Cannabis Licensing Process – Odours and Good Production Practices

A federal license from Health Canada is required to cultivate, process and sell cannabis for medical or non-medical purposes. One of the public concerns regarding these licenses is mitigating odours from Cannabis related activities. This blog highlights the Good Production Practices to address and minimize potential odour impacts to the public.

According to the Cannabis Licensing Application Guide (the “Guide”), as part of the licensing application process, the applicant is required to provide a Good Production Practices (GPP) Report that clearly demonstrates how the GPP requirements will be met. GPP compliance may be verified at any time by Health Canada.

Of particular note,  the October 2019 amendment to Part 5 Section 85 of Cannabis Regulations, states that any building, or part of a building, where cannabis or anything that will be used as an ingredient is produced, packaged, labelled, stored or tested must be equipped with a system that;

• filters air to prevent the escape of odours associated with cannabis plant material to the outdoors;

• provides natural or mechanical ventilation with sufficient air exchange to provide clean air and to remove unclean air in order to prevent the contamination of the cannabis or thing that will be used as an ingredient;

• is accessible and, if necessary for its cleaning, maintenance or inspection, is capable of being disassembled;

• is capable of withstanding repeated cleaning; and

• functions in accordance with its intended use.

In the list of elements to demonstrate that GPP are applied, the Guide mentions “Description of air filtration system, including type, specifications, number and location of air filters installed (e.g., HEPA, carbon, charcoal, combination, portable filters) and a diagram and/or floor plan detailing the air filtration and ventilation system (e.g., air intake and air exhaust locations and direction of air flow within the building(s))”. Demonstrating compliance is the responsibility of the applicant.

The Guide also states “prior to submitting an application, applicants for licenses to cultivate, process and sell for medical purposes (with possession of cannabis) must provide with their application a copy of the written notice to local authorities who are located in the area of the proposed site, as part of their application”. Hence, local governments/municipalities play a vital role in regulating nuisance issues such as odours and noise at the community level.   In addition, the Municipal Guide to Cannabis Legalization, April 2018, encourages local governments to focus efforts on proper use and operation of the odour control equipment and opt for proactive approaches to cannabis-related odour and nuisance abatement.  This guide will be discussed further in a future blog posting.  As an example, odour impact assessments and control plans might be included in requirements for rezoning applications or development approvals. Zoning setbacks, landscaping, buffers or similar requirements may be considered for certain types of facilities that are anticipated to cause odour or other nuisances.

For a successful cannabis license application It is imperative to demonstrate that odours or odour causing Volatile Organic Compounds (VOCs) from the cannabis facilities will be adequately considered and controlled, if necessary,. Apart from more traditional carbon air filtration systems, there are various alternate odour control solutions (e.g. odour neutralization systems, ionization tube systems, ultra-violet technologies, etc.)  which can be designed to meet the specific requirements of each facility..  It is worth noting that Public Health Ontario and Metro Vancouver refer to these alternate solutions as potential odour control options in their publications.

In summary, to help maximize the chance of a success, your Cannabis Licensing Application should demonstrate that Good Production Practices will be following which includes specific measures to address and minimize potential odour impacts.

 Please contact info@ortech.ca for further information. We’d be happy to help.

AWMA Conference Presentation - The Odorous Business of Cannabis

Presented by Ciara De Jong - AWMA Conference Oct 30 2019

Click on the pictures below to scroll through the slides.

If you have any questions, please contact Ciara at cdejong@ortech.ca.

MSAPR Part 2: Important Upcoming 2020 Deadlines for your Spark Ignition Engines

By: Giulia Celli

The Multi-Sector Air Pollutants Regulations (the MSAPR) was registered by Environment and Climate Change Canada (ECCC) in June 2016 with the objective to achieve consistent Canada-wide performance standards for certain industrial facilities and equipment.   Stationary spark ignition engines are targeted under Part 2 of the MSAPR.  MSAPR establishes a process for registering, monitoring, testing and reporting of oxides of nitrogen (NOx) emissions and provides NOx emission intensity limits (ppmvd15% or g NOx / kWh) which are phased in over time. For more information on MSAPR Part 2, click here.

Important Upcoming 2020 Deadlines for your Spark Ignition Engines

Important upcoming MSAPR Part 2 2020 deadlines are:

January 1, 2020: Notice of Election to have engine deemed “low-use”

This election can be made at any time and may take effect retroactively, on January 1 of the year in which the notice was provided, if the number of hours that the engine was operating was recorded. Otherwise, the election will take effect January 1 of the subsequent year.

March 31, 2020: Documentation that establishes an after-treatment control system is in place

Documentation that establishes an after-treatment control system is in place is required if the equipment is installed after March 31, 2020. This documentation is only required for control systems servicing “regular-use” engines.

July 1, 2020: Registration of a Change

Registration is required by July 1 that follows the year in which there is a change in the “responsible person” or change in the engine. If there was a change in the “responsible person” or change in the engine in the 2019 calendar year, the engine is required to be registered, or if previously registered the registration needs to be updated, by July 1, 2020. The original registration deadline was July 1, 2017 for “modern” engines and January 1, 2019 for “pre-existing” engines.

July 1, 2020: Annual Compliance Report for Modern Engines

An Annual Compliance Report must be submitted for each “modern” engine annually by July 1. For “pre-existing” the Annual Compliance Report is not required until 2022.

October 31, 2020: Notice of Election for use of Yearly Average Approach

Notice of Election for use of Yearly Average Approach for an engine (or all engines in a group) is required by October 31 before the first year the Yearly Average Approach is to be used (typically this would be October 31, 2020) or before the first year the approach is changed from Flat Limit to Yearly Average. Use of the Yearly Average Approach is only permitted for “pre-existing” engines.

For more information on ORTECH MSAPR services, click here.

What happens if the Industrial Conservation Initiative (ICI) goes away? – Part 2

By: Ka-Ming Lin

Part 1 of this blog was posted back in February.  It talked about what the Industrial Conservation Initiative (ICI) is, why it is so important, and what it’s near term future looked like.  Of special note was the fact that the Industrial Rate Review was pending.  The consultation period for the Industrial Rate Review ran from April 1 to July 16 and a report summarizing the comments received has been released.

The ICI program allows some customers to control their Global Adjustment (GA) charges which can result in very substantial reductions to their electricity costs.  As both GA charges and ICI eligibility has increased, the ICI program has taken on a bigger role in Ontario’s electricity landscape.  As a result, it is becoming more important for anyone interested in the cost of electricity in Ontario to follow developments which could impact the ICI program.

What the Government heard

While the consultation report was for the Industrial Rate Review overall, the summary report focused overwhelmingly on the ICI.  Of the six categories of comments received, two are directly about the ICI specifically, and three specifically mention the ICI in their summaries.  The ICI focus of the comments speaks to both the size of the ICI impacts on stakeholders, as well as the nature of the ICI, which puts control and agency in the hands of the customers.  This results in the government hearing about how the ICI impacts participants in terms of, not only electricity costs, but impacts to their overall operations.  Additionally, the government also heard about how the ICI program was impacting non-participants.

