pa. Code, Chapter 245 requirements remain in effect.
    • If you have more questions or would like our support, please contact the Pennsylvania Trinity Consultants office.
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    Rhode Island

    • Annual Emission Inventory deadline is extended to June 30, 2020.
    • The Rhode Island Department of Environmental Management (RIDEM) will not enforce any violations of the federal summer gasoline and RFG requirements from May 1, 2020 through May 20, 2020.
    • If you have more questions or would like our support, please contact the Rhode Island Trinity Consultants office.
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    South Carolina

    • Regulatory compliance assistance requests should be directed to environmentalcompliance@dhec.sc.gov.
    • Emission inventories due date extended to April 30, 2020.
    • On-site implementation logs due on or before April 30, 2020.
    • Asbestos personnel license extensions provided for licenses that expire before April 29, 2020.
    • Wastewater permit required testing and reports can be extended to April 30, 2020.
    • If you have more questions or would like our support, please contact the South Carolina Trinity Consultants office.
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    South Dakota

    • Facilities must contact the South Dakota Department of Environment & Natural Resources (DENR) for case-by-case approval to deviate from applicable permit conditions.
    • Facilities should still submit wastewater Discharge Monitoring Reports (DMRs). If you are unable to collect or analyze samples, complete the following steps on your DMR:
      • For paper submissions, complete DMR to the best of your ability and write “COVID-19” as a notation.
      • For electronic submissions via NetDMR, enter “Z” as the no data indicator (NODI) code and attach or mail a cover letter explaining why you couldn't collect required samples. Call 605-773-3351 to report the situation to DENR as soon as possible.
    • If you have more questions or would like our support, please contact the South Dakota Trinity Consultants office.
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    Tennessee

    • Large number of staff working from home. Permit applications are being received, reviewed, and issued.
    • The Tennessee Department of Environment and Conservation (TDEC) is evaluating the need for and ability to exercise discretion regarding expiration of any license, permit, or certification that would expire prior to April 30, 2020.
    • Environmental divisions may extend deadlines for Public Comment periods set to expire prior to April 30, 2020.
    • Routine fieldwork, on-site compliance inspections, and monitoring visits may be deferred.
    • Non-emergency compliance investigations have been delayed until they can be safely performed.
    • If you have more questions or would like our support, please contact the Tennessee Trinity Consultants office.
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    Texas

    • Occupational license expiration dates are extended 30 days for March and April 2020 expirations.
    • Paper exams are cancelled through May 2020.
    • MS4 annual reports and multi-sector general permit (MSGP) Discharge Monitoring Reports submitted on or before April 30, 2020 are considered on time.
    • Computer-based testing is not currently available. Validity of new applications are extended until testing is available.
    • Point source emissions inventory reporting (EIs) deadline is extended until April 30, 2020.
    • The 2019 annual compliance reports received on or before April 30 are considered on time.
    • Submit Discharge Monitoring Reports (DMRs) online using EPA's NetDMR. The deadline is extended to April 30, 2020.
    • Submit water rights applications online or email directly to Amy Settemeyer at amy.settemeyer@tceq.texas.gov. If file is too large to email, use TCEQ FTPS.
    • To arrange a water rights pre-application meeting, email Amy Settemeyer at amy.settemeyer@tceq.texas.gov and a conference call meeting will be arranged.
    • Submit change of ownership requests online or email Joe Nicosia directly at joe.nicosia@tceq.texas.gov. If file is too large to email, use TCEQ FTPS.
    • Mass emissions cap and trade (MECT) and highly reactive volatile organic compound emissions cap and trade (HECT) reporting deadline is extended to April 30, 2020.
    • If you encounter unavoidable non-compliance, email BOTH OCE@tceq.texas.gov and Ramiro Garcia at Ramiro.Garcia@tceq.texas.gov with specific information related to enforcement discretion requests.
    • If you have more questions or would like our support, please contact the Texas Trinity Consultants office.
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    Utah

    • The Utah Department of Environmental Quality (UDEQ) offices are closed to the public until further notice.
    • UDEQ is requesting that all applications, letters, and general correspondence be electronic. Each division has set up electronic submission portals on their respective webpages.
    • Site-specific extensions and exemptions for compliance issues such as stack testing will be determined on a cases-by-case basis. Please email Jay Morris at jpmorris@utah.gov for such air related requests.
    • UDEQ will exercise enforcement discretion for non-compliance on a case-by-case basis. Facilities must document and demonstrate that the COVID-19 pandemic is the root cause of non-compliance and that every practical effort was made to avoid and minimize the non-compliance.
    • If you have more questions or would like our support, please contact the Utah Trinity Consultants office.
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    Vermont

    • Generic reports and applications may be submitted electronically here.
    • The Vermont Department of Environmental Conservation (VT DEC) staff is working from home, so please refrain from mailing in applications.
    • VT Annual Air Registration deadline remains due on May 15, 2020.
    • If you have more questions or would like our support, please contact the Vermont Trinity Consultants office.
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    Virginia

    • Non-compliance issues will be reviewed on a case-by-case basis. The Virginia Department of Environmental Quality (DEQ) will exercise reasonable enforcement discretion within its authority when deciding whether to pursue potential violations caused by pandemic-related disruptions.
    • If your facility is unable to comply, communicate regularly with the DEQ. Document the specific nature and dates of noncompliance, identify how COVID-19 was the cause, share decisions and actions taken, and return to compliance as soon as possible.
    • Limit the amount of DEQ field monitoring activity that includes air monitoring, surface water investigations, and groundwater monitoring investigation programs. All other field work remains suspended.
    • Facilities are expected to remain in compliance with their wastewater discharge permits. If they are unable to do so, they are required to contact DEQ immediately.
    • The vehicle emissions inspection program for Northern Virginia drivers remains operational. Please call 703-583-3900 for assistance and avoid in-person visits.
    • If you have more questions or would like our support, please contact the Virginia Trinity Consultants office.
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    Washington

