SCS Engineers will sponsor and exhibit at The 35th Annual Environmental Law Conference at Yosemite this October 15th – 18th at Tenaya Lodge in Fish Camp, CA. The 35h Annual Environmental Law Conference at Yosemite brings together California’s top leaders in environmental, land use, and natural resources law. It’s the largest and most prestigious event of its kind in the state. We hope you will join us and many of our nation’s top environmental officials, lawyers, and other professionals for four days of legal education and collegiality. Mark your calendars!
Join SCS Engineers as Silver Sponsors at the upcoming CRRA 2026 – Annual Conference and Trade Show, this August 30 – September 2, 2026, at the Sheraton San Diego Resort, in San Diego, California. As a Silver Sponsor, SCS Engineers is proud to participate in the conference themed “Rooted in California Values.” Each year, the California Resource Recovery Association organizes one of the most comprehensive and informative conferences dedicated to recycling and sustainable materials management in California and beyond. CRRA’s Annual Conference & Trade Show is where California’s recycling and sustainability community comes together. With 800+ attendees, 100+ industry expert speakers, and over 30 solution-packed sessions, it’s the must-attend event for anyone shaping the future of zero waste.
Join us in supporting this important event! Register now!
Join SCS Engineers as Sponsors and Exhibitors at the 2026 SDHF Annual Affordable Housing and Community Development Conference in San Diego, CA on October 1st, 2026. San Diego Housing Federation’s Annual Affordable Housing & Community Development Conference brings together more than 600 developers, builders, architects, lenders, property managers, service providers, elected and agency officials and staff, community, and business leaders to share innovative approaches to affordable housing, community, and economic development. Join us this year for the SDHF Annual Affordable Housing and Community Development Conference at the Marriott Marquis Thursday, October 1st.
More information and registration available here: 2026 Affordable Housing & Community Development Conference — San Diego Housing Federation
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 July 7, the California Air Resources Board (CARB) announced it will hold a virtual public workshop to support the development of the California Corporate Greenhouse Gas Reporting Program authorized by Senate Bill (SB) 253, as amended by SB 219. See the link below.
CARB staff will provide an update on regulatory concepts for Scope 1 and 2 greenhouse gas (GHG) emissions reporting requirements for 2027 and beyond, including data assurance. Staff will also discuss CARB’s proposed approach for Scope 3 emissions reporting beginning in 2027 (summarized below).
The workshop will be held virtually on Zoom (only) on Tuesday, July 21, 2026, at 9:30 am – 12:30 pm (Pacific Time). Register for virtual attendance.
Workshop materials are to be posted to the California Corporate Greenhouse Gas (GHG) Reporting and Climate Related Financial Risk Disclosure Programs webpage on July 20, 2026. Staff plans to take verbal feedback during the workshop, with written feedback to be sent to .
CARB’s Proposed Options for Scope 3 Reporting (March 23, 2026, Workshop)
Option 1: Starting in 2027, all Scope 3 categories
Option 2: Industry Sector Phase-In for 2027
Option 3: Category Phase-In for 2027
Recap of Program
The California Corporate Greenhouse Gas Reporting Program under SB 253 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
Need support? Feel free to reach out to us. We are happy to have a chat with you!
We welcome you to join our next SCS Engineers free, educational webinar, Fire Prevention & Emergency Response Planning for Solid Waste Facilities, on Thursday, July 16th. Our panelists include real-world examples, safety considerations, and strategies for improving fire response and prevention of surface fires, which can greatly reduce risk to staff and the facility. We leave plenty of time for you to ask questions during our open forum Q-and-A period.
Our comprehensive session highlights the critical need for specialized surface fire risk management in the solid waste industry, focusing on prevention, preparedness, and coordinated response to protect facilities, personnel, and the environment.
Our webinar is tailored for landfill and solid waste facility operators, owners, safety coordinators, community liaisons, agency staff, and insurers. Join us to see your facilities through a new lens and identify ways to use local infrastructure and essential services more productively.
Join SCS Engineers as Platinum Sponsors at the WSWRA 2026 Annual Conference—an engaging week of insightful presentations, valuable networking, and meaningful discussions with waste and recycling professionals from across the region. This annual gathering brings together industry leaders, technical experts, and peers to share knowledge, explore innovative solutions, and strengthen connections that move the industry forward.
As a longtime partner tosolid waste and recycling organizations, SCS is excited to support this year’s program featuring:
• Engaging speakers and technical sessions
• Insightful vendor exhibits
• Opportunities to connect with peers and reconnect with colleagues
Be sure to visit the SCS booth to meet our team and learn how we can support your environmental and engineering needs.
We’re also proud to share that members of our RMC team—Melissa Russo and Sean Gordon—will be speaking on Wednesday, August 18th.
Don’t miss this opportunity to expand your knowledge, connect with industry experts, and be part of the conversation shaping the future of waste and recycling.
Click here for more details and registration information
Join solid waste and infrastructure experts on July 15th as ASCE and SCS Engineers explore emerging issues and critical solutions in solid waste infrastructure. The event, Making the Grade: Solid Waste, follows the release of ASCE’s 2025 Report Card for America’s Infrastructure, and will examine how solid waste infrastructure is performing across key criteria including safety, resilience, capacity, and innovation.
The conversation will highlight report findings, supporting rationale for the solid waste grade, and a look ahead to key solutions. Additionally, panelists will discuss on-the-ground experiences linking the report to practitioner experience.
Featured panelists include:
Register Here: https://zoom.us/webinar/register/WN_O0ViL8AuQkicEy7P9lrFgw#/registration
SCS Engineers will be at the 40th Annual Environmental Permitting Summer School (EPSS) conference. This program takes place July 21–24, 2026, at the JW Marriott Marco Island in Marco Island, Florida. Bringing together more than 1,200 attorneys, consultants, engineers, government officials, developers, and industry professionals to explore the latest developments in environmental permitting, energy, and growth management across Florida.
The conference features 300+ expert speakers, 80+ interactive breakout sessions, and an exhibitor program showcasing innovative solutions and emerging trends. Attendees can earn continuing education credits while gaining practical insights into evolving regulations, policies, and best practices.
SCS is proud to have a team of experts attending the conference including, Brittney Odom, Gina Rodriguez, Marco Hernandez, Chris King, Steven Freund, Som Kundral, Neil Campbell, Joshua Blanco, Justin Craig, Leslie Smith, Tom Mesk, and Katie Megar. Come see us at Booth #203.
Brittney Odom will be presenting two sessions during the conference: Land and Golf Course Redevelopment: Opportunities and Challenges on Wednesday, July 22 and Remediation and Site Closure Strategies: Practical Solutions to Complex Sites on Friday, July 24. These sessions will explore key environmental considerations, redevelopment opportunities, and practical approaches for addressing complex site challenges. Connect with the SCS team to learn how we help clients navigate environmental permitting requirements, site redevelopment, remediation, and regulatory compliance while delivering sustainable, practical solutions.
SCS is also proud to sponsor the inaugural Roots of Adventure Kids Event, a hands-on environmental education experience hosted in partnership with the Florida Department of Environmental Protection at the Rookery Bay Environmental Learning Center. Designed for children of registered EPSS attendees, the program offers guided boat tours, estuary touch tank experiences, interactive exhibits, and opportunities to learn about wildlife, water quality, mangroves, and coastal ecosystems through engaging activities.
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
Need support? Feel free to reach out to us. We are happy to have a chat with you!
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