Agricultural growing and harvesting operations are typically exempt from air planning, permitting and odor nuisance regulations. However, cannabis operations may require approval from the local Planning Commission. They may also require air permits from the local air regulatory agency for manufacturing operations (e.g., for solvents and associated combustion equipment such as boilers). Air permit applications for cannabis manufacturing operations may include the following based on project-specific conditions:
In addition to these permitting services, and to avoid costly nuisance complaints, cannabis growers may also need odor-related services such as:
While these may seem like imposing lists for air planning they are not for engineers who work in the industry.
Developing effective plans to mitigate odors is vital in gaining Planning Commission approvals which often depend upon resolving concerns raised by the public. Comprehensive OAPs and OMPs include odor control Best Management Practices (BMPs) and adaptive management strategies for responding to odor complaints when cannabis operations are near residences and schools.
Odor Control – Odor Nuisance Mitigation Case Study
Cannabis greenhouses in the Carpinteria, California region were causing off-site odor nuisances at nearby residences. The inherent smell needed addressing, as odor-neutralizing vapors along cannabis greenhouse perimeters and ridgelines were not providing adequate odor control.
Working with Cannabis Association for Responsible Producers (CARP) Growers, Pacific Stone, Groundswell, and Envinity Group, SCS Engineers utilized its air quality and odor expertise to collect continuous measurements using our SCSent-i-PED (Pollutant and Environmental Data). SCSent-i-PED is a state-of-the-art method for measuring TRS compounds to the parts per billion (ppb) level. The system can assess concentrations in real time, and a single machine can assess multiple locations and sources within a facility. This method successfully assessed relative odor levels and spatial/temporal fluctuations in odor-causing emissions.
Data collection is vital and useful to:
SCS, through its years of experience in air quality and odors, provides cost-effective, sustainable solutions that enable greenhouses and facilities to coexist in urban and suburban environments. Our clients not only get solutions, but they also have the data and science to understand better how odors behave and vary within a cannabis greenhouse.
To learn more, watch a video about air planning and managing greenhouse odors at https://www.scsengineers.com/services/clean-air-act-services/odor-monitoring-and-control/
About the Author: Paul Schafer is a Vice President and Project Director at SCS Engineers and the firm’s National Expert on Ambient Air Monitoring. During his technical career, Paul has assumed key roles in several nationally significant monitoring efforts. He has in-depth experience interfacing with regulatory agencies regarding the performance of monitoring systems, source emission tests, and continuous process monitors, which SCS operates for our clientele. He has had direct working experience with multiple local, state, and federal agencies regarding monitoring programs and air quality impact assessments. As with all solutions at SCS, cost control management and defensible technical performance are primary goals integral to all sustainable monitoring programs.
In its October 28, 2022, meeting, the Virginia Waste Management Board voted to adopt changes to the Virginia Solid Waste Management Regulations known as Amendment 9. Amendment 9 was initiated several years ago, and the amendments address issues that have arisen since the previous amendment. The changes involve updated standards for siting, operation, and monitoring of landfills as well as revising exemptions for open burning of waste. Following adoption by the Board, the amendment is now undergoing Executive Branch Review.
Some of the key changes that are part of this amendment include the following:
About the Authors:
Josh Roth, PE, is a Vice President and Project Director with the Landfill Gas (LFG) Group in the SCS Reston, VA office. He supports LFG engineering projects involving remediation system design, emissions inventories and air permitting, migration and odor control, ambient air sampling and reporting, LFG and CER due diligence projects, GHG emission mitigation and reporting, field sampling and assessments, and general emissions control projects.
Mike Mclaughlin, PE, JD, is SCS Engineers’ Senior Vice President of Environmental Services. He is a licensed engineer and attorney with over 40 years of professional experience providing advice on environmental matters. He is an expert on environmental compliance, remediation, and allocation of response costs. He is a member of the Board of Governors of the Virginia State Bar Environmental Law Section, and Budget Officer of the American Bar Association’s Section of Environment, Energy and Resources (ABA SEER).