In Support of the ICI

The government heard that the ICI program was critical to the success and competitiveness of participants as well as providing tangible peak shaving benefit to the grid.  Some stakeholders stated that the viability of their businesses were dependent on the program and other stakeholders noted that they had made investment decisions based on the program and warned that changing the program would have negative consequences.

ICI Criticisms

The ICI program requires facilities to adjust their electricity usage in ways that are not related to their business.  Some businesses did not appreciate having to shift focus away from their lines of business in order to manage their electrical loads.  Some businesses experienced lost production as a result of ICI incentives.  Some ICI participants noted that the increase in ICI eligibility has made actual participation in the program more difficult by widening the peaks that need to be shaved.  This uncertainty has added a new level of risk to operations as missing even a single peak can have substantial financial consequences.  Additionally it was noted that the program represents a subsidization of ICI participants by non-participants and that this created a competitive disadvantage to smaller businesses.

Living with Uncertainty

The ICI program adds a great deal of uncertainty to operations. Here’s just a sample of the questions that facility managers need to ask themselves:

·         When do I need to start reducing my load, and when will it be safe to return to normal?

·         Will I be able to hit all 5 peaks?

·         Will the GA still remain such a large portion of electricity costs in the future?

·         How long will the ICI program be around?

This uncertainty results in facilities being unable to predict their future energy costs, which has serious impacts on the ability of businesses to plan their operations.  The government has been given this message quite clearly, and while there is support for the program’s continuation, even participants that were generally satisfied with the program had criticism.

This summary report doesn’t say where the government will go with industrial electricity rates, but it does collect the concerns and issues that stakeholders have raised.  The ICI program is clearly an important program and any changes made to it will have to be executed with care and consideration for the businesses that will be heavily impacted.  However, it does appear that changes are coming, as even supporters of the program recognize that it has flaws.

The approach to living with uncertainty is knowledge and planning.  It’s important to understand what the conditions are, how they might change, and what that actually means to your bottom line. Only then can we figure out what can be done, not only to mitigate negative impacts but also to get in position to take advantage of new opportunities.  As the electricity landscape continues to evolve, ORTECH will keep watch on developments with this approach in mind. 

Operating an Internal Combustion Generator in Ontario? Apply for the Right Environmental Permit.

By: Limin Sun

Are you installing a new generator for daily use or converting an existing emergency generator?  You may find the permitting process to be a little daunting. 

In Ontario, there are two types of internal combustion generators allowed.  The first type, standby generators, is typically used for shorter operation periods and in emergency situations.  The second type, power generators, is used more often and for non-emergency situations. 

Both types of generators have their own applicable regulatory requirements in Ontario. 

The Ministry of Environment, Conservation and Parks is the Ontario Government body through which the generator permitting process takes place.  Through them you will apply for an Environmental Compliance Approval (ECA).  To obtain the correct permit in a timely manner, you have to understand the approval timing as well as the potential permitting barriers and solutions. Also, it certainly helps to prepare a good permitting plan in advance.

To help with perspective, a comparison of the two types of generators is summarized below.

If you have any questions, please contact Limin Sun at lsun@ortech.ca.

Do Your Continuous Emission Monitors Need to be PG/7 Compliant?

By: Tina Sanderson

Does your facility have Continuous Emission Monitors (CEMs) installed to analyze or monitor:

·         combustion gases including carbon monoxide, carbon dioxide, nitrogen oxides, oxygen and sulphur dioxide;

·         pollutants such as ammonia, hydrogen chloride, particulate matter, total reduced sulphur and volatile organics;

·         volumetric flowrate;

·         moisture; and/or

·         temperature? 

If you have CEMs, do you know if you have compliance analyzers or process monitors? And why does it matter?

The Issue

In most cases it is easy to determine if your facility has compliance analyzers; the facility is required through their environmental permit to install and operate CEMs for the parameters listed in the permit. 

But what about those analyzers that measure parameters not specifically listed in the permit, such as carbon dioxide, volumetric flowrate or moisture?  Or monitors used to optimize the process?  Many facilities regard these components of the system as process monitors.  However, if the data generated from the process monitor is being used to determine annual emissions for reporting to the National Pollutant Release Inventory (NPRI), Greenhouse Gas Reporting or other reporting initiatives then the expectation is that you are operating the analyzers to a compliance quality standard.

Unfortunately some facilities find out too late, usually after an unfavourable audit, that the CEMs they are using are not being operated and maintained appropriately.  In most cases, it is expected that analyzers being used to generate data for federal and provincial reporting initiatives are installed and operated in accordance with Environment Canada Report EPS 1/PG/7, “Protocols and Performance Specifications for Continuous Monitoring of Gaseous Emissions from Thermal Power Generation”, December, 2005 (PG/7) (Note: regulators commonly apply this protocol to a wide range of industrial facilities, not just thermal power generation).

What are the requirements of PG/7?

PG/7 details installation requirements and performance specifications that must be met to ensure the data is of the highest quality possible.  At a minimum the analyzers must pass the following performance specifications:

·         daily zero and span calibration drift using either protocol gases or gases certified to an accuracy of 2% for each component measured;

·         quarterly Cylinder Gas Audit (CGA) using protocol gases for each component measured and a quarterly Stack Gas Flow Test if volumetric flowrate is measured;

·         semi-annual Relative Accuracy Test Audit (RATA) for each component measured (may be waived to an annual basis if certain relative accuracy and availability requirements are met);

·         annual availability for each component; and

·         annual independent inspection of the CEMs. 

 In addition to the performance specifications listed above, the facility must have a Quality Assurance/Quality Control Manual that details the activities that must be implemented to ensure that the data generated by the CEMs will be complete, accurate and precise.  The manual should be reviewed and updated on an annual basis typically after the independent inspection.

What happens next?

Your environmental consultant should ensure that your facility is meeting or exceeding the requirements of PG/7 including:

·         Preparation of Quality Assurance/Quality Control Manuals.

·         Managing a facility’s performance evaluation requirements to ensure that quarterly, semi-annual and annual evaluations are scheduled and conducted to meet the requirements of PG/7.

·         Conducting Relative Accuracy Test Audits, Flow Audits and Cylinder Gas Audits.

·         Conducting Annual Independent Inspections to ensure that facilities are meeting the Quality Assurance objectives of PG/7 and identifying areas of improvement.

·         Conducting on-site training to ensure facility personnel understand the requirements of PG/7 and the importance of the Quality Assurance/Quality Control Manual.

·         On-going technical support to aid facilities in interpreting PG/7 and understanding how it applies to their facility.

For more information on this article please contact:

Does Your Cannabis Extraction Operation need to Register in the Environmental Activity Sector Registry ("EASR")?

Photo by Demi Pradolin on Unsplash

For more information on this article please contact info@ortech.ca.

Ontario’s Regulation 1/17 requires persons engaging in activities that discharge (or may discharge) contaminants to the air, to register in the Environmental Activity Sector Registry (“EASR”), unless the activities do not meet the criteria in the Regulation.  To answer the title of this piece, yes, the Ministry of Environment, Conservation and Parks (“MECP”) will require Cannabis Extraction operations to be registered in the province’s Environmental Activity and Sector Registry ("EASR"). 

