Air Quality Consulting and Permitting in Ontario

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Air Quality Consulting and Permitting in Ontario
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Completing a Natural Heritage Assessment without losing your mind
By Andrea McDowell ([email protected] ) Reading time: 3 minutes 30 seconds
Environmental field work in support of an environmental assessment forms the bulk of the work required to gain regulatory approvals and permits for a new energy project. It’s also unpredictable, depending on factors such as terrain, results of preliminary field studies, ever-changing regulations and guidelines, and weather conditions. But take heart: there are steps that can be taken in the project planning stages to minimize delays and maximize the chance that your approvals will be received on time.
1. Complete a thorough constraints study before beginning Different kinds of habitats require different kinds of field studies at different times of year. Doing legwork to understand what features might be possible at your project site will allow you to work those restrictions into your schedule from the outset. While surprises can always arise later when biologists are on the ground—an endangered species found during botanical surveys, a sighting of a rare bird—a detailed constraints analysis will allow you to rule out many features in advance.
2. Gain (or hire) a thorough understanding of all of the Natural Heritage Assessment guidelines in Ontario Regulations can be misleading when it comes to Natural Heritage Assessments. The Renewable Energy Approvals regulation, for instance, states only that a “site investigation” must be done of all lands and waters within 120m of a planned project location. It would be easy to assume that detailed notes from a site investigation taking a single day would meet the requirement of the regulation. However, the Ministry of Natural Resources must be satisfied that the investigation conforms to their guidelines and protocols; and manuals detailing those guidelines and protocols run for thousands of printed pages. The details buried in those printed pages can make or break your project schedule. It is imperative that whoever is planning your Natural Heritage work know what studies need to be done at what time of the year; if you don’t get your amphibian surveys underway by March or April, depending on where in the province you are, you will be waiting until next March or April to begin. Similarly, many studies can only be conducted under certain weather conditions—light or dark, above 8C or 20C, sunny or cloudy.
3. Use pre-construction survey commitments to your advantage wherever possible In some cases, it is possible to defer certain kinds of habitat usage surveys until after completion of the Environmental Assessment documents, if the habitat is treated as significant in the reports with all appropriate mitigation measures factored in. If the habitat turns out to be significant when later evaluated, the appropriate protections are already in place; if it’s not, those mitigation measures and other commitments no longer apply. This process is well-developed with Renewable Energy Approval studies, but it is also worth trying with other EAs where waiting for the appropriate time for necessary studies may put a project at risk. This will depend on negotiations between the Ministry of Natural Resources and the biologists who will be undertaking the field studies.
4. Beware turnover Some government agencies have high rates of turnover thanks to a dependence on short-term contract staff. The regulator you are dealing with today may no longer be around when the reports are submitted for final approval. While it is tempting to accept if a regulator offers to cut you some slack on the timing restrictions of a particular study or the specific work involved, keep in mind that the final decision-maker may have a different perspective; if you end up needing to re-do some portion of your program, it can end up being more expensive and time-consuming than if you’d gone the long way around to start with. Know how much risk you are willing to assume with turnover rates at the agency you are dealing with, and add some buffer to your schedule in case you need to repeat a portion of your field work. Natural Heritage Assessments and the associated field investigations can represent 80% of the effort and time required to complete and environmental assessment—a situation often frustrating for project proponents and designers, who are used to the more structured and predictable worlds of engineering. However, the risks and uncertainties—if accepted and planned for from the outset—can be successfully managed, allowing your project to be constructed on time.
For more information on how ORTECH can assist your Permitting needs, visit our Environmental Assessment page or our page or email us at [email protected]
Agency Consultation
By Andrea McDowell ([email protected] ) Reading time: 3 minutes 30 seconds
Agency Consultation
Any consultation process has challenges that are unique to the stakeholder, and agency consultations are no different. While regulators are tasked with helping proponents structure field work programs and move their projects through the Environmental Assessment process, there are conflicting imperatives that can make this frustrating for all concerned. Ultimately—as proponents find during the process—regulators do not prioritize project budgets or schedules. Their belief, fair or not, is that budgets and schedules are the concern of the proponent and it is up to the proponent to meet all regulatory requirements without budgetary exceedances or project delays. Complaints about regulatory delays affecting project viability will have very little impact. To effectively engage with agency representatives, it is imperative to understand their point of view.
