It’s still unclear how the process of securing environmental approvals for combined heat and power (CHP) systems will be streamlined, but the Ontario government’s recent pledge has been greeted enthusiastically in the buildings sector. Property and facilities managers are typically pressed to navigate daunting complexities in pursuit of the potential energy savings and backup contingency that CHP (also known as cogeneration) can deliver.
“We went through two approval processes for cogeneration systems installed at condominiums we manage and they were pretty painful,” recalls Rob Detta Colli, manager of energy and sustainability for Crossbridge Condominium Services. “A cogeneration system is a very good fit for some condominiums so I’d welcome an effort to streamline those approvals.”
That intention was announced in a list of initiatives associated with Bill 132, the proposed Better for People, Smarter for Business Act, omnibus legislation introduced in late October to amend or repeal dozens of provincial statutes. However, because the promised action will occur through a regulation, which doesn’t require endorsement in the legislature, there is no actual reference to it in the Bill.
EASR process hinted
Based on hints in the government’s accompanying backgrounder, observers well versed in the Environmental Protection Act theorize that the Environmental Activity and Sector Registry (EASR) process will be the instrument employed. It was established in 2010 as an alternative approval path for activities or sectors that are specifically identified in an associated regulation under the EPA.
The government of Ontario website advises EASR has been devised for activities or sectors that, when properly regulated, pose “minimal risk to the environment and human health” or have “known environmental impacts” because they are reliant on commonly used equipment and processes. EASR registrants must meet stringent eligibility requirements and will continue to be subject to inspections and penalties for non-compliance.
“It’s complicated and you might need to hire a consultant to do it for you, but it speeds up the process compared to the more rigorous and lengthy Environmental Compliance Approval process,” explains Matt Gardner, an associate practicing with Willms & Shier Environmental Lawyers. “There has been a slow but steady stream of new prescribed activities that have been added to the list so it could be that the government intends to add CHP technologies to the list of EASR-eligible activities.”
CHP systems using wood biomass fuels or natural gas turbines are flagged in the government backgrounder. It presents biomass as a benign replacement for diesel generators in remote northern Ontario communities, which could also run self-sufficiently on the wood chip by-products of local timber industries. Hospitals, universities and their clientele are cited as prospective province-wide beneficiaries.
“This initiative would make it easier for businesses to manage their costs and for hospitals and universities to adopt the technology to make them more resilient to natural disasters and weather-related emergencies, ensuring they are better equipped to remain open and functional in times of need,” the backgrounder submits.
Resilience critical in health care facilities
Stable, consistent backup generation capacity is especially critical for health care providers — a necessity that came to the forefront during the prolonged December 2013 ice storm and power outage in southern Ontario. Many facilities managers began exploring CHP options in its aftermath.
“I agree that CHP improves our ability to manage costs and increase resiliency,” says Michael Lithgow, manager, energy and climate change, at Sunnybrook Health Sciences Centre in Toronto. “The challenges include getting the business case to work, noise emissions and electrical interconnection, perhaps even more so than air emissions.”
In its current operating model, EASR involves a sequence of technical, stakeholder and general public scrutiny of environmental impacts. Technology would not be green-lighted for a streamlined approvals process until it had undergone detailed analysis and the resulting study was posted on Ontario’s Environmental Registry for comment. A subsequent draft regulation following from those steps would also be posted on the Environmental Registry.
That appears to be in line with health care providers’ priorities. “I support a streamlined process, but not a weakening of emissions standards that’s unsupported by science,” Lithgow reiterates.
Meanwhile, any potential for cost reductions and simplified processes would be welcome.
“Cogeneration is increasingly being incorporated into multi-residential infrastructure,” observes Joe Hoffer, a partner and specialist in residential tenancy and municipal law with Cohen Highley LLP. “Cogeneration approval processes being streamlined will be good for fostering innovation and implementation of those systems.”
“There are many situations where a customer-owned CHP can improve operating costs and reduce greenhouse gas emissions, but CHP rules have fluctuated significantly over the past decade,” says Andrew Pride, an engineer and energy management specialist. “Having clear and consistent rules would help industry and businesses bring effective CHP back into their budgets.”
Barbara Carss is editor-in-chief of Canadian Property Management.