Companies face intense pressure to drive sustainability across their operations as regulators, investors, and young professionals ask for more efforts to tackle Climate Change. This year alone marks several monumental events. Among them is a proposed Securities and Exchange Commission (SEC) rule requiring businesses to disclose climate risks, including greenhouse gas emissions. And United Nations COP27, where public and private decision-makers worldwide continued ongoing collaboration to strategize on meeting the Paris Agreement goals.
Forward-thinking, sustainability-conscious companies, are responding to the proverbial “writing on the wall,” trying to figure out their carbon footprint and how to reduce it. Professionals whose first call is to protect the health of the communities they serve are at the forefront of this sustainability movement.
The success of initiatives hinges on careful attention to every step and the presence of many integral components between them. Environmental, Social, and Governance – ESG and applying these non-financial factors as part of a sustainability analysis process identifies material risks and growth opportunities. Achieving the outcomes you aim for commands a robust, rounded approach that accounts for greenhouse gas emissions; energy, water, and land use; and waste management, among variables that impact carbon footprint.
“The job commands meticulous reporting and data analysis skills to measure and understand the impact. And it calls for a whole menu of technical and business competencies to deliver a comprehensive strategy that is both economically and environmentally sustainable,” says SCS Engineers’ Director of Sustainability Ajay Vonkarey.
About Ajay Vonkarey
Vonkarey, new to the national environmental consulting, engineering, and construction company, is a seasoned civil and environmental engineer with years of experience as a sustainability professional.
Vonkarey’s forte is building and supporting teams that develop and execute sustainability roadmaps. He leads a multidisciplinary team at SCS in helping customers plan, executes, and report on similar strategies to lessen their carbon footprint as they reach for zero waste and other ambitious goals.
“This is a good marriage of my background and experience in planning for sustainability and the broad and extensive environmental experience of SCS, which has long recognized the importance of responsibility to people and the planet,” Vonkarey says.
Taking a Holistic Approach
Clients turn to SCS for assistance with air, water, and soil compliance and reporting, greenhouse gas monitoring, inventories, and verification. And they come for support in ensuring efficient resource utilization while reducing carbon footprints—whether converting methane into clean, renewable energy; redeveloping idle brownfields into vibrant community assets; or designing and building compost and recycling facilities.
Now SCS is expanding its services in response to evolving industry demands driven by changing environmental and economic conditions and tightening regulations. Vonkarey is building a multidisciplinary team from the firm’s pool of experts to offer more support as clients opt to take their sustainability work further or close the gaps between plans and measurable outcomes.
“SCS has worked for decades on ‘the downstream’ end of sustainability—designing and executing projects for improved environmental outcomes. We are leveraging our expertise to deliver a holistic, balanced approach, beginning upstream— with the work that must happen at the start of the journey. We stay with the client through every step in between to ultimately provide successful end-to-end sustainability solutions,” Vonkarey says.
The multi-faceted process starts with an asset assessment, which starts with a Materiality assessment, broken down by each asset and its emissions.“We examine the consumption and utilization of these resources. The data we capture tells us, do we focus on real estate? Do we need to look closer at our energy or water utilization?”
This information also informs deeper decisions associated with the next step, which is to build a roadmap. This detailed plan will guide the integration of clients’ sustainability goals and strategies across their businesses.
“Once we have the roadmap in place, we will do what SCS has done for the past 52 years: execute those plans and collect and verify data to report outcomes. That data ultimately informs how to improve efficiency moving forward and reach the NetZero goal faster,” Vonkarey says.
While strategically approaching every stage is critical to delivering comprehensive sustainability solutions, as important is to have a full-service team in place. Rounded expertise is essential to devising technically sound solutions with lasting environmental and economic benefits.
“We have scientists, geologists, civil and environmental engineers who design and build projects. We have technology developers and specialists who collect, manage and analyze data. And on the business side, SCS has financial staff to inform smart investments and human resource management,” says Vonkarey.