1. Politics
Regulators ultimately work for the Ministers in charge of their agencies, which means that they ultimately also work for the larger public. These loyalties are keenly felt by most civil servants. When a project or type of project becomes contentious, the potential political implications will make the agency very conservative.
Entire offices can be involved in responses to letters of complaint from the public, particularly regarding high-profile projects. Complaints from the proponent regarding time delays will be dealt with in a similar fashion. The preparation of letters, emails, briefing notes, and media lines is time consuming and, while staff are working on these, they’re not working on your project. No civil servant ever wants to see their Minister be questioned in Parliament over a project they are working on, which tends to mean that certainty is prioritized over efficiency. Reasonably certain, particularly in high profile cases, will not be sufficient. If you can assure a regulator that you know exactly what is going on, understand the process and the reasons for it, and have fully considered the issues they are most concerned with, they are more likely to feel safe when signing their name to your project.
2. Turnover
While the myth of the stable safe public service career is still alive and well, for most young civil servants this is no longer the case—in some Ministries more than others. It is possible for a front-line worker to spend a decade moving from one one-year contract to another, often resulting in changes in job title and description every April. Contract government workers often find the funding runs out for their employment around February or March and won’t be reinstated until May. If your main contact at a regulatory agency is a contract worker, it goes without saying that your project will be affected by this uncertainty. Some years, there will simply be no one on the job in late winter as the annual funding dries up and no new funding decisions have been made; progress will grind to a halt when an election is called; and the person you are consulting with today about the required structure of your field work program or hydrology analysis may not be the person evaluating the final work when it is done.
Try not to schedule crucial agency meetings or negotiations around year-end (April 1), as this is when staffing will be most severely affected. Avoid making agreements with regulators that are not likely to be approved of by his or her successor, if he or she is assigned to a different role and you are starting again with someone new. Effective agency consultation is essential to gaining the approvals necessary for a successful project. The key to gaining regulatory support for a proposal is understanding the agency’s mandate and perspective.
For more information on how ORTECH can assist your Permitting needs, visit our Environmental Assessment page or our page or email us at [email protected]
Paul Complin AWMA Fellow
The senior management of ORTECH Consulting Inc. is pleased to announce that Paul Complin will be awarded the AWMA Fellow. This award from the Air and Waste Management Association recognizes members that excel in two areas: professional accomplishments and service to the Association for a period greater than 15 years. ORTECH is very proud of Paul’s accomplishments, commitment to the industry, and overall enthusiasm. We all agree, Paul continues to be a strong leader in our compliance and permitting team.
A little about Paul…. Bio: Paul has over 30 years of experience in environmental engineering with an emphasis on air related issues. His areas of expertise include air pollution control, combustion processes, process analysis, inventory development, source assessment, audits, policy and regulatory development, abatement programs and waste management. Paul has held positions in government consulting, industry and government and has managed and contributed to a broad variety of projects in refineries, chemical plants, surface coating, manufacturing, steel, pulp and paper and other industries for new facilities and in developing amelioration programs at existing facilities to ensure their compliance.. Paul is a licensed Chemical Engineer in Ontario.
Is it a Wynne for the Environment?
