Learn about SCS Engineers Air Emissions Services
Key Takeaways: CARB’s July 21 Workshop
The California Air Resources Board (CARB) held a virtual public workshop to support the development of the California Corporate Greenhouse Gas Reporting (GHG) Program authorized by Senate Bill (SB) 253 as amended by SB 219. Below is a summary of the update provided, including CARB’s regulatory concepts for Scope 1 and 2 GHG emissions reporting requirements for 2027 and beyond. Also, CARB discussed its proposed approach for Scope 3 emissions reporting to begin in 2027.
Proposed Future Requirements for Corporate GHG Reporting
Most of the workshop addressed CARB’s proposed regulatory language, to be included in a 2027 rulemaking proposal.
Register Session 1 – Data Users & Public Interest Stakeholders
Date: Wednesday, August 5, 2026
Time: 10 a.m.-12 p.m. PT
Data users and public interest stakeholders, including universities, research institutions, Non-Governmental Organizations (NGOs), Environmental, Social, and Governance (ESG) software providers, consultants, assurance providers, and organizations that analyze or apply climate data to support public accountability, environmental justice, consumer interests, assess community impacts, and share data for public understanding.
Register Session 2 – Manufacturing, Industrial, Fuel & Life Sciences
Date: Wednesday, August 12, 2026
Time: 10 a.m.-12 p.m. PT
Companies engaged in oil and gas, refining, chemicals, metals, construction materials, mineral processing, automotive, aerospace, pharmaceuticals, biotechnology, and medical devices.
Register Session 3 – Agriculture, Food, Beverage & Forestry
Date: Wednesday, August 19, 2026
Time: 10 a.m.-12 p.m. PT
Companies involved in farming, livestock, forestry, food processing, beverages, agricultural products, tobacco, and related processing with significant land sector emissions.
Register Session 4 – Energy, Utilities, Transportation, Logistics & Waste Management
Date: Wednesday, August 26, 2026
Time: 10 a.m.-12 p.m. PT
Companies involved in generating electricity, renewable energy, water and gas utilities, transportation, freight, airlines, rail, shipping, and waste management.
Register Session 5 – Retail, Consumer Goods, Technology & Commercial Services
Date: Wednesday, September 2, 2026
Time: 10 a.m.-12 p.m. PT
Companies engaged in retail, apparel, wholesale, e-commerce, software, semiconductors, telecommunications, media, entertainment and gaming, real estate, hospitality, construction services, and professional services.
Register Session 6 – Banking, Finance & Insurance
Date: Wednesday, September 9, 2026
Time: 10 a.m.-12 p.m. PT
Companies involved in banking, insurance, asset management, investment, fintech, credit union services, asset management and private equity, capital markets, non-bank financial institutions, and other investors.
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SCS Engineers Technical Bulletin: Understanding EPA’s Proposal to Provide States Greater Flexibility in Minor New Source Review (NSR) Public Participation Requirements
Executive Brief
This bulletin discusses EPA’s proposed changes to the federal minimum public participation requirements for minor NSR permitting programs and, more importantly, what those changes could mean for future project planning, permitting strategy, and plant or facility operations.
Why Should Management Care?
When I first reviewed EPA’s proposed rule, my initial reaction was that it appeared to be a relatively minor procedural change. The proposal does not change emission limits, modify permitting thresholds, or expand the applicability of the minor NSR program.
The more I thought about it, however, the more I realized this proposal is not really about public notice. It is about project planning. One lesson I have learned over the years is that permitting often becomes part of the project’s critical path. Delays in obtaining a permit can affect equipment procurement, construction schedules, startup dates, and ultimately project costs. That is why this proposal caught my attention; recognizing this helps management be in control and reassured about project timelines.
If EPA finalizes the rule, states and local air agencies—not EPA—will decide whether public notice and comment remain part of their minor NSR permitting programs. Some states may choose not to revise their permitting programs if their existing requirements already meet or exceed EPA’s minimum requirements.
The proposal itself does not shorten permitting schedules. Whether permitting becomes more efficient will depend on how individual states respond. For now, management should continue planning projects in accordance with today’s permitting requirements while monitoring future developments.
Questions Management Should Be Asking
Rather than asking whether EPA is changing the rule, I think management should be asking different questions.
Those are the questions and aims that will determine whether this proposal has any practical business value.
Plant Environmental and Compliance Perspective
From the perspective of the plant environmental manager, very little has changed today.