Meanwhile, operators remain focused on other endeavors that need their full attention: their day-to-day operations, bringing in new customers, and expanding their markets. At the same time, as new climate policies and rules are rolling out and emission reduction targets increase, they have plans to meet them.
An Optimistic Outlook
“We read the headlines about Climate Change too, but our perspective differs from that of many stakeholders. At SCS, we are greatly encouraged by the extensive efforts already started. We want to help operators understand what is and will be expected of them as they are called on to address environmental issues. We can show how those expectations relate to their specific business. And we can help ensure their investment in the most appropriate, sound strategies. Together, we can make the planet better,” Vonkeray says.
EPA has opened applications for Federal recycling and composting grants. These grant programs are SWANA-supported and may assist in funding education and infrastructure. The EPA program is divided into two areas providing states, municipalities, and other entities the opportunity to apply for millions of dollars in funds. The Solid Waste Infrastructure for Recycling (SWIFR) and Education and Outreach Grant Programs were established by the Save Our Seas 2.0 Act and the Bipartisan Infrastructure Law.
EPA will be accepting applications for both programs through January 16, 2023.
The SWIFR Grant Program provides $275 million over five years for states, municipalities, and tribes to:
The Recycling Education and Outreach Grant Program provides $75 million over five years to states, municipalities, tribes, non-profit organizations, and public-private partnerships to:
Nena Shaw, EPA Acting Director for the Resource Conservation and Sustainability Division, will speak about the grant programs and related EPA waste-related initiatives during her keynote presentation at WASTECON 2022 on Thursday, December 8, in San Diego, California.
Note that $100 million of this funding is available to help build and transform solid waste infrastructure, manage materials to achieve a circular economy, reduce greenhouse gas emissions, and create cleaner, resilient, and healthier communities through composting and organics management programs.
Please contact your SCS program manager or one of our national experts to learn more or get support with your application. We’re always here to help.
The Young Professionals Planning Committee (YPPC) recently got together in Long Beach, California, for our annual meeting. During the meeting, we set goals for 2023, laid out the 2023’s calendar of events, elected new officers, and participated in team-building activities. Team building activities included reviewing our DiSC profiles, tower building focused on cooperation and communication, and a cooking class, whipping up So-Cal favorites with Mexican-themed dishes. The meeting kicked off the new YPPCs tenure, consisting of 13 members from 8 business units representing our Young Professionals across the nation.
The SCS Young Professionals Program was established years ago and includes all employees at SCS Engineers who are 40 years of age and under. The YP Planning Committee produces the Program content and acts as a liaison for the Program between SCS YPs, corporate leadership, and at Board of Directors meetings.
Our membership is spread across various regions of the country to represent the entire company.
We offer a variety of resources and activities for all YPs, including:
For more information check out these pages:
Hydrogen is commonly produced using steam methane reforming (SMR), which requires heat, a catalyst, and feedstock such as natural gas. SMR operations generate atmospheric emissions from combustion and process vents which may require air permitting. Air permitting can be a complicated process that delays facility construction and project start-up.
Comprehensive feasibility studies include phases to facilitate pre-application meetings and submission of a complete air permit application in a timely, cost-effective manner. Based on our case studies, SCS suggests a four-phase approach.
Phase 1: Preparation and Due Diligence
To begin the evaluation, your engineer compiles all available project information, such as plot plans, process flow diagrams, equipment lists with specifications, zoning, grading, and utilities. Since project specifications are subject to change, your engineer must remain flexible and iterative in their analysis approach as new data becomes available.
Phase 2: Emissions Analysis
The next phase is to calculate the project’s potential to emit criteria pollutants and greenhouse gases (GHGs). The calculation assesses potential requirements for Best Available Control Technology (BACT), emission offsets, Title V, and climate change mitigation. Always use an engineering firm with expertise in GHG emissions inventories and third-party verification of GHG emission inventories and reduction credits. Here’s why, based on the analysis, your engineer will be looking for these factors to smooth the application process:
Project emissions complied with BACT limits based upon a comparison to other permitted SMR facilities.
