Final thoughts Red Tape Challenge How red tape is hurting biomass development in Ontario By Bruno Zrno – Engineering Biomass Business Developer, Viessmann n early May, I participated in the Red Tape Challenge (RTC) roundtable discussion in Cambridge, Ontario. The Red Tape Challenge, launched by the Ministry of Economic Develop-ment, Employment and Infrastructure (MEDEI), is “an online consultation tool designed to identify and eliminate dupli-cation, lessen compliance burdens, short-en 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 con-I “Ontario is significantly behind in modern standards to support the industry...” sulting on automotive parts manufactur-ing sector regulations. Since one of the cat-egories 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 gov-erning the discharge of pollutants in On-tario is the Environmental Protection Act. As per this Act, the Ministry of Environ-ment and Climate Change (MOECC) re-quires 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 in-stalled certified equipment goes through the testing process. Also, it is understand-able 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 proj-ect, every single time. When we talk about the modern bio-mass boilers, we are referring to proven, high-efficient and fully automatic multi-stage combustion technology with oxy-gen, temperature and pressure sensors controlled by a complex PLC system. These boilers are manufactured and certi-fied 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 car-bon monoxide monitoring of flue emis-sions if the equipment is tested during the certification process and if testing is per-formed 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 modi-fications to the product post-certification would void the warranty. 2. What is the reason for acoustic as-sessment 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 pres-sure 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 ap-propriate 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 stan-dard fuel for fossil fuel boilers or that driv-ers will not use a cooking oil for diesel mo-tors, 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 in-dustry 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 lo-cal wood industry and forestry), Ontario is significantly behind. While other prov-inces see multiple installations of mod-ern wood biomass systems every year (in schools, universities, hospitals and condo buildings in downtown cores etc.), Ontar-io 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 moderniza-tion of the bio-industry standards. • MAY/JUNE 2016 30 Canadian BIOMASS
Canadian Biomass June 2016: Page 30
