EPA Updates OTAQ BABA Implementation Procedures with New Waiver Guidance

EPA's Office of Transportation and Air Quality issued updated BABA Implementation Procedures (January 2026) covering DERA, Clean School Bus, Clean Ports, and Clean Heavy-Duty Vehicles programs. Updates include: new guidance on Cognizant Agency determinations for multi-agency funded projects; clarified Purpose, Time, and Place (PTP) test for project scope; new Appendix 5 on Waiver Request Process; and new Q5.15 on De Minimis Waiver for mobile equipment and fueling infrastructure. Notably clarifies that for the Clean School Bus Program, BABA applies to charging infrastructure but NOT to the school buses themselves.