Permit applications currently being prepared should continue following existing state and local permitting requirements. Existing project schedules should not be modified in response to a proposed federal rule. However, environmental managers have an opportunity to begin discussing with plant management how this proposal could affect future projects. For example, if their state ultimately revises its permitting program, eliminating or reducing public notice requirements for certain minor NSR permits could shorten one step in the permitting process. Whether this ultimately saves a few days or several weeks will depend on how each state implements the final rule and how much time public participation currently adds to its permitting process.
One question I would expect from management is: “If EPA finalizes this proposal, could our next project move through permitting more quickly?”
Today, the honest answer is, “We do not know yet.”
That answer will depend on whether your state decides to revise its own permitting program. Environmental managers should continue to monitor the EPA’s rulemaking and future actions by their state or local permitting authority. They should also begin evaluating how any changes could affect their facility’s or plant’s permitting strategy, project schedules, and coordination with the permitting agency. As with many permitting issues, the most effective strategy will vary by state and by project.
Background
Current federal regulations require approved state minor NSR programs to include minimum public participation procedures before certain permitting actions are finalized. EPA is proposing to remove that federal minimum requirement. Importantly, EPA is not proposing to eliminate public participation nationwide. Instead, EPA is proposing to allow each state or local permitting authority to determine whether public notice and comment remain appropriate for its own permitting program.
This distinction is important because the proposal does not automatically change permitting procedures nationwide.
Strategic Considerations
The more interesting question is not whether the EPA finalizes this proposal. The more interesting question is what the states do next. Some states may conclude that their current permitting process works well and decide not to make any changes. Others may view this proposal as an opportunity to streamline routine permitting actions.
As someone who has worked with state permitting agencies for many years, I expect there will be a variety of responses rather than a single nationwide approach. Companies operating in multiple states already know that permitting requirements vary from state to state. If EPA finalizes this proposal, public participation could become another area where those differences exist. That is why facilities should continue to work closely with their permitting professionals and plan projects based on each state’s requirements rather than assuming a common national approach.
The SCS Engineers Perspective
One mistake I occasionally see is companies assuming that a proposed federal rule immediately changes how permits are issued. That is rarely the case. Even if EPA finalizes this proposal, many states would still need to determine whether changes to their own regulations are appropriate. Some may revise their permitting programs, while others may not.
From my perspective, facilities should continue planning projects in accordance with today’s permitting requirements. The proposal is worth watching—not because it changes permitting today—but because it may influence how permitting is administered several years from now. That is where the real business impact may occur.
For more information about EPA’s proposed rule, visit https://www.epa.gov/nsr.
For specific guidance or questions, please get in touch with SCS Engineers for an expert in your state, or the Author, John Tsun. John Tsun is a Project Director and SCS’s National Practice Leader for Industrial Clean Air Act (CAA) Services, with more than 35 years of experience leading complex environmental compliance projects. His background spans a wide range of industrial sectors, including petroleum, pharmaceutical, chemical, power generation, manufacturing, and government agencies.
On June 24, the California Air Resources Board (CARB) announced a 3-month extension in the reporting deadline for covered companies for their first year reporting of corporate Scope 1 and Scope 2 greenhouse gas (GHG) emissions. The due date has been moved from August 10 to November 10, 2026.
The extension will be reflected in an updated regulatory proposal to give companies additional time following the formal adoption of CARB’s pending SB 253 and SB 261 regulations. The CARB Board approved the initial regulation on February 26, 2026.
CARB also announced that it will propose limited changes to the regulation to clarify certain requirements and will make them available for comment as part of a forthcoming 15-day public comment period.
Because this step may delay the finalization of this regulatory package, CARB proposed, as part of this 15-day change, a three-month deferral of the reporting deadline. The new proposed reporting deadline of November 10 will help ensure reporting entities have additional clarity following approval of the final regulation before reporting is due.
Recap of Program
The California Corporate Greenhouse Gas Reporting Program, established by SB 253 (codified in HSC § 38532), requires U.S.-based companies, with total annual revenues exceeding one billion dollars ($1,000,000,000) that do business in California, to annually disclose their Scope 1, Scope 2, and Scope 3 emissions for their prior fiscal year. SB 253 requires that the initial (first-year) annual emissions disclosures in 2026 address Scope 1 and Scope 2 emissions, and, in subsequent years (beginning in 2027), include Scope 3 emissions.
For Details Visit – California Corporate Greenhouse Gas Reporting: Notice of Upcoming Rulemaking Update to Further Clarify Requirements and Deferring 2026 Reporting Deadline
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What happened at the February 26, 2026, California Air Resources Board (CARB) public hearing and meeting?
