A great way to gain competitive advantage or close more sales is to provide a complete solution for your clients. Part of the solution that is often overlooked, in Ontario, is air quality permitting. Air Quality permits can cause additional fees for your client and strain your relationship with your clients, if not included. ORTECH has seen this time and time again when clients call us and suggest their solution provider failed to educate them on air quality permitting.
With all the regulations in Ontario, it is tough to keep up. If the equipment you are selling is triggering an Ontario Environmental Approval, this document is for you. If you are not sure, just keep reading, the regulations have changed. This article is geared towards Original Equipment Manufacturers (“OEM”), service providers or installers of equipment to industry or commercial operations in Ontario.
Air Quality Permitting: The Basics
For air quality permits in Ontario, any time a business installs new equipment, or upgrades existing equipment, that project might trigger a need for a new or amended air quality permit. On the basic level, your clients will need a permit if their equipment, new or old, emits emissions, noise, or odour into the environment.
For your clients, this is what you need to know. Ministry of Environment, Conservation and Parks (“MECP”), formerly Ministry of Environment and Climate Change (“MOECC”) has inspectors that will blitz an industry, so there is always a threat of getting a compliance letter and having to move fast to comply with an inspectors request. This can mean costs for your clients that they did not expect. It will take their eye off of their core business and for the most part, will be looking to you, the OEM or installer, for answers.
As a vendor selling equipment, it is a good idea to review your offerings and see if they are potential triggers for a new air quality permit or amending of an existing permit. This is where an Air Quality Expert, like ORTECH, can assess your situation.
To start, there are two types of Environmental Approvals in Ontario. Depending on the nature of your clients business activities, you will apply or register for one of the following:
- Environmental Compliance Approval (“ECA”)
- Environmental Activity and Sector Registry (“EASR”)
An EASR is a virtually instantaneous approval with less ongoing annual requirements as compared to the traditional ECA.
Let’s back up and define each compliance path, ECA and EASR. These hyperlinks will take you directly to the MECP website specific to each compliance path. Determining which compliance path is right for your clients is dependent on the complexity and uniqueness of the operation. For more complicated operations, with higher potential for environmental impacts, an ECA is typically required, and the EASR is used for more common activities or operations with less potential impact. The following helps define these different levels of complexity outlined in the regulations.
One of the fastest ways to determine your compliance path is to use the industry North American Industry Classification System ("NAICS") codes. The default MECP approach is that all activities and sectors go through the EASR process unless expressly excluded by the Regulation. The following NAICS codes are specifically excluded from the EASR process.
Does Permitting apply to my equipment?
Now, ORTECH has been in the business of Air Quality consulting for over 40 years, so it's not realistic for an OEM or installer to be expected to know all the intricacies of an ever-changing regulatory process. This is where the next graphic should help. Also, you will have the option to call us and discuss your equipment compliance requirements below.
This graphic will help you if your equipment category is not there, please contact ORTECH.
If your equipment is on the list above and it has been confirmed that your client will need an ECA or EASR, what can you do? Being proactive is one approach that will not only add value to your offering but also differentiate you from your competition. To add value, our suggestion is to get as much of the supporting documentation ready or prepared and provide it as part of your proposal package. This could be in the form of an Air Permit Package. Even though most permits are very site-specific regarding emissions or points of impingement (think: closest neighbours that will be affected by your emissions), you can still provide emission factors, odour units and noise levels. This information will help your client through the air quality permitting process.
If you are interested in an assessment of your solutions or equipment, please contact us.