Do you want to extend the hours of operation at your waste transfer facility to provide better customer service? Or bring in waste from a neighbouring municipality? Or possibly you want to recover and recycle some of the material that’s delivered to your transfer station instead of sending it all to landfill?
Although these are all environmentally insignificant modifications, these changes would typically require an amendment to a Certificate of Approval (CofA) for a waste management facility. Amending a CofA is not just time consuming and costly to the facility operator, it also consumes the limited resources at the environment ministry and therefore slows down the processing of applications for new waste facilities or applications for amendments for changes that are more environmentally significant.
As part of an overall initiative by the Ontario Ministry of the Environment to streamline the approval process for waste facilities and to provide better guidance to applicant’s, the ministry recently introduced the Comprehensive CofA process for waste transfer and processing facilities. This development should be of interest to policymakers across the country.
The objective of the Comprehensive CofA is to provide a company with operational flexibility to make changes to their waste facility without a requirement to make an application for an amendment. It allows industry to plan and to make changes to their facilities in a timely manner and to reduce the delays associated with the traditional approvals process.
A Comprehensive CofA incorporates additional conditions to ensure that the ministry is kept informed of the continued site operations, that the company remains in compliance with legislative requirements, and that the environment is not adversely affected. The extent to which operational flexibility is permitted by a Comprehensive CofA for a waste disposal site is contained within the Engineer’s Report provided by the proponent.
The Engineers Report basically establishes pre-approved limits for site conditions and defines the envelope of operational flexibility that the site can work within without requiring further approvals. The Engineers Report must be prepared under the direction of and signed by an Independent Professional Engineer. The Environmental Bill of Rights posting includes a description of both the start up operations and the full operating envelop as defined in the Engineers Report so that stakeholders are advised of what future operations may happen at the site.
Golder Associates prepared the first application for a Comprehensive CofA for a waste transfer and processing facility in September of 2008. Since that time, one other Comprehensive CofA has been granted for a waste transfer and processing facility.
The environment ministry hopes to see all traditional certifications for waste transfer and processing facilities converted to Comprehensive CofAs within the next several years. If you are considering applying for approval for a new waste transfer and processing facility or making modifications to your CofA for your current facility, you should consider the benefits of a Comprehensive CofA.
The rate of change in most industries is moving at an ever-increasing pace, and this is particularly true of the waste industry. New technologies for material recovery are constantly being developed and Extended Producer Responsibility is providing incentives to recover materials far beyond what was traditionally being done. The Comprehensive Cof A recognizes that the pace of industrial change is significant and that site owners need to react.
The approval requirements for a Waste Comprehensive CofA are described within the ministry’s “Guide for Applying for Approval of Waste Disposal Sites” which can be accessed on the Ministry website at www.ene.gov.on.ca/envision/gp/4183e.pdf Also, the ministry has published an electronic orientation session for applicants and consultants at www.ene.gov.on.ca/publications/7125e.pdf
To view a sample application package for a Comprehensive CofA for a waste transfer and processing facility, check the ministry website at www.ene.gov.on.ca/envision/gp/6837e.pdf
Pam Russell, P. Eng., is a Senior Waste Engineer with Golder Associates Ltd. in Whitby, Ontario. Contact Pam at firstname.lastname@example.org
This article was written with the assistance of Tim Edwards, Special Projects Engineer, Environmental Assessment and Approvals Branch, Ontario Ministry of the Environment.
“The Comprehensive Cof A recognizes that the pace of industrial change is significant and that site owners need to react.”