On Thursday, February 26, CARB voted to approve regulations implementing California’s two climate disclosure requirements. To implement these laws, the board approved the draft regulation, which provides key definitions, establishes annual compliance fees, and sets deadlines for the first year of reporting.
What are the key elements of the new regulation?
Since these regulations were just issued, what enforcement is expected in 2026?
CARB emphasized that its enforcement guidance remains in effect, which provides accommodation for the first year of reporting. In its press release following the hearing, CARB noted that its priority is to support compliance through stakeholder engagement, and it will exercise enforcement discretion as long as good-faith efforts are made in first-year submissions.
When are climate risk disclosures under SB 261 due?
Enforcement of SB 261 is on a Ninth Circuit injunction, as acknowledged by CARB at the hearing. That injunction does not extend to SB 253. More than 120 climate-related financial risk reports have been voluntarily submitted and are publicly available at CARB’s SB 261 public docket.
What are the plans for future regulations under these laws?
CARB staff noted that additional topics are to be addressed in future guidance, with further SB 253 regulations to be proposed later this year. These are to address Scope 3 GHG emissions reporting, assurance, and reporting deadlines in 2027 and beyond.
CARB SB 253 and SB 261 Resources
See below for links to the notice of staff meeting presentation, the adopted regulatory text, and the press release, along with contact information for subject-matter experts should you require further assistance.
Oregon’s Department of Environmental Quality (ODEQ) has accredited SCS Engineers’ lead verifiers with the electricity power entity specialty under the ODEQ Clean Fuels Program (CFP). The CFP is a regulatory cap-and-trade system designed to reduce greenhouse gas emissions from fossil fuels.
SCS is now accredited to perform EPE (electricity power entity) transaction verifications for businesses and utilities that are required to report under the CFP. The main type of project under the program is electric charging stations.
The ODEQ requires Electricity Power Entities to submit quarterly reports in the Oregon Fuel Reporting System (OFRS) to verify electricity transactions. SCS, as an accredited third-party verification body, ensures data quality and accuracy, with specific verification statements required for electricity suppliers. Clients receive a full verification report including; information on facility boundaries and data sources, a description of accounting procedures and data management, a copy of the verification plan, a description of the data checks the verification body conducted, a log of issues, any qualifying comments the verification body would make about its findings during the verification process, and a copy of the verification report and statement.
SCS GHG verification scope includes entity-wide disclosures, single facilities, public and private electricity generation facilities, compliance offsets, and renewable fuel pathways. SCS Engineers also conducts independent audits of environmental data, including electricity and water usage, waste, and energy use, to support accuracy, compliance, and efficiency across all operations.
In addition, as an Accredited CFP Verification Body in Oregon, SCS Engineers verifies the following programs:
If you’d like to learn more about these programs or cap-and-trade, please get in touch with our GHG experts at SCS Engineers.
Additional Resources:
SCS Engineers periodically prepares SCS Technical Bulletins – short, clear summaries of rules, plans, standards, and advice. On January 2, 2026, the U.S. Environmental Protection Agency (EPA) announced that it will no longer consider the health-related monetary benefits of reducing air pollution when developing regulations. See 40 CFR Part 60 [EPA-HQ-OAR-2024-0419; FRL-11542-01-OAR], RIN 2060-AW21, New Source Performance Standards Review for Stationary Combustion Turbines and Stationary Gas Turbines.
Just because the EPA has de-emphasized health benefits in its cost-effectiveness analyses of pollution control options does not mean that facilities would be protected from liability for any health impacts they cause. In fact, there is risk that if a facility employs a less stringent level of pollution control as a result of EPA’s new policy, that choice, albeit allowed by the linked NSPS regulation, could increase the potential for more health impact lawsuits to be filed as well as to increase the facility’s liability because they chose to utilize a control technology that did not adequately reduce health impacts.
Navigating the Changing Regulatory Landscape: What the New ‘No Health Costs’ Approach Means for Industrial Clients
In our ever-evolving regulatory environment, staying ahead of policy changes is key to maintaining both compliance and strategic foresight. Recently, the EPA’s shift in its regulatory stance—specifically the decision not to factor health costs into pollution controls—has raised important considerations for the industrial sector.
