GREATER VANCOUVER REGIONAL DISTRICT CLIMATE ACTION … · 2016. 2. 5. · February 5, 2016 GREATER...

February 5, 2016

GREATER VANCOUVER REGIONAL DISTRICT CLIMATE ACTION COMMITTEE

REGULAR MEETING

Wednesday, February 3, 2016 1:00 PM

2nd Floor Boardroom, 4330 Kingsway, Burnaby, British Columbia

R E V I S E D A G E N D A1 1. ADOPTION OF THE AGENDA

1.1 February 3, 2016 Regular Meeting Agenda That the Climate Action Committee adopt the agenda for its regular meeting scheduled for February 3, 2016 as circulated.

2. ADOPTION OF THE MINUTES

2.1 November 4, 2015 Regular Meeting Minutes That the Climate Action Committee adopt the minutes of its regular meeting held November 4, 2015 as circulated.

3. DELEGATIONS 4. INVITED PRESENTATIONS 5. REPORTS FROM COMMITTEE OR STAFF

5.1 2016 Climate Action Committee Priorities and Work Plan Designated Speaker: Allan Neilson, General Manager Planning, Policy and Environment Department That the Climate Action Committee endorse the Work Plan contained in the report

dated January 12, 2016, titled “2016 Climate Action Committee Priorities and Work

Plan”.

1 Note: Recommendation is shown under each item, where applicable.

Climate Action Committee -

Climate Action Committee Regular Agenda February 3, 2016

Agenda of 4

On Table Attachment 2

5.2 Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008 Designated Speaker: Esther Bérubé, Program Manager, Bylaw and Regulation Development Planning, Policy, and Environment Department That the GVRD Board:

a) Receive for information the report titled “Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008; and

b) Direct staff to continue discussions with stakeholders on the use of term limits in Metro Vancouver’s air quality permitting system.

5.3 Amendments to GVRD Air Quality Management Fees Regulation Bylaw No. 1083,

2008 Designated Speakers: Esther Bérubé, Program Manager, Bylaw and Regulation Development Roger Quan, Director, Air Quality and Climate Change Planning, Policy, and Environment Department That the GVRD Board:

a) Give first, second and third reading to Greater Vancouver Regional District Air Quality Management Fees Regulation Amending Bylaw No. 1230, 2016; and

b) Pass and finally adopt Greater Vancouver Regional District Air Quality Management Fees Regulation Amending Bylaw No. 1230, 2016.

5.4 Partnering Agreements and Funding for Metro Vancouver’s Wood Stove Exchange

Program Designated Speaker: Derek Jennejohn, Lead Senior Engineer Planning, Policy and Environment Department That the GVRD Board: a) authorize the participation of wood burning appliance retailers in Metro

Vancouver’s wood stove exchange program; b) direct staff to publish Metro Vancouver’s intention to work with wood burning

appliance retailers listed in (c) below to carry out the program; c) authorize the Greater Vancouver Regional District to enter into a partnering

agreement with each of the following retailers to establish the terms and conditions of the services they would provide to Metro Vancouver as part of the program:

i. Alpha Home Energy Centre Ltd., Abbotsford, BC ii. B.C. Fireplace Service Inc., New Westminster, BC iii. Big Valley Heating & Sheet Metal Ltd, Maple Ridge, BC iv. Bowen Building Centre Ltd., Bowen Island, BC v. Bridge Fireplace Group, Port Coquitlam, BC vi. Dagg’s Gas Gallery, Abbotsford, BC

Climate Action Committee - Page 2


Agenda of 4

vii. Delco Fireplaces Ltd., Langley, BC viii. Fireplace by Maxwell, North Vancouver, BC ix. Fireplaces To Go Manufacturing Distributors Ltd., Coquitlam, BC x. Gasland Equipment & Fireplaces Inc., Surrey, BC xi. Hilltop Plumbing & Heating Ltd., White Rock, BC xii. Mainland Fireplaces, Langley, BC xiii. R.E. MacDonald Stoves and Stones Ltd., Langley, BC xiv. The SHP Fireplace Warehouse, Richmond, BC xv. The Olde Stove Works, Mission, BC xvi. Vaglio Fireplace Ltd., Vancouver, BC xvii. Warm Hearth Heating Centre, Maple Ridge, BC;

d) authorize the Chief Administrative Officer to execute the partnering agreements listed in (c) above; and

e) send a letter to the BC Minister of Environment requesting continued funding for the Provincial Wood Stove Exchange Program.

5.5 Manager’s Report

Designated Speaker: Allan Neilson, General Manager Planning, Policy and Environment Department That the Climate Action Committee receive for information the report dated January 20, 2016, titled “Manager’s Report”.

6. INFORMATION ITEMS

6.1 Climate Change Warning Labels on Gas Pump Nozzles – Correspondence dated October 27, 2015 from Derek Corrigan, Mayor, City of Burnaby, addressed to Greg Moore, Chair, Metro Vancouver.

6.2 Climate Leadership Plan Discussion Paper – Correspondence dated October 23,

2015 from Mary Polak, Minister of Environment, addressed to Greg Moore, Chair and Directors, Metro Vancouver.

6.3 Metro Vancouver’s Comments on the Marine Shipping Addendum to the EIS for

RBT2 – Correspondence dated December 15, 2015 from Elisa Campbell, Director, Regional Planning, Metro Vancouver, addressed to Debra Myles, Panel Manager, Roberts Bank Terminal 2 Project, Canadian Environmental Assessment Agency.

6.4 Public Consultation for Proposed Grain Terminal at Lynnterm West Gate – Correspondence dated December 9, 2015 from Karl Gerrand, CEO, G3 Terminal Vancouver, addressed to Greg Moore, Chair, Metro Vancouver.

6.5 Implementation Plans for Two Priority Species at Risk on the Coast of BC – Correspondence dated December 23, 2015 from Steve Gordon, Manager, Biodiversity and Old Growth, Ministry of Forests, Lands and Natural Resource



Agenda of 4

Operations, addressed to Carol Mason, Commissioner/Chief Administrative Office, Metro Vancouver.

7. OTHER BUSINESS 8. BUSINESS ARISING FROM DELEGATIONS 9. RESOLUTION TO CLOSE MEETING

Note: The Committee must state by resolution the basis under section 90 of the Community Charter on which the meeting is being closed. If a member wishes to add an item, the basis must be included below.

10. ADJOURNMENT/CONCLUSION That the Climate Action Committee adjourn/conclude its regular meeting of February 3, 2016.

Membership: Corrigan, Derek (C) – Burnaby Reimer, Andrea (VC) – Vancouver Buhr, Karl – Lions Bay Dupont, Laura – Port Coquitlam Harris, Maria – Electoral Area A

Jackson, Lois - Delta Martin, Mary – Surrey Masse, Robert – Maple Ridge Stevenson, Tim – Vancouver

Steves, Harold – Richmond Storteboom, Rudy – Langley City Villeneuve, Judy – Surrey Williams, Bryce – Tsawwassen


GREATER VANCOUVER REGIONAL DISTRICT CLIMATE ACTION COMMITTEE

Minutes of the Regular Meeting of the Greater Vancouver Regional District (GVRD) Climate Action Committee held at 1:02 p.m. on Wednesday, November 4, 2015 in the 2nd Floor Boardroom, 4330 Kingsway, Burnaby, British Columbia. MEMBERS PRESENT: Vice Chair, Councillor Andrea Reimer, Vancouver (arrived at 2:03 p.m.) Mayor Karl Buhr, Lions Bay Councillor Laura Dupont, Port Coquitlam Director Maria Harris, Electoral Area A Mayor Lois Jackson, Delta Councillor Mary Martin, Surrey (departed at 2:00 p.m.) Councillor Robert Masse, Maple Ridge Councillor Tim Stevenson, Vancouver (arrived at 2:02 p.m.) Councillor Harold Steves, Richmond Councillor Rudy Storteboom, Langley City Councillor Judy Villeneuve, Surrey Chief Bryce Williams, Tsawwassen MEMBERS ABSENT: Chair, Mayor Derek Corrigan, Burnaby STAFF PRESENT: Allan Neilson, General Manager, Planning, Policy and Environment Carol Mason, Commissioner/Chief Administrative Officer Deanna Manojlovic, Assistant to Regional Committees, Board and Information Services, Legal and

Legislative Services Acting Chair In the absence of the Chair and the Vice Chair, the Committee was requested to appoint an acting chair.

It was MOVED and SECONDED That the Climate Action Committee appoint Director Karl Buhr as acting Chair for its regular meeting scheduled for November 4, 2015.

CARRIED

2.1

Minutes of the Regular Meeting of the GVRD Climate Action Committee held on Wednesday, November 4, 2015 Page 1 of 5


1. ADOPTION OF THE AGENDA

1.1 November 4, 2015 Regular Meeting Agenda It was MOVED and SECONDED That the Climate Action Committee adopt the agenda for its regular meeting scheduled for November 4, 2015 as circulated.

CARRIED 2. ADOPTION OF THE MINUTES

2.1 October 7, 2015 Regular Meeting Minutes It was MOVED and SECONDED That the Climate Action Committee adopt the minutes of its regular meeting held October 7, 2015 as circulated.

CARRIED 3. DELEGATIONS No items presented. 4. INVITED PRESENTATIONS No items presented. 5. REPORTS FROM COMMITTEE OR STAFF

5.1 Integrated Regional Climate Action Framework and Update on Metro Vancouver Corporate Energy Management Plan Members were provided with a verbal update on Metro Vancouver’s Regional Climate Action Framework and Corporate Energy Management Plan, highlighting: the goals and next steps in the climate action framework project; the drivers and development process for the energy management plan; and the near term and long term program objectives for the energy management plan. Discussion ensued on: • providing clear direction on the role of cities, regions, provincial and federal

governments in meeting goals • the amount of GHG emissions from electricity versus other fuels Presentation titled “Energy Management Program Update” is retained with the November 4, 2015 Climate Action Committee agenda.

5.2 Metro Facts in Focus Policy Backgrounder: Green Infrastructure Report dated October 5, 2015 from Erin Embley, Regional Planner, Planning, Policy and Environment, conveying the Metro Facts in Focus Policy Backgrounder: Green Infrastructure, a new edition in the Metro Vancouver Facts in Focus series.



Members were provided with a presentation on the Metro Facts in Focus Policy Backgrounder: Green Infrastructure, highlighting green infrastructure opportunities across the urban landscape and key considerations in advancing a regional green infrastructure network. Presentation titled “Green Infrastructure Facts in Focus” is retained with the November 4, 2015 Climate Action Committee agenda. It was MOVED and SECONDED That the GVRD Board receive for information the report dated October 5, 2015, titled “Metro Facts in Focus Policy Backgrounder: Green Infrastructure”.

CARRIED

5.3 Green Infrastructure Technical Report: Connecting the Dots Report dated October 5, 2015 from Erin Embley, Regional Planner, Planning, Policy and Environment, conveying a technical report titled “Connecting the Dots: Regional Green Infrastructure Network Resource Guide” that was prepared in support of ongoing efforts by Metro Vancouver member municipalities to improve and enhance a regional green infrastructure network. It was MOVED and SECONDED That the GVRD Board receive for information the report dated October 5, 2015, titled “Green Infrastructure Technical Report: Connecting the Dots”.

CARRIED 5.4 Urban Forest Climate Adaptation Guidelines for the Metro Vancouver Region

Report dated October 7, 2015 from Marcin Pachcinski, Division Manager, Electoral Area and Environment, Planning, Policy and Environment, conveying information about a project that staff has recently embarked upon to develop Urban Forest Climate Adaptation Guidelines for the Metro Vancouver Region.

2:00 p.m. Councillor Mary Martin departed the meeting. Members were provided with a presentation on the Urban Forest Climate Adaptation Guidelines project, highlighting the project deliverables and timelines.

2:02 p.m. Councillor Tim Stevenson arrived at the meeting. 2:03 p.m. Councillor Andrea Reimer arrived at the meeting and assumed the chair.

Presentation titled “Urban Forest Climate Adaptation Guidelines” is retained with the November 4, 2015 Climate Action Committee agenda.



It was MOVED and SECONDED That the Climate Action Committee receive for information the report dated October 7, 2015, titled “Urban Forest Climate Adaptation Guidelines for the Metro Vancouver Region”.

CARRIED

5.5 Greater Vancouver Regional District Air Quality Management Bylaw No. 1082, 2008 – Officer Appointment Report dated October 23, 2015 from Ray Robb, Environmental Regulation and Enforcement Division Manager, Legal and Legislative Services, appointing staff as an Officer pursuant to the Environmental Management Act and Greater Vancouver Regional District Air Quality Management Bylaw No. 1082, 2008. It was MOVED and SECONDED That the GVRD Board appoint Donna Hargreaves as an Officer, pursuant to the Environmental Management Act and Greater Vancouver Regional District Air Quality Management Bylaw No. 1082, 2008.

CARRIED

5.6 Air Quality Bulletins During Cool Weather Months Report dated October 15, 2015 from Julie Saxton, Air Quality Planner, Planning, Policy and Environment, providing an overview of a pilot project to use air quality bulletins to supplement the existing air quality advisory services which have typically been used during the summer months. Members were provided with a verbal report on the air quality bulletins pilot project to take place fall 2015 and winter 2016. It was MOVED and SECONDED That the GVRD Board receive for information the report dated October 15, 2015, titled “Air Quality Bulletins during Cool Weather Months”.

CARRIED

5.7 Manager’s Report Report dated October 15, 2015 from Allan Neilson, General Manager, Planning, Policy and Environment, updating the Climate Action Committee on the 2015 work plan; 2014 Lower Fraser Valley air quality monitoring report; new air quality monitoring station in New Westminster; mobile air monitoring unit (MAMU); and the Province of BC’s Cumulative Effects Framework. Members were informed about a staffing appointment to the position of Program Manager, Air Quality Bylaw and Regulation Development in the Planning, Policy and Environment department. In response to questions, members were informed that staff will explore the implications and opportunities for interregional cooperation in relation to the



provincial cumulative effects framework and report back to the Committee on their findings. It was MOVED and SECONDED That the Climate Action Committee receive for information the report dated October 15, 2015, titled “Manager’s Report”.

CARRIED


It was MOVED and SECONDED That the Climate Action Committee receive for information the following Information Items: 6.1 Workshop agenda information titled “Feast AND Famine! Solutions and Tools in

Response to a Changing Climate in BC”, Co-hosted by Partnership for Water Sustainability in BC and Irrigation Industry Association of BC

6.2 Metro Vancouver Comments on Project Permit Application for the Vancouver Airport Fuel Delivery Project Fuel Receiving Facility

6.3 Fraser Valley Air Quality Public Forum notice - Air Pollution: What are the Impacts? CARRIED

7. OTHER BUSINESS

No items presented. 8. BUSINESS ARISING FROM DELEGATIONS No items presented. 9. RESOLUTION TO CLOSE MEETING No items presented. 10. ADJOURNMENT/CONCLUSION

It was MOVED and SECONDED That the Climate Action Committee conclude its regular meeting of November 4, 2015.

CARRIED (Time: 2:29 p.m.)

____________________________ ____________________________ Deanna Manojlovic, Andrea Reimer, Vice Chair Assistant to Regional Committees 12140595 FINAL



To: Climate Action Committee

From: Allan Neilson, General Manager, Planning, Policy and Environment Department

Date: January 12, 2016 Meeting Date: February 3, 2016

Subject: 2016 Climate Action Committee Priorities and Work Plan

RECOMMENDATION That the Climate Action Committee endorse the Work Plan contained in the report dated January 12, 2016, titled “2016 Climate Action Committee Priorities and Work Plan”.

PURPOSE To provide the Climate Action Committee with the priorities and work plan for the year 2016.

BACKGROUND At its October 7, 2015 meeting, the Climate Action Committee endorsed the 2016 Budget and Business Plan for the Air Quality and Climate Change function, which was used in providing the basis for the 2016 Budget approved by the Board on October 30, 2015. The Business Plan for Air Quality and Climate Change, along with elements of the business plans for Regional Planning and Corporate Strategies, were used to develop the priorities in the Climate Action Committee’s work plan presented in this report.

The work plan presented in this report is consistent with the Climate Action Committee’s terms of reference, and the Board Strategic Plan.

2016 Work Plan The Climate Action Committee is the standing committee of the Metro Vancouver Board that provides advice and recommendations on policies, bylaws, plans, programs, budgets and issues related to the Air Quality & Climate Change service, the Environmental Planning function and Environmental Regulation and Enforcement.

Key actions in the 2016 work plan for the Committee are described below, listed according to the Committee responsibilities listed in its Terms of Reference (Attachment 2).

Climate Change and Energy The Board Strategic Plan 2015 to 2018 includes a strategic direction to “Develop, adopt and implement a regional climate action strategy for reducing regional greenhouse gas emissions and adapting to climate change” which establishes one of the key work program priorities for 2016.

Under this strategic direction, staff will be seeking direction from the Committee on an Integrated Regional Climate Action Framework, which will tie together the various initiatives and actions related to both climate change mitigation and adaptation, and delineate the areas of responsibility for these actions across different levels of government. It is proposed that a workshop be held with the Committee on this framework early in the year.

5.1


2016 Climate Action Committee Priorities and Work Plan Climate Action Committee Meeting Date: February 3, 2016

Page 2 of 3 As the year progresses, a number of projects under the umbrella of the Integrated Regional Climate Action Framework will be brought forward to the Committee:

• Additional programs for reducing greenhouse gas emissions from prioritized business sectors, buildings, vehicles and industrial sources

• Consideration of a greenhouse gas emissions reduction target as a component of Metro 2040, the regional growth strategy, as mandated through the Local Government Act

• Implement a regional approach to climate change adaptation • Implement additional energy and greenhouse gas reduction offset projects that will achieve

and maintain Metro Vancouver’s status as a carbon neutral organization • Enhance outreach and communication regarding climate change • Develop indicators and measures to support and inform climate actions • Continue to implement corporate energy management program

Air Quality

• Develop new and amended air quality bylaws and regulations towards goals for protection of human health and environment and continuous improvement in air quality, for Board adoption

• Staff will present a proposed 5 year work program for bylaw and regulation development to the Committee early in 2016 and seek feedback

• Continue to enhance implementation of Non‐road Diesel Engine Emission Regulation, including partnerships with other levels of government

• Improve public understanding of air quality and climate change issues and initiatives, including through the preparation of the fifth annual Caring for the Air report

• Develop new programs in partnership with other levels of government to address air quality and greenhouse gas emissions from on‐road light‐ and heavy‐duty vehicles

Environmental Planning • Conclude participation as an intervenor in the National Energy Board process for the Trans

Mountain Expansion Project • Participate in assessments of environmental impacts, regional economic benefits and social

implications associated with major projects in the region, including but not limited to: o George Massey Tunnel Replacement Project o Roberts Bank Terminal 2 o Burnco Aggregate Project

• Initiate a review and revision of the Ecological Health Action Plan, to include broad consultation

• Develop a regional approach to invasive species, including convening and creating a work plan for an Invasive Species Task Force

• Complete the Urban Forest Adaptation Guidelines project • Prepare and launch GrowGreen website for amateur gardeners


2016 Climate Action Committee Priorities and Work Plan Climate Action Committee Meeting Date: February 3, 2016

Page 3 of 3 Sustainability Innovation Funds

• Review proposals for funding, from the GVRD, Liquid Waste and Water Sustainability Innovation Funds and make recommendations to the Board on proposals to support in the 2016‐2017 period.

• Receive reports on the status and progress on deliverables on projects that the Committee approved funding for in 2015.

The 2016 work plan for the Climate Action Committee is provided as Attachment 1, including the expected time frame for reports to this Committee. The Committee will be updated on the status of the actions and projects in this work plan on a monthly basis per the Committee’s schedule.

ALTERNATIVES 1. That the Climate Action Committee endorse the Work Plan contained in the report dated January

12, 2016, titled “2016 Climate Action Committee Priorities and Work Plan”. 2. That the Climate Action Committee provide alternative direction to staff.

FINANCIAL IMPLICATIONS The priorities in the 2016 work plan of the Climate Action Committee are consistent with the 2016 Budget approved by the Board on October 30, 2015 and key actions included in the associated Business Plans and Budget.

SUMMARY / CONCLUSION The work plan presented in this report conveys the priorities for the Climate Action Committee in 2016 and is consistent with its terms of reference and the 2016 Budget approved by the Board. Staff recommends that Alternative 1 be adopted.

