Final Thoughts: Red tape challenge

The Red Tape Challenge, launched by the Ministry of Economic Development, Employment and Infrastructure (MEDEI), is “an online consultation tool designed to identify and eliminate duplication, lessen compliance burdens, shorten response times and make it easier for businesses to interact with government.”  (www.ontario.ca/page/red-tape-challenge)

The first phase focus of the RTC is consulting on automotive parts manufacturing sector regulations. Since one of the categories is Environmental Regulations, with subcategories such as Rules of Boiler Use and Environmental Approvals Process, I was able to address the obstacles facing the wood biomass industry in Ontario.

The main provincial legislation governing the discharge of pollutants in Ontario is the Environmental Protection Act. As per this Act, the Ministry of Environment and Climate Change (MOECC) requires that an Environmental Compliance Approval (ECA) must be obtained for all wood burning equipment. That means that in the same “basket” we have outdoor stoves, custom made furnaces-boilers and modern certified biomass boilers.

It is understandable that first time installed certified equipment goes through the testing process. Also, it is understandable and desirable that custom made, un-certified equipment goes through that process every time. The “problem” with the current Act and costly ECA approval is that you have to test the same-identical, certified equipment for every single project, every single time.

When we talk about the modern biomass boilers, we are referring to proven, high-efficient and fully automatic multi-stage combustion technology with oxygen, temperature and pressure sensors controlled by a complex PLC system. These boilers are manufactured and certified to meet all North American and European industry, safety and environmental standards. Modern biomass boilers meet all CSA and TSSA standards.

For modern biomass boilers, current standards require ECAs for identical certified boilers burning identical certified fuels every single time. There are three issues that immediately emerge:

1. What is the reason for constant carbon monoxide monitoring of flue emissions if the equipment is tested during the certification process and if testing is performed during commissioning?

If changes are made to the equipment, then we are not talking about the certified equipment anymore. Furthermore, the use of uncertified fuel and/or any modifications to the product post-certification would void the warranty.

2. What is the reason for acoustic assessment of certified equipment, in cases where a sound testing report is available and performed by third party companies?

For all standard equipment in HVAC industry, sound power and/or sound pressure results are sufficient proof for acoustic performance.

3. What is the reason for air dispersion modelling if you have a requirement for emission limits and fuel standards, plus a venting system designed according to standards?

Fossil fuel boilers have fuel standards and boiler performance reports with appropriate fuels with no requirement for dispersion modelling. But if a user burns a waste oil with boiler certified for standard oil, emission levels will be way out.

Just as regulatory bodies and industry in general trust that users will use a standard fuel for fossil fuel boilers or that drivers will not use a cooking oil for diesel motors, the same trust should be considered with certified wood biomass boiler users. The point that I am trying to make is that equipment will give the output according to the fuel being used.

And if anyone ever wondered why Ontario is so behind in wood biomass industry compared to B.C., Quebec, NWT or Maritime provinces, the answer lays in the very costly environmental approval process. While the wood biomass industry in other provinces has modern standards that support the industry (especially local wood industry and forestry), Ontario is significantly behind. While other provinces see multiple installations of modern wood biomass systems every year (in schools, universities, hospitals and condo buildings in downtown cores etc.), Ontario is still living in the perception of wood biomass technology as an old stove with black smoke spewing out of the chimney.

Ontario recently launched a Climate Change Mitigation and Low Carbon Economy Act with the plan of creating a low-carbon economy through a cap and trade system. With wood biomass being recognized as carbon neutral fuel, the plan should focus on change and modernization of the bio-industry standards.