 This registry applies to all facilities which are not specifically excluded in the regulation (https://www.ontario.ca/laws/regulation/170001) either due to their primary activity code (NAICS code) or their specified activities.  For those more familiar with the Environmental Compliance Approval (“ECA”) process, the requirements for the Air Emissions EASR process differ from the ECA process in that review and approval from the MECP is not required (see ORTECH’s blog here for further explanation).

 Under the EASR process, Facilities are required to submit an application and maintain documents and records, but approval and authorization is essentially granted upon registration.  This allows Facilities to implement changes to operations or start construction on new equipment installations without regulatory delay.  This self-permitting approach is meant to improve the time it takes for industry to obtain air and noise permits.

 My extraction method does not produce any air emissions.  Do I still require an EASR?

 Yes, a registration is still required. 

 Odour control, and more specifically air emissions/Volatile Organic Compounds (“VOC”) control, is expected to be needed for both a solvent-based and solvent-free cannabis extraction process.  A solvent based process will have some VOC air emissions, which may or may not be odorous.  In fact, even highly efficient solvent-based processes can lose 4 – 6 % of their solvent during the extraction process.  The current regulations consider all these loses to be airborne, thus the need for the EASR. 

 The super-critical CO2 extraction method, which is solvent-free, does not emit contaminants directly. However, processes called Winterization and Distillation follow similar methods as CO2 extraction where contaminants/odour are released, requiring an EASR.  CO2 extraction is also highly energy intensive, so other contaminants like nitrogen oxides (“NOx”) from fuel burning need to be considered.  In addition, it is a requirement to assess potential noise impacts as part of the EASR process.

 When do I need to do this?

 As of December 31, 2016, if you made or make changes to your emission related operations, or if you install new equipment that have emissions, you must determine if your facility is required to register for an EASR.

 What are the requirements for the EASR process?

1. Assess all emissions from the facility for comparison with MECP limits.

2. Assess all substances that have no MECP limits.

3. Assess noise and odour emissions.

4. Develop and implement noise and odour mitigation control plans (i.e. odour control reports), if required.

5. Develop maintenance and operational procedures, complaints and record management requirements.

How can ORTECH help?

ORTECH has been involved in environmental permitting and odour assessments for over forty years and is experienced in the operation and performance of air pollution control equipment for many different NAICS code operations.  Experience which ORTECH can provide for the preparation of Odour Screening Reports, Best Management Practice Plan (“BMPP”) Reports and Odour Control Reports includes:

• Odour emission testing at point, area and fugitive sources in many types of NAICS code facilities.

• Odour performance evaluation of odour control equipment, such as biofilters, adsorbents, wet scrubbers, ozonation systems and ultra-violet devices.

• Emission testing for odourous compound emissions including aldehydes amines, ammonia, carboxylic acid, hydrocarbons, ketones, reduced sulphur compounds and volatile organic compounds such as terpenes.

• Determination of odour threshold values for specific odourous compounds which have no published values.

• Effects of processes and process changes on odour emissions.

• Atmospheric dispersion modelling for odours and odourous compounds.

• Community odour surveys and assessment of odour complaints.

• Preparation of odour testing reports, Emission Survey and Dispersion Modelling (“ESDM”) reports, ECA applications and EASR applications.

ORTECH is also experienced at providing odour expert witness testimony at trials, hearings and tribunals.

For more information on this article please contact info@ortech.ca.

Coming Changes to Environmental Compliance Approvals (ECAs). Is your facility ready?

Photo by Flo Dnd.

Schedule 3 standards will apply to all facilities as of February 1st, 2020—is your facility ready?

By: Giulia Celli

As of February 1st, 2020 Schedule 3 standards will apply to all facilities and the Reg346 model will no longer be an “approved dispersion model” under O.Reg.419/05 (the Regulation). However, as of February 1st, 2019, all Environmental Compliance Approval (ECA) applications must already include Emission Summary and Dispersion Modelling (ESDM) reports showing compliance with Schedule 3 standards and using SCREEN3 or AERMOD models.

What is the difference between Schedule 2 and Schedule 3 standards?

Schedule 2 and Schedule 3 of the Regulation both provide a list of contaminants and the respective concentration of each contaminant that is not to be exceeded at a point of impingement. In the Schedule 2 list of contaminants, these limits are based on half hour averaging periods, whereas Schedule 3 limits are based on variable averaging periods. The approved dispersion model when Schedule 2 contaminants are evaluated is the Reg346 model. Schedule 3 contaminants are to be evaluated using the SCREEN3 and AERMOD models. For most facilities, Schedule 2 standards apply from January 31, 2010 to February 1, 2020. Schedule 3 standards will apply as of February 1st, 2020.

Do facilities need to update their ESDM reports now to maintain compliance?

The next time you prepare or update your ESDM report you need to ensure that the Schedule 3 standards, as well as the applicable models are used. This could occur during an annual update of an ESDM report – either as required by regulation (which is to be done each year by March 31st) or as required by a condition of an ECA. An ESDM report update may also be triggered by making any modifications to the facility or by a follow-up action from an inspection or audit.

ORTECH can help you prepare for the 2020 phase-in of Schedule 3 standards. Please contact us for more information.

ORTECH Welcomes Mike Santavy as our new Ambient Air and Water Quality Manager.

ORTECH Consulting Inc. (ORTECH) is pleased to announce that Mike Santavy, B.Sc. has joined our Sarnia team as Ambient Air and Water Quality Manager.  He has lived in the Sarnia area and has worked in the petrochemical, oil and gas sector for over 20 years with diverse experience including environment and environmental management systems, auditing, assurance, and safety and operational risk to name a few.  These skills and experience will be a valuable resource to our broad range of industrial clients and will support ORTECH in continually improving our process of providing the highest quality environmental data that our clients and other stakeholders can have confidence in.        

ORTECH, an operating subsidiary of Kontrol Energy (“KNR”), is one of Canada’s leading atmospheric science firms providing technology based consulting services and expertise in environmental science and engineering to government, industrial and financial organizations. ORTECH’s Sarnia office has been providing independent third-party ambient air and water quality monitoring and consulting services to local industry for over 60 years.

Does my Municipal Building Need an Environmental Approval (ECA or EASR)?

By: Giulia Celli

The answer to this question depends on several factors such as the equipment you have installed, the location of the equipment and the potential for any environmental impacts.  Let’s back up and provide a bit of context.  The Ontario Government’s environmental rules say that if your business emits any contaminants to the air, you must comply with the regulation however, there are exemptions to this rule.  Section 9 (3) of the Ontario Environmental Protection Act, R. S. O. 1990, (the EPA) and O. Reg. 524/98 specify the (limited) types of equipment, activities, and operations that are exempt from needing an Environmental Compliance Approval (ECA) or an Environmental Activity and Sector Registry (EASR) registration. These exemptions include low capacity natural gas comfort heating systems, and standby power systems. Systems that you would generally find in a municipal building.

For example, an HVAC system that meets the following criteria is likely to be exempt:

·         Each combustion unit uses only natural gas, propane or both natural gas and propane as fuel, and

·         The thermal input rating of each combustion unit is not greater than 10.5 million kilojoules per hour.