Attachments: 1. Climate Action Committee 2016 Work Plan. 2. Climate Action Committee Terms of Reference. 3. 2016 Metro Vancouver Climate Action Committee Meeting Dates. 10766657


Climate Action Committee 2016 Work Plan Report Date: January 12, 2016 Priorities

1st Quarter Status

Submit Written Argument and present Oral Summary Argument to National Energy Board for Trans Mountain Expansion Project

in progress

Conduct workshop with Climate Action Committee to seek direction on development of an integrated regional climate action framework

in progress

Consider 5 year work program related to the development of air quality bylaws and regulations and provide direction to staff

in progress

Report on consultation program initiated in 2015 regarding proposed amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Bylaw No. 1083, 2008, and present proposed bylaw amendments to the Climate Action Committee for GVRD Board approval

in progress

Advise BC Environmental Assessment Office of Metro Vancouver’s participation in working group related to George Massey Tunnel Replacement Project

in progress

Initiate review and revision of Ecological Health Action Plan, including broad consultation process

pending

Complete Urban Forest Adaptation Guidelines in progress

2nd Quarter

Review proposals made to the three Sustainability Innovation Funds and make recommendations to the Board on proposals to support in the 2016‐2017 period.

in progress

Prepare fifth annual Caring for the Air report and expand outreach in progress

Report on the development of the next phase of the energy and greenhouse gas reduction program for small‐ and medium‐sized businesses

pending

Launch website to assist electric vehicle owners living in strata buildings to access charging

pending

Review workplan and consultation process for Invasive Species project pending

Initiate consultation on proposed amendments to Non‐road Diesel Engine Emission Regulation

pending

Participate in environmental assessment processes as requested pending

Review Metro Vancouver GrowGreen website for amateur gardeners (Sustainability Innovation Fund project initiated in 2015)

pending

Report on Water Conservation Research and 2016 Campaign (Sustainability Innovation Fund project initiated in 2015)

pending

5.1 Attachment 1


3rd Quarter

Report on progress on implementation of corporate energy management program pending

Implement additional energy and greenhouse gas reduction offset projects that will achieve and maintain Metro Vancouver’s carbon neutral status

pending

Present a draft policy on internal carbon pricing, to ensure greenhouse gas emissions are considered in Metro Vancouver business decisions

pending

Launch Home Energy Labelling campaign (Sustainability Innovation Fund project initiated in 2015)

pending

Initiate consultation on proposed regulatory mechanisms to reduce discharge of odorous air contaminants from permitted sources

pending

Initiate consultation on proposed amendments to Automotive Refinishing Regulation

pending

Develop new programs in partnership with other levels of government to address air quality and greenhouse gas emissions from on‐road light‐ and heavy‐duty vehicles

pending

Report on the implementation of the Strata Energy Advisor pilot project (Sustainability Innovation Fund project initiated in 2015)

pending

Consider approach to greenhouse gas emissions reduction target as a component of Metro 2040, the regional growth strategy

pending

4th Quarter

Propose amendments to Automotive Refinishing Emission Regulation Bylaw, for Board adoption

pending

Adopt Integrated Regional Climate Action Strategy pending

Report on the results of the Smart Drive Challenge (Sustainability Innovation Fund project initiated in 2015)

pending

Participate in environmental assessment processes as requested pending

Consider proposed 2017 climate action, air quality, environmental planning and energy programs and budget

pending

Engage with external agencies on proposed regulatory mechanisms to reduce emissions from residential wood burning

pending

Report on Reducing Grease in Sewers – Behaviour Change Pilot Project (Sustainability Innovation Fund project initiated in 2015)

pending

10766657


Climate Action Committee Terms of Reference

The Climate Action Committee is the standing committee of the Metro Vancouver Board that provides advice and recommendations on policies, bylaws, plans, programs, budgets and issues related to the Air Quality & Climate Change service, and the Environmental Planning function within Regional Planning. Committee Responsibilities Within the scope of the Board Strategic Plan, Integrated Air Quality and Greenhouse Gas Management Plan, Ecological Health Action Plan, and Metro Vancouver Financial Plan, the Committee provides guidance and oversight to staff on the implementation of the annual work plans and business plans that govern the Air Quality and Environmental Planning areas of service. Specific Committee responsibilities include the following:

• Air Quality & Climate Change − The Committee guides the implementation of the strategies and actions outlined in the Integrated Air Quality and Greenhouse Gas Management Plan. The Committee monitors the progress made in achieving the Plan’s vision of “healthy, clean and clear air for current and future generations”, and the Plan’s three goals related to the protection of public health and the environment, the improvement of visual air quality, and the minimization of the region’s contribution to global climate change. The Committee recommends changes and updates to the Plan.

• Energy − The Committee oversees and guides the efforts of staff in working with municipalities, the private sector, not‐for‐profit societies and others to develop strategies and programs aimed at achieving the efficient use of energy, promoting the use of alternative energies, and reducing the region’s overall carbon footprint, all in an effort to mitigate climate change.

• Environment − The Committee guides and monitors the organization’s actions under the Ecological Health Action Plan. Recommendations on changes and updates to the Plan are made by the Committee to the Board.

• Climate Change Adaptation − The Committee works to develop, for recommendation to the Board, climate change adaptation policies and programs.

• Environmental Reviews − The Committee explores the anticipated environmental impacts, regional economic benefits and social implications associated with significant energy and other capital projects proposed for the region by public and private authorities.

• Sustainability Innovation Funds − The Committee oversees the review of proposals for funding under Metro Vancouver’s Sustainability Innovation Funds, and makes recommendations to the Board on proposals to support. The Committee receives case study

5.1 Attachment 2

10674398 January 7, 2015


reports on all funded projects, and monitors the overall performance of the Sustainability Innovation Fund program.

Committee Membership and Meetings The Chair, Vice Chair and members are appointed annually by the Chair of the Metro Vancouver Board. The Committee meets monthly, except for August and December, and holds special meetings as required. A quorum of 50% plus one of the Committee membership is required to conduct Committee business. Committee Management The Committee Chair, or in the absence of the Chair the Vice‐Chair, is the chief spokesperson on matters of public interest within the Committee’s purview. For high profile issues the role of spokesperson rests with the Metro Vancouver Board Chair or Vice Chair. On technical matters or in cases where an initiative is still at the staff proposal level, the Chief Administrative Officer or a senior staff member is the appropriate chief spokesperson. Where necessary and practical, the Board Chair, Committee Chair and Chief Administrative Officer confer to determine the most appropriate representative to speak. The Chief Administrative Officer assigns a General Manager as Committee Manager for the Committee. The Committee Manager is responsible for coordinating agendas and serves as the principal point of contact for Committee members.


5.1 Attachment 3

2016 Metro Vancouver Climate Action Committee Meeting Dates

Meetings are held in the 2nd floor Boardroom at 4330 Kingsway, Burnaby. Meetings are subject to change. Check the calendar on the Metro Vancouver website or the respective meeting agenda

to confirm times and locations.

Climate Action

Wednesday, February 3 1:00 pm

Wednesday, March 2 1:00 pm

Wednesday, April 6 1:00 pm

Wednesday, May 4 1:00 pm

Wednesday, June 1 1:00 pm

Wednesday, July 6 1:00 pm

Wednesday, September 7 1:00 pm

Wednesday, October 5 1:00 pm

Wednesday, November 2 1:00 pm



From: Esther Bérubé, Program Manager, Bylaw and Regulation Development Planning, Policy, and Environment Department

Date: January 25, 2016 Meeting Date: February 3, 2016

Subject: Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008

RECOMMENDATION That the GVRD Board:

a) Receive for information the report titled “Consultation on Amendments to GVRD Air QualityManagement Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008; and

b) Direct staff to continue discussions with stakeholders on the use of term limits in MetroVancouver’s air quality permitting system.

PURPOSE This report summarizes the feedback received by Metro Vancouver during consultation on proposed amendments to GVRD Air Quality Management Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008. The report also provides information on the issue of term limits in Metro Vancouver’s air quality permitting system, and seeks direction to continue discussions with stakeholders on this issue.

BACKGROUND At its meeting on October 7, 2015, the Climate Action Committee received for information the report titled "Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008", dated September 10, 2015. The report presented proposed amendments on which staff intended to initiate consultation. The proposed amendments addressed:

• definitions, processes and permit application fees proposed for air quality permit renewals;• new administrative fees for specific tasks;• fee adjustments to account for inflation;• an increase to the natural gas/propane comfort heating exemption in Bylaw 1082 from 0.1

MW (0.33 million BTU/h) to 0.3 MW (1 million BTU/h) to reduce the number ofcommercial/industrial heating units requiring explicit authorization; and

• the definition in Bylaw 1082 for residential fireplace fuel.

Included in the report reviewed by the Climate Action Committee at its October 7, 2015 meeting was an Intentions Paper (Attachment 1). The paper provided readers with background information on Metro Vancouver’s authority in regulating air emissions within the GVRD, and on the air quality permitting system in place in the region. The paper also outlined all proposed bylaw changes along with the rationale for the changes, and presented permit fee implications for various size permit

5.2


Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008

Climate Action Committee Meeting Date: February 3, 2016 Page 2 of 5

holders. The paper was made widely available to air quality permit holders and a range of other stakeholders in the region. ENGAGEMENT AND CONSULTATION Overview From November 23, 2015 to January 4, 2016, Metro Vancouver undertook a formal engagement and consultation process on amendments to Bylaws 1082 and 1083. Metro Vancouver sent two notices of consultation on November 23, 2015 and December 18, 2015 to 284 individuals representing local governments and agencies, public institutions, developers, utilities, community organizations, private facilities permitted or regulated by the GVRD for air emissions, current air quality permit applicants and business associations. These stakeholders received links to the Bylaw 1082 and 1083 Amendments website that provided all information on the proposed amendments, as well as the necessary contact information for providing feedback. Metro Vancouver held one group meeting and four individual meetings (some by conference call) with concerned stakeholders in December, 2015, and January, 2016. All feedback received through the consultation process is presented in the Engagement and Consultation Program Compilation (Attachment 2). Stakeholder Feedback Metro Vancouver received 16 responses to the notices of consultation. Issues and concerns have been compiled along with Metro Vancouver’s responses in the Program Compilation table (Attachment 2). As shown in the table, most respondents commented not on the proposed amendments, but instead on the use of term limits in the air quality permitting system. The following points summarize all of the feedback received:

• concerns over the use of term limits in the air quality permitting system, particularly over the possible introduction of term limits for operators who were previously granted permits without expiry dates;

• significant concern with the potential uncertainty faced by permitted facilities and operations that are granted term-limited permits, particularly in cases where permits have terms that may be considered short in duration;

• concern with the unknown scope of future process requirements that would apply at the time of permit renewal;

• concern over the potential time, effort, and costs incurred by permit applicants to navigate through and complete the permit applications process;

• concern with the discretion afforded the District Director in the setting of term limits for permits;

• mixed support for the concept of permit renewals; • some concern regarding the size of the maximum application fee in the proposed alternative

fee structure for permit applications to replace expiring permits; • support for permit application fees that cover the costs of Metro Vancouver’s regulatory

program and associated work; • opposition to the requirement for public notification of a permit renewal application;




• some concern over the increased exemption for natural gas and propane comfort heating,

with interest in alternative mechanisms to reduce emissions from comfort heating devices under 0.3 MW in capacity; and

• general support for clarification to the residential fireplace or stove fuel definition. In addition to these points, stakeholders shared suggestions for the enhancement of monitoring and enforcement, and the use of continuous data-driven performance review mechanisms. No comments were received on the proposed amendments to introduce new administrative fees for non-electronic reporting, or on the proposed amendments to adjust administrative fees based on inflation. Term Limits As noted, several respondents raised concerns regarding the use of term limits in the air quality permitting system. Staff understand the concerns raised, and propose to continue discussions with stakeholders on the term limits issue. It should be emphasized, however, that the use of term limits in the permitting system is a practice that Metro Vancouver has had in place for several years, and has used consistently since at least 2008 as an effective way to promote continuous improvement in air quality. Term limits require permits to be reviewed periodically, and in so doing provide an opportunity for regulators to ensure that new and emerging information is taken into account in the setting of authorized emission levels. Such information may relate to the impacts of air contaminants on air quality, implications of certain emissions for public health and climate change, changes to local receiving environments, changing pollution control technologies, and other factors. In all, Metro Vancouver considers term limits an important tool in fulfilling its mandate to protect the region’s airshed. It is important to recognize, as well, that Metro Vancouver’s authority to establish term limits for air quality permits is clear, and that the regional district has not proposed as part of the current process any amendments related to its existing authority. The authority for term limits is identified in Section 11(1) of Bylaw 1082 as follows (emphasis added):

11. The district director may issue a permit to allow the discharge of an air contaminant subject to requirements for the protection of the environment that the district director considers advisable and without limiting the generality of the foregoing the district director may do one or more of the following in the permit:

1) place limits and restrictions on the quantity, frequency and nature of an air

contaminant permitted to be discharged and the term for which such discharge may occur.

Decisions made by the District Director regarding term limits may, under the terms of the Environmental Management Act, be appealed to the Environmental Appeal Board. NEXT STEPS In its role as the regulator of air quality throughout the region, Metro Vancouver strives for openness and transparency in the development and explanation of regulations. Two-way communication with all stakeholders, including operators and facilities that must obtain permits, is a key element in Metro Vancouver’s approach to fulfilling its regulatory mandate. Given the responses received during the




recent consultation exercise, staff believe that further discussion with stakeholders on the issue of term limits is important. Staff are seeking the Committee’s direction to participate in additional discussion with stakeholders, including but not limited to industry, on this specific issue. Concurrent with the ongoing discussions on the use of term limits, staff intend to proceed with the amendments to Bylaws 1082 and 1083 that were outlined to the Climate Action Committee at its October 7, 2015 meeting, and to stakeholders in the Intentions Paper. The bulk of these proposed amendments will be presented for consideration to the Climate Action Committee in the first half of 2016. A specific amendment dealing with application fees for air quality permits, however, is being presented to the Committee at this meeting (February 3, 2016). This amendment, which is presented in report 5.3 (“Amendments to GVRD Air Quality Management Fees Regulation Bylaw 1083, 2008”), is time sensitive.

ALTERNATIVES 1. That the GVRD Board:

a) Receive for information the report titled “Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008; and

b) Direct staff to continue discussions with stakeholders on the use of term limits in Metro Vancouver’s air quality permitting system.

2. That the Climate Action Committee provide alternative direction to staff. FINANCIAL IMPLICATIONS If the Board chooses Alternative 1, staff will hold additional discussions with permit holders and other stakeholders on the issue of term limits. Staff time and other costs incurred in developing regulations, preparing proposed bylaw amendments, and engaging stakeholders in discussions on proposed changes, are provided for in the annual Board-approved air quality program budgets. Tax requisition revenues are collected to fund some initiatives and programs in the Air Quality and Climate Change division, but are not used to fund the regulatory activities. Financial implications associated with the proposed amendment to the application fees in Bylaw 1083 are identified in the accompanying report 5.3 on the February 3, 2016 Committee agenda. SUMMARY / CONCLUSION This report summarizes the feedback received by Metro Vancouver during consultation on proposed amendments to GVRD Air Quality Management Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008. The report also provides information on the issue of term limits in Metro Vancouver’s air quality permitting system, and seeks direction to continue discussions with stakeholders on this issue. At its meeting on October 7, 2015, the Climate Action Committee received for information the report titled "Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008", dated September 10, 2015. The report presented proposed amendments on which staff intended to initiate consultation.




From November 23, 2015 to January 4, 2016, Metro Vancouver undertook a formal engagement and consultation process on the proposed amendments. Sixteen responses were received. Most respondents commented not on the proposed amendments, but instead on the use of term limits in the air quality permitting system. Staff understand the concerns raised, and propose to continue discussions with stakeholders on the term limits issue. It should be emphasized, however, that the use of term limits in the permitting system is a practice that Metro Vancouver has had in place for several years, and has used consistently since at least 2008 as an effective way to promote continuous improvement in air quality. It is important to recognize, as well, that Metro Vancouver’s authority to establish term limits for air quality permits is clear, and that the regional district has not proposed as part of the current process any amendments related to its existing authority. In its role as the regulator of air quality throughout the region, Metro Vancouver strives for openness and transparency in the development and explanation of regulations. Given the responses received during the recent consultation exercise, staff believe that further discussion with stakeholders on the issue of term limits is important. Staff are seeking the Committee’s direction to participate in additional discussion with stakeholders, including but not limited to industry, on this specific issue. Concurrent with the ongoing discussions on the use of term limits, staff intend to proceed with the amendments to Bylaws 1082 and 1083 that were identified to the Climate Action Committee at its October 7, 2015 meeting, and to stakeholders in the Intentions Paper. One specific amendment dealing with application fees for air quality permits is being presented to the Committee in an accompanying report (report 5.3) on the February 3, 2016 agenda. Attachments (Doc # 17349380): 1. Intentions Paper: Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air

Quality Management Fees Regulation Bylaw No. 1083 2. Engagement and Consultation Program Compilation – Amendments to Bylaws 1082 and 1083 References: 1. Bylaw 1082 and 1083 Amendments website

http://www.metrovancouver.org/services/air-quality/consultation/bylaw1082-1083-amendments/Pages/default.aspx

17357453




Intentions Paper Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083

October 2015

5.2 Attachment 1


Intentions Paper on Proposed Amendments to Metro Vancouver’s Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083

1. Introduction

Metro Vancouver is considering changes to Greater Vancouver Regional District (GVRD) Air Quality Management Bylaw No. 1082 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083. This intentions paper outlines the proposed changes, and elicits informed comment on these changes.

Who should read this?

This intentions paper will be of interest to:

(1) Industrial, commercial or institutional facilities that operate under a Metro Vancouver permit or air emission regulation, or that may be required to operate under a permit or emission regulation, particularly those with limited term permits; and

(2) Other interested parties.

2. Background

Metro Vancouver regulates air emissions in the region under B.C.’s Environmental Management Act. This mandate is governed by GVRD Air Quality Management Bylaw No. 1082. To support this mandate, Metro Vancouver collects fees from permitted and regulated entities to cover the costs of its air quality function. GVRD Air Quality Management Fees Regulation Bylaw No. 1083 provides the basis for how these fees are assessed.

When the GVRD Board adopted Bylaws 1082 and 1083 in 2008, air emission permit renewals were not common. Since then, permits have been issued with fixed terms, meaning that permit holders will need to apply for a new permit prior to permit expiry, and pay new permit application fees. For some facilities the existing application fees might be considered unfair. While new permits require substantial resources, permit renewals require less; however, the bylaw currently imposes the same fee for both. Consequently this intentions paper proposes a distinct fee structure for permit renewals, to correct that unfairness before these permits expire.

In addition, several housekeeping amendments, including comfort heating exemptions, residential wood burning clarifications, inflation adjustments and new fees for permit administrative activities are proposed.

3. Proposed Amendments to the Bylaws

Metro Vancouver proposes to make the following changes to Bylaws No. 1082 and 1083 (the Bylaws):

• Renewal of permits: Define air quality permit renewals as a process different from newpermit issuance and permit amendment, and set application fees for permit renewals.

OCTOBER 2015 2


• New administrative fees and fee inflation adjustments: Add fees for certain administrativetasks, and adjust existing administrative fees for inflation.

• Natural gas/propane fired comfort heating: Increase the natural gas/propane comfortheating exemption in Bylaw 1082 from 0.1 MW (0.33 million BTU/h) to 0.3 MW (1 millionBTU/h) to reduce the number of commercial/industrial heating units requiring explicitauthorization.

• Residential fireplace fuel clarification: Improve the clarity of Bylaw 1082 regardingresidential fireplaces by changing “wood” to “clean wood”, and by modifying the sectioninto a more readable format.

3.1 Renewal of Permits

Section 11(1) of Bylaw 1082 allows the district director to issue a permit to authorize the discharge of air contaminants to the environment with conditions including “restrictions on the … term for which such discharge may occur”. Fixed terms are necessary so that permits are reviewed to ensure that permit conditions encourage continuous improvement where warranted, and take into account new information about air contaminants, changing receiving environments, expended pollution control capital, confidence in the adequacy of permit conditions, and changing technology. All permits issued or amended from mid-2015 forward are expected to have fixed terms, ranging from 2-3 years up to twenty years, depending on the facility, surrounding community and other factors.

Permit renewals:

• Are generally more complex than permit amendments because of the number of emissionsources that require review;

• Require less effort than new permit issuances because a thorough review would have beenconducted at the time of permit issuance - although this might not always be up-to-dategiven information and technology changes with time; and

• Should be as transparent to the public as new permit issuances, and should thereforeundergo a public notification process so that potentially affected parties are given theopportunity to comment.

Proposed fees for permit renewals are based on the following principles:

• Cost recovery/user pay: Fees should be collected on a cost recovery basis. Users shouldpay in accordance with the level of effort required to regulate their business and the effortrequired for a thorough technical review of the permit, both of which are proportional tothe complexity of the site.

• Discharger pay/impact weighting: Payments recovered from regulated businesses shouldbe related to the environmental impact of the contaminants discharged by those businessesand fees for air contaminants should be weighted according to the potential impact of thatcontaminant.

