Will facilities that have…

Will facilities that have an ECA with a limited operational flexibility condition, require to updated odour BMPP or OTBRs annually, similar to annual ESDM and AAR reports?

Does the 6 month phase-in period proposed, after the ERO decision is posted, pertain to the time to get a new application submitted to the MECP, or until MECP approval? What impact, if any, will there be on applications already in queue?

Can the MECP provide clarity on how the Guideline will impact existing ECAs retroactively? What will be the trigger mechanism for existing facilities/ECA holders to adopt this Guidance?

The need to prepare an OTBR where no sensitive receptors exist, or no history of complaints exists, seems onerous and costly for facilities, especially those with small-scale operations. Please consider an ‘OTBR-lite’ option for those industries. An example may be an OTBR that focuses on jurisdictional review and available technologies effectiveness, and less so on estimating emissions and modelling.

Estimating odour emissions from proposed sources will be difficult for many sources/activities, as odour values vary significantly between sources/locations (if even publicly available). Will MECP provide additional guidance, such as historical source information for common odour sources in Ontario?

Can the MECP provide clarity on the Technical Standards Exemption? Does the exemption apply to any facility that is registered under an existing Technical Standard, hence does not need to prepare Odour BMPPs or OTBRs, regardless of Tier or activity?

Guidance recommending 1 ou is concerning. FIDOL should be considered prior to limiting a facility to any odour value.

We recommend input be sought from air practitioners and external groups, on the proposed accreditation process for odour measurement laboratories. European, American, and ISO bases exist.