·         If the HVAC system includes a cooling tower, drift loss from the cooling tower is controlled by drift eliminators.

And a standby power system that meets the following criteria is likely to be exempt:

·         The system is used and operated only during power outages or for testing or performing maintenance on the system;

·         The standby power system uses only one or more of the following as fuel: biodiesel, diesel, natural gas, and propane;

·         Each exhaust stack that is part of the standby power system is oriented vertically (and not obstructed by a rain cap);

·         Each generation unit that is part of the standby power system and that uses diesel or biodiesel as fuel, must meet, at a minimum, the Tier 1 Emission Standards set out in Table 1 of 40 CFR 89.112 (United States)

·         Each generation unit that is part of the standby power system and that uses propane or natural gas as fuel, must have a maximum discharge of 9.2 grams of nitrogen oxides per kilowatt hour

Other exemptions include things such as equipment used for food and beverage preparation at retail locations, items associated with low occupancy dwellings, some mobile equipment, and more. To complicate matters, the equipment may be exempt from requiring a permit but the facility itself is still required to meet this standard from the EPA:

“…despite any other provision of this Act or the regulations, a person shall not discharge a contaminant or cause or permit the discharge of a contaminant into the natural environment, if the discharge causes or may cause an adverse effect.” 

For municipal operations in multi-tenant buildings this general provision of the EPA can create some issues when air intakes are not sufficiently separated from equipment which would be otherwise exempt from obtaining an ECA or EASR permit.   

For due diligence, it is recommended to have all equipment that emits any contaminants (including noise and odour) to the air assessed for compliance. It is recommended that a letter from a qualified person stating that the facility is in compliance with Ontario regulations is kept with the facility.

If you have any questions about this post, please reach out to Giulia Celli at gcelli@ortech.ca.

Do you need Odour Control? An Engineered Approach to Designing Cannabis Odour Control Solutions.

In Canada’s fledgling Cannabis industry it doesn’t have to be govern by rule-of-thumb when it comes to odour control solutions.  

Often, the industry practice to control Cannabis odour is to have odour control equipment vendors install systems using various rules of thumb for effectiveness.  These rules of thumb are generally based on the equipment needed per floor area of the facility, or per unit of air change, and tend more towards guesstimate than finely-tuned, results-driven performance.  While vendors know their equipment, they don’t necessarily know your facility. If every facility were the same, controlling odour in this manner would be fine; but of course they are not.  Every facility is different, and installing Cannabis odour solutions by rule of thumb can be inefficient and uneconomical.

The best approach to controlling the Cannabis odour from your site is to use the most up-to-date science to analyze the specific potential of odour emissions, and their impact on the surrounding community. Through an engineered approach, a customized solution for your facility should then be designed.

A phased approach for designing odour control solutions. 

·         Phase 1.  Is an Odour Control Solution Needed? - In Phase 1, utilize available site specific information such as size of the cannabis growing area or the intended production capacity and perform analysis based on the current best-practices to arrive at an emissions scenario that, in an ideal world, would not require odour control.

·         Phase 2.  What is the Optimal Odour Control Solution? - Based on the results in Phase 1, if the requirement for odour control is confirmed, conduct detailed analysis to present the optimal odour control options available. The ORTECH concept is don’t design a solution that eliminates 99% of the odour if that level of control is not necessary for your specific facility.   

This phased approach provides an odour control solution that is flexible in design, and that meets the level of control necessary for the specific situation.  Examining all the potential solutions and equipment options from recognized vendors for a facility’s odour control ensures the best fit for the Client.  Ultimately, you should be confident that you have selected the right odour services and control solution provider; a phased approach will help you do that.

The best Odour solution for your project; costed effectively.

Back to rules of thumb; the current one for odour solution equipment is to place three, twelve inch filters for every thousand square feet of growing space.  Using this method equipment costs can become prohibitive rather quickly.  As well, systems that are setup like this are not taking into account the facility as a whole; they can be inefficient, packing more odour control than is needed, or missing opportunities for smarter odour control.   Rules of thumb shouldn’t bind how you look at your facility; instead let scientific analysis and modelling guide your process.

Be proactive in addressing potential challenges related to odours from your facility, but be wary of paying too much for solutions that are not efficient or cost-effective.

What we’ve been up to?

In the past year, ORTECH has helped a large prospective grower submit an air quality assessment report as a part of their rezoning application for growing Cannabis.  We have also been developing an odour management plan for one of Canada’s largest Cannabis growers.  ORTECH has a long history of helping clients resolve odour issues, coupled with recent success. We would be pleased to apply this expertise in assisting with a strategy for your Cannabis facility.

ORTECH has been providing odour assessment and analysis services for over 40 years to our industrial, commercial and municipal clients.  Our experience will help us find the most cost effective and efficient solution for your project. 

Contact info@ortech.ca for any inquiries related to Cannabis Odour Solutions. We’d be happy to help!

Quick Takes on the Upcoming Changes to the Electricity Sector

Image: Renee Gaudet

By: Ka-Ming Lin

The Minister of Energy, Northern Development and Mines (“MENDM”) made an announcement yesterday introducing the “Fixing the Hydro Mess Act”.  This legislation was presented by the Minister as having three main components:

Changes to Conservation Programs. 

The changes to the conservation programs  are described in a Backgrounder on the Ontario Newsroom, available at this link.  These programs are currently administered by local distribution companies (“LDCs”) such as Toronto Hydro or Alectra.  The new legislation will centralize these programs under the Independent Electricity Systems Operator (the “IESO”).  Additionally, the source of funding for these programs will change.  Historically the costs of conservation programs have been rolled into the Global Adjustment (“GA”) which is charged to the electricity using rate base (i.e. it is paid by electricity users).  Future funding for these programs will instead come from the tax base.

Moving conservation programs to the IESO may also result in changes to the conservation programs themselves.  The Backgrounder provides details on which existing programs are expected to be provided in equivalent programs under the IESO and it also lists a number of programs which are expected to be discontinued.

OEB overhaul.

The government is proposing fundamental changes to the governance structure of the Ontario Energy Board (the “OEB”) with the intention to separate management, administrative and adjudicative functions.  A Backgrounder on these changes is available from the Ontario Newsroom at this link.

While the OEB will still have a Board with the Chair reporting to the Minister and be responsible for the adjudicative processes, there will also be a CEO who will handle “executive leadership for all operational and policy aspects of the organization”.  Among other changes proposed is a new section in the OEB annual report outlining efforts made to simplify regulatory requirements.

These changes are described as being “informed by the recommendations of the OEB Modernization Review Panel, stakeholders, and regulatory experts.”  The OEB Modernization Panel Report is available here at this link.

Affordable Electricity and Improving Transparency.

Efforts on this third area are described in an Ontario Newsroom Backgrounder available at this link. 

Average electricity rate increases for residential customers will be held to inflation.  Note that the government still intends on achieving substantial cuts to electricity costs.  For industrial customers, consultations on rate policy is expected to begin in the coming weeks.  As discussed in a previous blog post, changes to industrial electricity rates have the potential to seriously impact Industrial Conservation Initiative (“ICI”) projects.