• Equity: Cost recovery should be apportioned in an equitable manner between sources.• Incentive to reduce: Fees should be based on discharge quantities to provide an incentive

to reduce contaminant discharges.

OCTOBER 2015 3


Proposed changes Metro Vancouver proposes to add permit renewals and associated public notification requirements to Bylaw 1082 and to add application fees for permit renewals to Bylaw 1083.

Metro Vancouver proposes to assess a permit renewal application fee of $220 plus twice the total emission fees payable for the emissions specified in the renewal application. If the total is greater than $50,000, the application fee would be the lesser of the above or $50,000 plus twice the emission fee for any requested increase in emissions. Examples are provided in Appendix 1.

Under the proposed fee structure, while most facilities would pay permit renewal application fees similar to those for a new permit, the most complex facilities would have fees of $50,000 plus an adjustment for any increase in emissions, compared with upwards of $750,000 under the existing fee structure.

3.2 New Administrative Fees and Inflation Adjustments to Fees

Some permitting and administrative costs are not covered in the fee bylaw (Bylaw 1083):

• Air quality permits can be suspended either automatically for non-payment of fees, or by request of the permittee, in situations, for example, when a facility’s start-up is substantially delayed. A permit suspension fee would help cover the cost of processing the suspension.

• Permits that have been suspended, but not cancelled, can be reinstated. A permit reinstatement fee would help cover the cost of processing the reinstatement.

• While most permittees and registrants make use of Metro Vancouver’s electronic reporting portal, some reports continue to arrive in hardcopy and must be handled separately for electronic conversion. A non-electronic report processing fee would help cover the cost of processing hardcopy reports.

The base administrative portion of total emission fees has remained $200 since Bylaw 1083 was adopted in 2008. According to the Bank of Canada, the rise in the Canadian inflation rate from 2008 through 2015 has been an annual average of 1.36 per cent, or an overall increase of 9.93 per cent.

Proposed changes Metro Vancouver proposes that the following additional fees be added to the fee bylaw:

(1) $220 for a permit suspension;

(2) $220 for a permit reinstatement; and

(3) $220 for processing of non-electronic reports.

Additionally, Metro Vancouver proposes that the $200 base fee be increased to $220 to account for inflation.

OCTOBER 2015 4


3.3 Natural Gas/Propane Fired Comfort Heating

Natural gas/propane fired comfort heating devices (boilers or furnaces) up to 0.1 MW (0.33 million BTU/h) are exempt from Bylaw 1082. However, GVRD Boilers and Process Heaters Bylaw 1087 authorizes natural gas or propane boilers up to 3 MW with the sole requirement that NOx emissions not exceed 60 mg/m3 of flue gases. This leads to situations where comfort heating devices greater than 0.1 MW in size require authorization, while facilities with comfort heating natural gas or propane boilers less than 3 MW in total are conditionally authorized without having to take additional steps. Furthermore, commercial natural gas fired units (such as roof top units on office buildings or retail facilities) in the range of 0.1 – 0.2 MW (0.3 to 0.7 million BTU/h) and up to 0.33 MW (1 million BTU/h) are not uncommon, and few if any are currently permitted, nor does Metro Vancouver want them to be.

Proposed changes To streamline queries about the permitting requirements for comfort heating devices, and to close the gap between Bylaws 1082 and 1087 with respect to relatively small devices, Metro Vancouver proposes to increase the Bylaw 1082 comfort heating exemption to 0.3 MW (1 million BTU/h) where facility capacity is less than 3 MW.

3.4 Residential Fireplace Fuel Clarification

Bylaw 1082 section 8 restricts the fuels used in residential fireplaces or woodstoves to “wood, paper or derivatives of wood and paper, or natural gas,” but is not clear regarding the types of wood, which may lead to the impression that any wood (e.g. painted or glued wood, such as plywood) is acceptable for use. Metro Vancouver proposes to add a definition for “clean wood” to the Bylaw and to replace “wood” with “clean wood” in section 8.

“Clean wood” would be defined as wood that has been seasoned or allowed to dry, and is uncontaminated wood free of glue, paint or preservative, or foreign substances harmful to humans, animals or plants when burned. This definition is based on the definition of “biomass” in Bylaw 1087, as well as elements of the Code of Practice for Residential Wood Burning Appliances, prepared by the Canadian Council of Ministers of the Environment.

3.5 Implementation

The amended Bylaws will take effect upon approval by the Board.

4. Providing Comments on Proposed Intentions for the Bylaws

Metro Vancouver welcomes feedback with respect to any or all of the proposed changes. All comments and suggestions will be compiled into a consultation summary report and will be carefully considered in development of the amended Bylaws No. 1082 and 1083.

Comments received will be treated with confidentiality by Metro Vancouver staff and contractors when preparing consultation reports. Please note that comments you provide and information that identifies you as the source of those comments may be publicly available if a freedom of

OCTOBER 2015 5


information (FOI) request is made under the Freedom of Information and Protection of Privacy Act. If you have any questions or comments regarding the consultation process, call 604-432-6200. Following consultation on this Intentions Paper, Metro Vancouver staff will prepare a draft amendment to the Bylaw. It is anticipated that the draft Bylaw amendment will be before the GVRD Board in the winter of 2016, together with input from consultation. To ensure that your comments are considered, please provide feedback by December 31, 2015 to [email protected]. Thank you for taking the time to consider these potential Bylaw changes and provide your input. 10625675

OCTOBER 2015 6


mailto:[email protected]

Appendix 1 – Proposed Permit Renewal Fee Examples

Example 1 - Small facility

(e.g. grain terminal)

Example 2 - Medium facility (e.g. wood products

manufacturing)

Example 3 - Large facility

(e.g. cement plant) Annual Emission Fees, specified in Renewal: $8,000 $25,500 $378,600 Previous Annual Emission Fees: $4,400 $21,900 $375,000

Increase in Emission Fees: $3,600 $3,600 $3,600

Method A Base fee: $ 220 $220 $220 Annual Emission Fees, specified in Renewal: $8,000 x2 $16,000 $25,500 x2 $51,000 $378,600 x2 $757,200 Method A Permit Renewal Fee: $16,220 $51,220 $757,420

Method B Annual Emission Fees, maximum amount with Renewal: $50,000 $50,000 Increase in Emission Fees: $3,600 x2 $7,200 $3,600 x2 $7,200 Method B Permit Renewal Fee: Min $ 50,000 $57,200 $57,200

Lesser of Method A or B? A A B

Permit Renewal Fee $16,220 $51,220 $57,200

BBaassee ffeeee $$222200 22xx aannnnuuaall eemmiissssiioonn ffeeeess MMeetthhoodd AA ppeerrmmiitt rreenneewwaall ffeeee

FFoorr ffaacciilliittiieess wwiitthh ccuurrrreenntt aannnnuuaall eemmiissssiioonn ffeeeess uupp ttoo $$2255,,000000,, nnoo cchhaannggee ((MMeetthhoodd AA iiss aallwwaayyss lleessss tthhaann MMeetthhoodd BB))

FFoorr ffaacciilliittiieess wwiitthh aannnnuuaall eemmiissssiioonn ffeeeess ggrreeaatteerr tthhaann $$2255,,000000,, lleesssseerr ooff MMeetthhoodd AA oorr BB

$$5500,,000000 22xx iinnccrreeaassee ffrroomm pprreevviioouuss eemmiissssiioonn ffeeeess MMeetthhoodd BB ppeerrmmiitt rreenneewwaall ffeeee

OCTOBER 2015 7

11977474 Climate Action Committee -

Engagement and Consultation Program Compilation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008

January 29, 2016

17310539

5.2 Attachment 2


THIS PAGE LEFT BLANK INTENTIONALLY


Table of Contents Climate Action Committee Meeting Minutes (October 7, 2015) …………………………………………………. 3 Committee Report (October 7, 2015 CAC meeting) ………………………………………………………………….... 9 Intentions Paper ……………………………………………………………………………………………………………………….. 13 Issues and Responses Table ………………………………………………………………………………………………………. 21 Summary of Correspondence ……………………………………………………………………………………………………. 35

Outgoing Correspondence ………………………………………………………………………………………………… 43 Incoming Correspondence ………………………………………………………………………………………………… 65

Consultation webpage ………………………………………………………………………………………………………………. 107 Summary of meetings ……………………………………………………………………………………………………………….. 111 Stakeholder Database ……………………………………………………………………………………………………………….. 115


DIRECTION TO PROCEED

1Climate Action Committee -

GREATER VANCOUVER REGIONAL DISTRICT CLIMATE ACTION COMMITIEE

Minutes of the Regular Meeting of the Greater Vancouver Regional District (GVRD) Climate Action Committee held at 1:08 p.m. on Wednesday, October 7, 2015 in the 2nd Floor Boardroom, 4330 Kingsway, Burnaby, British Columbia.

MEMBERS PRESENT: Chair, Mayor Derek Corrigan, Burnaby Vice Chair, Councillor Andrea Reimer, Vancouver (departed at 2:45 p.m.) Councillor Laura Dupont, Port Coquitlam Director Maria Harris, Electoral Area A Mayor Lois Jackson, Delta Councillor Mary Martin, Surrey Councillor Robert Masse, Maple Ridge Councillor Tim Stevenson, Vancouver Councillor Harold Steves, Richmond Councillor Rudy Storteboom, Langley City Councillor Judy Villeneuve, Surrey

MEMBERS ABSENT: Mayor Karl Buhr, Lions Bay Chief Bryce Williams, Tsawwassen

STAFF PRESENT: Allan Neilson, General Manager, Planning, Policy and Environment Carol Mason, Commissioner/Chief Administrative Officer Deanna Manojlovic, Assistant to Regional Committees, Board and Information Services, Legal and

Legislative Services

1. ADOPTION OF THE AGENDA

1.1 October 7, 2015 Regular Meeting Agenda

It was MOVED and SECONDED That the Climate Action Committee adopt the agenda for its regular meeting scheduled for October 7, 2015 as circulated.

CARRIED

Minutes of the Regular Meeting of the GVRD Climate Action Committee held on Wednesday, October 7, 2015 Page 1of6


2. ADOPTION OF THE MINUTES

2.1 July 15, 2015 Regular Meeting Minutes

It was MOVED and SECONDED That the Climate Action Committee adopt the minutes of its regular meeting held July 15, 2015 as circulated.

3. DELEGATIONS No items presented.

4. INVITED PRESENTATIONS No items presented.

5. REPORTS FROM COMMITTEE OR STAFF

5.1 2016 Budget and Business Plan - Air Quality and Climate Change

CARRIED

Report dated September 22, 2015 from Roger Quan, Director, Air Quality and Climate Change, Planning, Policy and Environment, presenting the 2016 Air Quality and Climate Change Budget and Business Plan for consideration by the Climate Action Committee.

Members offered the following comments:

• that, in future, budget materials explain how the key performance objectives

and key actions link to the budget expenditure items

• that the provision of life-cycle product service support be given consideration

in the procurement process

• that in the interests of budget transparency, capital expenditure items

should be differentiated from the operating budget

It was MOVED and SECONDED That the Climate Action Committee endorse the 2016 Air Quality and Climate

Change Budget and Business Plan as presented in the report titled "2016 Budget

and Business Plan - Air Quality and Climate Change" dated September 22, 2015

and forward them to the Board Budget Workshop on October 21, 2015 for

consideration. CARRIED

5.2 Fraser River Salinity Benchmarking Study Report dated September 4, 2015 from Theresa Duynstee, Regional Planner, Planning, Policy and Environment, seeking approval to contribute $10,000 in funding towards a study that will investigate the potential impacts of increased

Minutes of the Regular Meeting of the GVRD Climate Action Committee held on Wednesday, October 7, 2015 Page 2 of 6


salinity levels in the Lower Fraser River due to the salt wedge moving further upstream as a result of changes in the hydrology of the river.

Members were informed about the origin of the funding request and provided with an overview of the goals of the study.

Members offered comments about: • funding from the federal and provincial levels of government for the project • exploring synergies between the Fraser River Salinity Benchmarking Study

and Kwantlen Polytechnic University's study on bioregional food sustainability

Request of Staff Staff was requested to inform Kwantlen Polytechnic University about the Fraser River Salinity Benchmarking Study.

It was MOVED and SECONDED That the GVRD Board approve a $10,000 contribution to the Fraser River Salinity Benchmarking Study as described in the report dated September 4, 2015 titled, "Fraser River Salinity Benchmarking Study".

CARRIED

5.3 Metro Vancouver Input to Provincial Climate Leadership Plan Process Report dated September 18, 2015 Jason Emmert, Air Quality Planner, and Ali Ergudenler, Senior Engineer, Planning, Policy and Environment, providing an update on the submissions made by Metro Vancouver to the provincial Climate Leadership Plan process.

It was MOVED and SECONDED That the GVRD Board write to the Minister of Environment conveying its support for the Metro Vancouver staff submission of detailed policy comments on the Provincial Climate Leadership Plan, as a follow-up to the Board's previous communication to the Minister on foundational climate action policies of importance within the Metro Vancouver region.

CARRIED

5.4 Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008 Report dated September 10, 2015 from Derek Jennejohn, Lead Senior Engineer Planning, Policy and Environment, providing an overview of proposed amendments to Greater Vancouver Regional District Air Quality Management Bylaw No. 1082, 2008 and Greater Vancouver Regional District Air Quality Management Fees Regulation Bylaw No. 1083, 2008, concerning air quality permit renewals and other bylaw housekeeping changes on which staff intend to initiate consultation.



It was MOVED and SECONDED That the Climate Action Committee receive for information the report dated September 10, 2015, titled "Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008".

CARRIED

5.5 Connecting Environmental Quality to Climate: Air and Waste Management Association's 108th Annual Conference and Exhibition Report dated August 10, 2015 from Derek Corrigan, Chair, Climate Action Committee, and Conor Reynolds, Senior Project Engineer, Planning, Policy and Environment, providing a report on their attendance at the Air and Waste Management Association's Annual Conference and Exhibition titled "Connecting the Dots: Environmental Quality to Climate".

It was MOVED and SECONDED That the Climate Action Committee receive for information the report dated August 10, 2015, titled "Connecting Environmental Quality to Climate: Air and Waste Management Association's 108th Annual Conference and Exhibition".

CARRIED

5.6 Update on Regional Ground-Level Ozone Strategy Report dated September 9, 2015 from Roger Quan, Director, Air Quality and Climate Change, and Eve Hou, Air Quality Planner, Planning, Policy and Environment, updating members on the Regional Ground-Level Ozone Strategy.

Members were provided with a short video explaining how ground-level ozone is created, and a presentation highlighting the results of research on the transportation of nitrogen oxides emissions in the Lower Fraser Valley airshed.

Presentation titled "NOx Transport in Our Region" is retained with the October 7, 2015 Climate Action Committee agenda.

It was MOVED and SECONDED That the Climate Action Committee receive for information the report dated September 9, 2015, titled "Update on Regional Ground-Level Ozone Strategy''.

CARRIED

5.7 Climate Change and Air Pollution Warning Labels on Gasoline Pumps Report dated August 29, 2015 from Laurie Bates-Frymel, Air Quality Planner, Planning, Policy and Environment, responding to the Climate Action Committee's June 17, 2015 request by providing a report on jurisdictional considerations and other issues raised relative to legislating climate change and air pollution warning labels on gasoline pumps.

2:45 p.m. Councillor Reimer departed the meeting.



It was MOVED and SECONDED That the Climate Action Committee receive the report dated August 29, 2015, titled "Climate Change and Air Pollution Warning Labels on Gasoline Pumps" for information.

CARRIED

5.8 Manager's Report Report dated September 25, 2015 from Allan Neilson, General Manager, Planning, Policy and Environment, updating the Climate Action Committee on the 2015 work plan, Trans Mountain expansion project, Fraser Surrey Docks, air quality advisories in the summer of 2015, visual air quality, Urban Forest Climate Adaptation Guidelines for the Metro Vancouver region, Emotive campaign, and BC SCRAP-IT program pilot for commercial trucks.

Members were provided with a presentation on the Emotive campaign, highlighting the events attended in different municipalities during the summer 2015 campaign.

Presentation titled "Emotive Summer 2015 Season Event" is retained with the October 7, 2015 Climate Action Committee agenda.

It was MOVED and SECONDED That the Climate Action Committee receive for information the report dated September 25, 2015, titled "Manager's Report".

CARRIED


6.1 New York Times Article dated September 30, 2015, "Test Emissions Where Cars Pollute: On the Road"

It was MOVED and SECONDED That the Climate Action Committee receive for information the following item: 6.1 New York Times Article dated September 30, 2015, "Test Emissions Where

Cars Pollute: On the Road"

7. OTHER BUSINESS No items presented.

8. BUSINESS ARISING FROM DELEGATIONS No items presented.

9. RESOLUTION TO CLOSE MEETING No items presented.

CARRIED



10. ADJOURNMENT /CONCLUSION

It was MOVED and SECONDED That the Climate Action Committee conclude its regular meeting of October 7, 2015.

Deanna Manojlovic, Assistant to Regional Committees

12044829 FINAL

CARRIED (Time: 2:58 p.m.)

Derek Corrigan, Chair



5.4


From: Derek Jennejohn, Lead Senior Engineer Planning, Policy and Environment Department

Date: September 10, 2015 Meeting Date: October 7, 2015

Subject: Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008

RECOMMENDATION That the Climate Action Committee receive for information the report dated September 10, 2015, titled “Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008”.

PURPOSE This report provides an overview of proposed amendments to Greater Vancouver Regional District Air Quality Management Bylaw No. 1082, 2008 (Bylaw 1082) and Greater Vancouver Regional District Air Quality Management Fees Regulation Bylaw No. 1083, 2008 (Bylaw 1083), concerning air quality permit renewals and other bylaw housekeeping changes on which staff intend to initiate consultation.

BACKGROUND When the GVRD Board adopted Bylaws 1082 and 1083 in 2008, renewals of air emission permits were not common, since most permits had been issued in perpetuity. More recently, permits have been issued with fixed terms, several of which expire in early 2016.

This report outlines proposed permit renewal amendments intended to address any potential concerns associated with the pending expiration of permits. Additional housekeeping amendments are proposed for the Bylaws to improve enforceability and adjust fees for inflation. An Intentions Paper has been prepared (Attachment), which will be used as the basis for consultation with affected stakeholders.

Proposed Amendments Permit Renewals Applications for new permits and permit amendments are defined in Bylaws 1082 and 1083. Permit renewals, which result when a permit expires, are not specifically identified. Consequently, permit renewal application fees would be similar to fees paid for a new permit, and as a result the largest emitters may pay fees that they would consider to be unreasonable. Staff recommends clarifying the concept of permit renewals in the Bylaws and placing a cap on permit renewal fees.

Adjustments for Inflation Since the Board endorsed Bylaw 1083 in 2008, no adjustments have been made to administrative fees. Staff propose to increase these fees marginally to account for inflation, and add fees for permit suspensions, permit reinstatements, and non-electronic filing of reports, that require administrative effort but are not covered in the current fee structure.


Revision to the Exemption for Comfort Heating Bylaw 1082 currently exempts natural gas or propane boilers or furnaces with a capacity less than 0.1 MW from the requirements of the Bylaw. Commercial heating units, such as those in retail, institutional and commercial buildings can often be larger than this, and in theory since they are not covered by any emission regulation bylaw, they are currently not authorized if they are not covered under a permit. However, given the small capacity of, and low emissions from these types of comfort heating units, permitting is unnecessary and staff recommends that the natural gas or propane boiler or furnace exemption in Bylaw 1082 be increased to 0.3 MW.

Residential Wood Burning Fuel Definition Although Bylaw 1082 requires that only “wood, paper or derivatives of wood and paper, or natural gas” be used as fuels in residential fireplaces or wood stoves, this requirement is not necessarily clear in some cases and staff recommends additional clarification of acceptable fuels. Further clarification is proposed for the language of this section of Bylaw 1082.

ALTERNATIVES This report is provided for information only. No alternatives are presented.

FINANCIAL IMPLICATIONS The proposed change in fees will result in less revenue for Metro Vancouver, due to a reduction in fees for permit renewals. However these revenues were not anticipated when the current Bylaw was adopted, as it did not include a mechanism for renewal of existing permits. In the absence of the proposed amendments, there are a number of cases where holders of permits that are due to expire in 2016 will have to pay fees that could be seen as onerous and/or unreasonable. These fees would be an unintended consequence of permit term limits that have been established to reduce emissions and promote continuous improvement in air quality.

An inflationary adjustment to administrative fees will result in a minor increase in revenues as they will primarily only impact permit fees. Revenues are expected to increase approximately $5,000 if this change goes ahead.

Provisional budgets for 2016 have been prepared under the assumption that the proposed revisions to Bylaws 1082 and 1083 will be approved.

