Services for ECAs with Limited Operational Flexibility
Environmental Compliance Approvals (ECAs) may include certain powerful conditions, called Limited Operational Flexibility (LOF) conditions that allow certain modifications to be made to the approved Facility without first obtaining an ECA amendment (avoiding lengthy reviews of a year or more). An approval with these conditions is called Environmental Compliance Approval with Limited Operational Flexibility (ECAwLOF), although some older approvals (issued prior to October 31, 2011) may be called Basic Comprehensive Certificates of Approval.
Any facility can request the inclusion of LOF conditions as part of their ECA application. The trade-off for the increased flexibility provided by LOF conditions is the imposition of more onerous and ongoing documentation and reporting requirements, including an annual submission to the Ministry of the Environment (MOE). Additionally, the LOF conditions must be renewed, typically after 5 to 10 years of issuance.
More details on ECAswLOF, including specifics on what types of modifications may or may not be allowed under LOF, and details on documentation and reporting requirements can be found here.
ORTECH is pleased to offer the following ECAwLOF related services:
- Prepare an application for an ECAwLOF,
- Prepare an application to renew an ECAwLOF,
- Develop modification tracking and documentation procedures,
- Update an Emissions Summary and Dispersion Modelling (ESDM) report,
- Prepare a Maximum Concentration Level Assessment,
- Review incoming contaminant concentration standards,
- Prepare and submit an Annual Written Summary (AWS) to the MOE, and
- Prepare tabulated summaries of emission rate change.