Controlling electricity rates through direct action means that there will be a variance between the true cost of electricity and what is billed.  The proposed legislation will replace all existing rebates and subsidies with a single rebate line item to be shown on the bill.  Thus the true cost of electricity will be available to customers with an expected implementation date of November 2019.

Changes are also proposed to the Fair Hydro Plan refinancing of the GA.

Final Thoughts

These represent some very fundamental and sweeping changes to the electricity industry in Ontario.  The potential impacts and implications may be very wide reaching.  If electricity costs are a significant concern for your business, it is important for you to keep engaged and informed with how these changes will be implemented.

What happens if the Industrial Conservation Initiative (ICI) goes away?

Are you ready for Energy Policy Changes in Ontario?

By: Ka-Ming Lin

The Industrial Conservation Initiative (ICI) is a program in which large industrial users of electricity could reduce their costs by lowering their load during Ontario’s peak demand hours.  This benefits the electricity system by shaving the highest peaks.  In 2018, the ICI was expanded by substantially reducing the size threshold for eligibility, allowing many more facilities the opportunity to participate.  Some companies made capital decisions to provide their facilities with the flexibility to shave their peaks, with costs to be recouped in future electricity savings under this program.

The current government has launched a review of industrial electricity rates as stated in Ontario’s Plan for the People.

“The government understands the challenges to Ontario industry caused by the high cost of electricity. This is why the government, as part of its open for business policy, is launching a public review of current electricity pricing for industrial users. It will also review written submissions to assess what makes sense and what does not, to better align with the needs of industrial consumers.”

The Industrial Conservation Initiative

The benefit the ICI provides for participants is a change in how they are assessed Global Adjustment (GA).  GA is part of the cost of electricity and is usually charged on an energy used basis.  Under the ICI, participants were instead charged GA based on their share of load only during Ontario’s five highest demand hours.  Thus if a facility could lower it’s demand to zero during these hours, it would be assessed zero in GA Charges.  The GA does vary in amount from month to month, but in the past few years it has accounted for around 80% of the energy costs of electricity, so these savings could be very substantial.

One of the drawbacks of the ICI program is the delay in getting benefits.  The GA charges under ICI are based on your peak demand factor from the previous year.  Facilities which fully engaged with the ICI and made capital investments in order to reduce their utility costs had to do so for longer term benefits.  Changes to the way industrial customers are charged for electricity therefore poses a real risk to these longer term savings.

Energy Storage

One approach companies used for the ICI is installing battery energy storage systems.  This application is well suited to batteries, as it requires only a few hours of storage – a type of application where lithium-ion batteries deliver their best bang for the buck.  With the recent price decline for stationary battery systems and the opening of the ICI to a larger pool of eligible participants, battery systems for “GA busting” became financially viable for many facilities.  Unfortunately, those business cases are now at risk due to the potential for changes to industrial rates.

Mitigating this degree of policy risk is very difficult as the specifics for future energy policies, or even the timeline for when those policies will take effect, is mostly unknown. 

IESO Programs

The IESO has been working to integrate storage into the grid with multiple procurement’s for energy storage facilities.  Unfortunately, energy storage opportunities with the IESO have generally been for standalone “front of the meter” type facilities.  The exception to this case is the demand response (DR) auction. However, DR suppliers need to be qualified and this will be difficult for most individual businesses, especially those who engaged in ICI due to the lowering of the size threshold.  DR however does allow for aggregators, so there may be a solution provider who can enroll your asset into their DR fleet and provide you an avenue to get those revenues.

The ICI program has been providing the IESO with substantial peak shaving, which has benefits to the grid.  Eliminating the ICI or changing industrial rates in a way to make the ICI irrelevant could result in significant increases in peak demand, which would be costly to address.  The latest IESO Ontario Demand Forecast estimates the ICI as providing a reduction of 1,450 MW – 1.5 times the capacity that would have been provided by the cancelled Oakville gas plant.

Changes which threaten the ICI will have costs and impacts not only for participants, but for the grid as a whole.  However, as information regarding the industrial rate review is limited, it’s not clear how these impacts will be considered.  Perhaps changes to the industrial electricity rates provide enhanced value for peak shaving or possibly a temporary program may be implemented to transition current ICI participants over to the new rate regime.  It is not clear at this time what direction the rate review is headed, but it is clear that ICI participants are providing value and losing that benefit will be costly to the ratepayer.

Behind the meter opportunities

“GA busters” are by necessity “behind the meter” facilities. The main value streams other than GA busting for behind the meter energy storage are demand charge reduction, energy arbitrage, and resilience. With the possible exception of resilience, these streams are much less valuable than what the ICI can provide.  Even with the case of resilience, that benefit is currently being enjoyed by ICI participants, so this value cannot replace the loss of the ICI.  Demand charge reduction and energy arbitrage are also existing benefits for ICI participants.  Thus existing value streams have very limited ability to “step up” to mitigate any loss of savings should the ICI program go away, or be substantially changed.

There is potential for new value streams in providing resilience. The Made-in-Ontario Environment Plan targets resilience and climate change adaptation as priorities for the province. It requires municipalities to supplement disaster response action plans. 

Conclusion

The ICI program provides Ontario’s electricity grid and participants with a great deal of benefit, but the future is uncertain.  The Industrial Rate Review poses the potential to severely impact the business cases for “GA busting” projects.  However, losing the benefits provided by the ICI can be quite costly to the system and the ratepayer; and any changes to industrial rates should bear those impacts in mind.  In the longer term, changes to how resilience is valued, and how electricity distribution operates, should provide alternate sources of revenue for these types of facilities.  However, those changes are uncertain at this time, and will take much longer to implement than changes to industrial rates.  This leaves a potential gap, both in the value and the timing of these alternate sources of revenue.

As a result of this gap, facilities already invested in the ICI program should be reviewing their business models and considering how they can respond to various different Industrial Rate Review outcomes.  Those engaged with third parties delivering GA busting as a service should have certainty of how their Service Agreements have allocated these policy risks.  Parties who are considering getting in to the ICI program need to understand the context of potential changes to the system in order to make informed decisions.  Regardless of your circumstance, a deep understanding of the implications of the Industrial Rate Review is important for any ICI-eligible facility. 

Ortech is assisting customers in becoming better prepared for the changes that may come and will continue to monitor policy changes as well as seek to assist our customers with implementation opportunities.

Equipment Exemptions for ECA or EASR

I own a commercial development—do I need an environmental approval (ECA or EASR)?

By: Giulia Celli

The answer to this question depends on several factors such as the equipment you have installed, the location of the equipment and the potential for any environmental impacts.  Let’s back up and provide a bit of context.  The Ontario Government’s environmental rules say that if your business emits any contaminants to the air, you must comply with the regulation however, there are exemptions to this rule.  Section 9 (3) of the Ontario Environmental Protection Act, R. S. O. 1990, (the EPA) and O. Reg. 524/98 specify the (limited) types of equipment, activities, and operations that are exempt from needing an Environmental Compliance Approval (ECA) or an Environmental Activity and Sector Registry (EASR) registration. These exemptions include low capacity natural gas comfort heating systems, and standby power systems. Systems that you would generally find in a commercial development.