SUMMARY / CONCLUSION Staff are initiating consultation on proposed changes to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008 to introduce permit renewals and associated fees as a unique process, and to make additional housekeeping amendments. A consultation process will be undertaken with stakeholders and interested parties to review the proposed amendments, before bringing proposed bylaw amendments to the GVRD Board for consideration.


Attachment: Intentions Paper – Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083 (Doc #11977474).

11734864


Intentions Paper Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083

October 2015

5.4 Attachment


Intentions Paper on Proposed Amendments to Metro Vancouver’s Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083

1. Introduction

Metro Vancouver is considering changes to Greater Vancouver Regional District (GVRD) Air Quality Management Bylaw No. 1082 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083. This intentions paper outlines the proposed changes, and elicits informed comment on these changes.

Who should read this?

This intentions paper will be of interest to:

(1) Industrial, commercial or institutional facilities that operate under a Metro Vancouver permit or air emission regulation, or that may be required to operate under a permit or emission regulation, particularly those with limited term permits; and

(2) Other interested parties.

2. Background

Metro Vancouver regulates air emissions in the region under B.C.’s Environmental Management Act. This mandate is governed by GVRD Air Quality Management Bylaw No. 1082. To support this mandate, Metro Vancouver collects fees from permitted and regulated entities to cover the costs of its air quality function. GVRD Air Quality Management Fees Regulation Bylaw No. 1083 provides the basis for how these fees are assessed.

When the GVRD Board adopted Bylaws 1082 and 1083 in 2008, air emission permit renewals were not common. Since then, permits have been issued with fixed terms, meaning that permit holders will need to apply for a new permit prior to permit expiry, and pay new permit application fees. For some facilities the existing application fees might be considered unfair. While new permits require substantial resources, permit renewals require less; however, the bylaw currently imposes the same fee for both. Consequently this intentions paper proposes a distinct fee structure for permit renewals, to correct that unfairness before these permits expire.

In addition, several housekeeping amendments, including comfort heating exemptions, residential wood burning clarifications, inflation adjustments and new fees for permit administrative activities are proposed.

3. Proposed Amendments to the Bylaws

Metro Vancouver proposes to make the following changes to Bylaws No. 1082 and 1083 (the Bylaws):

• Renewal of permits: Define air quality permit renewals as a process different from newpermit issuance and permit amendment, and set application fees for permit renewals.


• New administrative fees and fee inflation adjustments: Add fees for certain administrativetasks, and adjust existing administrative fees for inflation.

• Natural gas/propane fired comfort heating: Increase the natural gas/propane comfortheating exemption in Bylaw 1082 from 0.1 MW (0.33 million BTU/h) to 0.3 MW (1 millionBTU/h) to reduce the number of commercial/industrial heating units requiring explicitauthorization.

• Residential fireplace fuel clarification: Improve the clarity of Bylaw 1082 regardingresidential fireplaces by changing “wood” to “clean wood”, and by modifying the sectioninto a more readable format.

3.1 Renewal of Permits

Section 11(1) of Bylaw 1082 allows the district director to issue a permit to authorize the discharge of air contaminants to the environment with conditions including “restrictions on the … term for which such discharge may occur”. Fixed terms are necessary so that permits are reviewed to ensure that permit conditions encourage continuous improvement where warranted, and take into account new information about air contaminants, changing receiving environments, expended pollution control capital, confidence in the adequacy of permit conditions, and changing technology. All permits issued or amended from mid-2015 forward are expected to have fixed terms, ranging from 2-3 years up to twenty years, depending on the facility, surrounding community and other factors.

Permit renewals:

• Are generally more complex than permit amendments because of the number of emissionsources that require review;

• Require less effort than new permit issuances because a thorough review would have beenconducted at the time of permit issuance - although this might not always be up-to-dategiven information and technology changes with time; and

• Should be as transparent to the public as new permit issuances, and should thereforeundergo a public notification process so that potentially affected parties are given theopportunity to comment.

Proposed fees for permit renewals are based on the following principles:

• Cost recovery/user pay: Fees should be collected on a cost recovery basis. Users shouldpay in accordance with the level of effort required to regulate their business and the effortrequired for a thorough technical review of the permit, both of which are proportional tothe complexity of the site.

• Discharger pay/impact weighting: Payments recovered from regulated businesses shouldbe related to the environmental impact of the contaminants discharged by those businessesand fees for air contaminants should be weighted according to the potential impact of thatcontaminant.

• Equity: Cost recovery should be apportioned in an equitable manner between sources.• Incentive to reduce: Fees should be based on discharge quantities to provide an incentive

to reduce contaminant discharges.


Proposed changes Metro Vancouver proposes to add permit renewals and associated public notification requirements to Bylaw 1082 and to add application fees for permit renewals to Bylaw 1083.

Metro Vancouver proposes to assess a permit renewal application fee of $220 plus twice the total emission fees payable for the emissions specified in the renewal application. If the total is greater than $50,000, the application fee would be the lesser of the above or $50,000 plus twice the emission fee for any requested increase in emissions. Examples are provided in Appendix 1.

Under the proposed fee structure, while most facilities would pay permit renewal application fees similar to those for a new permit, the most complex facilities would have fees of $50,000 plus an adjustment for any increase in emissions, compared with upwards of $750,000 under the existing fee structure.

3.2 New Administrative Fees and Inflation Adjustments to Fees

Some permitting and administrative costs are not covered in the fee bylaw (Bylaw 1083):

• Air quality permits can be suspended either automatically for non-payment of fees, or byrequest of the permittee, in situations, for example, when a facility’s start-up is substantiallydelayed. A permit suspension fee would help cover the cost of processing the suspension.

• Permits that have been suspended, but not cancelled, can be reinstated. A permitreinstatement fee would help cover the cost of processing the reinstatement.

• While most permittees and registrants make use of Metro Vancouver’s electronic reportingportal, some reports continue to arrive in hardcopy and must be handled separately forelectronic conversion. A non-electronic report processing fee would help cover the cost ofprocessing hardcopy reports.

The base administrative portion of total emission fees has remained $200 since Bylaw 1083 was adopted in 2008. According to the Bank of Canada, the rise in the Canadian inflation rate from 2008 through 2015 has been an annual average of 1.36 per cent, or an overall increase of 9.93 per cent.

Proposed changes Metro Vancouver proposes that the following additional fees be added to the fee bylaw:

(1) $220 for a permit suspension;

(2) $220 for a permit reinstatement; and

(3) $220 for processing of non-electronic reports.

Additionally, Metro Vancouver proposes that the $200 base fee be increased to $220 to account for inflation.


3.3 Natural Gas/Propane Fired Comfort Heating

Natural gas/propane fired comfort heating devices (boilers or furnaces) up to 0.1 MW (0.33 million BTU/h) are exempt from Bylaw 1082. However, GVRD Boilers and Process Heaters Bylaw 1087 authorizes natural gas or propane boilers up to 3 MW with the sole requirement that NOx emissions not exceed 60 mg/m3 of flue gases. This leads to situations where comfort heating devices greater than 0.1 MW in size require authorization, while facilities with comfort heating natural gas or propane boilers less than 3 MW in total are conditionally authorized without having to take additional steps. Furthermore, commercial natural gas fired units (such as roof top units on office buildings or retail facilities) in the range of 0.1 – 0.2 MW (0.3 to 0.7 million BTU/h) and up to 0.33 MW (1 million BTU/h) are not uncommon, and few if any are currently permitted, nor does Metro Vancouver want them to be.

Proposed changes To streamline queries about the permitting requirements for comfort heating devices, and to close the gap between Bylaws 1082 and 1087 with respect to relatively small devices, Metro Vancouver proposes to increase the Bylaw 1082 comfort heating exemption to 0.3 MW (1 million BTU/h) where facility capacity is less than 3 MW.

3.4 Residential Fireplace Fuel Clarification

Bylaw 1082 section 8 restricts the fuels used in residential fireplaces or woodstoves to “wood, paper or derivatives of wood and paper, or natural gas,” but is not clear regarding the types of wood, which may lead to the impression that any wood (e.g. painted or glued wood, such as plywood) is acceptable for use. Metro Vancouver proposes to add a definition for “clean wood” to the Bylaw and to replace “wood” with “clean wood” in section 8.

“Clean wood” would be defined as wood that has been seasoned or allowed to dry, and is uncontaminated wood free of glue, paint or preservative, or foreign substances harmful to humans, animals or plants when burned. This definition is based on the definition of “biomass” in Bylaw 1087, as well as elements of the Code of Practice for Residential Wood Burning Appliances, prepared by the Canadian Council of Ministers of the Environment.

3.5 Implementation

The amended Bylaws will take effect upon approval by the Board.

4. Providing Comments on Proposed Intentions for the Bylaws

Metro Vancouver welcomes feedback with respect to any or all of the proposed changes. All comments and suggestions will be compiled into a consultation summary report and will be carefully considered in development of the amended Bylaws No. 1082 and 1083.

Comments received will be treated with confidentiality by Metro Vancouver staff and contractors when preparing consultation reports. Please note that comments you provide and information that identifies you as the source of those comments may be publicly available if a freedom of


information (FOI) request is made under the Freedom of Information and Protection of Privacy Act. If you have any questions or comments regarding the consultation process, call 604-432-6200.

Following consultation on this Intentions Paper, Metro Vancouver staff will prepare a draft amendment to the Bylaw. It is anticipated that the draft Bylaw amendment will be before the GVRD Board in the winter of 2016, together with input from consultation.

To ensure that your comments are considered, please provide feedback by December 31, 2015 to [email protected].

Thank you for taking the time to consider these potential Bylaw changes and provide your input.

10625675



Appendix 1 – Proposed Permit Renewal Fee Examples

Example 1 - Small facility

(e.g. grain terminal)

Example 2 - Medium facility (e.g. wood products

manufacturing)

Example 3 - Large facility

(e.g. cement plant) Annual Emission Fees, specified in Renewal: $8,000 $25,500 $378,600 Previous Annual Emission Fees: $4,400 $21,900 $375,000

Increase in Emission Fees: $3,600 $3,600 $3,600

Method A Base fee: $ 220 $220 $220 Annual Emission Fees, specified in Renewal: $8,000 x2 $16,000 $25,500 x2 $51,000 $378,600 x2 $757,200 Method A Permit Renewal Fee: $16,220 $51,220 $757,420

Method B Annual Emission Fees, maximum amount with Renewal: $50,000 $50,000 Increase in Emission Fees: $3,600 x2 $7,200 $3,600 x2 $7,200 Method B Permit Renewal Fee: Min $ 50,000 $57,200 $57,200

Lesser of Method A or B? A A B

Permit Renewal Fee $16,220 $51,220 $57,200

BBaassee ffeeee $$222200 22xx aannnnuuaall eemmiissssiioonn ffeeeess MMeetthhoodd AA ppeerrmmiitt rreenneewwaall ffeeee

FFoorr ffaacciilliittiieess wwiitthh ccuurrrreenntt aannnnuuaall eemmiissssiioonn ffeeeess uupp ttoo $$2255,,000000,, nnoo cchhaannggee ((MMeetthhoodd AA iiss aallwwaayyss lleessss tthhaann MMeetthhoodd BB))

FFoorr ffaacciilliittiieess wwiitthh aannnnuuaall eemmiissssiioonn ffeeeess ggrreeaatteerr tthhaann $$2255,,000000,, lleesssseerr ooff MMeetthhoodd AA oorr BB

$$5500,,000000 22xx iinnccrreeaassee ffrroomm pprreevviioouuss eemmiissssiioonn ffeeeess MMeetthhoodd BB ppeerrmmiitt rreenneewwaall ffeeee

11977474 19Climate Action Committee -

ISSUES AND RESPONSES TABLE


Metro Vancouver's Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Bylaw No. 1083

Issues and Metro Vancouver's Responses

Issue # Category Source Issue/Comment/Question Metro Vancouver Response

Permit Renewal and Associated Fees1 Permit

Application FeesKori Jones, Energy Specialist, Fraser Heath Authority, E-mail Jan. 6/16

Clarification sought on which Health Authority facilities are affected by these proposed changes and how the proposed amendments would impact their fees.

Most Health Authority facilities are authorized under GVRD Bylaw 1087 and are not impacted by the proposed changes. Additionally, institutions are exempt from paying fees under Bylaw 1087. The one exception is Vancouver General Hospital, which has a permit.

2 Permit Application Fees

Rebecca Abernethy, Environmental Policy Analyst, Fraser Valley Regional District, E-mail, Dec. 6/15

Support for amendment to fees associated with permit renewals.

Support for fee structure noted.


Jelena (Yellena) Denin Djurdjevic, Manager, Laboratory Services and Environment, Lantic Inc., E-mail, Dec. 6/15

Clarification sought for the increase in fees and the different annual emission fees ("previous" and "specified in Renewal") mentioned in Appendix 1 of the Intentions Paper.

Appendix 1 was intended to illustrate the differences in fees for small vs medium vs large facilities, where the permit application includes increased emissions. Both “previous” and “specified in renewal” emission fees were shown to illustrate the case where permittees have requested an increase in emission limits (i.e. "specified in renewal" is the same as “requested in application”).

In most cases "previous" would equal "requested in application" (no change in authorized limits) or the latter would be even lower for permittees wanting to decrease limits (and therefore fees). There would be no increase in emission fees in the former case, and in the latter it would actually be a decrease.




Jelena (Yellena) Denin Djurdjevic, Manager, Laboratory Services and Environment, Lantic Inc., E-mail, Dec. 6/15

Clarification sought on the use of a flat $3,600 increase in emission fees in all scenarios in Appendix 1 of the Intentions Paper.

The flat $3,600 increase was used to provide an illustrative example of how an emission fee increase of the same magnitude could affect different sized facilities. The $3,600 value was chosen to show what would happen to facilities with fees right around that transition from under $25K to over $25K should they apply for increased emission limits.


Darren Brown, Manager, Environment & Public Affairs, Lafarge, Letter Jan. 15/16

Ken Carrusca, Environment and Marketing (Western Region), Cement Association of Canada, E-mail Jan. 11/16

Support for fair fees that align with the Metro Vancouver principle of cost recovery and user pay

Support for fee structure noted.


Eileen Jang, Environmental Manager, Lehigh Hanson Materials Limited, E-mail with attached letter Jan. 4/16


Proposed initial renewal fee of $50,000 is excessive and unwarranted.

Requests that MV provide the rationale for the proposed initial renewal fee of $50,000.

Permit application fees are intended to be reflective of the level of effort required for Metro Vancouver to review an application that completes the Air Quality Authorization Process posted on Metro Vancouver's website. Based on the principle of cost recovery through polluter payment, an application fee is based on emissions specified in a permit, and as such, facilities with greater emissions pay higher application fees. A fee of $50,000 approximates the time and resources needed for Metro Vancouver to review an application for a larger facility.




Stakeholder Meeting, Metro Vancouver Head Office, Jan. 19/16

Concern that support for proposed fee structure for permit renewals could incorrectly imply support for term limits.

Support for fee structure noted, with an acknowledgement of significant concerns around term limits. Metro Vancouver sees the proposed changes to the application fees that will be charged to facilities that already have term limits in their permits as a separate issue from the broader use of term limits. Metro Vancouver proposes to continue discussing the use of term limits with all affected stakeholders.



New permits for existing facilities are perceived to be less complex than for brand new facilities. More clarity on the expected complexity of permit applications for existing facilities is needed.

Metro Vancouver's Guidance for Air Permit Applications describes the permit application process and explains which steps could be applicable to existing facilities. Some existing facilities can be complex to review.

9 Public Notification Requirements

Greg D'Avignon, President and CEO, BCBC, E-mail with attached letter, Jan. 4/16




Concern about the cost and effort involved in public notification. This should not be required for projects that are continuing previously authorized activities or decreasing emissions.

Instead of introducing the concept of permit renewals and associated public notification requirements, Metro Vancouver will use existing mechanisms in Bylaw 1082 to replace expired permits. As such, no changes are proposed to Bylaws 1082 or 1083 with respect to public notification requirements. Metro Vancouver's Guidance for Air Permit Applications describes when public notification is required .Metro Vancouver proposes to continue discussions with stakeholders on the implications of term limits and the process for replacing an expired permit.



10 Public Notification Requirements

Ron Sander, Vice President Major Projects and Environment, Neptune Bulk Terminals (Canada) Ltd., Letter December 23/15

Insufficient information on public notification expected of operators and on timeline for Metro Vancouver's decision related to an operator's public notification requirements.

Metro Vancouver's Guidance for Air Permit Applications describes when public notification is required or applied at the discretion of the District Director for various types of applications.

Exemption for Natural Gas and Propane Boilers up to 0.3 MW11 Exemptions to

Bylaw 1082Rebecca Abernethy, Environmental Policy Analyst, Fraser Valley Regional District, E-mail, Dec. 6/15

If the exemption for natural gas and propane comfort heating devices is broadened, then Metro Vancouver is strongly encouraged to pursue other ways to reduce emissions from these sources.

Caution noted. Staff propose to revisit the limit of 0.1 MW for the exemption for natural gas and propane-fired comfort heating devices at a later time. Meanwhile, Metro Vancouver proposes to reduce emissions from these small, widespread sources through initiatives such as the Strata Energy Advisor program, Small and Medium Enterprise program, and facilitation of district energy initiatives where appropriate.

Residential Fireplace Fuel Definition12 Residential

Furnace Fuel Definition


Support for clarification of the definition for residential fireplaces and stove wood fuel.

Support noted. Staff propose to revisit the definition of residential fireplace and stove fuel as part of a broader review of Bylaw 1082.



Other Issues13 Permit term

limits - Financial risks


Brad Eshleman, President, Western Stevedoring, E-mail with attached letter Jan. 4/16

Brett Malkoske, Vice President, Business Development, G3, E-mail with attached letter, Jan. 5/16

Rob MacKay-Dunn, Director, Public Policy and Communications, The Vancouver Board of Trade, E-mail Jan. 4/16

Mark Edwards, Community and Government Relations, Teck Resources Limited, E-mail with attached letter Jan. 4/16


Jon Garson, President and CEO, The British Columbia Chamber of Commerce, Email with attached letter Jan. 11/16

ff id &

Permit term lengths do not adequately reflect the long-term nature of capital investment. Investors look for security of "tenure" before committing funds. Permit terms that are too short and renewal provisions that appear to have "hard stops" and/or "cold-stop" expirations increase the risks for all sizes of business and jeopardize investments needed for economic growth.

The scope of the proposed amendments does not include changes to the use of term limits.

Metro Vancouver proposes to continue engaging with stakeholders in a discussion around the use of term limits and any implications for continued investment.



14 Permit term limits - Financial risks





Mark Edwards, Community and Government Relations, Teck Resources Limited, E-mail with attached letter Jan. 4/16


Jeff Scott, President & CEO, Fraser Surrey Docks, Letter Jan. 14/16


Permit term limits will increase business operating costs. Permit applicants incur significant costs in engaging expert consultants and in internal staff time.

The scope of the proposed amendments does not include changes to the use of term limits or to the permit application process.

Metro Vancouver proposes to continue discussions with stakeholders around the use of term limits, including concerns related to business operating costs.





Brad Eshleman, President, Western Stevedoring, E-mail with attached letter Jan. 4/16

Duncan Wilson, Vice President, Corporate Social Responsibility, Port Metro Vancouver, E-mail with attached letter Jan. 4/16

Stakeholder Meeting, Metro Vancouver Head

Little certainty that a permit will be renewed after the term expires or that the magnitude of changes required for an existing facility will be feasible, which is exacerbated by short term limits. Stopping operations if a permit is not renewed in time triggers significant costs and could impact investment potential and economic growth.


Metro Vancouver will engage with stakeholders in a discussion around the use of term limits in air quality permits and the process for continuation of an existing/expiring permit.




Concerns that introduction of permit term limits without specific clarifications on details will destabilize industry in the region.


Metro Vancouver will engage with stakeholders in a discussion around the use of term limits and implications for the stability of industry.



Concern that permit term limits are not being grandfathered and are not limited to new air permits.


Metro Vancouver will engage with stakeholders in a discussion around the use of term limits and concerns about term limits for existing permits.



18 Permit term limits - Proposed alternative action


Alternative approach to continuous improvement proposed that relies on data-based output review mechanisms triggered throughout the duration of a permit.

The scope of the proposed amendments does not cover Metro Vancouver's approach to reviewing the environmental impacts of permitted sites.Metro Vancouver will discuss alternative ways to improve air emissions as part of the proposed continuing discussions with stakeholders on the issue of term limits.

19 Permit term limits - Policy


Due to the significant capital outlay for cement manufacturing plants - it is suggested that at the very least permits issued to these facilities would be longer term, and in the 10 to 20 year range.


Metro Vancouver will engage with stakeholders in a discussion around the use of term limits and the determination of the term length.






