[Emission]

Yes, you can change the pads without bleeding the brakes (just like you can replace the pads without turning the rotors).

However, you may need to pull some brake fluid from the system to get the new pads in the calipers (the retracting pistons will force fluid back into the reservoir and can spill over). Most of us bleed the brakes at this time because it is easy since the wheels are already off and you are right there...