By Andrea McDowell ([email protected] ) Reading time: 1 minutes 30 seconds
The recent Liberal majority win, while surprising, is likely to be good news for Ontario’s environmental sector—if only because decisions can now be made and implemented. With the pressures of the constant possibility of an election in Ontario now gone for a few years, many projects and agency decisions have been on hold, from the Long-Term Energy Planning and the RFP process for large renewables, to smaller decisions on individual projects still working their way through the approvals process. These should now start to move faster. Kathleen Wynne has no direct experience with environmental issues, either before entering politics or since; her cabinet experience includes stints with Aboriginal Affairs and Education. The environmental industry in Ontario can hope that her bridge-building in those Ministries will facilitate less controversial policies and projects over the coming years; however, the lack of direct experience is also likely to lead to mis-steps, as with her commitment to not siting renewable energy projects in communities that are not “willing hosts” (in response, all municipalities in Ontario with decent wind resources passed motions declaring themselves not to be willing hosts).
For more information on how ORTECH can assist your environmental assessment or due diligence needs, visit our Environmental Assessment page or email us at [email protected]
Archaeology and Cultural Heritage Assessments without panic
By Andrea McDowell ([email protected] ) Reading time: 2 minutes 30 seconds
Given the focus put on Natural Heritage and Public Consultation in the Class EA and REA processes, it’s easy to let the archaeological and cultural heritage assessments slide. This can be dangerous, as weather restrictions are every bit as real for archaeology as for natural heritage; it’s easy for a last-minute change to a layout to derail a project if the archaeological study has not been properly planned. Following are a few things to keep in mind: 1. Plan on snow It’s tempting to hope for good weather and plan your archaeological field surveys later in the fall or earlier in spring, but if Mother Nature has a long winter in mind, you could find your work and your project delayed by a season or three. Fields not only need to be clear of snow and crops, they need to be recently ploughed and weathered for at least a few weeks. Give yourself enough time to get the project location ploughed and weathered well before there is a chance of snow in the fall, or you could be waiting until April or May to get the field work done. 2. Plan on layout changes No matter how final your layout is today, there is always the possibility that it will be less final tomorrow. New noise receptors, new natural heritage information, new agency guidelines, new turbine model specs, geotechnical studies, and newly endangered species all have a way of shifting final turbine locations and roads by a few to a few hundred metres when you can least afford new field studies. Try to give yourself the space to move project components later when you need to by surveying a much larger area than you plan to use. If the budget allows it, you may want to consider having entire usable fields surveyed, as a single pass at the beginning over a large area is much less expensive than multiple smaller passes later on when project components shift. 3. Plan on agency delays Archaeological studies can take several months to review, revise, and receive confirmation letters for. Anticipate at least seven months between the submission of the report and receipt of the MTCS sign-off. 4. Plan on a cultural heritage study It’s tempting to push back against the requirement for a cultural heritage study, particularly if you are in a relatively undeveloped area with few apparent cultural heritage resources. However, cultural heritage studies typically cost less than $10,000, can be completed in a few weeks at any time of year, and take less time for agency review than archaeological studies do. They are typically the least troublesome part of any energy project approval application. Unless your project truly cannot afford the six weeks from contract signature to MTCS confirmation letter, consider completing the cultural heritage study before the MTCS requests it.
For more information on how ORTECH can assist your Permitting needs, visit our Environmental Assessment page or our page or email us at [email protected]
Ontario's Long Term Energy Plan
Ontario Ministry of Energy Embraces Energy Storage as part of the Long Term Energy Plan (LTEP)
TORONTO – Dec. 2, 2013 – The Ontario Energy Storage Alliance (OESA) commends the Honourable Bob Chiarelli, the Ontario Minister of Energy, for recognizing the role of energy storage in the Long Term Energy Plan (LTEP) announced today. The Ontario Government’s plan to include storage technologies in its procurement process starting with 50 megawatts by the end of 2014 recognizes the important role innovative storage technologies can play to make our electricity system more flexible and efficient.
“Energy storage offers new options and capabilities for a modern, efficient, reliable power system that will make better use of Ontario’s clean energy resources” said Cam Carver, OESA Chair. “We look forward to participating in this important initiative and helping to achieve appropriate regulatory treatment for energy storage.”
