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:
The actual text of EPA’s final rule rescinding the 2009 Endangerment Finding was published this morning. Several other documents in support of the final rule also were posted on the EPA website: Final Rule: Rescission of the Greenhouse Gas Endangerment Finding and Motor Vehicle Greenhouse Gas Emission Standards Under the Clean Air Act | US EPA
Most of the rule’s immediate effects will be on motor vehicles. The regulations directly affected are 40 CFR Parts 85 (Control of Air Pollution from Mobile Sources), 86 (Control of Emissions from New and In-Use Highway Vehicles and Engines), 600 (Fuel Economy and Greenhouse Gas Exhaust Emissions of Motor Vehicles), 1036 (Control of Emissions from New and In-Use Heavy-Duty Highway Engines), 1037 (Control of Emissions from New Heavy-Duty Motor Vehicles, and 1039 (Control of Emissions from New and In-Use Nonroad Compression-Ignition Engines)
The final rule does not affect criteria pollutant emission standards, mobile-source air toxics standards, or vehicle fuel-economy standards (also known as Corporate Average Fuel Economy, or CAFE, standards).
How will the rescission of the Endangerment Finding affect the solid waste industry? To the extent that heavy-duty trucks and equipment become less expensive with no requirements to limit GHG emissions, solid waste companies will see savings. However, major CAA regulatory programs such as New Source Performance Standards for landfills and operating permits for landfill gas control systems are unlikely to be affected, at least in part, because, at the federal level, the threshold triggers for these programs are based on non-methane organic compounds rather than greenhouse gas emissions.
It remains to be seen if EPA will follow through on changes to the Mandatory Greenhouse Gas Reporting Program under 40 CFR Part 98 as proposed last September. Among those changes would be to eliminate GHG reporting for 46 industrial categories, including municipal solid waste landfills and industrial waste landfills. Some of those affected have asked the EPA to continue requiring GHG reporting because they do not want to be subject to numerous state reporting programs, including New York’s new program that takes effect in 2027, as well as California, Oregon, and Washington, which already have GHG reporting. Some states that require GHG reporting directly reference 40 CFR Part 98 and/or rely on the EPA’s electronic Greenhouse Gas Reporting Tool (eGGRT).
Another aspect of the rescission of the Endangerment Finding is any effect that may have on any preemption of state laws outside the motor vehicle context. Several states are not waiting for the EPA in this regard, requiring GHG reporting and disclosures as a matter of state law.
The recission final rule is based on the EPA’s interpretation of the Clean Air Act as a legal matter. Although EPA “continues to harbor concerns regarding the scientific analysis contained in the Endangerment Finding . . . . the Administrator is not basing this action on a new finding under CAA section 202(a)(1). Rather, we conclude that the EPA lacks statutory authority to resolve these questions under CAA section 202(a)(1).” Section 202(a)(1) covers emission standards for new motor vehicles or new motor vehicle engines.
Boiled down to its essence, EPA is saying that it never had the legal authority from Congress to regulate GHGs under the Clean Air Act. It says that the CAA addressed air pollution having local and regional impacts, not pollution that may affect global climate change. By taking this approach, the EPA avoids addressing climate science altogether.
Under the Supreme Court’s “major questions” doctrine, President Obama couldn’t regulate greenhouse gas emissions outside the fence line as part of the Clean Power Plan in the electric utilities sector. President Biden couldn’t require COVID-19 vaccinations or forgive student loans en masse. President Trump might not have been able to impose tariffs under the International Emergency Economic Powers Act because such major questions require specific congressional authorization. EPA cites the major questions doctrine as requiring rescission of the 2009 Endangerment Finding.
The goal appears to be to secure the Supreme Court’s affirmation of the EPA’s current views before Mr. Trump leaves office. The Court has considered aspects of EPA’s GHG regulations from time to time since the 2009 Endangerment Finding was published. Of course, the Court said that EPA could prepare an Endangerment Finding, but it never directly considered the finding itself. If the Court ultimately rules that the CAA does not authorize the EPA to regulate GHGs, one assumes that, until Congress passes a new law addressing GHGs, there will be no such regulation at the federal level.
