Contributed by Trey Hess P.E., Principal, PPM Consultants
I had the opportunity today to hear Kristy Eubanks, Deputy Regional Administrator for EPA Region 4, speak at last week’s 34th Annual Environmental Law and Regulation Conference in Orange Beach, Alabama. Her presentation covered a lot of ground: permitting reform, cooperative federalism, data centers, AI, energy reliability, water reuse, WOTUS, PFAS, coal combustion residuals, Title V permits, and emergency response.
That is a full plate.
But I left with one practical thought: no matter how much the federal policy direction changes, the work still comes down to the record. The permit record. The site record. The compliance record. The old tank file. The sampling data. The inspection history. The emails with the agency that nobody can find when they suddenly matter.
That may not sound exciting, but it is where projects succeed or get bogged down.
EPA Region 4 covers Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, and seven federally recognized tribes. For PPM’s clients across the Southeast, Region 4’s priorities are not far-off Washington policy. They show up in air permits, water certifications, brownfield projects, data center site selection, PFAS questions, stormwater plans, and facility inspections.
The Practical Message: Faster Permitting Still Requires Better Preparation
One of the strongest themes from Ms. Eubanks’ presentation was permitting reform.
She spoke about the need for clearer timelines, more predictable decisions, and better coordination among EPA, states, tribes, and local governments. She also described EPA’s current emphasis on cooperative federalism, which is a phrase we hear often but sometimes do not unpack enough.
In practice, it means the states are not just bystanders. In Region 4, state agencies like ADEM, MDEQ, FDEP, GA EPD, and others carry a large share of the day-to-day permitting and compliance work. EPA headquarters may write the national rules, but the regions and states are where those rules meet real facilities, real sites, and real deadlines.
That matters for business.
A project with a clean, organized application can benefit from a more efficient process. A project with inconsistent records, missing calculations, unclear site history, or unresolved compliance issues will still struggle, even in a reform-minded environment.
PPM recently covered this exact point in our article on EPA’s new Title V renewal guidance. Streamlining is helpful, but it is not a substitute for a clean permit record.
Title V, NSR, and the “Nothing Has Changed” Problem
EPA has issued recent guidance intended to streamline certain Clean Air Act Title V operating permit renewals and expedite EPA review of Title V permits. That is welcome news for facilities that have stable operations and well-maintained records.
But “nothing has changed” can be a dangerous phrase.
A facility may think nothing has changed because the main process line is still running. Meanwhile, a boiler was replaced, throughput changed, a control device was modified, a state rule was updated, or a construction permit condition was folded into the operating permit years ago and never revisited.
That is where Title V renewals can become harder than they need to be.
Before a facility leans on streamlining, it should take a hard look at:
- Emission unit inventories.
- NSR and PSD applicability history.
- Permit limits and monitoring requirements.
- Deviation reports and compliance certifications.
- Stack testing and control device records.
- Changes in production, materials, or operating hours.
- The old Statement of Basis and whether it still tells the right story.
The fastest permit is not always the shortest application. It is the application that gives the permit writer confidence.
PPM’s air permitting, compliance, and reporting team works with facilities on these issues every day, including Title V, NSR, emission calculations, reporting, agency coordination, and record reviews.
Data Centers Have Become Environmental Projects
Another issue that stood out was the connection between AI, data centers, electricity demand, and environmental permitting.
Ms. Eubanks put it plainly: AI needs data centers, data centers need power, and power brings air, water, infrastructure, and community questions with it.
That is the part some developers still underestimate.
A data center is not just a building with servers. Depending on the site and design, it can involve emergency generators, air permitting, electrical infrastructure, water supply, wastewater capacity, stormwater management, wetlands, noise, community concerns, and backup fuel storage.
EPA has now created a Clean Air Act Resources for Data Centers page to help developers, agencies, communities, and tribes find air-related resources in one place. That is a useful step, especially as these projects move into more communities across the Southeast.
PPM has also written about how brownfield sites may fit into this conversation in Reclaiming the Ground: Brownfield Sites and the Future of Data Centers.
My view is simple: some of the best sites for future infrastructure may be sites we have already used once. But those sites need honest environmental due diligence up front. Old industrial property can be a tremendous opportunity, but only if the environmental conditions, utilities, access, and reuse plan are understood before everyone falls in love with the project schedule.
Water Reuse Is Moving From “Nice Idea” to Business Strategy
Water reuse was another important part of the presentation.
In the Southeast, we sometimes talk about water as if it will always be available because we get plenty of rain. Anyone who has worked with industrial water supply, drought planning, wastewater capacity, or fast-growing communities knows better.
EPA’s Water Reuse Action Plan 2.0 puts renewed attention on reuse for industry, energy, agriculture, technology, and data center cooling. That is not just an environmental topic. It is an infrastructure topic.
For manufacturers, utilities, local governments, and developers, water reuse can affect:
- Long-term operating costs.
- Wastewater discharge limits.
- Cooling water availability.
- Community growth.
- Industrial recruitment.
- Drought resilience.
- Permit strategy.
The environmental side of water reuse still has to be done correctly. Treatment standards, end use, discharge implications, public communication, and regulatory approvals all matter. But the business case is becoming easier to see.
PPM’s water permitting, compliance, and reporting services help facilities evaluate those questions in the context of NPDES permits, discharge monitoring, stormwater, wastewater treatment, and compliance strategy.
WOTUS: Figure It Out Before the Site Plan Is Finished
Few regulatory issues create more confusion for landowners and developers than WOTUS, or “Waters of the United States.”