OESA represents a broad alliance of Ontario-based organizations that design, develop and operate energy storage projects, products and services. The full spectrum of energy storage technologies are represented among its members, including advanced batteries, flywheels, compressed air, power-to-gas, pumped hydro, and thermal storage. Ontario is home to a cluster of world-leading energy storage technologies. The scope and scale of applications also varies but includes everything from behind-the-meter storage systems for retail customers, to large grid-scale storage solutions that mitigate the intermittency of wind and solar and harvest the persistent surplus of off-peak generation capacity.
“This is great news for energy innovation in Ontario” said Jon Dogterom, Cleantech Practice Lead at the MaRs Discovery District. “The worldwide market for energy storage technologies is growing quickly, and is projected to be worth $30 billion within a decade. By rolling out made-in-Ontario energy storage technologies at home, we strengthen our domestic grid and set ourselves up to capture this global market.”
OESA will be expanding its member base in 2014 to include new technology developers and storage end-users. OESA will also reach out to recruit a broader range of stakeholders including energy suppliers, distribution utilities, energy agencies and electric transportation developers and users. More information about OESA, key contacts and a current roster of its members can be found at:
Click here for a Summary of the Plan by ORTECH's Ka Ming Lin.
Valuation of Rooftop Solar Projects
Valuation of a Rooftop Solar Project in Ontario: Valuation of a rooftop solar project, participating in the Ontario Power Authority’s (OPA) Feed in Tariff (FIT) program is a very dynamic and fluid process. The OPA goal was an internal rate of return (IRR) levered ranging between 10-12%. The pricing of a commissioned solar project has dropped considerably over the last 2 years but the IRR has essentially remained the same.
In determining the value of a project, two other factors must be considered. One, the type of contract, in this case, FIT 2 and FIT 3. ORTECH assumes most of the FIT 1 projects are either built or in the process of being built. The other factor is where the project lies in the life-cycle. Two notable phases, Pre-NTP (financial close) and Commissioned. It is ORTECH’s experience that most term sheets on the equity side use these two time frames in the life-cycle as acquisition points.
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For more information on how ORTECH can assist you with your Project, please email [email protected] or via phone 904 822 4120x 680.
Understanding Rural Community Dynamics: How to be a good neighbor
By Leah Deveaux ([email protected] ) Reading time: 2 minutes 30 seconds
Rural communities are often tight knit with a strong sense of place identity and have a distinct culture. In these communities pressure from outsiders to change the status quo can result in the community banding together to fight in order to protect their values and ways of life. Wind power in rural communities can be seen as a push by governments to industrialize the rural landscape by outsiders who never become part of the community. What is Place Identity? Some rural communities develop a sense of self identity which may include more than an individual or family grouping, an identity that extends to all community members creating a communal identity. This identity appears to stem from a need to protect the community from outside disruptions such as loss of agricultural land to other types of land uses (such as wind development), urbanization, political agendas and policies, and as a way to protect rural values in the face of changing demographics and landscapes. It is important to understand rural dynamics, especially in a time where city centric policy is resulting in financial and political resources being allocated to address urban problems. Rural areas provide much of the requirements of life such as food and water, and most recently they contain vast tracts of land which are viewed as suitable for industries which have been forced out of larger cities. This changing social structure of rural communities may not be met with an adequate level of political or financial support. How Place Identity Can Lead to Protectionist Networks Communal identities are a form of insular networking which functions to protect ‘insiders’ and perceived community values and ways of life from external forces of change. Beggs, Hurlbert and Haines (1996) refer to this concept as community attachment, and Larsen (2004) describes this as Place Making. Within these networks strong bonds occur and can lead to communities joining together for social change; in a case study of a resource dependent community in northern British Columbia Canada Larsen notes that the community members “… turned the act of place making into a tactic of resistance, using it to protest and, in some cases, defeat large-scale resource projects such as hydroelectric dams”. This bonding together of individuals over a place and an outside force which threatens that place can occur for many different reasons. Harner (2001) examines how place identity is constructed through a relationship between landscapes and power relationships, and how these can be important in a time of political economic changes. The place identity either being created by or triggered by an exterior force and community support is required to protect the rural way of life. Larsen’s case study in British Columbia is based on this pretext, that the formation of protectionist networks is formed out of a sense of place and the need to protect that space from undesirable developments or actions. Industrialization of rural landscapes can be a factor which may trigger community action through a strong sense of place identity and result in grass-roots movements to protect community values. Wind Power Context Wind power in Canada is a relatively new development in the rural landscape. In addition to the development of wind facilities in rural communities across the country rural communities are facing increased infrastructure demands as well as decreasing financial resources which can play a role into how wind developers are viewed by the community. It is important for wind developers to consider many factors when entering communities. As decisions on where to place wind developments are primarily resource based, it is difficult for many developers to choose communities which welcome such developments, and as is beginning to occur in some heavily developed areas of Ontario, communities which once welcomed wind developments are becoming fatigued with the sheer volume.
