by Brian Sulley
Ontario’s lengthy environmental compliance approval (ECA) process has been a significant roadblock to many businesses. At RWDI, we have consistently seen approvals take more than a year—and sometimes as much as two to five years.
A change that aims to fix this problem took effect on January 1, 2017. The Ministry of the Environment and Climate Change (MOECC) adopted a new regulation (O. Reg. 1/17) that will streamline and expedite the approvals process for a wide swath of the regulated community.
The new process will mean immediate approval for many applicants. The fee structure may also be attractive. However, the process for preparing the application will be different.
The bottom line: If your facility has air or noise emissions, you will need to revisit your approach to documenting environmental compliance.
So, what does this mean for you? For universities, colleges, hospitals, and many small to medium-sized industrial facilities with air emissions, the benefit to you will be immediate and significant. For industrial facilities, the impact will depend on the industrial classification under which your business is registered.
Whatever your sector, the application process will change. The key difference is that the application must be “signed and sealed” by a licensed engineering practitioner (LEP). With this signoff, the engineer is attesting that the application is correct. When the signed and sealed application is deposited at the MOECC website, approval is immediate.
The new signoff means that your engineering consultant is putting his or her reputation on the line based on your data. So the engineer may ask you for more, and more rigorous, data.
For this reason, it’s even more important for both you and your engineer to invest in developing a strong partnership that focuses on working together to evaluate your operations. As a partner, your engineering consultant can help you identify the most cost-effective ways to present a strong compliance application.
This kind of partnership has always been a hallmark of how we work at RWDI. We’ll be working collaboratively with clients to evaluate their data and collection processes. Site visits will be more critical, or even mandatory in cases where we’re not directly familiar with the facility. If robust data collection isn’t in place, we’ll help design new procedures that are effective and efficient. As a partner, we may also participate in the client’s decision process, so we can provide input at critical decisions that affect regulated activities.
Ontario Regulation 1/17 may be only the first change to the ECA process. Further regulatory changes are proposed that could exempt many other facilities from the air and noise approvals process. We see the adoption of this regulation as a good opportunity for facilities in all sectors to refresh their approach to environmental compliance.
I’ll talk about the shifting landscape of environmental compliance in the webinar Evolution of the Ontario Environmental Compliance Approvals Process – What’s Changing, and How Will It Affect Your Facility? on March 22, 2017.