Shorter fixed term limits for air quality permits will make it more difficult for industrial sites to invest in environmental and safety improvements that are dependent on industry's ability to receive financing.


Metro Vancouver will engage with stakeholders in a discussion around the use of term limits and any impact on investments in industry, including investments for environmental improvements.






Jeff Scott, President & CEO, Fraser Surrey Docks, Letter Jan. 14/16

Opposition to implementation of Permit term limits.

The scope of the proposed amendments does not include changes to the use of term limits. Metro Vancouver will engage with stakeholders in a discussion around the use of term limits.



Opposition to implementation of Permit term limits for permanent operations such as cement plants.

The scope of the proposed amendments does not include changes to the use of term limits. Metro Vancouver will engage with stakeholders in a discussion around the use of term limits.


Dan Bradley, Energy Utilization Manager, Fortis BC, E-mail, December 17/15

Kori Jones, Energy Specialist, Fraser Heath Authority, E-mail Jan. 6/16



Clarification needed around how fixed permit terms will be determined.

The scope of the proposed amendments does not include changes to the use of term limits or how they are determined. Metro Vancouver will engage with stakeholders in further discussions on the use of term limits.



Support for permit term limits. Support noted, although the scope of the proposed amendments does not include changes to the use of term limits..





Inclusion of cumulative air quality assessment in the permit review process could impact a facility's ability to renew permits in the future.

The scope of the proposed amendments does not include changes to the permit application review process. Metro Vancouver will engage with stakeholders in a discussion around the permit application review process for permits that reach their term limits.



A minimum fixed permit term of 10 years is recommended.

The scope of the proposed amendments does not include changes to the use of term limits or how they are determined. Metro Vancouver will engage with stakeholders in a discussion around the use of term limits, including duration of the term.




Ron Sander, Vice President Major Projects and Environment, Neptune Bulk Terminals (Canada) Ltd., Letter Dec. 23/15

Expressed interest in meeting with Metro Vancouver to discuss the proposed changes to permit term limits.

Metro Vancouver held individual and collective meetings with concerned stakeholders in December 2015 and January 2016 to clarify the scope of the proposed amendments and discuss concerns around term limits.



MV's rationale for shorter term permits demonstrates bias against larger facilities, since some may not have a significant impact on air quality.


Metro Vancouver will engage with stakeholders in a discussion around the use of term limits and the rationale for how they are determined.





Permit term limits should be decided on an operator's history and effectiveness to work with their local community, and on the outcomes of an operator's environmental protection efforts.

The scope of the proposed amendments does not include changes to the use of term limits or how they are determined. Metro Vancouver will engage with stakeholders in a discussion around the use of term limits.



The district director's discretion around the level of confidence in proposed measures creates uncertainty around what is expected from an applicant in a permit application.

The scope of the proposed amendments does not include changes to the permit application process or how term limits are determined. Metro Vancouver will engage with stakeholders in a discussion around term limits to address concerns around uncertainty.



The rationale for setting permit term limits includes the criteria that considers whether control technologies are "stable or evolving". This may create a disincentive for operators to make investments in new and emerging technological improvements.

The scope of the proposed amendments does not include changes to the use of term limits or how they are determined. Metro Vancouver will engage with stakeholders in a discussion around the use of term limits.

32 Permit term limits - Proposed alternative action


An alternative approach to continuous improvement could involve enhancing monitoring and enforcement of permitted sites.

The scope of the proposed amendments does not include changes to Metro Vancouver's compliance promotion program. However, Metro Vancouver will proposes to discuss suggestions to continuously improve air emissions during future discussions with stakeholders on the use of term limits.

33 Permit term limits - Regional economic impact



Permit term limits may impact future regional investment, employment, and the regional economy.


Metro Vancouver will engage with stakeholders in a discussion around the use of term limits and any regional impacts.



34 Other bylaws Dan Bradley, Energy Utilization Manager, Fortis BC, E-mail, December 17/15

Questions on calculating fees in GVRD Boilers and Process Heaters Bylaw No. 1087. Which value is used for boiler capacity - GJ or MW? What value is used for the volume of flue gas in each GJ of NG and in each GJ of biomass?

The emissions fee calculation uses facility boiler capacity in GJ/hr. Operators can report either MW or GJ/hr, and Metro Vancouver converts to the appropriate units (e.g. convert MW to GJ/hr by multiplying by 3.6).The volume of flue gas used in the emissions fee calculation is calculated stoichiometrically. For natural gas, it is 260 DSm3/GJ (corrected to 3% O2). For biomass, it is 436 DSm3/GJ (corrected to 8% O2).


SUMMARY OF CORRESPONDENCE


Bylaws 1082 and 1083 Amendments - Summary of Correspondence

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23-Nov-15 OUT Email

Notice of Public Consultation - Amendments to Air Quality Management Bylaws Stakeholders

18-Dec-15 OUT Email

Reminder: Notice of Public Consultation - Amendments to Air Quality Management Bylaws Stakeholders

11-Jan-16 IN LetterBC Chamber of Commerce Jon Garson

Proposed Amendments to Air Quality Bylaw No. 1082 and Air Quality Management Fees Bylaw No. 1083 Metro Vancouver

4-Jan-16 IN LetterBusiness Council of British Columbia Greg D'Avignon

Intentions Paper: Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Metro Vancouver

11-Jan-16 IN LetterCement Association of Canada Ken Carrusca

Proposed Amendments to GVRD Air Quality Management Bylaws No. 1082 and 1083

Program Manager, Bylaw and Regulation Esther Berube

17-Dec-15 IN Email Fortis BC Dan Bradleycall with FortisBC - Regulations 1082 & 1083 Metro Vancouver

Esther Berube Maari Hirvi Mayne

6-Jan-16 IN Email Fraser Health Kori JonesProposed Amendments to Air Quality Management Inquiry

Metro Vancouver Air Quality Bylaws


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14-Jan-16 IN Letter Fraser Surrey Docks Jeff Scott

Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation

Manager, Environmental Regulation & Ray Robb

6-Dec-15 IN Email

Fraser Valley Regional District Rebecca Abernethy

Notice of Public Consultation - Amendments to Air Quality Management Bylaws


4-Jan-16 IN Letter Western Stevedoring Brad EshlemanProposed Amendments Air Quality Bylaws No. 1082 and 1083 Metro Vancouver Ray Robb

4-Jan-16 IN EmailThe Vancouver Board of Trade Rob MacKay-Dunn

Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation

Director, Air Quality Policy & Climate Change Roger Quan

4-Jan-16 IN Letter Teck Mark Edwards Air Quality Bylaw Amendment Metro Vancouver

4-Jan-16 IN Letter Lehigh Cement Eileen M. Jang

Proposed Amendments to GVRD Air Quality Management Bylaw No. 1082 and GVRD Air Quality Management Fees

Program Manager, Bylaw and Regulation Esther Berube

4-Jan-16 IN Letter Port Metro Vancouver Duncan WilsonProposed Amendments to Bylaws 1082 and 1083

General Manager, Planning, Policy and Environment Allan Neilson

5-Jan-16 IN Letter G3 Brett Malkoske

Intentions Paper, Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Metro Vancouver


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9-Dec-15 IN Email Lantic IncJelena Denin Djurdjevic

Notice of Public Consultation - Amendments to Air Quality Management Bylaws


23-Dec-15 IN Letter Neptune Terminals Ron Sander Permit Term Limits Metro Vancouver

18-Dec-15 OUT Emailcall with FortisBC - Regulations 1082 & 1083 Fortis BC Dan Bradley

11-Jan-16 OUT EmailProposed Amendments to Air Quality Management Inquiry Fraser Health Kori Jones

15-Dec-15 OUT Email Bylaw 1082 & 1083The Vancouver Board of Trade Aaron Robinson

15-Jan-16 IN Letter Lafarge Darren Brown

Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083

Program Manager, Bylaw and Regulation Development Esther Berube


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14-Jan-16 OUTMeeting Invite

Discussion on Proposed Amendments to GVRD Air Quality Bylaws 1082 and 1083

BC Chamber ofCommerce, Business Council of British Columbia, Cement Association of Canada, Fortis BC, Fraser Health, Fraser Surrey Docks, Fraser Valley Regional District, Western Stevedoring, The Vancouver Board of Trade, Teck, Lehigh Cement, Port Metro Vancouver, G3, Lantic Inc, Neptune Terminals


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20-Jan-16 OUT EmailJanuary 19 discussion of proposed amendments to Bylaws 1082 and 1083

BC Chamber ofCommerce, Business Council of British Columbia, Cement Association of Canada, Fortis BC, Fraser Health, Fraser Surrey Docks, Fraser Valley Regional District, Western Stevedoring, The Vancouver Board of Trade, Teck, Lehigh Cement, Port Metro Vancouver, G3, Lantic Inc, Neptune Terminals, National Public Relations, McCarthy Tetrault, Lafarge


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26-Jan-16 OUT Emailfollowup to our conversation this morning

Business Council of British Columbia Denise Mullen

26-Jan-16 IN EmailBusiness Council of British Columbia Denise Mullen

followup to our conversation this morning

Director, Air Quality Policy & Climate Change Roger Quan


OUTGOING CORRESPONDENCE


Rebecca O'Brien

From: Metro Vancouver Air Quality BylawsSent: Monday, November 23, 2015 4:25 PMTo: Metro Vancouver Air Quality BylawsSubject: Notice of Public Consultation - Amendments to Air Quality Management Bylaws


Public Consultation on Bylaws 1082 and 1083November 23, 2015 Dear Stakeholder, Metro Vancouver is proposing changes to its Air Quality Management Bylaw No. 1082 (Bylaw 1082) and its Air Quality Management Fees Regulation Bylaw No. 1083 (Bylaw 1083) related to:

Renewal of permits and related fees Adjustments to administrative fees for inflation and new fees for some administrative

tasks Broader exemption for natural gas or propane‐fired comfort heating Clarification to the definition of residential fireplace or stove wood fuel

A copy of the Intentions Paper and additional information on the proposed amendments can be found at Air Quality Public Consultation. Please provide feedback by January 4, 2016 to [email protected] Best regards, Esther Bérubé, P.Eng., M.Eng. Program Manager, Bylaw and Regulation Development Air Quality and Climate Change – Metro Vancouver


Rebecca O'Brien

From: Metro Vancouver Air Quality BylawsSent: Friday, December 18, 2015 2:34 PMTo: Metro Vancouver Air Quality BylawsSubject: Reminder: Notice of Public Consultation - Amendments to Air Quality Management

Bylaws


Reminder: Public Consultation on Bylaws 1082 and 1083

December 18, 2015

Dear Stakeholder,

Metro Vancouver is proposing changes to its Air Quality Management Bylaw No. 1082 (Bylaw 1082) and its Air Quality Management Fees Regulation Bylaw No. 1083 (Bylaw 1083). We thank everyone that has submitted feedback to date. Metro Vancouver encourages stakeholders to provide feedback by January 4, 2016 to [email protected]

The proposed amendments are related to: Renewal of permits and related fees Adjustments to administrative fees for inflation and new fees for some administrative

tasks Broader exemption for natural gas or propane‐fired comfort heating Clarification to the definition of residential fireplace or stove fuel

A copy of the Intentions Paper and additional information on the proposed amendments can be found at Air Quality Public Consultation.

Best regards,

Esther Bérubé, P.Eng., M.Eng. Program Manager, Bylaw and Regulation Development Air Quality and Climate Change – Metro Vancouver


Rebecca O'Brien

From: Esther BerubeSent: Tuesday, December 15, 2015 11:56 AMTo: 'Aaron Robinson'Cc: Roger Quan; Derek Jennejohn; Ray RobbSubject: RE: Bylaw 1082 & 1083

Categories: Yellow Category

Hi Aaron,

Thank you for your interest in the proposed amendments to Bylaws 1082 and 1083.

Metro Vancouver is encouraging the submission of feedback by January 4, 2016. As Ray noted, we will continue to consider feedback received until revised bylaws are adopted.

Best regards,

Esther

Esther Bérubé, P.Eng., M.Eng. Program Manager, Bylaw and Regulation Development Air Quality and Climate Change t. 604‐436‐[email protected]

metrovancouverSERVICES AND SOLUTIONS FOR A LIVABLE REGION

From: Ray Robb Sent: Tuesday, December 15, 2015 9:43 AM To: 'Aaron Robinson' Cc: Roger Quan; Derek Jennejohn; Esther Berube Subject: RE: Bylaw 1082 & 1083

Aaron,

It is our intent to consider term limits on all requests for new air permits and also to consider term limits whenever amending an existing air permit. For information on consultation on bylaw amendments, I am directing you to Roger Quan (and some key staff) whose division manages air quality bylaw amendments (although I can advise that it has generally been the practice of Metro Vancouver to consider all comments received regardless of the date as long as they are received before a bylaw is adopted – so from that perspective the difference in the dates is not material).

Regards,

Ray Robb

From: Aaron Robinson [mailto:[email protected]] Sent: Thursday, December 10, 2015 12:13 PM


To: Ray Robb Subject: Bylaw 1082 & 1083

Dear Ray,

I’ve been asked to prepare a submission in response to your public consultation outreach and I am hoping you can help me with a couple of quick questions that will assist me in focusing our comments.

I’ve been reading through some of the material on the term limits that Metro Vancouver is proposing for air permits. I was hoping youcould clarify whether it is Metro Vancouver’s intention to incorporate term limits into existing air permits – or if this is intended specifically for new air permits issued?

Also, is the feedback submission date on your proposed amendments to the Air Quality Management by-laws December 31, 2015 or January 4, 2016?

I look forward to your clarification on these matters.

Thanks,

Aaron Robinson Senior Policy Advisor, Greater Vancouver, The Vancouver Board of Trade t. 604.640.5461 f. 604-681-0437boardoftrade.com

The Vancouver Board of Trade | Suite 400, 999 Canada Place | Vancouver | BC | V6C 3E1 | Canada


Rebecca O'Brien

From: Esther BerubeSent: Friday, December 18, 2015 5:26 PMTo: '[email protected]'Cc: Maari Hirvi Mayne; Derek JennejohnSubject: RE: call with FortisBC - Regulations 1082 & 1083Attachments: 2015-05-06 - Memo - Factors to Consider when Proposing the Term for an Air Quality

Permit.doc_.pdf; Designation of B for Fee Calculation for B&H 1087_.pdf

Importance: High


Hi Dan,

Thanks for following up with questions on the emission fees and proposed changes. Please see our answers below.

Question 1: The air contaminant fees calculation shows Z = A*B*C*D*E*F Where C is the facility capacity in MW (or GJ per hour), as provided by the operator 1 MW = 3.6 GJ/hour, so which value do you use for capacity in the calculation. MW or GJ/hour?

(1) If the operator gives us MW, we first convert that to GJ/hr by multiplying by 3.6 GJ/hr/MW. If they give us GJ/hr, we use that number.

Question 2: What value do you use for the volume of flue gas determined to be in each GJ of natural gas and in each GJ of Biomass?

(2) The volume of flue gas (“B” in the calculation) is calculated stoichiometrically. For natural gas, it is 260 DSm3/GJ (corrected to 3% O2 in the stack, at 0% O2 it would be more in the range he noted). For biomass, it is 436 DSm3/GJ (same principles but corrected to 8% O2 in the stack). The policy approved by the district director is attached.

Question 3: Could you send me the background document on how fixed terms will be determined?

(3) The district director’s guidelines on factors to consider when recommending a permit term limit are attached. As mentioned, the district director is currently reviewing these guidelines.

Institutional Boilers To reiterate what was discussed about fees associated with institutions, the exemption for air contaminant emission fees only applies if the authorization of a boiler falls under Bylaw 1087 because facility capacity is under 50MW, instead of requiring a permit under Bylaw 1082. Bylaw 1087, Section 13 states that “No fees are payable for residential or institutional boilers, or residential or institutional process heaters.” Facility capacity is the sum of all boilers operating at a site that use the same fuel.

We’d be glad to discuss any additional questions.

Best regards,




Maari Hirvi Mayne Senior Project Engineer, Environmental Regulation and Enforcement Legal and Legislative Services t. 604.456.8823


‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐

From: Bradley, Dan [mailto:[email protected]] Sent: Thursday, December 17, 2015 9:42 AM To: Esther Berube Cc: Maari Hirvi Mayne Subject: call with FortisBC ‐ Regulations 1082 & 1083

Hi Esther, Maari, and Derrick (?), Thanks so much for calling and explaining the emission fees and proposed changes to me.

I still have a couple of questions on calculating the fees. The air contaminant fees calculation shows Z = A*B*C*D*E*F Where C is the facility capacity in MW (or GJ per hour), as provided by the operator 1 MW = 3.6 GJ/hour, so which value do you use for capacity in the calculation. MW or GJ/hour? What value do you use for the volume of flue gas determined to be in each GJ of natural gas and in each GJ of Biomass?

Have a great Christmas

Dan Bradley Energy Utilization Manager Market Development

[email protected] Ph: (604) 592 7647

This email was sent to you by FortisBC*. The contact information to reach an authorized representative of FortisBC is 16705 Fraser Highway, Surrey, British Columbia, V4N 0E8, Attention: Communications Department. You can unsubscribe from receiving further emails from FortisBC or email us at [email protected].

*”FortisBC” refers to the FortisBC group of companies which includes FortisBC Holdings. Inc., FortisBC Energy Inc., FortisBC Inc., FortisBC Alternative Energy Services Inc. and Fortis Generation Inc.

This e-mail is the property of FortisBC and may contain confidential material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. FortisBC does not accept liability for any errors or omissions which arise as a result of e-mail transmission. If you are not the intended recipient, please contact the sender immediately and delete all copies of the message including removal from your hard drive. Thank you.


metrovancouver MEMORANDUMSERVICES AND SOLUTIONS FOR A LIVABLE REGION

Legal and Legislative ServicesTel. 604 432-6200 Fax 604 436-6707

TO: Permitting and Enforcement Officers DATE: May 6, 2015Environmental Regulation and Enforcement Division

FROM: Ray Robb FILE NO.

District Director

RE: Factors to Consider when Proposing the Term for an Air Quality Permit

Purpose

To provide guidance to staff concerning the appropriate term of an air quality permit.

Background

The district director may issue a permit to authorize the discharge of air contaminants to theenvironment with conditions that are considered advisable for the protection of the environment.Such conditions may include the authorization being subject to a fixed term.

Air contaminants can be harmful at levels well below ambient objectives. In addition, technologicalinnovation is driving down the cost of air pollution control and also reducing the amount andharmfulness of air contaminants that are the consequence of business activity. Further, the MetroVancouver Integrated Air Quality and Greenhouse Gas Management Plan adopted by the Boardadvocates “continuous improvement”. Consequently, periodic review of air quality permitrequirements by establishing permit term limits is considered “advisable for the protection of theenvironment”. The benefits of periodic review must be balanced against the uncertainty and costexperienced by industry. In addition, an operation that has reached the end of its permit term hasgenerally invested substantial resources which may have remaining usefulness and, unlike newproposed facilities seeking permits, must be taken into account in permit term extensionrequirement negotiations.

Permit terms of five years or less will enable more timely review of permit requirements todetermine whether air contaminant emission reductions are reasonably achievable. Short durationpermits also provide Metro Vancouver with greater ability to respond to changes in information,technology, research and development as well as environmental and societal needs.

At the same time, the benefits to air quality must be balanced against reasonableness and efficiencyconsiderations for both the applicant and Metro Vancouver. Applicants who invest significantcapital into their operations, require some certainty that the installed works will have a reasonableoperating life. Similarly, the processing of permit amendments involves significant consumption oftime and resources for both the applicant and Metro Vancouver.

10925585


Permitting and Enforcement OfficersProposing a Term for Air Quality Permits

Page 2 of 3

For these reasons, permit term limits should balance environmental protection concerns againstcapital and other resource considerations. Unless requested by the Applicant, permit term limits ofless than five years should only be used in unusual circumstances, such as when there is a need tocollect further information concerning the discharge, treatment options and/or receivingenvironment impacts before authorizing emissions for a longer duration. At the other end of thespectrum; given the changing nature of operations, emission control capabilities and receivingenvironment concerns, terms greater than 15 years should only be used in very stable and low riskcircumstances. A permit term greater than 20 years would seem excessive under anycircumstances.

Factors to Consider when Proposing a Term for an Air Quality Permit

The factors the district director will consider when determining the appropriate permit term,include but ate not limited to:1. Quantity and type of air contaminants emitted

Larger facilities and more harmful air contaminants warrant shorter duration permits. Theduration of a permit should be inversely, non-linearly proportional to the annual permitfees. For example, if one facility has ten times the fee of another similar facility, the termon the larger emission fee discharger may be in the order of one-half of the term for thesmaller fee discharger. Permits with fees in excess $50,000 should generally have permitterms of less than eight years.

