Rather than worrying about when to have a rally step, I've just declared that they are now just personally declared. Its now just a basic action (once per encounter, whenever):

MODIFIED: Rally Step (PGp79)- Rally steps are now personal only and may be declared once at any point during an encounter. You may still be subject to attacks/effects if you take a Rally Step.

jh

How do you deal with the rule that says that NPC ACE budget resets at rally steps?

I don't track ACE dice. That's another bit of accounting I threw out the window. They're GM "cheaters" dice anyways. If I needed to, I suppose that I'd just have the "monsters" do a rally step. Honestly though, I don't bother accounting for ACE dice. I throw them in there when I feel its crucial to the feel of the game or simply ignore them entirely.

jh