The Ministry of the Environment, Conservation and Parks (MECP) is proposing an updated approach to addressing odour issues. This proposed guidance is presented in the draft document “Guideline to Address Odour Mixtures in Ontario” (Odour Guideline). In addition, the MECP has proposed a methodology for completing odour assessments for odour mixtures in a draft Technical Bulletin. The comment period for the proposed documents is May 4, 2021 - July 3, 2021 (60 days). Comments may be submitted here. MECP is proposing that the Environmental Compliance Approval (ECA) application requirements outlined in the proposal be phased in 6 months from the decision date.

The Odour Guideline builds on the approach that is currently used in the Air Emissions Environmental Activity Sector Registration (AE EASR) Regulation to address assessment of odour in ECA and Renewable Energy Approval (REA) applications and provide guidance on assessing odour in Land Use Compatibility studies. The Odour Guideline does not change the requirements for contaminants with odour-based standards (or other benchmarks) under the local air quality regulation (O. Reg. 419/05). Key proposed updates to the approach to addressing odour issues are summarized below.

Activity / Process Tiers

Currently, activities that are governed by the AE EASR Regulation are categorized into two tiers based on their potential to emit odour. MECP has proposed three tiers for activities and processes that are not governed by the AE EASR Regulation. Tier 3 is for activities and processes that have a significant risk of causing an adverse effect due to odours. There are no odour setback distances for Tier 3 activities and processes. In general, all facilities with Tier 3 activities and processes will be required to develop and implement a Best Management Practices Plan (BMPP) to ensure odours are minimized.

When submitting an ECA application, facilities with Tier 3 activities or processes should arrange a pre-consultation meeting with the MECP. It is recommended that this meeting be at least 3-6 months before the application is submitted.

Odour Technology Benchmarking Report (OTBR)

MECP has proposed a new tool for addressing odours, an Odour Technology Benchmarking Report (OTBR). An OTBR is similar to the Odour Control Report (OCR) required by the AE EASR Regulation. However, in addition to the OCR requirements, an OTBR also assesses and ranks all technically feasible options based on the predicted off-property odour reductions or resulting odour concentrations at odour receptors. An OTBR may be required as part of an ECA application, an REA application, or a Land Use Compatibility study.

Technical Bulletins Outlining Minimum Expectations

MECP will be developing additional guidance in the form of technical bulletins on minimum expectations for certain odorous activities and processes to encourage facilities to implement best practices and controls to reduce odour emissions. Once a technical bulletin is developed, a facility will no longer be required to submit an OTBR with their ECA application, provided they meet the minimum expectations outlined in the technical bulletin. Where available, minimum expectations should also be considered in Land Use Compatibility studies.

Odour Screening Form for ECAs

When completing an ECA application, MECP has proposed that an Odour Screening Form (OSF) should be used to determine whether any facility activities or processes have potential to cause odour impacts. Facilities with activities and processes that have the potential to cause odour impacts are ‘screened in’ by the OSF and additional odour work may be expected to be included in the ECA application, such as a BMPP or an OTBR.

How can ORTECH help?

Practicing an "Educate-Plan-Comply" progression to ensure our clients comprehend the regulatory process, our aim is for you to fully know the implications for your company.  We have worked on countless applications and have fine-tuned our approach, concentrating on a client-centric focus. 

ORTECH can assist you in determining the implications of the proposed odour guidelines on your current or future projects – from ECA applications to land use planning requirements through to the development of Best Management Plans, Odour control Reports and Technology Benchmarking Reports.