Project emissions that require the purchase of carbon credits on an ongoing basis to comply with Cap and Trade regulations.
Project emissions that do not trigger the need for emission offsets or Title V.
Phase 3: Regulatory Review
Conducting a regulatory review will identify potential requirements from local regulations such as California’s South Coast Air Quality Management District (SCAQMD). Using SCAQMD as an example, the project must comply with the additional rules.
Phase 4: Results and Conclusions
The comprehensive feasibility study summarizes the potential air quality permitting thresholds, requirements, costs, and schedule for your project. It includes all conclusions and supporting data for decision-making. With a comprehensive study in hand, your project is more sustainable, and you have valuable answers during discussions leading to obtaining a complete air permit.
SCS has over 50 years of environmental experience and trusted working relations with regulatory agencies. Many local, state, and federal agencies attend our free webinars, and industry associations request our input and insight when agencies are planning new rules. We serve as expert witnesses. If you’d like to learn more about developing air permitting strategies and applications, visit our website or contact us at .
About the Author: Greg Hauser is a Project Director responsible for environmental compliance projects. Greg brings over 30 years of experience with compliance topics such as air quality permitting, emission inventories, dispersion modeling, health risk assessments, and odor impact assessments. He surveys facilities to identify sources of interest, collects field samples of odorous emissions, develops odor emission profiles based on odor concentrations and flow rates, and conducts dispersion modeling to predict odor concentrations at or beyond the facility’s property boundary. He also provides health risk assessments for aerospace, manufacturing, wastewater treatment, and oil and gas facilities.
Applying the Lessons Learned – 1383 Compliance to your composting and food recovery planning can help make your program more sustainable.
SCS Engineers developed an SB 1383 Roadmap, which we customized for each municipality. The Roadmap outlines the requirements of SB 1383 by topic and by the responsible party. The Roadmap helped municipalities to plan for SB 1383 compliance, including a schedule for implementation, monitoring, reporting, and enforcement. Because SB 1383 is not only the responsibility of the Solid Waste Department, the Roadmap outlines the responsibilities of other municipal departments, including Administration, Finance, Purchasing, Fleet, Parks, etc.
SB 1383 requires the completion of capacity studies for organic waste recycling and edible food recovery. The Organic Waste Recycling capacity planning includes collecting data on the amount of organic waste (in tons) that will be disposed of, the amounts in tons of existing organic waste recycling infrastructure, both within and outside the county, that is available, and the amount of new or expanded capacity that will be needed to process the organic waste identified as being disposed of.
For the edible food recovery capacity planning, the counties had to estimate the amount of edible food that would be disposed of by commercial edible food generators, the existing capacity for food recovery organizations available in the County, the proposed or expanded food recovery organization that will be used to recover the edible food generated, and the new or expanded capacity that is necessary to recover the edible food that is generated.
It is a challenge for municipalities to meet these requirements, but feasible and sustainable using the SB 1383 Roadmap. Learn more on Wednesday, January 25, 2023, at the USCC Compost 2023 conference. During Session D1, the California Track Regulatory Trends and Experience at 8:15 – 9:45 am, Srividhya Viswanathan and Michelle Leonard discuss the Lessons Learned – 1383 Compliance, much of which is applicable for many evolving programs nationwide.
Glenn Haave has had a close relationship with protecting our environment for years, ever since his days working on the ocean towing ships in and out of ports. He figured his deep appreciation of his natural surroundings and desire to protect them might carry into his chosen career path, especially after earning a Bachelor of Science in Geology. But when he came to SCS Engineers as a high-spirited, new graduate, he had no idea of the opportunities that would come his way— both at SCS and serving in the U.S. Coast Guard Reserves.
“Both SCS and the Coast Guard hold you accountable to rise to the occasion and get the job done. With that trust and delegation of responsibilities, I am challenged to become a leader, which gives me a sense of duty and confidence,” Haave says.