If you have questions about federal, state, or local air quality regulations, reporting, or verification, please contact the experts at SCS Engineers.
SCS Engineers is proud to participate in Lucky Leaf Expo Minneapolis! Taking place February 27–28, 2026, at the Minneapolis Convention Center. As Minnesota emerges as one of the nation’s next major cannabis markets, this two-day conference brings together industry professionals, regulators, entrepreneurs, and job seekers to explore opportunities shaping the future of cannabis in the region. SCS Engineers partners with clients to address environmental compliance, odor control, zoning, and infrastructure planning challenges critical to sustainable cannabis operations. Register today!
Visit Booth #125 to connect with Eva Luu, Sonya Betker, Armando Hurtado-Garcia, and Christopher Petro, and attend the following SCS Engineers-led sessions:
Cannabis Without the Complaints: Zoning, Odor Control, and Sustainable Industry Growth
Presented by Christopher Petro and Armando Hurtado-Garcia
This session explores how cities can balance economic growth with community impacts through effective zoning, odor control standards, permitting strategies, and operational best practices that support long-term industry success.
Making Scents of Odor Control: Evaluating Mitigation Technologies and Trade-offs
Presented by Eva Luu and Armando Hurtado-Garcia
Drawing on years of field testing, this presentation compares odor control technologies by evaluating environmental conditions, maintenance needs, cost-effectiveness, and public perception to help decision-makers select the right solutions for specific operational scenarios.
As an employee-owned environmental consulting and construction firm, SCS Engineers supports the communities we live and work in year-round. But we all want to be doing something extra during the holidays.
In 2024, SCS donated to 43 local registered IRS 501(c)(3) charities during the holidays, positively impacting over 90,000 people! Our Corporate program has proven to be successful, so we plan to grow it this year.
In addition to supporting this year’s annual SCS Young Professional Group’s holiday fundraising, we plan to send significant donations to the four charities below that align with the environmental nature of our business and do so much for others. We will continue funding the Robert Stearns SWANA and the Environmental Research & Education Fund Scholarships.
These charities rely on consistent donations from patrons like SCS and you. We thank them all for their continuing humanitarian work. As always, we will continue to donate year round to the Red Cross and World Central Kitchen in support of people impacted by natural disasters worldwide.
Join SCS Engineers and John Tsun as he serves as one of the co-organizers for the 24th Annual Joint Venture NJDEP/Air & Waste Management Association (A&WMA) Regulatory Update Conference, November 21st.
This one-day virtual event provides attendees with the latest updates on New Jersey Department of Environmental Protection (NJDEP) regulatory initiatives and programs related to environmental compliance, air quality, contaminated site remediation and redevelopment, energy, materials sustainability, water quality, and climate change mitigation.
The conference offers a valuable opportunity for environmental professionals, regulators, and industry leaders to engage directly with NJDEP representatives and stay informed on emerging policies, research, and best practices shaping the future of sustainable environmental management. Register now.
The U.S. Environmental Protection Agency’s (EPA) Office of Land and Emergency Management (OLEM) announces it is updating guidance for addressing residential lead exposures at Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and Resource Conservation and Recovery Act (RCRA) sites.
The new directive for investigating and cleaning up lead in residential soil at contaminated sites emphasizes early collaboration with state and local partners to protect communities. You should consider this as a directive for all sites with residential lead contamination subject to CERCLA response and RCRA authorities, including federal facility cleanup programs subject to CERCLA Section 120, and potentially by federal agencies using response action authorities delegated to them under Executive Order 12580.
This Directive supersedes the January 2024 Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities in addressing lead contaminated soil on residential properties at CERCLA and RCRA sites.
The agency’s new guidance aims to address inefficiencies which slow progress to decrease lead exposure in residential neighborhoods at Superfund and hazardous waste sites. The updated directive establishes the following:
EPA will continue to use site-specific factors, including exposure considerations, soil lead background levels and community input, to make informed decisions on how to address lead exposure at each site.
The announcement on October 20, 2025, also includes a series of process improvements to accelerate response actions that address lead contaminated soil on residential properties including more nationally consistent cleanup decisions, early engagement with state and local partners, sharing best practices through the establishment of a National Center of Excellence for Residential Lead Cleanups, and specialized contracting mechanisms to leverage removal and remedial actions.