2. Sensitivity of receiving environmentPermit duration should be inversely proportional to the anticipated impacts. Sources whichreceive large numbers of complaints (i.e. odour) should generally be limited to five yearsunless there are substantial extenuating circumstances.

3. Cost of pollution control works relative to total facility costLonger duration permits are warranted where the capital cost of pollution control works area substantial portion of total facility cost and/or the treatment costs per tonne of aircontaminant are large. The relationship between the relative and absolute capital cost oftreatment works and permit terms is expected to be directly but non-linearly proportionalto permit terms. For example, a facility with $20 million worth of pollution control worksmay have a permit term of twice that of another facility of similar total capital cost but lessthan, say, $1 million worth of pollution control works.

10925585


Permitting and Enforcement OfficersProposing a Term for Air Quality Permits

Page 3 of 3

4. Confidence in adequacy of requirements to protect environmentGreater confidence by the district director that the permit will adequately protect theenvironment warrants longer duration permits. For example, if ambient monitoring, orcomplaint information is necessary to determine effectiveness of proposed works, a shorterduration permit is warranted — sufficient length of time should be provided to collectreasonably representative information but not so long that the community needs to endureimpacts that are outside “advisable for the protection of the environment” criteria if thedistrict director has underestimated the likely impact.

5. Emissions sources and pollution control technology stable or evolvingIf emission sources and treatment technologies are well established and unlikely to change,longer duration permits may be issued.

6. Potential for changing receiving environment needsIf the population density of the receiving environment is likely to increase dramatically orproximity to sources is likely to change (e.g., zoning allows condominium towers nearstacks) then shorter duration permits should be considered.

Of the above factors, the greatest weighting should be to the first and the least weighting should befor the last factors. In other words, the breadth in range of permit term is likely to be the greatestbetween sources that have substantially different fees. The estimation of potential receivingenvironment changes should have the least impact on proposed permit terms.

R. H. Robb, District DirectorGreater Vancouver Regional District

10925585


PROCEDURE - PR-0143-AQ Regulation & Enforcement Division

AMENDED

Designated Value for Variable “B” for the Purpose of Calculating Air Contaminant Emission Fees for Natural Gas and Propane

and Biomass Fired Boilers Under Boilers and Process Heaters Emission Regulation Bylaw No. 1087, 2008

Designation of Value for Variable “B”

Appendix 1 of the Boilers and Process Heaters Emission Regulation Bylaw No. 1087, 2008 describes the fee calculation method for emission fees for boilers and process heaters. Variable “B” in the equation Z = A x B x C x D x E x F refers to the predicted volume of flue gas in cubic metres per gigajoule of fuel energy input (m3/GJ). Detailed calculations on how variable “B” has been derived can be found in the attached Excel spreadsheet

For Natural Gas and Propane Variable “B” is hereby specified to be 260 m3/GJ for the purpose of calculating air contaminant emission fees for natural gas and propane fired boilers and process heaters. .

For Manufactured Wood Fuel (i.e. pellets) Variable “B” is hereby specified to be 353m3/GJ for the purpose of calculating air contaminant emission fees for manufactured wood fuel fired boilers.

For Biomass (i.e. hogfuel, wood chips) Variable “B” is hereby specified to be 436m3/GJ for the purpose of calculating air contaminant emission fees for biomass fired boilers.

Approved by: ------------------------------------- R. H. Robb District Director

Issued: March 31, 2009 Amended: May 17, 2010

e004913839


Rebecca O'Brien

From: Maari Hirvi MayneSent: Monday, January 11, 2016 12:00 PMTo: '[email protected]'Cc: Metro Vancouver Air Quality BylawsSubject: RE: Proposed Amendments to Air Quality Management Inquiry


Hi Kori –

As mentioned in our call, here is the information I mentioned and I’ve added probably more references than you need or want, but at least it will give you some idea of how we authorize air emissions from boilers in the region.

To begin, Metro Vancouver prohibits the discharge of air contaminants unless authorized under (1) a regulation, or (2) a permit (there is also a (3) if exempt, but in most cases what you would be dealing with is either (1) or (2). For details on exemptions refer to section 7 of Bylaw 1082).

Health Authority facilities with boilers are generally authorized under Metro Vancouver’s Boilers and Process Heaters Emission Regulation Bylaw No. 1087 ‐ scenario (1) above.

One notable exception (which I missed) is the VGH Energy Centre which is permitted – scenario (2) above. GVA1043 was issued in perpetuity (i.e. no expiry date) in 2010, and fees for this facility are on the order of $2000/year. The emission fees are based on standard natural gas combustion emission factors and facility capacity – see MV Bylaw 1083 for further details on emission fees per authorized contaminant. If this permit were amended, current policy would be to give it a term limit which would be subject to negotiations between MV and the facility.

Bylaw 1087 applies to facilities with “facility capacity” (sum of the individual capacities of all boilers/process heaters at the same location burning the same fuel – see bylaw for full definition) less than or equal to 50MW, hence the VGH permit where facility capacity is >50MW. Facilities less than 50MW can also be authorized under permit if this is what the proponent desires – but then fees kick in.

Bylaw 1087 specifically exempts fees for institutions (section 13) – however there may be some additional dialogue needed should there be a case where a private company owns/operates, for example, a DE facility for an institution (assuming less than 50MW and authorization under Bylaw 1087). We have not had that situation arise as of yet. Fees for a (private) biomass fuelled facility would likely be higher than for a similarly sized n.g. facility since combustion particulate emissions would be higher. Fees for regulated (private) facilities are described in Appendix 1 of Bylaw 1087.

Hope that helps, drop me a line if you have additional questions.

Take care ‐ Maari

Maari Hirvi Mayne Senior Project Engineer, Environmental Regulation and Enforcement Legal and Legislative Services t. 604.456.8823



From: Jones, Kori [mailto:[email protected]] Sent: Wednesday, January 06, 2016 10:35 AM To: Metro Vancouver Air Quality Bylaws Subject: Proposed Amendments to Air Quality Management Inquiry

Hello,

I have been reviewing the Proposed Amendments to Air Quality Management and would like to know how to obtain a list of the all the Lower Mainland Health Organisations that are currently registered to better understand the impact of permits renewal fees.

Any information on how to obtain a current list would be appreciated. I am assuming that all existing facilities with heating plants will have a permit but this information may be difficult to track from our end.

Also, how will the fixed terms be set from the 2‐20 year term? Specifically in relation to healthcare facilities for operating budgeting purposes.

Regards,

Kori Jones, CEM, EIT Energy Specialist ‐ FHA| Energy & Environmental Sustainability Mobile: 604.807.3716 | [email protected] 6th Floor, Sherbrooke Centre, 260 Sherbrooke Street, New Westminster, BC, V3L 3M2

Lower Mainland Facilities Management


Rebecca O'Brien

Subject: Discussion on Proposed Amendments to GVRD Air Quality Bylaws 1082 and 1083Location: 4330 Kingsway, Burnaby – 6th floor meeting room

Start: Tue 1/19/2016 12:30 PMEnd: Tue 1/19/2016 3:00 PMShow Time As: Tentative

Recurrence: (none)

Meeting Status: Not yet responded

Organizer: Metro Vancouver Air Quality BylawsRequired Attendees: [email protected]; Esther Berube; [email protected];

[email protected]; [email protected]; [email protected]; [email protected]; [email protected]

Hello,

Please join Metro Vancouver staff and concerned stakeholders in discussing the proposed amendments to GVRD Air Quality Bylaws 1082 and 1083.

Date: January 19, 2016 from 12:30‐3pm (12:30 – 1:00pm Registration and Lunch) Location: 4330 Kingsway, Burnaby – 6th floor meeting room Objectives: To discuss concerns and for Metro Vancouver staff to clarify the proposed amendments RSVP: Please confirm your attendance by January 15, 2016

Best regards,




Rebecca O'Brien

Subject: Metro Vancouver Conference Call re: Proposed Amendments to GVRD Air Quality Bylaws 1082 and 1083

Location: See conference call information below

Start: Thu 1/28/2016 9:00 AMEnd: Thu 1/28/2016 10:00 AMShow Time As: Tentative

Recurrence: (none)

Meeting Status: Not yet responded

Organizer: Metro Vancouver Air Quality BylawsRequired Attendees: Brett Malkoske; Loren Polak; Thomas Price; Monty Griffin; McCallum, Elisha; Karl

Gerrand

Teleconference dial‐in details: Toll free (Canada & USA) Dial 1‐877‐385‐4099 and follow the voice prompts Enter access code 1419533 followed by the # sign

Proposed Agenda 1. Introductions2. G3’s concerns3. Proposed amendments4. Next steps


Rebecca O'Brien

From: Roger QuanSent: Tuesday, January 26, 2016 2:42 PMTo: Denise MullenCc: Esther Berube; Allan NeilsonSubject: followup to our conversation this morning

Categories: For future reference

Hi Denise:

Thank you for the conversation this morning.

Staff are preparing the report which will go to the Board's Climate Action Committee on February 3, and then to the Board of Directors itself on February 26.

As outlined in our meeting with industry and business stakeholders on January 19, the report will seek Board approval for amendments to Bylaws 1082 and 1083. Proposed amendments will:

address permit application fees seek to provide clarity on defined terms related to residential wood burning revise the exemption for comfort heating sources, and adjust administrative fees for inflation and to recover costs for tasks such as processing non‐electronic reports

I understand from your comments this morning that the stakeholders you work with do not have any substantive issues with the amendments as proposed.

I also recognize, as you noted, that the intentions paper related to these amendments has opened the door to discussion about concerns about the use of fixed terms (durations) in air quality permits.

As I said at our meeting on January 19th, the use of term limits is outside the scope of the proposed amendments, where we are trying to address the fee issue for permits that do currently have expiration dates.

But we have heard quite clearly from stakeholders about their concerns about term limits in permits and that more discussion is needed. The report will describe the results of the consultation process, including an issues and responses table, and will bring forward the concerns we heard about term limits.

Accordingly, a second element of the recommendation to our Climate Action Committee and Board will seek direction from the Committee to continue the discussions we have already initiated with you and others on the use of term limits in air quality permits. I think that some of our existing groups, like the Business Council’s air issues working group and the group we met with last week, would provide excellent venues to hear your perspectives. Ultimately, we will need to consult with others as well, including groups that may be impacted by the operations of industry.

Lastly, we are aiming to post the agenda for the February 3 Climate Action Committee on our website before the end of this week. Here is a link to information on our website related to appearing as a delegation to one of our Committees, or to the Board: http://www.metrovancouver.org/boards/delegations/Pages/default.aspx

regards, Roger


Roger Quan Director, Air Quality and Climate Change Planning, Policy and Environment Department t. 604.436.6770c. 604.314.7255



INCOMING CORRESPONDENCE


jptuneTERMINALS

December 23, 2015

.1.TRO VANCOUVER

EnV1on,taI Reguiati nd Enforcement

Greater Vancouver Regional District (Metro Vancouver)Environmental Regulation and Enforcement Division Z015Legal and Legislative Services RE(EIVED DC4330 KingswayBurnaby, BC V5H 4G8 on

Ini’iAttention: Air Quality Bylaw Amendment Process Ocr Dep

Dear Metro Vancouver Staff:

Re: Permit Term Limits

I am writing on behalf of Neptune Terminals (Neptune) to provide our input to Metro Vancouver on the

proposed Amendments to Air Quality Management Bylaw No. 1082. Our response is based on the October2015 “Intentions Paper” and take into account the factors considered by Metro Vancouver outlined in Mr. R.H.

Robb’s memo (the “Memorandum”) of May 6, 2015.

Integrity and continuous improvement are core values for Neptune, and after more than 45 years of safelyoperating on the North Shore, we continue to strive to live up to our commitment and responsibilities; ourcompany prides itself on minimizing the impact of our operations on the community. We are proud that ourmeasures meet or exceed compliance with Port Metro Vancouver and the BC Ministry of Environment’sstandards.

However, the proposed by-law amendment will adversely affect our business interests. The imposition of term

limits seriously impairs the future viability of our operations through the curtailment of investment and the

addition of new onerous administrative burdens.

Below we articulate in more detail our specific concerns regarding the “Factors to Consider” outlined in theMemorandum. We have also provided suggestions for your consideration as you move forward with the

consultation on the proposed by-law changes.

1. Permit Terms Create Uncertainty for Investments

Neptune is concerned of unintended consequences created by the implementation of term limits and theapplication of any renewal processes. For example, the capital invested in Neptune is in excess of $800 million

and has been made, in large part, based upon Neptune’s ability to operate without permit term limits; this is

also true for Neptune’s bank lines. Imposing a term limit without evergreen renewal seriously impairs the

future viability of our business operations through curtailment of investment.

Neptune Bulk Terminals (Canada) Ltd, P.O. Box 86367 Tel: 604-985-7461North Vancouver, BC V7L 4K6 Fax: 604-985-8941

www.neptuneterminals.com


J1&PtUCTERMINALS

Page 2December 23, 2015Re: Permit Term Limits

In section 3.1 of the Intentions Paper, new renewal processes are proposed that include public notification

requirements, but provide no detail of requirements by an operator or a timeline that could be expected by

Metro Vancouver to make such decisions. Further the paper notes renewals are “generally more complex than

permit amendments.”

This change will create uncertainty. Neptune draws its experience with our recent amendment application,

which has taken over two years and cost $2 million and has yet to be concluded. We have undertaken

extensive environmental and health studies as well as noise, light and traffic to support our amendment.

While we believe it is necessary, it has been a time consuming and an expensive process. Repeating such a

process or one that might be “generally more complex” for each term limit renewal is, frankly,, not

sustainable.

In addition, all investments at Neptune must be justified by a detailed business case analysis in conjunction

with our shareholders. These investments have financial paybacks calculated to conclude within the term of

the land lease from the Vancouver Fraser Port Authority (aka Port Metro Vancouver). The remaining lease

term is 35 years. Any limitation period on a permit that could restrict Neptune’s ability to operate for the

entire lease term will very likely impair Neptune’s business investment opportunities and our ability to source

funding for continuous improvement projects, among them projects that have a direct benefit to the

environment.. In other words, imposing term limits will likely have the unintended consequence of restricting

the ability of companies to obtain financing for environmental enhancements to their operations.

2. Bias Against Larger Facilities

The Memorandum provides that larger facilities and more harmful air contaminants warrant shorter duration

permits. Although Neptune’s facility is large, and the fees currently associated with the Permit are not in

excess of $50,000.00, our independent studies conclusively demonstrate that the types of air contaminants

emitted from the facility are notsignificantly harmful to human health or the environment, thus warranting a

permit with no term limit.

As part of our permit amendment process, Neptune recently retained a number of highly qualified

independent environmental experts to study the terminal’s current and future operations to identify potential

impacts on air quality. RWDI Consulting Engineers and Scientists Inc. (“RWDI”), a highly respected consulting

engineering firm with specific expertise in air quality dispersion studies, was asked to measure, study and

model changes to current air emissions resulting from proposed improvements to Neptune’s coal handling

operations. RWDI examined current and future operations associated with Neptune’s improvements and

concluded that predicted air emission concentrations after the upgrades are completed will be close to that of

Neptune’s current operations. Importantly, RWDI concluded there will be no significant change in local air

quality. Local air quality is excellent. RWDI’s air dispersion study has been submitted to Metro Vancouver as

part of Neptune’s recent permit amendment application.

Neptune also retained a highly qualified leading toxicology, risk assessment and risk management consulting

firm, Intrinsik Environmental Sciences Inc. (“Intrinsik”) to conduct a screening level Human Health Risk


Neptune,___ TERMINALS

Page 3December 23, 2015

Re: Permit Term Limits

Assessment (“HHRA”) of the proposed improvements to Neptune’s operations. Intrinsik’s HHRA concluded

that the health risks associated with all air contaminants related to the proposed improvements are expected

to remain the same when compared to current operations and the project is not expected to contribute to

local health risks. Intrinsik’s HHRA study has also been submitted to Metro Vancouver as part of its recent

Permit amendment application.

These studies provide clear evidence of a basic flaw of the Memorandum: its bias against larger facilities.

3. Operational Practices and History Must be Considered

The Memorandum states that permits for sources which receive large numbers of complaints (i.e. odor)

should generally be limited to five years unless there are substantial extenuating circumstances. Neptune has

a long track record of open and respectful dialogue with the community, listening to its neighbours concerns

and working to address issues as they arise. Over the years there have been very few complaints arising from

Neptune’s operations. Neptune responds promptly to all questions from the public and engages independent

scientists to conduct thorough investigations when needed. We encourage Metro Vancouver to consider an

operator’s history and effectiveness of working with their local community when making decisions.

4. Outcomes Should Drive Decisions

Neptune maintains a leading edge environmental management system to ensure protection of the

environment. Combined, the cost of Neptune’s environmental management system exceeds $40 million,

which represents a substantial portion of Neptune’s overall facility costs. However, we believe the outcomes

of an operator’s environmental protection efforts are the most important, rather than the dollars spent.

5. “Confidence” is too Subjective a Criteria

Neptune acknowledges the need for Metro Vancouver to have confidence in their regulations and the ability

to monitor outcomes when assessing and granting permits. However, the inclusion of “greater confidence by

the district director” as a criteria is too subjective and does not provide operators with specific measures and

outcomes to base their applications. Neptune has demonstrated the continuous improvement of its

environmental management systems arises from its business philosophy rather than through direction of

regulation.

The imposition of “confidence” as a measure will be difficult, if not impossible to anticipate. Further, the level

of “confidence” will likely change when the district director changes, which means there is a lack of continuity

and that, in turn, creates further uncertainty.


December 23, 2015Re: Permit Term Limits

6. Creates Deterrents to Innovation

çptuneTERMINALS

To embody the continuous improvement value, Neptune is constantly evaluating ways to improve ouroutcomes. While treatment technologies are well established and unlikely to change significantly for oursector, the imposition of a criteria that considers whether technologies are “stable or evolving” may createanother disincentive for operators to make investments in new and emerging technological improvements.

In summary, Neptune has strong concerns regarding the imposition of air permit term limits in the proposed

Bylaw No. 1082 Amendment. Further, based on our recent experience to amend our air permit, MetroVancouver’s regulator oversight is already substantial and rigorous such that there is no regulatory lacunae

existing through a lack of permit term limits. There is no compelling evidence demonstrating the regulator

currently lacks any tool necessary to provide for the reasonable protection of the environment.

We appreciate the opportunity to provide this feedback and trust you will incorporate these views as part ofyour decision making process. Should you have any questions, please do not hesitate to contact me at the

address below, or via e-mail at [email protected].

IALS (CANADA) LTD.

CC: Greg Moore, Board Chair, Metro Vancouverdo City of Port Coquitlam2580 Shaughnessy StreetPort Coquitlam BC, V3C 2A8

Carol Mason, Chief Administrative Officer, Metro Vancouver4330 KingswayBurnaby BC V5H 468

Yours very truly,

NEPTUNE BULK

Vice President Major Projects and Environment


January 11, 2016

Metro Vancouver Board of Directors and Environmental Regulation and Enforcement Division 4330 Kingsway Burnaby, BC V5H 4G8 Via email: [email protected]

To Whom It May Concern:

Re: Proposed Amendments to Air Quality Bylaw No. 1082 and Air Quality Management

Fees Bylaw No. 1083

Thank you for the opportunity to offer our comments on the proposed amendments to Metro Vancouver’s Air Quality Management Bylaws. Though the submission deadline has passed, we trust our input we still help shape the direction of these amendments.

The BC Chamber of Commerce is looking to address cost/fee and oversight issues stemming from the potential amendment to air quality permits by adding term limits. While the Chamber recognizes the role the regional government plays in air quality, and the need for environmental standards that meet the public interest, the proposed amendments do cause concern from a number of our members within the Metro Vancouver business community. The proposed amendments might be well-meaning, but the fact is the Chamber believes not all the consequences might have been fully conidered through.

As we all know, Metro Vancouver is a primary point of entry as part of Canada’s Gateway to the Asia-Pacific. Our regional, provincial and national economies all depend on constant and on-going investments in our industrial capacity and the infrastructure that is needed to realize this capacity. Given many of these investments needed to fuel our international trade objectives are very large in both scope and funding, these businesses and their investors plan their investments with the expectation that they will achieve a return on it over decades. The BC Chamber does not believe the current proposed permit length of 2 to 20 years represents an adequate understanding of the long-term nature of these significant capital investments. This proposed amendment will create tremendous uncertainty for future operations and likely have a negative impact on our industrial and port-related businesses to secure financing and/or justify further capital investments.

At the same time, the BC Chamber is equally concerned that Metro Vancouver’s concept around permit renewals will have the likely outcome of further freezing investment. Businesses making large industrial and infrastructure investments are looking for certainty before they commit funds to a given project. The introduction of potential “cold stops” in operations every time a permit needs to be renewed does not provide the security investors seek for their investment. In fact, this kind of process increases the risk and cost to business.

