2020 Final Phase-in of O. Reg. 419 for some facilities
By February 1, 2020 the final phase-in of the new dispersion models and requirement for abidance with the new air quality standards will come into force for the majority of facilities in Ontario.
Starting in 2005, with the introduction of Ontario Regulation 419, different industry groups were required to show compliance with these updated models and standards by certain phase-in dates. Some industries had a phase-in date of February 1, 2010, others by February 1, 2013. However, the vast majority of industries and facilities in Ontario have until 2020 to document their compliance. This applies even if no changes are made to equipment at their facility, which would normally require a permit amendment.
For many of our clients that have required permit amendments, in the last few years, we have been migrating them over to the 2020-compliant standards and modelling in advance of that date. For other clients, we have begun re-assessment work already, as it is known that meeting the new air quality standards with the new models will generally be more difficult than for the old 1/2-hr standards under O. Reg. 346 (the previous permitting regulation). Implementation of the new models and air standards may cause a facility to fall-out of compliance under exactly the same operational scenarios as used all along.
Airzone strongly recommends beginning re-assessment work as soon as possible as this will allow time to deal with any non-compliance issues (in which case emissions/modelling refinements may be investigated or mitigation evaluated, whichever turns out to be less costly).