Combining Geology, Hands-On Experience, and Teamwork
Starting at SCS doing groundwater and soil sampling and helping remediate landfills for redevelopment, Haave proved to be a fast learner. Quickly building on his skills, he was presented with a unique proposition– to join one of only a few multidisciplinary teams in the country that design and install deep well injection infrastructure. EPA-approved injection wells are safe for placing fluids underground into porous geologic formations. These underground formations may range from deep sandstone or limestone to a shallow soil layer. Injected fluids may include water, wastewater, brine (salt water), or water mixed with chemicals.
Planning, permitting, and executing these projects is a multifaceted undertaking encompassing geologic consulting, reservoir engineering, and deep drilling, with environmental protections and sustainability as core goals.
“Few geologists ever get to work on this type of job. These projects require a lot of capital, time, and very specialized expertise. I was fortunate to be working at SCS’s Miami office at the right time, able, and willing,” says Haave, drawn to complex tasks calling for a razor-sharp eye for detail, focus, and discipline.
Drawing on his experience supporting the Miami-Dade Water and Sewer Department Ocean Outfall Legislation Injection Well Program, where he saw 11 wells constructed in a demanding, high-profile project, he is now on a multidisciplinary team of SCS professionals.
Innovations in Carbon Sequestration – Protecting Our Environment
Now, he takes on a new charge: working on a type of deep injection well called a Class VI well. This sophisticated infrastructure directs carbon dioxide (CO2) liquids and gases into the ground for long-term storage. A fairly new, EPA-approved carbon sequestration technique, it is proven effective at substantially reducing CO2 emissions to the atmosphere.
“Class VI wells are an exciting evolution as the world looks to decarbonize the economy. I feel like I am part of an extraordinarily innovative solution where I am using my background to support a global effort to impact our climate positively,” Haave says.
“I feel a sense of purpose in that we are helping mitigate exponential global warming. At least as important, I am comforted that what we do brings hope that my son, daughter, and their generation will grow up on a healthy, safe planet.”
Another Dimension – U.S. Coast Guard A School
As he embraces this unique opportunity to help the environment, he celebrates another milestone: graduating from U.S. Coast Guard A School and advancing in rank to Marine Science Technician Petty Officer Third Class. His calling will be responding to pollution incidents to protect U.S. waters and inspecting facilities and container vessels that transfer hazardous materials to and from land.
Getting into the Reserves is not easy, nor are the next steps. Making it into A school after boot camp is typically a two-year journey: the waiting list of accomplished graduates is long.
Haave finished three intensive months of classroom work; mock training in the field, morale-building exercises to keep spirits high while away from family and friends, and a battery of testing.
Through these rigorous trials, he took on the honorary role of Master at Arms, leading and mentoring his shipmates and serving as a liaison between the crew and captain.
“Becoming a Coast Guardsman was like a dream come true. It was something I had wanted to do since I was 19. But I needed time to mature. I did a lot of soul searching before I could fully realize what was entailed in living up to Coast Guard expectations; to truly embrace that it’s about a sense of duty to country and family, and to deliver on that conviction,” says Haave, now 37, and nominated as a most inspirational person by his shipmates and instructors.
When he shared his long-envisioned, materialized aspiration with his SCS supervisors, he was unsure what they would think; he was taking on another big commitment.
“They were not only accommodating, but they are proud. SCS Engineers is a military-friendly organization. They are always supportive, flexible, and believe in me.”
In the Coast Guard, he had a choice from a far-encompassing list of specialty areas, given his high military school entrance score. He chose marine science technology because it tied in with his civilian work – navigating and ensuring adherence to federal regulations and being a steward of the environment.
Gazing back at how far he’s advanced in just the last few years, then looking forward, Haave says, “You know, I’m just 37 years old. I feel like I have a lot more in my gas tank –the amazing experiences I have been fortunate to have are just the beginning. I see more opportunities to advance as a leader and to become an even more rounded geologist, able to approach every project comprehensively and deeply.”