    Puget Sound Clean Air Agency (PSCAA)

    • Hard copy permit applications accepted but electronic submittals are preferred.
  • Northwest Clean Air Agency (NWCAA)

    • Hard copy permit applications and email submissions being accepted.
    • No policies have been set to extend regulatory deadlines, and situations are being handled on a case-by-case basis.
  • Olympic Region Clean Air Agency (ORCAA)

    • Permit applications are being accepted via hard copy, email, and online.
  • Southwest Clean Air Agency (SWCAA)

    • Hard copy permit applications and email submissions being accepted.
    • If Method 9 certifications expire due to class cancellations or travel restrictions, readings and observations should continue to be conducted.
  • Yakima Regional Clean Air Agency (YRCAA)

    • Hard copy permit applications and email submissions being accepted.
  • Ecology Eastern Regional/Central Regional Office

    • Permit applications should be submitted in the same format that was previously set. If the application was previously submitted via hardcopy, then submit a hardcopy. If the application was previously emailed, then submit via email.
  • If you have more questions or would like our support, please contact the Washington Trinity Consultants office.

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    Washington D.C.

    • D.C. Department of Energy and Environment (DOEE) personnel are working remotely until further notice.
    • Air permit applications can be mailed to the DOEE office or emailed to Stephen Ours at Stephen.Ours@dc.gov. Electronic signatures will not be accepted. Applications must be signed and scanned.
    • If you have more questions or would like our support, please contact the Washington D.C. Trinity Consultants office.
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    West Virginia

    • All rules, regulations and permitting requirements under the jurisdiction of the West Virginia Department of Environmental Protection (WVDEP) remain in full effect.
    • WVDEP expects facilities to continue to be operated in a manner that fully protects human health and the environment.
    • Facilities that are unable to meet environmental compliance obligations due to COVID-19 should contact the WVDEP and follow the requirements outlined in the EPA memorandum.
    • If you have more questions or would like our support, please contact the West Virginia Trinity Consultants office.
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    Wisconsin

    • Wisconsin Department of Natural Resources (WDNR) COVID-19 Environmental Compliance Process
    • All entities should make every effort to comply with their environmental compliance obligations.
    • Spills or compliance problems that pose an imminent or actual threat to health or the environment should call (800) 943-0003 and select “1”. This number is monitored 24/7.
    • Email your main DNR contact for your facility for non-emergent compliance flexibility requests.
    • Most WDNR staff are teleworking and may have limited access to files and delayed online connectivity. WDNR staff will keep their voicemails and out-of-office messages up to date and will respond as they are able. WDNR asks that customers:
      • Email whenever possible to communicate with staff.
      • Set-up conference calls or Skype meetings in lieu of in-person meetings.
      • Request electronic public records online using our standard system, whenever possible.
    • State staff are not currently available to access physical files and no staff are available on-site to allow physical inspection of files by the public until the Governor's COVID-19 restrictions have been lifted.
    • Submit documents electronically, preferably via a download link (ftp servers, DNR system, etc.). If that option is not available to you, DNR staff can receive emails up to 20 MB.
    • Please refer to the presentation and notes from the latest WDNR Air Management Study Group meeting for more information on COVID-19 impacts to the air program.
    • If you have more questions or would like our support, please contact the Wisconsin Trinity Consultants office.
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    Wyoming

    While the Department of Environmental Quality (DEQ) and the Oil and Gas Conservation Commission remain open, efforts to minimize person-to-person contact are ongoing and many staff are working from remote locations. Anyone who must conduct business in person is asked to adhere to social distancing guidelines and keep all groups to less than 10. General information on COVID-19 in Wyoming is available at https://covid19.wyo.gov/.

    • Most activities are being transitioned to online as possible, with computer kiosks made available to the public at DEQ offices.
    • DEQ has released temporary guidance on enforcement and compliance assurance, available here.
    • Submissions (Reports, applications, notifications, etc.): Hard copies are still generally accepted in most cases - however, electronic submissions are encouraged when systems are available.
  • Water Quality: The Electronic Discharge Monitoring Report system has been in place for several years for submission of discharge data: http://deq.wyoming.gov/wqd/edmr/ Additionally, an electronic document submittal form has been set up for each Water Quality Division section (Groundwater, WYPDES, Water/Wastewater, and Watershed), or the General Water Quality Division form can be used if the section is unknown.

  • Air Quality: The Division's IMPACT system can be used for nearly all submissions, once individual submitters are properly registered in the system: http://deq.wyoming.gov/aqd/impact-system/resources/impact-portal/

    Land Quality: Electronic permitting and reporting can be conducted via MIDAS: http://deq.wyoming.gov/lqd/midas-e-permitting/

    Solid and Hazardous Waste: The website addresses to upload documents are:

  • Public comments on rulemakings can be done electronically via http://wq.wyomingdeq.commentinput.com/. Public comments on proposed permits must be submitted via hard copy or FAX.

    If you have more questions or would like our support, please contact the Wyoming Trinity Consultants office.

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Canada

  • The Environment and Climate Change Canada (ECCC) has decided to extend the deadline for the National Pollutant Release Inventory (NPRI) and Federal Greenhouse Gas Reporting Program (GHGRP) reporting for the 2019 calendar year to July 31, 2020.
  • If you have more questions or would like our support, please contact the Toronto Trinity Consultants office.

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