EPA plans for a roadmap for response action decision-making at residential properties and other high impact areas for children (e.g., schools, playgrounds). EPA defines residential properties as any area with high or unrestricted accessibility to sensitive populations (e.g., young children less than 7 years old) and includes, but is not limited to, properties containing single- and multifamily dwellings, apartment complexes, vacant lots in residential areas, schools, daycare centers, community centers, playgrounds, parks and other recreational areas, green ways, and any other areas where young children may risk exposure to site-related contaminated media. The roadmap will include engineered and non-engineered approaches.
Establish a National Center of Excellence for CERCLA Residential Lead Cleanups as a centralized resource to share expertise across regions, identify and facilitate efficiencies, and establish best management practices across all phases of characterization and cleanup.
CERCLA five-year reviews (FYRs) remain an essential statutory tool to evaluate protectiveness of both engineered and non-engineered remedy components at any site where hazardous substances, pollutants or contaminants remain on site above levels that permit unlimited use and unrestricted exposure, per CERCLA Section 121(c) and 40 CFR Part 300.430(f)(4)(ii). The findings of a FYR may result in the need for further evaluation, cleanup and/or institutional controls to support short- and/or long-term protection.
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:
Recently, Donald Trump issued four executive orders extending Clean Air Act – NESHAP compliance deadlines for a number of specific facilities that provide medical equipment sterilization, burn coal to make electricity, manufacture certain synthetic chemicals, or mine taconite. The big headline is the EPA announcing plans to rescind the ‘endangerment finding’ that allows climate regulation. However, at the same time coal combustion residuals rules are being changed. This Regulatory Alert contains language from the four executive orders, which includes a list of the specific facilities that have been granted extensions to comply. In each order, the President finds that the technology required is not available and that it is in the interest of national security to provide the extensions.
Normally there is a notice-and-comment rulemaking under the Administrative Procedures Act to extend deadlines. If the courts allow the President to continue invoking national security we may see more such executive orders modifying regulations. Follow SCS Engineers on social media to read our SCS Technical Bulletins, which summarize regulatory proposals and changes for public and private entities.
As the regulatory landscape continues to evolve, proactive planning is critical to preserving flexibility, value, and mitigating risk. We encourage businesses to consult with environmental engineers and consultants and their legal counsel to navigate these changes for continued sustainable success.
NESHAP – EtO Rule
On April 5, 2024, the Environmental Protection Agency published a final rule, pursuant to section 112 of the Clean Air Act, 42 U.S.C. 7412, titled National Emission Standards for Hazardous Air Pollutants: Ethylene Oxide Emissions Standards for Sterilization Facilities Residual Risk and Technology Review, 89 FR 24090 (EtO Rule). The EtO Rule imposes new emissions-control requirements on commercial sterilization facilities.
Certain stationary sources subject to the EtO Rule, as identified in Annex I of this proclamation, are exempt from compliance with the EtO Rule for a period of 2 years beyond the EtO Rule’s relevant compliance dates (Exemption). This Exemption applies to all compliance deadlines established under the EtO Rule applicable to the stationary sources listed in Annex I, with each such deadline extended by 2 years from the date originally required for such deadline. The effect of this Exemption is that, during each such 2-year period, these stationary sources will remain subject to the emissions and compliance obligations in effect prior to the issuance of the EtO Rule. In support of this Exemption, I (Trump) hereby make the following determinations:
The technology to implement the EtO Rule is not available. Such technology does not exist in a commercially viable form sufficient to allow implementation of and compliance with the EtO Rule by the compliance dates set forth in the EtO Rule. It is in the national security interests of the United States to issue this Exemption for the reasons stated in paragraphs 1 and 3 of this proclamation. Link
ANNEX I
International Sterilization Laboratory
Affected Facility/Source: Groveland Facility, Florida
Becton Dickinson and Company
Affected Facility/Source:
KPR US, LLC d/b/a Kendall Patient Recovery
Affected Facility/Source: Augusta Facility, Georgia
MedXL, LLC
Affected Facility/Source: Ardmore Facility, Oklahoma
Aligned Medical Solutions
Affected Facility/Source:
Professional Contract Sterilization, Inc.
Affected Facility/Source: Taunton Facility, Massachusetts
Sterigenics U.S., LLC
Affected Facility/Source:
Cosmed Group, Inc.
Affected Facility/Source:
Arthrex
Affected Facility/Source: Ave Maria Facilities (2), Florida
Cook Incorporated
Affected Facility/Source: Ellettsville North Facility, Indiana
ALCON Research Ltd.
Affected Facility/Source: ALCON Advance Optic Device Center, North Facility, West Virginia
Affected Facility/Source: Allentown Manufacturing Facility, Pennsylvania
DeRoyal Industries, Inc.
Affected Facility/Source:
Sterilization Services of Georgia, Inc.
Affected Facility/Source: Atlanta Facility, Georgia
Sterilization Services of Virginia, Inc.
Affected Facility/Source: Richmond Facility, Virginia
Trinity Sterile, Inc.
Affected Facility/Source: Trinity Sterile, Inc., Maryland
LivaNova USA, Inc.
Affected Facility/Source: LivaNova Arvada Facility, Colorado
Covidien LP
Affected Facility/Source: Covidien North Haven Facility, Connecticut
Medtronic Xomed LLC
Affected Facility/Source: Jacksonville Facility, Florida
Medtronic Puerto Rico Operations Company, Inc.
Affected Facility/Source:
Advanced Product Solutions
Affected Facility/Source: Columbia Facility, Alabama
Affected Facility/Source: Salinas, Puerto Rico
Steri-Tech, Inc.
NESHAP – MATS Rule
On May 7, 2024, the Environmental Protection Agency published a final rule, pursuant to section 112 of the Clean Air Act, 42 U.S.C. 7412, titled National Emissions Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review, 89 FR 38508 (Rule), which amended the preexisting Mercury and Air Toxics Standards (MATS) rule to make it more stringent. The Rule’s effective date was July 8, 2024. Id. Its compliance date is July 8, 2027, 3 years after its effective date. See 89 FR 38519.
Certain stationary sources subject to the Rule, as identified in Annex I of this proclamation, are exempt from compliance with the Rule for a period of 2 years beyond the Rule’s compliance date — i.e., for the period beginning July 8, 2027, and concluding July 8, 2029 (Exemption). The effect of this Exemption is that, during this 2-year period, these stationary sources are subject to the compliance obligations that they are currently subject to under the MATS as the MATS existed prior to the Rule. In support of this Exemption, I (Trump) hereby make the following determinations:
a. The technology to implement the Rule is not available. Such technology does not exist in a commercially viable form sufficient to allow implementation of and compliance with the Rule by its compliance date of July 8, 2027.
b. It is in the national security interests of the United States to issue this Exemption for the reasons stated in paragraphs 1 and 3 of this proclamation. Link
ANNEX I
Affected Facility/Source: Cardinal Unit 1, Unit 2, and Unit 3, Ohio
Tri-State Generation and Transmission Association
Affected Facility/Source: Craig Generating Station Unit 2 and Unit 3, Colorado
City Water, Light and Power
Affected Facility/Source: Dallman Unit 4, Illinois
Cardinal Operating Company
NESHAP – HON Rule
On May 16, 2024, the Environmental Protection Agency published a final rule titled New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, 89 FR 42932 (HON Rule). The HON Rule imposes new emissions-control requirements on certain chemical manufacturing facilities, some of which were promulgated pursuant to section 112 of the Clean Air Act, 42 U.S.C. 7412.
Certain stationary sources subject to the HON Rule, as identified in Annex I of this proclamation, are exempt from compliance with those aspects of the HON Rule that were promulgated under section 112 of the Clean Air Act, 42 U.S.C. 7412 for a period of 2 years beyond the HON Rule’s relevant compliance dates (Exemption). This Exemption applies to all compliance deadlines established under the HON Rule applicable to the stationary sources listed in Annex I, with each such deadline extended by 2 years from the date originally required for such deadline. The effect of this Exemption is that, during each such 2-year period, these stationary sources will be subject to the emissions and compliance obligations that they are currently subject to under the applicable standard as that standard existed prior to the HON Rule. In support of this Exemption, I (Trump) hereby make the following determinations:
a. The technology to implement the HON Rule is not available. Such technology does not exist in a commercially viable form sufficient to allow implementation of and compliance with the HON Rule by the compliance dates in the HON Rule.