We thank all of our veterans and appreciate Glenn Haave for his service to the U.S. Coast Guard and his commitment to protecting our environment with SCS Engineers by advancing sustainable environmental practices and solutions.
Find out more about carbon sequestration and greenhouse gases:
Video: Building a Well
Information: Deep Well Injection and Sequestration Wells
Safe engineering takes discipline and teamwork –qualities that have always served SCS and our clients with innovative, proven solutions for running operations more efficiently and greener. For a rewarding career, consider SCS Engineers, where all employee-owners have a vested interest in every solution.
Protect Our Environment and Controlling Climate Change
The ISWA World Congress attracted 1,200 participants this year despite the pandemic and received major coverage in the news while heating up social media channels. The Business Times Singapore published an 8-page supplement and a feature article about James Law and his views as Chair of the ISWA Landfill Group on what we, as individuals and communities, can do to protect our environment.
Featured speakers included Alex Stege and his Solid Waste Emissions Estimation Tool (SWEET) used in a project in Tyre Caza, Lebanon. SWEET allows solid waste planners to compare emissions from implementing different programs and quantify the effectiveness of available waste management options in reducing emissions of GHGs and air pollutants.
Alex presented during the Waste Management In An Era Of New Energy track. His discussion covered Evaluating the Energy Potential of 16 Landfill Gas to Energy Projects in China to be financed by the International Finance Corporation (IFC). There are 24 landfill gas-to-energy projects in China, including ten sites already under operation. In 2021, IFC hired SCS Engineers to evaluate the NCWI estimates and prepare a report providing independent LFG generation and recovery projections for the 16 landfills. The project developer (NCWI) provided IFC with waste data and LFG generation and recovery projections for 16 of their project site landfills from the report indicating a sufficient supply of recoverable LFG to support their planned facility capacities.
SCS Engineers was asked to comment to the NWRA and SWANA industry groups in their October 6 letter to U.S. Environmental Protection Agency on the proposed new EPA rule changes for GHG reporting. SCS’s deep expertise and knowledge of GHG monitoring and reporting, especially GHG rule k values, help inform the revisions and determinations for data elements under the Greenhouse Gas Reporting Rule. Ref. Docket ID No. EPA-HQ-OAR-2019-0424.
It is wonderful to see ISWA and SWANA in leadership roles to help us meet a global challenge!
Biosolids Composting – Award Winning Facility in Hillsborough County – Environmental Category
The Planning Commission celebrated its 40th Annual Planning & Design Awards at a ceremony in late October. The event is in conjunction with a nationwide celebration of the American Planning Association’s National Community Planning Month.
The County Planning Commission recognized a joint effort between the County Board of County Commissioners, the Solid Waste Management Department, the County Water Resources Department, and SCS Engineers with its 2022 Excellence Award.
Hillsborough County combines tons of mulched yard cuttings and biosolids (treated wastewater residue) to create an in-demand soil amendment. Mixing, curing, and selling the product preserves disposal space at the Southeast Hillsborough County Landfill, saving taxpayers about $1.5 million in hauling, disposal, and other costs over five years. Selling the resulting soil supplement, meanwhile, adds new revenue.
Yard waste was traditionally burned to produce electricity or mixed with cover at the landfill. Treated wastewater by-products, known as biosolids, were trucked to the landfill for disposal, thus filling the landfill faster and, when combined with other organic matter creating greenhouse gases.
The plan to produce and sell compost results from a partnership between the County operations and SCS Engineers committed to finding a more efficient and environmentally friendly solution to reuse the two types of waste. The product meets stringent federal guidelines and regulations, providing a nutrient-rich material that safeguards consumers, crop production, and the environment.
Thanks to everyone who joined the celebration showcasing excellence in planning and design that contributes to the quality of life in Hillsborough County. If you’d like to learn more about this biosolids composting facility, please contact Kollan Spradlin or .
Communities across our nation are going greener, we suggest these educational resources: