Differences Between Air Quality Assessments for Permits and Full Impact Assessments
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As you are likely aware, Canada takes its protection of the environment very seriously. There is a network or hierarchy of legislation that ensures the preservation of clean air, water, valuable natural resources, and habitats.
As a business involved in manufacturing of any sort, it is essential to have a valid air quality permit in order to comply with Ontario’s Ministry of the Environment, Conservation, and Parks (MECP) regulations on this count.
This regulatory body oversees operations that are to be compliant with emissions standards. There are guidelines (the A-10 Guidelines on Emissions Summary and Dispersion Modelling [ESDM] Reporting) that direct operators on the proper development patterns accounting for surrounding residential, industrial, commercial, institutional, and open space uses.
Although, in most cases, air emissions compliance is tested at the proponent’s property boundary, using regulatory models such as SCREEN3 or AERMOD, there are some cases where “on-site” receptors must be assessed. This is the case if you have separate tenants on-site, or if you operate in an industrial “mall”. In the case of industrial malls, there may be further requirements to assess for “same structure” air contamination.
Same structure assessments are required where you are not the only occupant of a contiguous building. Airflow patterns around buildings, carrying away emissions, differ from airflow away from isolated industrial complexes. Those airflow patterns around buildings can transport your emissions to openings (doors, openable windows, garage doors) of neighbouring tenants, and cause an air quality impact. For so-called “same-structure” contamination, the ASHRAE model must be used.
It is important to know what the requirements are in order to obtain an air emissions permit; air pollution permits in Ontario are of two types – either an Environmental Compliance Approvals (ECAs) or Environmental Sector Activity Registrations (EASRs) – my other blogs explain the difference between the two.
The Provincial Policy Statement 2005 (PPS) states that all municipal land use policies must be consistent with a set of requirements. In broad terms, the PPS states that land use patterns within settlement areas shall be based on densities and a mix of land uses which avoid or minimize negative impacts to air quality and promote energy efficiency in general. This is usually assessed in cases of re-zoning, or other actions taken under the Planning Act. Planning Act assessment requirements are more stringent than permitting requirements as they should conform to the PPS which uses the term “adverse effects.” The only way one can assess for adverse effects is by conducting a complete air quality impact assessment.
Air quality impact assessment for permitting are based on the specific requirements set forth by the MECP and, in general, do not require baseline air quality to be accounted, do not require certain contaminants to be assessed (e.g., PM2.5 and PM10) and do not require tail-pipe emissions from vehicles to be assessed. If you’re interested in a fuller explanation of the differences you can read a paper I co-authored and published in the Ontario Planning Journal in 2015. For a developer, this means the following patterns or practices will gain you points in applying for an air quality permit
- Large property lots (for easier air and noise compliance)
- Distant from Housing clusters or other “sensitive receptors” (for easier noise compliance)
The general idea is clear of course. Land Use Planning should (in theory) alleviate any problems encountered in permit applications. But since environmental land use compatibility is often not appropriately assessed this may leave industry with environmental liabilities which may not be eliminated by having an emissions permit in place. Which is why it is highly recommended to acquire the services of an environmental consulting company that will assist you in navigating this complex field.