From a practical perspective, this shift may influence how future air regulations—particularly those related to fine particulate matter (PM2.5) and ozone—are developed and communicated. While public health considerations remain part of the regulatory discussion, the absence of quantified health benefits in economic analyses could change how the overall impacts of new rules are presented. For regulated entities, this underscores the importance of staying engaged with both regulatory agencies and surrounding communities, and continuing to demonstrate a commitment to sound environmental stewardship as policy approaches evolve.
Understanding the Policy Shift
Traditionally, many environmental regulations have included an assessment of health-related costs and benefits. By taking those out of the equation, the EPA is essentially focusing on the economic and technical sides of compliance without formally weighing public health impacts. For industrial clients, this can translate into changes in how permitting and compliance standards are framed.
Implications for Compliance and Strategy
From a practical standpoint, this shift could mean that certain emissions controls or pollution abatement measures are viewed through a more cost-efficiency lens rather than a health-impact lens. For some facilities, that might reduce the immediate burden of justifying certain health-based mitigation steps. For others, it could lead to a re-examination of how to align with both federal requirements and community expectations.
Staying Proactive and Engaged
Even as the regulatory focus shifts, our advice to clients remains the same: stay proactive. Engaging early with regulatory agencies, understanding the broader community context, and maintaining a commitment to sustainable practices will help ensure that your projects not only meet the letter of the law but also foster long-term trust and reliability with your stakeholders.
Community Implications and Local Engagement
It’s also worth noting that while this regulatory shift focuses less on health costs, the well-being of the local community remains a priority. Industries will still need to engage with residents and local stakeholders to address concerns and demonstrate that, even in a changing regulatory landscape, maintaining trust and environmental responsibility remains key.
Potential Implications for Litigation and Facility-Level Risk
While the recent policy shift does not, by itself, create new regulatory requirements, it may have secondary implications for how air quality impacts are evaluated and challenged outside the federal rulemaking process. By placing less emphasis on monetizing public health benefits in regulatory analyses, future EPA rules may yield a narrower administrative record for health-based justifications, even where health impacts remain an underlying consideration.
In this context, challenges related to air quality impacts may increasingly occur at the facility or permit level, rather than through direct challenges to federal regulations. State agencies, local governments, community organizations, and other stakeholders may rely on state statutes, permitting programs, nuisance claims, or environmental justice frameworks to raise concerns regarding localized or cumulative impacts.
For facility owners and operators, this underscores the importance of maintaining robust, defensible compliance programs. Adherence to permit conditions remains essential, but facilities may also benefit from enhanced documentation of operational controls, emissions performance, monitoring data, and responsiveness to community or regulator inquiries. In some cases, voluntary risk-management measures or early engagement during permitting and modification processes may help reduce the likelihood that disputes will escalate into enforcement actions or litigation.
Technical Takeaway for Facility Owners
As federal rulemaking places less emphasis on quantified health benefits, risk management increasingly shifts to the facility level. Facility owners should assume that:
If you’d like to understand your facilities risk or further investigate O&M program assessment, please get in touch with our experts at SCS Engineers.
Meet our Author: John Tsun, National Practice Leader – Industrial Clean Air Act Services, SCS Engineers.
Additional Resources:
On December 11, 2025, the U.S. Environmental Protection Agency (EPA), Office of Air and Radiation (OAR), launched a new webpage entitled the Clean Air Act Resource for Data Centers. The site centralizes regulatory data, modeling tools, and permitting guidance. Designed to accelerate data center construction, the OAR staff is also available for case-by-case consultations with permit authorities and developers. The website has three primary categories:
Regulator Resources: Focuses on power sources, a major concern for planning data centers and AI infrastructure. Common sources of primary and backup power are subject to New Source Performance Standards (NSPS) for certain air emissions and National Emission Standards for Hazardous Air Pollutants (NESHAP).
Air Permitting Resources: Aggregates guidance documents and historical interpretation letters to see how EPA has handled similar permitting requests in the past, offering a clearer picture of statutory obligations under New Source Review (NSR) requirements and federal regulations.
Modeling Guidance: Provides access to the EPA’s “Guideline on Air Quality Models,” offering technical methods for demonstrating Clean Air Act (CAA) and NO2 National Ambient Air Quality Standard (NAAQS) compliance during planning.
The EPA initiative aims to help businesses and communities navigate federal air quality rules, specifically under the Clean Air Act (CAA) requirements that EPA acknowledges are essential for pollution control. Officials stated the webpage will be updated continuously as the agency moves to reform industry guidance for data center developers.
