In case you missed it, the Ministry of Environment and Climate Change (MOECC) recently proposed three “Air Zones” for the province. According to the June 22, 2015, announcement, the Zones will be the following:
- Air Zone 1 – Areas with limited pollution from either point or non-point sources or transboundary influence; where air quality management activities are focused on maintaining good air quality.
- Air Zone 2 – Areas under pressure from multiple sources including some or all of the following: non-point sources, smaller point sources, individual large industrial point sources, transboundary influences; where air quality management activities are focused on multiple broad-based initiatives targeting many sources.
- Air Zone 3 – Areas with a concentration of large industrial sources; where air quality management activities are focused on the abatement of local industrial emissions as well as non-industrial sources.
Why the proposed Air Quality Management Zones (AQMZ)? According to the MOECC, “The System is a comprehensive approach consisting of an interconnected set of drivers and mechanisms for governments to achieve continuous improvements to overall air quality using an all sources approach.”
Translation: expect additional pressure to reduce air discharges.
In speaking with my colleagues in our US offices, they said this looks suspiciously like attainment and non-attainment areas. The US bases attainment/non-attainment on the level of “Criteria Pollutants” (Ozone, Particulate Matter, Carbon Monoxide, Nitrogen Oxides, Sulfur Dioxide, and Lead). If this looks familiar, it should, as it closely resembles the Canadian Ambient Air Quality Standards (CAAQS).
A facility located in a non-attainment area (US) may have additional permitting pressures and requirements. That’s because the area is already believed to have compromised air quality. Accordingly, air discharge limits can be more stringent, and air quality control technologies can also be more onerous.
With this in mind, could an Ontario company that is located in an Air Zone 3 designation receive additional scrutiny before allowing an air discharge?
Certainly, if the AQMZ follow the US lead in attainment/non-attainment areas, it may have an impact on future, allowable discharges. But, as Environment Canada points out, there is a big difference between Canada and the US. “Under the American Clean Air Act, penalties can be levied on states where the NAAQS (National Ambient Air Quality Standards) are not being met. Under the Canadian Environmental Protection Act, 1999, the CAAQS are voluntary objectives.”
Nevertheless, this is one of the reasons we suggest that Canadians not only follow regulations in Canada, but also monitor regulatory activity in the US as well.
If you have questions about air discharges or any other Environmental Compliance Approval, contact my colleague, Andrew Tymec, P. Eng., (atymec@dragun.com) at 519-979-7300, ext 118.