b. It is in the national security interests of the United States to issue this Exemption for the reasons stated in paragraphs 1 and 3 of this proclamation. Link
ANNEX I
NESHAP – Taconite Rule
On March 6, 2024, the Environmental Protection Agency published a final rule, pursuant to section 112 of the Clean Air Act, 42 U.S.C. 7412, titled National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing, 89 FR 16408 (Taconite Rule). The Taconite Rule imposes new emissions-control requirements on taconite iron ore processing facilities.
Certain stationary sources subject to the Taconite Rule, as identified in Annex I of this proclamation, are exempt from compliance with the Taconite Rule for a period of 2 years beyond the Taconite Rule’s relevant compliance dates (Exemption).The technology to implement the Taconite Rule is not currently available, and it is necessary to issue this Exemption now because long design, permitting, and construction lead times mean that regulated entities will not be able to meet the relevant compliance deadlines absent compliance relief. This Exemption applies to all compliance deadlines established under the Taconite Rule, with each such deadline extended by 2 years from the date originally required for such deadline. The effect of this Exemption is that, during each such 2-year period, these stationary sources are subject to the emissions and compliance obligations that they are currently subject to under the applicable standard as that standard existed prior to the Taconite Rule. In support of this Exemption, I (Trump) hereby make the following determinations:
a. The technology to implement the Taconite Rule is not available. Such technology does not exist in a commercially viable form sufficient to allow implementation of and compliance with the Taconite Rule by the compliance dates in the Taconite Rule.
b. It is in the national security interests of the United States to issue this Exemption for the reasons stated in paragraphs 1 and 3 of this proclamation. Link
ANNEX I
On April 17, 2025, the U.S. Environmental Protection Agency (EPA) announced it will extend the compliance deadlines for coal combustion residual (CCR) management unit (CCRMU) requirements. This action will allow facilities to submit both sections of the Facility Evaluation Report simultaneously, provided that both reports are turned in no later than February 8, 2027.
EPA is also extending the groundwater monitoring requirements for owners or operators of coal combustion residual management units until August 8, 2029. Because the Facility Evaluation Report and groundwater monitoring requirements are necessary for compliance with other CCRMU requirements, EPA is aligning these remaining CCRMU compliance deadlines.
EPA has proposed to approve North Dakota’s CCR program application, which would allow the state to manage coal ash disposal in surface impoundments and landfills. EPA is also working with Wyoming and other states as they seek to manage their CCR programs without federal oversight.
EPA is accepting comments for 30 days after publication in the Federal Register. Unless EPA receives adverse comments, this final rule will be effective six months after publication in the Federal Register.
Additional Resources:
The U.S. meat and poultry industry generates slaughterhouse waste (SHW) as a by-product, which is converted into additional products through the rendering process to minimize waste. Although rendering generates sellable commodities, Anaerobic Digestion (AD) is a proven, scalable technology for offsetting energy-intensive processes and minimizing FOG and contaminants in wastewater. AD can provide new opportunities for onsite waste management paired with renewable energy production and biogas potential for thermal energy, electricity generation, and renewable natural gas (RNG) to offset operating costs.
The EPA’s proposed Effluent Limitations Guidelines (ELGs) will require that facilities add biological treatment, creating a new waste stream (waste biosolids) that could be managed along with other slaughterhouse wastes via anaerobic digestion.
SCS Engineers presents a free educational forum explaining the opportunities for the meat and poultry industry and how to determine if AD is feasible to help your operation reduce energy costs with biogas production and enable nutrient recovery while reducing wastewater contamination. We’ll cover:
Meet Dr. Erik Anderson, a senior SCS Liquid Management team member and a National Expert in AD. He has 15 years of experience in process design related to biomass engineering, specifically anaerobic digestion and other waste-to-energy systems. His work includes modeling biomass technologies for performance, cost, and economic evaluation or life-cycle analysis, combining material testing and/or pilot-scale testing for more value.
Additional ELG Resources:
Corporate Headquarters