For example, an HVAC system that meets the following criteria is likely to be exempt:

·         Each combustion unit uses only natural gas, propane or both natural gas and propane as fuel, and

·         The thermal input rating of each combustion unit is not greater than 10.5 million kilojoules per hour.

·         If the HVAC system includes a cooling tower, drift loss from the cooling tower is controlled by drift eliminators.

And a standby power system that meets the following criteria is likely to be exempt:

·         The system is used and operated only during power outages or for testing or performing maintenance on the system;

·         The standby power system uses only one or more of the following as fuel: biodiesel, diesel, natural gas, and propane;

·         Each exhaust stack that is part of the standby power system is oriented vertically (and not obstructed by a rain cap);

·         Each generation unit that is part of the standby power system and that uses diesel or biodiesel as fuel, must meet, at a minimum, the Tier 1 Emission Standards set out in Table 1 of 40 CFR 89.112 (United States)

·         Each generation unit that is part of the standby power system and that uses propane or natural gas as fuel, must have a maximum discharge of 9.2 grams of nitrogen oxides per kilowatt hour

Other exemptions include things such as equipment used for food and beverage preparation at retail locations, items associated with low occupancy dwellings, some mobile equipment, and more. To complicate matters, the equipment may be exempt from requiring a permit but the facility itself is still required to meet this standard from the EPA:

“…despite any other provision of this Act or the regulations, a person shall not discharge a contaminant or cause or permit the discharge of a contaminant into the natural environment, if the discharge causes or may cause an adverse effect.” 

For commercial developments in multi-tenant buildings this general provision of the EPA can create some issues when air intakes are not sufficiently separated from equipment which would be otherwise exempt from obtaining an ECA or EASR permit.   

For due diligence, it is recommended to have all equipment that emits any contaminants (including noise and odour) to the air assessed for compliance. It is recommended that a letter from a qualified person stating that the facility is in compliance with Ontario regulations is kept with the facility.

If you have any questions about this post, please reach out to Giulia Celli at gcelli@ortech.ca.

Kontrol Energy Completes Acquisition of CEM Specialties Inc

TORONTO, Ontario - September 20, 2018 - Kontrol Energy Corp. (CSE:KNR, FSE:1K8), (“Kontrol”, or the “Company”) announces that it has completed the acquisition of CEM Specialties Inc. (“CEMSI”), previously announced on March 28, 2018 when the Company entered into a Letter of Intent with CEMSI. CEMSI is an established and leading integrator of turn-key emission monitoring equipment and solutions. 

With more than 25 years of successful operating history, CEMSI provides the Canadian and US market with value added solutions for emissions and process monitoring applications.  For the fiscal year ending July 31, 2018 CEMSI generated revenues of $6 Million and EBITDA of approximately $1 Million.  A significant portion of CEMSI’s annual revenue is from multi-year recurring contracts and equipment sales.

“CEMSI is a leader and recognized brand in the emission monitoring and integration market,” says Paul Ghezzi, CEO of Kontrol Energy. “We are excited about the closing of this acquisition as it is a strong strategic fit with our existing emission business. Expanding our emission monitoring and solutions vertical in Canada and gaining a growing footprint in the USA is part of our overall strategic growth initiatives.”

According to the market research report Emission Monitoring Systems Market by System Type Global Forecast to 2025, the emission monitoring systems market is estimated to reach US $4.44 Billion by 2025 from US $2.39 Billion in 2018, at a CAGR of 9.3% between 2018 and 2025.

The aggregate purchase price for CEMSI is $3,350,000, of which the Company has paid $2,265,000 in cash on closing. There is a Vendor Take Back in amount of $502,500, representing 15% of the Purchase Price.  The Vendor Take Back shall accrue interest at a rate of six percent (6%) per annum. An additional $582,500 of the purchase price is subject to a 15-month holdback to accommodate post-closing purchase price adjustment and indemnity obligations of the Vendor. The Vendor has received 250,000 Common Share purchase Warrants.  Each Warrant is exercisable for one Common Share of the Company at a price of $0.75 per share for 3 years following the date of issue, subject to accelerated expiry in certain circumstances.

In conjunction with the acquisition, the Company has closed on a $2 Million secured loan with Pinnacle Diversified Private Income Limited Partnership, by its general partner Pinnacle Diversified Private Income GP Inc., and FirePower Capital. The loan has a term of 12 months. It is anticipated that the loan will be replaced by long-term senior secured debt and equity financing over the next 12 months. The lenders have received 750,000 Common Share purchase Warrants in aggregate. Each Warrant is exercisable for one Common Share of the Company at a price of $0.75 per share for 4 years following the date of issue, subject to accelerated expiry in certain circumstances.

“On a consolidated basis the acquisition will add approximately $6 Million to our year over year revenue growth,” continues Mr. Ghezzi. “Further, the acquisition will add to our earnings and operational cash flow generation starting in Q3 2018.  We have been able to achieve significant year over year revenue growth while maintaining less than 27 Million shares outstanding.  We are keenly focussed on continuing our strong growth trajectory and maximizing shareholder value.”

About Kontrol Energy

Kontrol Energy Corp. (CSE:KNR, FSE: 1K8) is a leader in energy efficiency through IOT, cloud and blockchain technology. With a disciplined mergers and acquisition strategy, combined with organic growth, Kontrol Energy Corp. provides market-based energy solutions to our customers designed to reduce their overall cost of energy while providing a corresponding reduction in Greenhouse Gas (GHG) emissions.

Additional information about Kontrol Energy Corp. can be found on its website at www.kontrolenergy.com and by reviewing its profile on SEDAR at www.sedar.com

About Pinnacle

The investment objectives of Pinnacle Private Diversified Private Income Limited Partnership are to invest in a diversified portfolio of private debt and/or equity securities of issuers involving investments and loans, consistent and reliable cashflows capable of supporting a monthly target cash distribution of 5.5% to 9.0% per annum, after fees and expenses, plus potential additional annual performance distributions. https://www.pinnaclefunds.ca

About FirePower Capital

FirePower Capital is the investment banking and private capital firm built for Canada’s entrepreneurs. Our team of 30+ deal professionals helps their mid-market businesses complete mission-critical transactions, by advising them or investing in their companies directly. http://www.firepowercapital.com

SOURCE Kontrol Energy Corp.

We invite all shareholders and stakeholders to join the Kontrol Energy Investor Group: https://www.8020connect.com/groups/kontrol-energy-corp-203

Neither IIROC nor any stock exchange or other securities regulatory authority accepts responsibility for the adequacy or accuracy of this release. 