Ms. Eubanks discussed EPA and the U.S. Army Corps of Engineers’ effort to revise the WOTUS definition following the Supreme Court’s decision in Sackett v. EPA. The goal, as described in the presentation, is to create clearer jurisdictional lines and reduce uncertainty for landowners, farmers, developers, and businesses.
That uncertainty is not academic.
If wetlands, streams, ditches, ponds, or drainage features are present, WOTUS questions can affect layout, permitting, mitigation, timing, and financing. These issues are especially important in brownfield redevelopment, industrial expansion, infrastructure projects, and large commercial sites.
The mistake is waiting too long.
Wetlands and waters should be evaluated during site selection, not after the engineer has finished the site plan. Once the layout is fixed and the closing date is approaching, every environmental issue feels more expensive.
PPM’s Phase I and Phase II Environmental Site Assessment and brownfield redevelopment teams often see this firsthand. Early review does not eliminate every problem, but it gives the project team more room to solve it.
PFAS: Do Not Wait for Perfect Certainty
PFAS came up as well, and for good reason.
The rules continue to move, but the practical risk is already here. EPA has addressed PFAS through drinking water standards, TSCA reporting, Toxics Release Inventory reporting, technical assistance, and funding programs. Region 4 also has laboratory support in Athens, Georgia, which Ms. Eubanks referenced during the presentation.
For industry, the key point is that PFAS is not just a drinking water issue.
PFAS may matter in:
- Due diligence.
- Phase I and Phase II ESA scoping.
- Wastewater and stormwater evaluations.
- Fire training areas and AFFF history.
- Metal plating, textiles, paper, landfill, and manufacturing sites.
- Property transactions.
- Lender and buyer concerns.
- Community communication.
PPM covered this in PFAS at a Crossroads: Why Industry Can’t Afford to Wait Until 2029. That title still captures the issue. Waiting for every regulatory question to be settled may feel cautious, but it can leave a facility unprepared when a transaction, permit, discharge question, or public concern brings PFAS to the front of the room.
A practical first step is not always sampling. Sometimes the first step is a careful review of site history, materials, products, waste streams, fire suppression systems, and nearby sources.
CCR, Emergency Response, and the Basics That Still Matter
Ms. Eubanks also discussed coal combustion residuals, or CCR, and EPA’s interest in state permit programs. That is an important issue for utilities, industrial landowners, redevelopment teams, and communities with legacy energy infrastructure.
CCR questions often involve more than disposal. They may involve groundwater monitoring, closure, corrective action, beneficial use, financial assurance, and redevelopment planning.
She also made a brief but practical point about emergency response. Region 4 is seeing common incidents such as mercury spills and secondary containment failures, particularly with wet weather.
That may not make headlines, but it should get attention.
Secondary containment failures are the kind of preventable problem that can quickly become a release, a reporting obligation, a cleanup project, and an enforcement concern. Facilities that store petroleum, chemicals, process materials, drums, totes, or wastewater should not overlook the basics.
PPM’s environmental compliance audit and emergency response oversight services are built around that practical reality. Compliance is not just about the big federal rulemaking. It is also about what happens in the containment area during the next heavy rain.
What I Would Tell a Client to Do Next
If a client asked me what to do with this EPA Region 4 update, I would not tell them to panic. I would tell them to get organized.
Start with the record.
Look at the permits, the site history, the open agency correspondence, the monitoring data, the waste determinations, the inspection reports, and the old assumptions everyone keeps repeating because they have been repeated for years.
Then ask a few plain questions:
- Does our permit record match our current operation?
- Are we ready for a Title V renewal or agency review?
- Do we understand our PFAS exposure points?
- Have we evaluated wetlands and WOTUS issues early enough?
- Are water supply and wastewater capacity part of our project planning?
- If we are looking at a data center or major industrial project, have we treated it as a multi-media environmental project?
- Are our secondary containment and spill response plans actually ready for bad weather?
Those questions are not complicated. But they can save a lot of time, money, and frustration.
For hazardous waste generators, PPM’s article VSQG or SQG? How to Know Where Your Business Stands on Hazardous Waste Regulations is a good reminder that even basic classification questions can affect day-to-day compliance.
For redevelopment teams, Brownfields Grants Are About to Get Harder to Win is also worth revisiting. Grant strategy, site control, reuse planning, and environmental due diligence all need to line up earlier than many communities expect.
Final Thought
The main message I took from EPA Region 4’s update is that environmental policy is moving toward faster decisions, clearer roles, and stronger coordination with states. That is good news for businesses and communities that are prepared.
But faster process does not fix a weak record.
The fundamentals still matter: good data, honest site evaluation, clean permit files, early agency coordination, and practical environmental judgment. Whether the issue is Title V, WOTUS, PFAS, CCR, water reuse, data centers, or brownfield redevelopment, the best time to solve the problem is before it becomes the reason a project slows down.
That is where PPM can help.
We work every day with clients across the Southeast who are trying to grow, redevelop, comply, and make sound environmental decisions without losing sight of the business objective. EPA Region 4’s update was a good reminder that those two goals — environmental protection and economic progress — work best when the technical record is ready.
Key Takeaways
- EPA Region 4’s current priorities are closely tied to permitting reform, cooperative federalism, energy reliability, AI infrastructure, water reuse, WOTUS, PFAS, CCR, and Title V efficiency.
- Faster permitting will help prepared facilities, but it will not replace the need for accurate records, defensible calculations, and complete applications.
- Data centers should be treated as multi-media environmental projects because they can involve air permitting, power, water, wastewater, stormwater, wetlands, fuel storage, and community concerns.
- PFAS, WOTUS, CCR, water reuse, and Title V issues should be addressed early in due diligence, site selection, redevelopment, and compliance planning.