The EPA did not specify what it intends to change, but said it will clarify how the regulations apply to modern facilities. The administration contends that streamlined development will ultimately protect consumers from rising electricity rates and cost-of-living increases.
According to the Georgetown Law Review, Bloomberg, and Utility Dive, communities and states that allow data center growth are experiencing substantial increases in utility costs, up to 267% over five years [1].
While it is not unusual for local taxpayers to cover part of the infrastructure costs, many consumers were unaware of just how substantial those costs are for data centers [2].
According to the Georgetown Law Review, there is currently no concise federal framework for regulating data center development, leaving regulation largely up to the individual states. However, a bill introduced by Senators Whitehouse and Fetterman, the Clean Cloud Act of 2025, would amend the Clean Air Act to set emissions standards for servers and other equipment used in data centers or crypto-mining facilities, and to require data collection on energy consumption. The Senate read the proposed bill and then referred it to the Committee on Environment and Public Works [3].
Electrical systems and ongoing energy systems account for the lion’s share of capital expenses and operational costs. There is a cost of land, but companies are now seeking to use Brownfields to obtain parcels closer to urban areas with more infrastructure.
The environmental impacts discussed here affect air quality because the massive amounts of electricity data centers consume to crunch data and keep systems cool are primarily generated by fossil fuels. Total global consumption of electrical power by data centers is anticipated to jump, with AI-optimized centers expected to see demand quadruple; AI’s share of data center power could rise from 5-15% to 35-50% by 2030 [4].
Our dependence is driving up carbon emissions and exacerbating global warming issues. Developing greener cooling methods for data centers will help minimize environmental impacts on air quality and reduce strains on local water resources for cooling [5]. That’s where SCS Engineers can help.
For more than five decades, SCS Engineers has helped industrial and infrastructure clients navigate complex environmental challenges — from permitting and regulatory compliance to energy, water, and air quality solutions. Our experience spans power generation, advanced manufacturing, resource recovery, and large-scale infrastructure projects, where we help transform operational challenges into cost-effective, sustainable outcomes. This depth of industrial expertise demonstrates that the U.S. can continue to lead in technology and innovation while responsibly protecting natural resources.
As your state or community looks toward supporting the U.S.’s technology future, know that there is an environmental engineering, consulting, and construction firm that finds a way to sustain business growth and protect our environment. Reach out to one of our Energy Management Professionals. We’re happy to help.
40 CFR Part 98
[EPA-HQ-OAR-2025-0186; FRL-12720-01-OAR]
RIN 2060-AW76
On September 12, 2025, the U.S. Environmental Protection Agency (EPA) proposed permanently removing program obligations for 46 of 47 Greenhouse Gas Reporting Program (GHGRP) source categories. Under the proposal, facilities, suppliers, and underground injection sites under these 46 source categories would no longer report to the EPA after the reporting year 2024.
EPA states it has reviewed the legality of the GHGRP and determined that there is no statutory requirement to collect greenhouse gas (GHG) emissions information for sectors other than the petroleum and natural gas source category (subpart W) segments subject to the Waste Emissions Charge (WEC).
The GHGRP requires reporting GHG data from large sources and suppliers across various industry sectors. The GHGRP collects greenhouse gas data from 47 source categories and currently has several years of data from these sources, including reports from more than 8,000 direct emitters and suppliers of GHGs. Among others, these include electrical generation, many production and manufacturing plants, solid and industrial waste landfills, geologic carbon dioxide sequestration and carbon dioxide injection, industrial wastewater treatment, and manure management.
Continued GHG Reporting
Most businesses and services will likely continue reporting, since they already have the technology in place and get a positive return on investment. Many organizations use these data in their sustainability/climate reporting, including measuring progress on meeting GHG reduction goals. Importantly, data collection allows them to identify and proactively act on operational issues, creating more efficiency. Finally, some states have a mandatory GHG program requiring reporting utilizing the federal criteria, so organizations will continue reporting to comply with state and local regulations. Many have found that providing the reports helps them remain good community stewards, show transparency in environmental programs, and avoid nuisance complaints.
For example, many landfills use data collection to balance the wellfield. A balanced wellfield optimizes GHG collection, which lowers odors and nuisance complaints, provides a safer working environment, and results in a steadier flow of better quality methane to enable a greater return on investment in Renewable Natural Gas plants.
Subpart W
EPA’s proposed amendments consist of two parts. First, the EPA proposes to permanently remove program obligations for facilities in the natural gas distribution segment. Under the proposal, facilities in the natural gas distribution segment of subpart W would no longer report to the EPA after the reporting year 2024.