Caution Regarding Forward Looking Statements:

Certain information included in this press release, including information relating to the integration of the CEMSI into Kontrol’s existing businesses and technology across Kontrol’s operating platform, Kontrol’s anticipated growth in scale and revenue, including anticipated proforma 2018 revenue and EBITDA run rate, and statements related to the expansion of emission monitoring and solutions across Canada and the USA, the provision of solutions to customers to reduce overall energy costs and greenhouse gas emissions reductions, carbon reduction and monetization programs, other statements that express the expectations of management or estimates of future performance, the anticipated replacement of the $2 million with long term debt and equity constitute "forward-looking statements". The forward-looking statements in this press release are presented for the purposes of providing information about management's current expectations and plans and such information may not be appropriate for other purposes. Where the Company expresses or implies an expectation or belief as to future events or results, such expectation or belief are based on assumptions made in good faith and believed to have a reasonable basis. Such assumptions include, without limitation, that CEMSI will be successfully integrated into the Company and that its revenues and growth projections will be consistent and meet with the Company’s expectations, that the revenue and EBITDA run rate of CEMSI’s and the Company’s subsidiaries will be consistent with and meet the Company’s expectations, that performance milestones will be achieved, that suitable businesses and technologies for acquisition and/or investment will be available, that such acquisitions and or investment transactions will be concluded, that sufficient capital will be available to the Company, that technology will be as effective as anticipated, that organic growth will occur, that the Company will succeed in completing its proposed financing, that all conditions precedent to the acquisition of CEMSI will be met within the required timeframes, and others. However, forward-looking statements are subject to risks, uncertainties and other factors, which could cause actual results to differ materially from future results expressed, projected or implied by such forward-looking statements. Such risks include, but are not limited to, that CEMSI will not be successfully integrated or will not perform as expected, that the revenue and EBITDA run rate of CEMSI and the company’s subsidiaries will be less than expected, performance milestones will not be achieved, there being a lack of acquisition and investment opportunities or that such opportunities may not be concluded on reasonable terms, or at all, that sufficient capital and financing cannot be obtained on reasonable terms, or at all, that technologies and emission monitoring solutions will not prove as effective as expected that customers and potential customers will not be as accepting of the Company's (including CEMSI’s) product and service offering as expected. Accordingly, undue reliance should not be placed on forward-looking statements and the forward-looking statements contained in this press release are expressly qualified in their entirety by this cautionary statement. The forward-looking statements contained herein are made as at the date hereof and the Company does not undertake any obligation to update publicly or revise any such forward-looking statements or any forward-looking statements contained in any other documents whether as a result of new information, future events or otherwise, except as required under applicable securities law.

For further information:
Paul Ghezzi, CEO
paul@kontrolenergy.com

Kontrol Energy Corp.,
180 Jardin Drive, Unit 9,
Vaughan, ON
L4K 1X8,

Tel: 905.766.0400
Toll free: 1.844.566.8123

Kontrol Energy Corp. Ranks No. 7 on the 2018 Startup 50

Toronto, ON, September 13th, 2018 - Canadian Business and Maclean’s today ranked Kontrol Energy Corp. (CSE:KNR, FSE:1K8), (“Kontrol”, or the “Company”) No. 7 on the 2018 Startup 50 ranking of Canada’s Top New Growth Companies. Serving as a companion list to the longstanding Growth 500 ranking of Canada’s Fastest-Growing Companies and produced by Canada’s premier business and current affairs media brands, the Startup 50 ranks younger companies on two-year revenue growth. Startup 50 winners are profiled in a special print issue of Canadian Business published with Maclean’s magazine and online at CanadianBusiness.com.

Kontrol made the 2018 Startup 50 list by growing its revenues by more than 2,000% over a two-year period.

“The 2018 Startup 50 winners suggest the future of Canadian entrepreneurship is extremely bright. They have brought new offerings to market, created indelible brands and disrupted established business models—all in an extremely short period of time,” says Deborah Aarts, Startup 50 and Growth 500 program manager. “Any aspiring entrepreneur should look to their stories for inspiration.”

“Kontrol is honoured to be on the Startup 50 ranking,” says CEO Paul Ghezzi. “This achievement reflects the strength of our energy solutions and the dedication of our team.”

About the Startup 50

Ranking Canada’s Top New Growth Companies by two-year revenue growth, the Startup 50 profiles the fastest-growing startups in the country. It is a companion list to the Growth 500 ranking of Canada’s Fastest-Growing Companies, which has, for 30 years, been Canada’s most respected and influential ranking of entrepreneurial achievement. Both the Startup 50 and Growth 500 are published in a special issue of Canadian Business published with Maclean’s magazine and at CanadianBusiness.com. For more information on the ranking visit Growth500.ca or CanadianBusiness.com  

About Canadian Business

Founded in 1928, Canadian Business is the longest-serving and most-trusted business publication in the country. It is the country's premier media brand for executives and senior business leaders. It fuels the success of Canada's business elite with a focus on the things that matter most: leadership, innovation, business strategy and management tactics. Learn more at CanadianBusiness.com.

About Kontrol Energy

Kontrol Energy Corp. (CSE: KNR, FSE: 1K8) is a leader in energy efficiency through IOT, cloud and blockchain technology. With a disciplined mergers and acquisition strategy, combined with organic growth, Kontrol Energy Corp. provides market-based energy solutions to our customers designed to reduce their overall cost of energy while providing a corresponding reduction in Greenhouse Gas (GHG) emissions.

Additional information about Kontrol Energy Corp. can be found on its website at www.kontrolenergy.com and by reviewing its profile on SEDAR at www.sedar.com

SOURCE Kontrol Energy Corp.

For further information:

Paul Ghezzi, CEO
paul@kontrolenergy.com

Kontrol Energy Corp.
180 Jardin Drive, Unit 9,
Vaughan, ON
L4K 1X8
Tel: 905.766.0400
Toll free: 1.844.566.8123

Neither IIROC nor any stock exchange or other securities regulatory authority accepts responsibility for the adequacy or accuracy of this release. 

Caution Regarding Forward Looking Statements:

Certain information included in this press release, including information relating to future financial or operating performance and other statements that express the expectations of management or estimates of future performance constitute “forward-looking statements”. Such forward-looking statements include, without limitation, statements regarding possible future acquisitions and/or investments in operating businesses and/or technologies, accelerated organic growth, the provision of solutions to customers and Greenhouse Gas emissions reductions, proposed financial savings and sustainable energy benefits and energy monitoring. Where the Company expresses or implies an expectation or belief as to future events or results, such expectation or belief are based on assumptions made in good faith and believed to have a reasonable basis. Such assumptions include, without limitation, that suitable businesses and technologies for acquisition and/or investment will be available, that such acquisitions and or investment transactions will be concluded, that sufficient capital will be available to the Company, that technology will be as effective as anticipated, that organic growth will occur, and others. However, forward-looking statements are subject to risks, uncertainties and other factors, which could cause actual results to differ materially from future results expressed, projected or implied by such forward-looking statements. Such risks include, but are not limited to, lack of acquisition and investment opportunities or that such opportunities may not be concluded on reasonable terms, or at all, that sufficient capital and financing cannot be obtained on reasonable terms, or at all, that technologies will not prove as effective as expected that customers and potential customers will not be as accepting of the Company’s product and service offering as expected, and government and regulatory factors impacting the energy conservation industry. Accordingly, undue reliance should not be placed on forward-looking statements and the forward-looking statements contained in this press release are expressly qualified in their entirety by this cautionary statement. The forward-looking statements contained herein are made as at the date hereof and the Company does not undertake any obligation to update publicly or revise any such forward-looking statements or any forward-looking statements contained in any other documents whether as a result of new information, future events or otherwise, except as required under applicable securities law.