#1201, 750 West Pender Street Vancouver, BC V6C 2T8 T 604.683.0700 F 604.683.0416 www.bcchamber.org



On this idea of certainty and cost to business, the Chamber believes applying for permit renewals at the end of each fixed term limit is also of considerable concern. To prepare and submit amendments to an existing permit is a costly endeavour. The Chamber understand this process could take up to 2 years and cost up to a million dollars or more. Investors appreciate this initial permit process is a cost of doing business, but to require a business/investor to go through this process every 2, 3 or even 20 years is a significant cost burden that is likely to prevent an investment decision being made in the Metro region.

The BC Chamber recognizes the public policy importance to protecting air quality, but any changes should seek the right balance between potential improvements in air quality to the risks of freezing capital investment and the jobs and economic prosperity that go with that investment. For this reason, the BC Chamber encourages Metro Vancouver not to go ahead with new term limits for air quality permits or with the new “renewal” concept. At the same time, the Chamber stands ready to work with Metro Vancouver and other stakeholders to address Metro’s cost/fee concerns without placing an unnecessary barrier to investment in the Metro Vancouver region.

Thank you again for the opportunity to provide the Chamber’s thoughts on this important issue. If you have any questions, please don’t hesitate to contact me.

Sincerely, The British Columbia Chamber of Commerce

Jon Garson President and CEO


1188 West Georgia Street, Suite 900, Vancouver, BC V6E 4A2 Tel: (604) 269-0582 www.cement.ca

January 11, 2016 By Email: [email protected]

Esther Berubé, P.Eng., M.Eng. Program Manager, Bylaw and Regulation Development Air Quality Department Metro Vancouver 4330 Kingsway Burnaby, BC V5H 4G8

Re: Proposed Amendments to GVRD Air Quality Management Bylaws No. 1082 and 1083

Dear Esther Berubé,

We write further to Metro Vancouver's request for comments on its proposed amendments to GVRD Air Quality Management Bylaw No. 1082, 2008 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008. The Cement Association of Canada works with and supports Lehigh Hanson Materials Limited and Lafarge Canada Inc., and both companies operate cement manufacturing plants in the region and are regulated by Metro Vancouver.

We support the principle of the proposed revisions to the fee structure as it is described in the Intentions Paper issued by Metro Vancouver in October 2015. We understand that one of the prime reasons for the amendment is to set a fee structure that is more reflective of the level of administrative effort that is carried out by Metro Vancouver staff in processing a permit renewal. We would however suggest that the calculation that would apply to the cement sector, in which a minimum fee of $50,000 would be assessed, may be higher than the corresponding level of effort. Given the substantial annual air quality permit fees paid by both Lafarge and Lehigh, we would suggest that this calculation be revisited. Consider that these operating facilities also pay significant fees and taxes to other levels of government, including property taxes to the host municipality, and the carbon tax to the Provincial government.

One further issue upon which we would seek further dialogue is that of the issuance of permits with a fixed term. In our review of the Metro Vancouver staff report presented to the Metro Vancouver Climate Action Committee at its October 7, 2015 we note that as recently as 2008 "most permits had been issued in perpetuity." It is therefore a relatively recent development in the transition to the issuance of permits with a fixed expiry date. While we have read some of


1188 West Georgia Street, Suite 900, Vancouver, BC V6E 4A2 Tel: (604) 269-0582 www.cement.ca

the justification for fixed expiry dates, we put forward that for industries such as the cement industry this may fail to recognize the on-going nature of these operations and in particular the significant capital outlay which is invested in the plants. It would be unfair, in our opinion, to issue a permit with a fixed expiry date to a cement manufacturing plant. At the very least we would propose that a permit be issued for a longer term, in the 10 to 20 year range. Our industry is not averse to working with permitting authorities such as Metro Vancouver when conditions change that may warrant a revision or amendment of existing permits.

One of the additional factors which arise out of a policy change of issuing permits with a fixed term is that of public notification. The intentions paper notes that "Permit renewals should be as transparent to the public as new permit issuances, and should therefore undergo a public notification process..." We propose that public notification should be commensurate with the proposed changes, if any, to the existing authorization. Consequently, if there are no proposed changes, or potentially even reductions in emissions, as a result of a permit renewal we recommend that the appropriate level or type of public notification that may be required should be minimized.

Thank you for the opportunity to provide input on the proposed amendments to Air Quality Bylaws No. 1082 and 1083. As we had discussed previously, the industry would be happy to meet to discuss the proposed amendments as well as the industry as a whole.

Should you have any questions, please feel free to call me at (604) 839-6627.

Sincerely,

Ken Carrusca, P.Eng. Vice President, Environment and Marketing (Western Region) Cement Association of Canada

cc: Eileen Jang, Lehigh Cement, Delta, BC Darren Brown, Lafarge Canada, Richmond, BC


16705 Fraser Highway

Surrey, B.C. V4N 0E8

Tel: (604) 576-7000

Fax: (604) 592-7122

www.fortisbc.com

January 29, 2016

VIA Email: [email protected]

Metro Vancouver Board of Directors and Environmental Regulation and Enforcement Division 4330 Kingsway, Burnaby, B.C. V5H 4G8 Re: Intentions Paper: Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fee Bylaw No 1083, dated October 2015 (the “Intended Amendments”) ______________________________________________________________________________

FortisBC Energy Inc. (“FortisBC”) provides natural gas public utility services in the Metro Vancouver area and operates facilities subject to permits issued under the provisions of the Greater Vancouver Regional District (“GVRD” or “Metro Vancouver”) Air Quality Management Bylaw No. 1082, 2008. FortisBC has both responsibilities and opportunities when it comes to issues concerning the environment and believes that it is important to participate in the growth of cities and towns FortisBC serves.

FortisBC has reviewed the Intended Amendments issued by Metro Vancouver in October 2015, and appreciates the opportunity to comment on the Intended Amendments as encouraged by Metro Vancouver (the “Commenting Process”). With this letter, FortisBC wishes to express its concern with the following aspects of the proposed changes to the Bylaw provisions regarding the renewal of permits.

Proposed Renewal Process

Sections 11 to 20 of the GVRD Air Quality Management Bylaw No. 1082 relate to the issuance and amendment of permits that authorize the discharge of air contaminants to the environment to manage the air quality. As FortisBC understands it, Metro Vancouver is considering adding a process specific to “renewal of permits”, which, as the Intended Amendments suggest, is different from new permit issuance and permit amendment.

FortisBC appreciates that the Bylaw may further “define” air quality permit renewal process; however, the Intended Amendments do not set out any specifics (except the potential public notification requirement and application fees for permit renewal) with respect to this proposed renewal process, such as what may constitute a renewal, what the differences are between permit amendment and permit renewal, what factors will be considered when issuing or denying a renewal, and what justifications are sufficient for adding new conditions during the renewal process. Since details are lacking in the Intended Amendments, FortisBC cannot assess the potential operational and financial impact of the proposed renewal process on FortisBC’s operation in the Metro Vancouver area and does not believe that the Commenting Process is as productive as it could have been.

Potential Fixed Term Permits

The Intended Amendments make it clear that one of the objectives for proposing a new process for permit renewal is to impose new conditions such as a fixed permit term during the renewal process. Although FortisBC understands Metro Vancouver’s desire for a fixed term permit as articulated in the Intended Amendments and in a memorandum from the District Director to Permitting and Enforcement Officer,

Climate Action Committee On Table Item 5.2

Attachment 2

Climate Action Committee - Page 109 - 1


dated May 6, 2015 (the “Memorandum”), FortisBC believes that imposing a fixed term on an existing permit that has no term limit during a permit renewal or amendment process can significantly affect decisions made in the past by permit holders and result in operational uncertainty that was not expected at the time of obtaining the permit. Current permit holders applied for and obtained a permit based on the regulatory scheme and practices at the time and made a long term investment at the time of obtaining the permit based on the conditions of the permit obtained.

Additionally, placing a term limit normally of 5 to 15 years as suggested in the Memorandum on new permits may impact investment decisions in the future in the Metro Vancouver area. FortisBC notes that the National Energy Board Act was recently amended to extend maximum permit length from 25 years to 40 years to recognize and facilitate investment in Canada.

Coupled with the lack of details of the proposed Bylaw provisions regarding the renewal of permits, FortisBC recommends that Metro Vancouver not amend the Bylaws to include the renewal of permits as planned at this time. Further details on the renewal process and further public consultation on the new process are necessary before enactment.

Thank you for the opportunity to comment on the Intended Amendments. Please do not hesitate to contact the undersigned at 604-592-7516 or [email protected] if you have any questions about our operation and about this letter.

Sincerely,

Jason Wolfe Director, Energy Solutions FortisBC Energy Inc.

1738212Climate Action Committee - Page 109 - 2

Rebecca O'Brien

From: Bradley, Dan <[email protected]>Sent: Thursday, December 17, 2015 9:42 AMTo: Esther BerubeCc: Maari Hirvi MayneSubject: call with FortisBC - Regulations 1082 & 1083

Follow Up Flag: Follow upFlag Status: Completed

Categories: Purple Category

Hi Esther, Maari, and Derrick (?), Thanks so much for calling and explaining the emission fees and proposed changes to me.

I still have a couple of questions on calculating the fees. The air contaminant fees calculation shows Z = A*B*C*D*E*F Where C is the facility capacity in MW (or GJ per hour), as provided by the operator 1 MW = 3.6 GJ/hour, so which value do you use for capacity in the calculation. MW or GJ/hour? What value do you use for the volume of flue gas determined to be in each GJ of natural gas and in each GJ of Biomass?

Could you send me the background document on how fixed terms will be determined?

Have a great Christmas

Dan Bradley Energy Utilization Manager Market Development

[email protected] Ph: (604) 592 7647

This email was sent to you by FortisBC*. The contact information to reach an authorized representative of FortisBC is 16705 Fraser Highway, Surrey, British Columbia, V4N 0E8, Attention: Communications Department. You can unsubscribe from receiving further emails from FortisBC or email us at [email protected].

*”FortisBC” refers to the FortisBC group of companies which includes FortisBC Holdings. Inc., FortisBC Energy Inc., FortisBC Inc., FortisBC Alternative Energy Services Inc. and Fortis Generation Inc.

This e-mail is the property of FortisBC and may contain confidential material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. FortisBC does not accept liability for any errors or omissions which arise as a result of e-mail transmission. If you are not the intended recipient, please contact the sender immediately and delete all copies of the message including removal from your hard drive. Thank you.

77Climate Action Committee - Page 110

Rebecca O'Brien

From: Jones, Kori <[email protected]>Sent: Wednesday, January 06, 2016 10:35 AMTo: Metro Vancouver Air Quality BylawsSubject: Proposed Amendments to Air Quality Management Inquiry Attachments: IntentionsPaper.pdf

Follow Up Flag: Follow upFlag Status: Flagged

Hello,

I have been reviewing the Proposed Amendments to Air Quality Management and would like to know how to obtain a list of the all the Lower Mainland Health Organisations that are currently registered to better understand the impact of permits renewal fees.

Any information on how to obtain a current list would be appreciated. I am assuming that all existing facilities with heating plants will have a permit but this information may be difficult to track from our end.

Also, how will the fixed terms be set from the 2‐20 year term? Specifically in relation to healthcare facilities for operating budgeting purposes.

Regards,

Kori Jones, CEM, EIT Energy Specialist ‐ FHA| Energy & Environmental Sustainability Mobile: 604.807.3716 | [email protected] 6th Floor, Sherbrooke Centre, 260 Sherbrooke Street, New Westminster, BC, V3L 3M2

Lower Mainland Facilities Management


January 14, 2016

Mr. Ray Robb Manager, Environmental Regulation & Enforcement Division Metro Vancouver 4330 Kingsway Burnaby, BC V5H 4G8

Dear Mr. Robb:

Re: Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083

We appreciate the opportunity to provide you with our comments with respect to your Intentions Paper concerning the above mentioned proposed changes to Bylaws 1082 and 1083. Fraser Surrey Docks LP (FSD) has been safely operating on the Fraser River for over 50 years. We operate on land that is leased from the Vancouver Fraser Port Authority (VFPA) on behalf of the Federal government. As a responsible tenant of the VFPA, we have worked hard to ensure all operations meet the highest standards of safety and environmental protection. Over the last five years FSD has provided over $280 million dollars in economic benefit to British Columbia through wages, taxes, supplies and services. We understand that the changes being proposed include fixed terms for permit, new fee structure and a new permit renewal process for all permits issued or amended from mid-2015 onward. Projects and infrastructure enhancements undertaken by terminal operators like FSD can be very comprehensive and require significant capital investment. In almost all cases, the investments require amortization periods in excess of 20 years. As a result, we are very concerned that fixed terms and additional renewal process will place a level of uncertainty to projects that will make the ability to secure capital for investment very difficult. Furthermore, the risk of operational shutdown, every couple of years, cannot be supported by customers in the supply chain. We recognize the work that Metro Vancouver undertakes on behalf of all stakeholders in the region. However we cannot support a change to the permit system that will require a party who elects to apply for a permit to face increased level of uncertainty on operations every few years. We believe that any changes to regulation should be consistent with the requirements of all levels of government and not developed in a manner that hinders economic development.

Sincerely,

Jeff Scott President & CEO Fraser Surrey Docks, LP

Cc: Mr. Roger Quan, Director, Air Quality Policy and Environment


Rebecca O'Brien

From: Rebecca Abernethy <[email protected]>Sent: Sunday, December 06, 2015 3:27 PMTo: Metro Vancouver Air Quality BylawsCc: Stacey BarkerSubject: RE: Notice of Public Consultation - Amendments to Air Quality Management Bylaws



Hello,

The Fraser Valley Regional District offers the following comments to the public consultation period on Metro Vancouver bylaws 1082 and 1083:

1. Support for the renewal of permits and related fees amendment, which should strengthen air quality protectionby requiring permit review on stated intervals (instead of being in place indefinitely).

2. Regarding the proposed broader exemption for natural gas and propane‐fired heat units for comfort heating: inaccordance with its Integrated Air Quality and Greenhouse Gas Management Plan, Metro Vancouver should beseeking to reduce emissions from all sources. Natural gas fired heating units in particular, for comfort heating,represent a substantial nitrogen oxides and greenhouse gas emission source in the region. If Metro Vancouverdoes not require certain sized heating units to be authorized (which offers the benefit of oversight, and effortfrom the proponent which may mean that fewer units are used due to the effort/fees required to registerthem), Metro Vancouver is strongly encouraged to continue to pursue other ways to reduce emissions fromthese sources.

3. Support for the clarified definition of wood to clean wood for residential fireplaces or stove wood fuel.

Regards,

Rebecca Abernethy

Environmental Policy Analyst

Fraser Valley Regional District

604‐702‐5057

From: Metro Vancouver Air Quality Bylaws [mailto:[email protected]] Sent: Monday, November 23, 2015 4:15 PM To: Metro Vancouver Air Quality Bylaws Subject: Notice of Public Consultation ‐ Amendments to Air Quality Management Bylaws


Public Consultation on Bylaws 1082 and 1083

November 23, 2015

Dear Stakeholder,

Metro Vancouver is proposing changes to its Air Quality Management Bylaw No. 1082 (Bylaw 1082) and its Air Quality Management Fees Regulation Bylaw No. 1083 (Bylaw 1083) related to:

Renewal of permits and related fees Adjustments to administrative fees for inflation and new fees for some administrative tasks Broader exemption for natural gas or propane‐fired comfort heating Clarification to the definition of residential fireplace or stove wood fuel


Please provide feedback by January 4, 2016 to [email protected]

Best regards,



January 5, 2016

To: Metro Vancouver Via: [email protected]

Re: Intentions Paper, Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083.

G3 Terminal Vancouver Limited Partnership (G3) is considering constructing the premier grain export facility on the west coast of Canada, to be located in Port Metro Vancouver. We have reviewed the above referenced paper, and we are extremely concerned with implied changes in Metro Vancouver (MV) policy. Specifically, our concern is with the statement: “All permits issued or amended from mid-2015 forward are expected to have fixed terms, ranging from 2-3 years up to 20 years, depending on the facility, surrounding community and other factors”, and with the attached memorandum outlining the factors to be considered when establishing the term.

G3 has been planning, designing, and preparing numerous permit/approval applications for the proposed facility for over a year. Numerous features of the facility have been specifically designed to meet the air emissions permit requirements of MV. These preliminary activities represent a significant investment. Once all necessary approvals are obtained, G3 will make the final decision whether to invest over $500 million to construct the facility over a three to four year period. The facility is expected to operate indefinitely, with a payback period on investment that is measured in decades.

Given the scale and long-term nature of the investment, the possibility of a permit with a fixed term – whether it is for 2 years or 15 years – will increase our cost and operational uncertainty, and adversely impact our appetite to make this investment. The memorandum suggests that most large facilities may have a relatively short term imposed. In spite of designing our proposed grain facility to MV’s current criteria (such as Best Available Technology and Air Quality Objectives), the proposed policy could mean the facility would be faced with curtailing operations and/or redesigning and reinvesting every few years in order to meet changing requirements. Since the permit review process includes consideration of cumulative air quality, G3’s ability to obtain renewals could also be impacted by other industrial facilities in the local area or region.

G3 has been working on permit application documents in consultation with MV for over a year in good faith, and we have included best in class standards and equipment in our design work to mitigate the possible emissions impacts that our proposed facility would have. The intention


2

paper suggests that renewals will require less effort than a new permit, but does not provide any certainty around the potential scope of these changes. While G3 has demonstrated its intention to be a good neighbour and corporate citizen adhering to best practice whenever practical, the proposed changes unfortunately introduce additional risk that cannot be qualified or quantified at this crucial time while we look to make our final investment decision for our project.

G3 urges Metro Vancouver to reconsider these proposed changes, or as expeditiously as possible lay out a definitive frame work so that G3 and all parties considering investment in the Metro Vancouver area are able to qualify and quantify what the proposed changes might mean for their potential investments.

Yours truly,

Brett Malkoske Vice President, Business Development, G3 [email protected] P: (204) 272-6611

c: Karl Gerrand, CEO, G3 Thomas Price, VP, Project Planning & Engineering, G3 Brad Eshleman, President, Western Stevedoring


January 15, 2016

Attention: Esther Bérubé, P.Eng., M.Eng. Program Manager, Bylaw and Regulation Development Air Quality and Climate Change Metro Vancouver 4330 Kingsway Burnaby, BC V5H 4G8

Re: Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083

Dear Esther,

Thank you for providing us the opportunity to comment on the proposed amendments to the above noted Bylaws 1082 and 1083. Of particular interest to Lafarge are the proposed changes to the permit renewal fee structure indicated in Bylaw No. 1083. We applaud the efforts of Metro Vancouver to provide a sensible and practical approach to the fee structure of permit renewals.

The Lafarge Richmond Cement plant is a strong supporter of the Metro Vancouver community and an exemplary corporate citizen. We are committed to environmental sustainability and we work closely with Metro Vancouver to minimize the potential impact of our operation on the environment. Since the cement plant began operation in 1957 we have made significant reduction in emissions, particularly with our facility-wide upgrade in 1999. We anticipate additional environmental modifications in the future as we move towards increased use of alternative and renewable fuels.

As you are aware we are currently going through the permit renewal process for our Richmond Cement plant. Based on the existing fee structure, denoted as Method A in Appendix 1 of the intentions paper, we expect the cost of renewing our permit to be approximately $800,000. This anticipated fee is not only cost prohibitive, it is out of alignment with the Metro Vancouver permit renewal principle of cost recovery / user pay.

As a large facility we understand that the level of effort by Metro Vancouver staff to complete the renewal process at a cement plant is significantly greater than small facilities that are less complicated. Consequently, we recognize the cost associated with our permit renewal will be higher, as indicated in Method B, Appendix 1 in the intentions paper. That said, it is important to note that we incur significant additional costs in engaging expert consultants and in internal staff time. All efforts to further reduce renewal fees are appreciated.

Although fixed terms for permits are not included in the proposed amendments, we look forward to further discussing this issue with Metro Vancouver. As previously mentioned we are committed to continuous improvement on environmental performance, and, we feel the intention behind fixed terms does not directly apply to a permanent operation such as ours. Short fixed terms will only divert funding from important improvement projects.


Thank you again for the opportunity to provide comment. We fully support your efforts to amend Bylaws 1082 and 1083. If you have questions feel free to contact me by email at [email protected] or by phone at 604-690-9950.