Below are some points which may help some developers, of even small projects, become better neighbours: • Understand the financial situation of your municipalities: It is important where possible to select communities which have the economic resources to handle all of the municipal approvals, inspections and consultations associated with permitting, constructing and operating a wind farm. Where this is not possible it would be a good gesture on the part of the developer to be prepared early on to provide support to the municipality to bring in third party consultants to assist in these items. • Participate in community events: Protectionist networks and place identity concentrate on ‘insiders’ and ‘outsiders’; it is therefore important that wind developers focus on integrating themselves into the communities that their projects will be a part of for 20 years or more. Examples of this include participation in summer and winter festivals, sponsoring sports teams, becoming members of local chamber of commerce, and hiring local trades people to construct and operate the project. • Do some background research: Learn about the history of the community; you may never be considered a true insider, but learning about the roots of the community, how other developers may have upset community members, how other industries may have become insiders, etc. may help you to integrate and be good neighbours. • Operate in good faith: Be honest, up front and open with municipalities and all members of the community at every stage of the project. • Have a community liaison: If possible this should be someone who is already a community member who understands the development process, as well as the communities needs.
Sources:
Beggs, J. Hurlbert, S. & Haines, V. (1996). Community Attachment in a Rural Setting: A Refinement and Empirical Test of the Systemic Model. Rural Sociology, 61(3), 407-426. Cloke, P. Milbourne, P. & Thomas C. (1997). Living Lives in Different Ways? Deprivation, Marginalization and Changing Lifestyles in Rural England. Transactions of the Institute of British Geographers, New Series, 22(2) 210-230. Harner, J. (2001) Place Identity and Copper Mining in Sonora, Mexico. Annals of the Association of American Geographers, 91(4) 660-680. Larsen, S. (2004). Place Identity in a Resource-Dependent Area of Northern British Columbia. Annals of the Association of American Geographers, 94(4), 944-960.
For more information on how ORTECH can assist your Permitting needs, visit our Environmental Assessment page or email us at [email protected]
Ontario Election 2014 and Energy
Here are some thoughts about the election and the energy industry moving forward.
Development of renewable energy projects can be a very lengthy process requiring substantial upfront investments. Tying up capital for lengthy periods coupled with the inherently political nature of energy and electricity policy results in a background level of uncertainty around the development of renewables. The results of the provincial election has provided mitigation to the industry with a sense of continuity.
Prior to the election call the government had just completed a long-term energy plan detailing policies, procurements and programs going out twenty years. Implementation of this long term plan was well underway with the continual refinement of the FIT program, as well as new competitive procurements for large renewable projects and energy storage. Resources had already been mobilized or allocated to respond to these procurements and programs and the election results allow those efforts to continue.
For more information on how ORTECH can assist you with your Renewable Energy Projects, please email [email protected] or via phone 905 822 4120x 680.