Managing Odour Complaints Best Practices

By Steve Thorndyke ( sthorndyke@ortech.ca )  Reading time: 2 minutes 30 seconds
There are many ways to deal with Odour complaints, either proactively or reactively.  Odours are not predictable, but you can manage them, if you receive a complaint.  Here are some suggestions:

• Encourage odour complainants to notify the plant as soon as possible after an odour episode and fill out a standard questionnaire with details about the odour event such as date, time, meteorological conditions, odour frequency, odour intensity and the character of the odour.
   
• Verify that the complaint is genuine or appears to be real and that it originates from the plant by noting the wind direction at the time of the complaint and visit the site of the complaint if the odour persists.
   
• If possible, correlate the odour complaints with specific activities at the plant which may have caused the complaint, including continuous activities at the facility and short-term activities such as loading a truck.
   
• Conduct periodic odour surveys in the plant and at areas surrounding the plant, with emphasis on sensitive odour receptors such as residences, schools and other places frequently visited by the public, to obtain data which will complement the complaint data.
   
• If there are several potential sources of odour emissions at the plant, conduct an odour emission survey at the plant with atmospheric dispersion modelling to assess the effect of these sources, both individually and in aggregate, at off-site odour receptors and
  use the dispersion modelling to rank the potential sources and develop a plan to reduce odour emissions at the sources, perhaps starting with the most significant odour emission sources.
   
• Repeat the odour emission survey and atmospheric dispersion modelling to assess the effects of any new odour reduction efforts at the plant, and consult with the complainants to determine if the reduction in odour concentration at the receptors is sufficient.
   
• Develop an odour management plan for the plant and protocols for dealing with odour complaints.  Hold public meetings to discuss the details of the plan and any progress in implementing the plan.

For more information on how ORTECH can assist your Air Quality needs, visit our Odour Assessment Page or ourpage or email us at mtingle@ortech.ca

Air Purification: How at Source Treatment Can Lead to Compliance with MECP Regulations and Save Energy and Money

From our Sister Division: Efficiency Engineering:   With new more stringent limits in effect for chromium VI, manganese and nickel, it is not uncommon for metal processing facilities to face compliance issues when trying to obtain an Environmental Compliance Approval or EASR Approval.

To read more, click here. 

The Ultimate Guide to Managing Odour Complaints!

You receive an email or a phone call from an irate neighbour complaining about an odour potentially from your facility, What do you do?  ORTECH has a structured approach to cost effectively manage the entire situation.

Gather Information: This means everything you can get your hands on.

Complainant: Ask them the following questions:

• What was your location when you first encountered the odour
• What day and time of day was it?
• Was the odour weak or strong?
• What did it smell like?
• What direction was the wind blowing?

Internal:  Ask the following questions:

• Does your operation generate odours as a standard business process?
• If yes, are these odours continuous or intermittent?
• Were you operating at the time of the complaint?
• Did anything unusual happen that might releae an odour at the time of the complaint (Poll your employees)?
• What were the weather conditions at the time (wind direction, wind speed, temperature)?
• Have you changed your processes or added any new activities that may generate odour?

External:  Ask the following questions:

• Were there any active construction sites operating nearby?
• Do you have neighbours that were operating at the time of the complaint and could have released an odour?
• Were there any other activities outside of your plant that could have contributed to the odour issue?

When gathering this information, best practices to keep in mind include:

1. Be calm and professional in all internal and external communications. The complainant will appreciate the behaviour and act accordingly.
2. Communicate with the complainant and acknowledge their concerns.
3. Agree to look into the situation but do not make any commitments  until you know your plant is responsible.  

Following this initial information gathering, it may be beneficial to hire a consultant.  A good odour consultant will have the ability to quickly assess the initial information and evaluate the potential source(s) of the odours and if warranted sample odours and quantify using an odour panel and dispersion modelling to provide evidence of the level of odour that was present in the area at the time.  Next steps to managing and odour complaint may include:    

Flux Chamber

Nasal Ranger

1. Provide all the information you have gathered to an odour consultant. Be honest and complete.  If the situation is your fault, there are a number of easy to implement solutions that can mitigate an odour issue.
    
2. Your consultant should perform a site visit along with you. You should visit the location of the complaint and the last known location of the expected source(s) of odour.  Some odours may linger which might present an opportunity to spot sample or setup odour sampling equipment that can collects samples over a period of time.
    
3. It is vital to determine if you were capable of causing the odour at the location that generated the complaint.  In some cases, the wind was blowing in the wrong direction or it was just physically impossible for your facility to release an odour and have it migrate to the location of the complaint.  A dispersion modeling analysis is a valuable tool for evaluating these type of situations. A good odour consultant will have this ability.  A detailed odour assessment report is an excellent way to back up your case to regulators or municipal bylaw officers or in the worst case, a court of law.

4. If practical considering the frequency and duration of the operation of the odourous source(s), your consultant can collect and analyze sample for content.  A lot of odours have known substances with odourous properties such as sulphur compounds or ammonia. Analysis for known substances may help to confirm whether or not your operations are responsible. 

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In addition, odour can be quantified using an odour panel. An odour panel is a group of six or more people pre-screened to have a “normal” level of odour sensitivity and who are trained to assess odours. The results in combination with dispersion modeling will provide you with further evidence on the level and extent of odour emanating beyond the boundaries of your plant

In summary, if you have an odour complaint, do not panic. Remain calm, ask questions, gather information and contact an odour professional that can assist you with solutions or building a case to defend your company against regulatory or legal action.

For more information or if you have questions, please contact Michael Tingle at mtingle@ortech.ca or via phone at 905 822 4120 x680

Has Your Facility Recently Been Inspected by the Ministry of Environment, Conservation and Parks ?

By Terry Lam (tlam@ortech.ca)

A common result of an Ministry of Environment, Conservation and Parks (“MECP”), formerly Ministry of Environment and Climate Change (“MOECC”) inspection for a small business is a finding that the facility is in administrative non-compliance because they are lacking the necessary environmental permits, such as an Environmental Compliance Approval ("ECA") or an Environmental Sector and Activity Registry ("EASR") registration. In fact, it has been estimated that 40% of facilities in Ontario, mostly small businesses, do not have the required permits.

If your facility has recently been required to submit an ECA application or to register an activity on the EASR as a result of an MOE inspection, it is important to take quick action to ensure that compliance dates are met. As a leading environmental consulting firm with over 50 years of experience, ORTECH’s qualified consultants can help your facility tackle these requirements in a timely, effective, and cost-efficient manner.

ORTECH can assist your facility:

• Negotiate with the MECP to obtain realistic compliance dates for inspection findings;

• Prepare and submit an ECA application for any industry, utility, or small business; and,

• Register an activity (such as a heating system) on the EASR.

Having ORTECH on your side will allow your facility to navigate the bureaucracy of permit applications as quickly and painless as possible, avoiding unnecessary frustration. Let our experience work for you.