Second, for the remaining nine segments of subpart W, EPA is proposing to suspend program reporting requirements until the reporting year 2034.
If Finalized as Proposed
No industries need to submit reports with 2025 data. However, EPA proposes extending the March 31, 2026, reporting deadline until June 10, 2026. If finalized before March 31, 2026, this extension would allow EPA time to issue a final rule before the regulatory deadline for reporting year 2025.
Public Hearings
EPA will hold a virtual public hearing for the proposed action 15 days after publication of this proposal in the Federal Register. Further details about the public hearing, including registration, will be available at https://www.epa.gov/ghgreporting/rulemaking-notices-ghg-reporting
EPA will accept comments for 47 days after publishing the proposal in the Federal Register.
Submit comments, identified by Docket ID No. EPA-HQ-OAR-2025-0186, using one of the following methods:
Greenhouse Gas Reporting Resources
Please join SCS Engineers in welcoming Dr. Aicha Slassi Senou to our Greenhouse Gas (GHG) and Climate Change Practice.
Dr. Slassi Senou brings over 10 years of expertise as a GHG and sustainability expert in GHG accounting, decarbonization planning, and life cycle assessments. She has successfully delivered over 30 third-party verified Corporate GHG Inventories for scopes 1, 2, and 3 by responding to auditors’ technical questions about data collection, calculations, in alignment with the World Resources Institute’s GHG Protocol’s Corporate Standards, and ISO 14064-1. She is skilled in managing corporate climate and GHG projects, including GHG inventories and climate disclosures, including reporting to the Science Based Targets Initiative and CDP.
Her experience includes end-to-end GHG inventory development for corporate clients from various sectors, including services and manufacturing. Over the last two years, she has experience ensuring compliance with GHG Protocol standards across Scopes 1, 2, and 3 for 45 corporate inventories. She has demonstrated deep technical expertise across all 15 Scope 3 categories. Dr. Slassi Senou delivered sector-specific decarbonization strategies, including value chain engagement for a Fortune 50 manufacturer and net-zero road mapping for multiple clients.
Victoria Evans, SCS’s National Expert on Climate Change, has this to add:
Aicha’s a formidable addition to our deep bench of engineers, scientists, and consultants. In addition to her expertise, she completed two Environmental Defense Fund (EDF) Climate Corps Fellowships, one with Hershey’s Company and one with Meta Inc.
Her background includes laboratory research on biochar’s carbon and environmental benefits from alternative feedstocks. She worked at Moody’s as a Corporate Sustainability Reporting (CSR) analyst on ESG data collection, analysis, and comparative ranking of corporations relative to their peers.
We’re sure Aicha will be pleased to hear from you. Please extend a greeting on LinkedIn.
Additional Resources:
Congratulations to Gabrielle Stephens for her promotion to lead SCS’s Southwestern U.S. Air Compliance Group. She brings over two decades of client success to the role.
Greenhouse gas (GHG) reporting or verification, regulatory air compliance, and air permitting services fall within Ms. Stephens’ purview. She leads teams that support clients in the solid waste and manufacturing industries, who find value in having a regulatory liaison to navigate ever-changing federal, state, and local regulations. These teams help maintain efficient operations and enhance business communication with stakeholders.
Regulatory agencies often operate independently, and knowledgeable environmental consultants know how best to meet multiple agency data requirements, resulting in positive relationships between agencies and clients. SCS clients find that improved communication helps minimize or prevent permitting and compliance delays. Agencies, especially air district staff, can depend on the accuracy of Clean Air Act experts who are experienced with newer technologies proven to work, but potentially new in a district.
Ms. Stephens’ experience spans multiple states, numerous air districts and local enforcement agencies.
Beyond her work in air permitting and compliance, Ms. Stephens works on emissions estimates and inventories and has extensive experience preparing permit-to-construct/operate and Title V permit applications. She has also undertaken projects evaluating and reporting to meet the federal Greenhouse Gas (GHG) Rule and the AB 32 Landfill Methane Rule. Her collaborative efforts with the solid waste industry contribute to multiple facilities obtaining landfill gas-to-energy and RNG permits that positively impact air quality.
Ms. Stephens’ air compliance audits, permitting, and compliance reporting for manufacturing facilities, including fiberglass boats, product removers, ceramics, paper products, and cement/aggregates, help ensure regulatory compliance and improve operational efficiency.
Additional Clean Air Act Resources:
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