Sincerely,

Darren Brown, M.Sc., R.P.Bio, EP Manager, Environment & Public Affairs British Columbia Lafarge - Building Better Cities Phone (604) 777-8049 | Mobile (604) 690-9950 Email: [email protected] Website: www.lafarge.com





http://www.lafarge-na.com/

Rebecca O'Brien

From: Jelena Denin Djurdjevic <[email protected]>Sent: Wednesday, December 09, 2015 5:15 PMTo: Metro Vancouver Air Quality BylawsSubject: FW: Notice of Public Consultation - Amendments to Air Quality Management Bylaws

Follow Up Flag: Follow upFlag Status: Completed


Hello Metro Vancouver Air Quality team,

The Appendix 1 was supposed to provide the clarification to the new fee structure, but it added additional confusion (at least for me).

Why did you use different Annual Emission Fees (“previous” and “specified in Renewal”)? Where does this increase come from if the fees for the emissions stay the same or get changed slightly by amendments of the fee bylaw (1083, 1135 etc.). Could you please elaborate why did you apply flat $3,600 increase in emission fees across the board (regardless of the company size).

That was the only issue that did not make sense at all.

Have a nice day

Jelena (Yellena) Denin Djurdjevic Manager, Laboratory Services and Environment Lantic Inc. P.O. Box 2150 Vancouver, BC, Canada, V6B 3V2 Phone: 604‐253‐1131 ext 4344 (@lab#1 ext 4313) Fax: 604‐253‐2517 e‐mail: [email protected]

"Happiness depends upon ourselves" ‐ Aristotle

www.rogerssugar.com Avis de confidentialité : ce message peut contenir des renseignements confidentiels appartenant exclusivement à Lantic Inc. Si vous n’êtes pas le destinataire indiqué ou prévu dans ce message, veuillez le supprimer et en aviser l’expéditeur de ce fait. Merci.

Confidentiality notice: Proprietary/confidential Information belonging to Lantic Inc. may be contained in this message. If you are not a recipient indicated or intended in this message, please destroy and advise the sender by return e‐mail.Thank you

SVP prendre en considération l'environnement avant d'imprimer ce courriel / Please consider the environment before printing this e‐mail


From: Metro Vancouver Air Quality Bylaws [mailto:[email protected]] Sent: Monday, November 23, 2015 4:27 PM To: Metro Vancouver Air Quality Bylaws Subject: Notice of Public Consultation ‐ Amendments to Air Quality Management Bylaws


Public Consultation on Bylaws 1082 and 1083

November 23, 2015

Dear Stakeholder,

Metro Vancouver is proposing changes to its Air Quality Management Bylaw No. 1082 (Bylaw 1082) and its Air Quality Management Fees Regulation Bylaw No. 1083 (Bylaw 1083) related to:

Renewal of permits and related fees Adjustments to administrative fees for inflation and new fees for some administrative tasks Broader exemption for natural gas or propane‐fired comfort heating Clarification to the definition of residential fireplace or stove wood fuel


Please provide feedback by January 4, 2016 to [email protected]

Best regards,



1 | P a g e

Lehigh Cement, a division of Lehigh Hanson Materials Limited

7777 Ross Road Delta, British Columbia V4G 1B8

P.O. Box 950 V4k 3S6

January 4th, 2016

Metro Vancouver 4330 Kingsway Burnaby, British Columbia V5H 4G8

Attention: Ester Berubé, P.Eng., M.Eng. Program Manager, Bylaw and Regulation Development

Re: Proposed Amendments to GVRD Air Quality Management Bylaw No. 1082 and GVRD Air Quality Management Fees Regulation Bylaw No. 1083

Dear Ms. Berubé:

As a major stakeholder, Lehigh Hanson Materials Limited appreciates the opportunity to respond to Metro Vancouver’s proposed amendments to its Air Quality Bylaw No. 1082 (Bylaw 1082) and its Air Quality Management Fees Regulation Bylaw No. 1083 (Bylaw 1083).

First of all, Lehigh understands that Metro Vancouver is moving in the direction that new permits and amended permits will have a fixed term and the status of perpetuity will be eliminated. Lehigh understands that fixed terms provide a means for periodic review and can encourage the permitted facilities to reduce emissions. In practice however, it has been our experience that the review process can be both long and onerous. We recommend that the minimum fixed term should be 10 years. In the duration of the fixed term, we recognize that there would always be the avenue to address specific emission sources within the permit as new environmental initiatives arise.

Secondly, Metro Vancouver’s proposed amendments recommend that permit renewals would undergo a public notification process. The B.C. Reg. 202/94, Public Notification Regulation, considers a decrease in the authorized quantity of the discharge, emission or stored material to be a minor amendment and in Schedule A of the regulation, minor amendments do not require notification, posting nor publication. Lehigh recommends that Metro Vancouver adhere to the guidelines of the B.C. Reg. 202/94 as facilities continue to pursue improvements to reduce emissions.

Finally, Lehigh agrees that the current fee structure must be amended for permit renewals. However we consider the proposed initial $50,000 renewal fee at the time of renewal is excessive and unwarranted. Lehigh already pays a high annual permit fee over $400,000 in addition to the BC Carbon Tax. At this point, we request that Metro Vancouver provide the rationale for a renewal fee of $50,000.


2 | P a g e

Thank you for providing the opportunity for public consultation on Bylaws 1082 and 1083. If you have any questions, please feel free to call me at my direct line (604) 952-5611.

Yours truly,

Eileen M. Jang, P.Eng. Environmental Manager, Lehigh Hanson Materials Limited.

Cc: K. Stuehmer J. van de Wetering


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January 4,20L6

Via email: [email protected]@ metrova ncouver. o rg

Allan NeilsonGeneral ManagerPlanning, Policy and EnvironmentMetro Vancouver4330 KingswayBurnaby BC, VsH 4G8

Dear Mr. Neilson,

RE: Proposed Amendments to Bylaws 1082 and 1O83

Vancouver Fraser Port Authority ('VFPA') was established under the Canada Marine Act tosupport Canadian trade objectives, uphold a high level of safety and environmental protection,and consider input from local communities.

We understand that Metro Vancouver is proposing amendments to air permitting bylaws 1082and 1083, and that among the changes proposed, included is a new'permit renewal' process,corresponding fees, and fixed terms for permits between 2-3 years up to 20 years.

Some of our tenants who have elected to apply for and maintain air permits have raisedconcerns that the proposed amendments will have significant, adverse effects on theirbusinesses, In particular, it has been brought to our attention that shorter fixed terms - andthe resulting uncertainty in operational continuity - will stifle capital investments that arecritical for supporting Canadian trade objectives, including safe and efficient shipping; thisuncertainty also makes it more difficult to invest in environmental improvements that aredependent on industry's ability to receive financing. Having regard to our mandate under theCanada Marine Act, we feel obliged to echo these concerns,

We believe VFPA and Metro Vancouver are aligned in their objectives to protect theenvironment and improve air quality. VFPA is committed to continuous environmentalimprovement in policy and in practice and has demonstrated this commitment throughcollaboration with industry, government agencies, and non-government organizations on avariety of environmental initiatives.

We understand the challenges of formulating and administering bylaws and appreciate theexcellent work that Metro Vancouver undertakes to ensure the region remains among themost livable in the world.

../2

100 The Pointe, 999 Canada Place, Vancouver, B.C. Canada V6C 3T4portmetrova ncouver. com

100 The Pointe, 999 Canada Place, Vancouver, C.-8. Canada V6C 3T4

Canadä95Climate Action Committee - Page 128

January 4,20!6Metro Vancouver

We would appreciate the opportunity to discuss the proposed changes to better understandthe implications for Canadian trade and to explore possible options for responding to concernsraised by our tenants and industry.

We thank you in advance for your consideration and look forward to meeting at your earliestconvenience.

Yours truly,

PORT METRO VANCOUVER

n lsonPresident, Corporate Social Responsibility

cc Ray Robb, Division Manager, Environmental Regulatory and Enforcement Services,Metro VancouverPeter Xotta, Vice President, Planning and Operations, Port Metro VancouverCarrie Brown, Director, Environmental Programs, Port Metro VancouverDean Readman, Director, Legal Services, Port Metro VancouverGreg Yeomans, Director, Planning and Development, Port Metro Vancouver


January 4, 2016

Greater Vancouver Regional District (Metro Vancouver) Environmental Regulation and Enforcement Division Legal and Legislative Services 4330 Kingsway, Burnaby BC, V5H4G8

Dear Metro Vancouver Staff:

Reference: Air Quality Bylaw Amendment

As one of Canada’s largest shippers, a major customer of Port Metro Vancouver and a major employer in Vancouver, Teck is concerned with Metro Vancouver’s proposed changes to the Air Quality Management Bylaw.

Specifically, I understand Metro Vancouver is proposing that “all permits issued or amended from mid‐2015 forward are expected to have fixed terms, ranging from two – three years up to 20 years, depending on the facility, surrounding community and other factors.”

If adopted these changes would create a high degree of uncertainty for any investment or development under consideration. Further, given the long-term, capital intensive nature of port infrastructure investment, applying fixed terms to permits does not provide the certainty required for companies to proceed with an investment. This has the potential to freeze all new major investment in port infrastructure in the Lower Mainland.

Further, the time and cost associated with applying for a permit or amendment is significant. Neptune Terminals, of which Teck is a shareholder, estimates that it can take two years and over $1 million dollars to prepare and submit an amendment to an existing permit. The requirement to repeat this process as frequently as every two years for previously approved infrastructure represents a significant new cost. Additionally, measures that discourage new investment in terminals will make our transportation system less efficient which could negatively impact air quality in the Lower Mainland over time.

In closing, we share Metro Vancouver’s goal of ensuring good air quality in the region and we believe the regional district has the necessary tools at its disposal to achieve that goal. However, contrary to the proposed amendment’s intent, if it is approved, it would create a high degree of uncertainly and costs with no quantifiable benefit for terminals, residents or the environment. Thank you for your consideration.

Sincerely,

Mark Edwards Vice President, Community and Government Relations Teck


Rebecca O'Brien

From: Roger QuanSent: Monday, January 04, 2016 3:20 PMTo: Esther BerubeCc: Derek JennejohnSubject: FW: Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air

Quality Management Fees Regulation Bylaw No. 1083




From: Rob MacKay‐Dunn [mailto:rmackay‐[email protected]] Sent: Monday, January 04, 2016 11:34 AM To: Roger Quan Cc: Carol Mason; Ray Robb; Allan Neilson; [email protected]; Aaron Robinson Subject: Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees Regulation Bylaw No. 1083

DELIVERED VIA E‐MAIL [email protected]

Mr. Roger Quan Director, Air Quality Policy & Climate Change Metro Vancouver 4330 Kingsway Burnaby, British Columbia V5H 4G8

Dear Mr. Quan,

Re: Proposed Amendments to Air Quality Management Bylaw No. 1082 and Air Quality Management Fees RegulationBylaw No. 1083

On behalf of The Vancouver Board of Trade (the “VBOT”), we respectfully submit our feedback to Metro Vancouver regarding the proposed amendments to Bylaw No. 1082 and Bylaw No. 1083. This feedback reflects the concerns and priorities of the VBOT Directors and our over 5,000 member businesses operating in the region.

Firstly, thank you for the opportunity to consult with the regional government regarding matters that affect our environment and our economy. We are proud that the Greater Vancouver region is a jurisdiction with some of the best


air quality in the world, and we support thoughtful regulations that manage to preserve our pristine air while balancing the critical needs of our regional economy.

We understand from the intentions paper that there are four proposed changes: renewal of permits, new administrative fees and fee inflation adjustments, natural gas/propane fired comfort heating, and residential fireplace fuel clarification. Based on initial discussions with our members, we have significant concerns with the proposed changes to the renewal of permits.

The VBOT is concerned that the introduction of a permit renewals process, without specific clarification on term limits, will destabilize industry in the Greater Vancouver region. These proposed changes coupled with the memorandum dated May 6, 2015 from a Metro Vancouver District Director (regarding factors to consider when proposing the term for an air quality permit) could potentially halt planned investment in industrial capital projects in the Metro Vancouver region. The memorandum specifies that most permits would range from 5 – 15 years unless special circumstances justify a term shorter than 5 years or a term of up to 20 years. The memorandum also states that a permit term over 20 years would be considered to be “excessive in any circumstance.” These limits are concerning to us as there is little certainty that a permit will be renewed after the term limit expires.

From an industry perspective, investments in capital projects are normally amortized over an average of 25 years. Any permit that expires before the amortization period of a capital project casts serious doubt in the eyes of investors. Restrictions or uncertainty respecting the future ability to use a capital asset will impact capital investment decisions, which will directly impact job creating in local industry. Metro Vancouver’s proposed changes could cause significant harm to our economy as we compete with other west coast gateway port regions like Seattle, Portland and Los Angeles. Losing investment to competing cities on the Pacific coast could hamper efforts to define the region as the preferred west coast gateway for Asia‐Pacific trade. Below is a summary of concerns as to how the proposed changes to the renewal of permits could put Metro Vancouver at a competitive disadvantage.

Uncertainty in permit term length and conditions We acknowledge that Metro Vancouver has chosen to pursue implementation of term limits. However, we cannot support term limits and term limit conditions that could hamper the future economic growth in the region. To ensure an environment that promotes economic growth, we would expect term limits to coincide with the life expectancy of capital investment, whether that is determined based on the amortization periods for financing or land lease terms. While examining the renewal process, the VBOT requests certainty from Metro Vancouver in how these term limits are to be determined. These criteria should be scheduled, similar to the fee structure.

Grandfathering of existing permits The VBOT is also concerned that term limits are not being grandfathered in and are not limited to new air permits. As there are currently permits issued by Metro Vancouver that exist in perpetuity, we are concerned to learn that opening sections of those permits up to amendment could in fact change the entire term of the permit. We see this as unacceptable. This method will discourage any new investment in continuous improvement, instead of encouraging investment in cleaner, more sustainable technology.

“Cold‐stop” expirations We do acknowledge the need for oversight as we take pride in the region’s high environmental standards; however, there are alternatives that need to be explored instead of “cold‐stop” permit expirations. Data‐based output review mechanisms that are triggered throughout the duration of a permit would be more conducive to providing certainty for business while ensuring that industry exceeds environmental standards by investing in continuous improvement.

Overall, we acknowledge the necessity for environmental regulation, but we also insist that environmental regulation be constructed in a manner that facilitates our economy instead of hindering it. We support having world‐class standards for air quality, but we also expect Metro Vancouver to preserve the economic climate to grow a world‐class economy. The two are not mutually exclusive.


Thank you for the opportunity to provide input on this important issue. We look forward to your response and further discussions for the betterment of both our environment and our economy.

Sincerely,

Rob MacKay‐Dunn

CC Carol Mason, CAO, Metro Vancouver

Allan Neilson, General Manager, Metro Vancouver Ray Robb, Division Manager, Metro Vancouver Iain Black, CEO & President, VBOT Aaron Robinson, Senior Policy Advisor, Greater Vancouver, VBOT

Rob MacKay-Dunn Director, Public Policy and Communications, The Vancouver Board of Trade t. 604.640.5454 f. 604-681-0437boardoftrade.com | facebook | twitter

The Vancouver Board of Trade | Suite 400, 999 Canada Place | Vancouver | BC | V6C 3E1 | Canada To unsubscribe email [email protected]


Western Stevedoring

Lynnterm

15 Mountain Highway

North Vancouver, British Columbia

Canada V7J 2J9

Telephone: 604 904 2800

Facsimile: 604 904 2801

Email: [email protected]

Western Stevedoring

Lynnterm

15 Mountain Highway


Canada V7J 2J9

Telephone: 604 904 2800

Facsimile: 604 904 2801


Western Stevedoring

Lynnterm

15 Mountain Highway


Canada V7J 2J9

Telephone: 604 904 2800

Facsimile: 604 904 2801


Lynnterm

15 Mountain Highway


Canada V7J 2J9

Telephone: 604 904 2800

Facsimile: 604 904 2801


MEMBER COMPANY

The Western Group Stevedoring and Terminal Services

January 4, 2016

Via Email: [email protected]

Metro Vancouver Great Vancouver Region District 4330 Kingsway, Burnaby BC V5H 4G8

Attention: Ray Robb, District Director

Dear Mr. Robb:

RE: Proposed Amendments Air Quality Bylaws No. 1082 and 1083

Western Stevedoring has been in the stevedoring and terminal business in B.C. since the 1940’s. We currently operate Lynnterm West Gate and Lynnterm East Gate which are two breakbulk terminals handling forestry products export and steel, pipe and project cargoes import.

We must express our serious concern with the proposed amendments to Air Quality Bylaws No. 1082 and 1083. The proposed changes to establish fixed terms for all permits issued or amended from mid 2015 forward will put substantial risks on long term investments necessary to develop and expand terminals in the Port of Vancouver. In addition, any large investment by any company in the lower mainland would face the potential of having to cease operations every two, three or however many years the original permit is issued for.

For our industry and others this is an untenable situation that will impose significant risk on decisions to make large investments in both improving current terminals and developing new terminals. Our Company serves the resource sectors of Canada with handling the export of forestry products, grain and project cargoes. New terminals to handle our trade to the world will be required in the future and this Bylaw change may have the unintended consequence of preventing those investments from being made by simply putting too much regulatory risk on the projects.



Western Stevedoring Page 2

MEMBER COMPANY

The Western Group Stevedoring and Terminal Services

We ask that you rethink your proposed changes and consider the long term implications of these types of regulatory changes in the Air Quality Bylaw’s.

Yours truly,

BRAD ESHLEMAN President

C.c. Robin Silvester, President & CEO, Port Metro Vancouver - [email protected] Terry Duggan, Acting President, BC Maritime Employers Association - [email protected] Stephen Brown, President, Chamber of Shipping - [email protected] Bob Wilds, Chair, BC Marine Terminal Operators Association – [email protected]






Rebecca O'Brien

From: Denise Mullen <[email protected]>Sent: Tuesday, January 26, 2016 3:18 PMTo: Roger QuanCc: Esther Berube; Allan NeilsonSubject: RE: followup to our conversation this morning


HI Roger

Thanks for this summary.

The only thing I will quibble with is the characterization of “do not have any substantive issues with the amendments as proposed”. We do but they are in relation to the linkages with terms limits, public notification requirements, and corollary process cost issues vis‐à‐vis amendments, as was articulated at length by Neptune.

I think a better way of characterizing comments related to fee changes is that business stakeholders are appreciative of efforts to minimize costs from the permitting process especially for many existing operators. However, we want to make sure that fee changes don’t fait accompli other policy changes (e.g., terms limits), which in our collective view may inadvertently introduce disincentives to continuous improvement (carrot versus stick), and increase the regulatory burden brought on by public consultation requirements that at the moment do not differentiate new activity versus continuation of existing operations (akin to re‐review and therefore undermine rights that are used to secure investment).

Denise

From: Roger Quan [mailto:[email protected]] Sent: January 26, 2016 2:42 PM To: Denise Mullen Cc: Esther Berube ; Allan Neilson Subject: followup to our conversation this morning

Hi Denise:

Thank you for the conversation this morning.

Staff are preparing the report which will go to the Board's Climate Action Committee on February 3, and then to the Board of Directors itself on February 26.

As outlined in our meeting with industry and business stakeholders on January 19, the report will seek Board approval for amendments to Bylaws 1082 and 1083. Proposed amendments will:

address permit application fees


seek to provide clarity on defined terms related to residential wood burning revise the exemption for comfort heating sources, and adjust administrative fees for inflation and to recover costs for tasks such as processing non‐electronic reports

I understand from your comments this morning that the stakeholders you work with do not have any substantive issues with the amendments as proposed.

I also recognize, as you noted, that the intentions paper related to these amendments has opened the door to discussion about concerns about the use of fixed terms (durations) in air quality permits.

As I said at our meeting on January 19th, the use of term limits is outside the scope of the proposed amendments, where we are trying to address the fee issue for permits that do currently have expiration dates.

But we have heard quite clearly from stakeholders about their concerns about term limits in permits and that more discussion is needed. The report will describe the results of the consultation process, including an issues and responses table, and will bring forward the concerns we heard about term limits.

Accordingly, a second element of the recommendation to our Climate Action Committee and Board will seek direction from the Committee to continue the discussions we have already initiated with you and others on the use of term limits in air quality permits. I think that some of our existing groups, like the Business Council’s air issues working group and the group we met with last week, would provide excellent venues to hear your perspectives. Ultimately, we will need to consult with others as well, including groups that may be impacted by the operations of industry.

Lastly, we are aiming to post the agenda for the February 3 Climate Action Committee on our website before the end of this week. Here is a link to information on our website related to appearing as a delegation to one of our Committees, orto the Board: http://www.metrovancouver.org/boards/delegations/Pages/default.aspx

regards, Roger




CONSULTATION WEBPAGE


Bylaw 1082 and 1083 Amendments Page 1 of 2

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Bylaw 1082 and 1083 Amendments

I-tome l/Pages/defaultaspxt a Seraices C/set ices/Paes/default.asxf a Air Ouality & Chmate Chance t/services/air-guaIityJPaes/defauIt.aspxt s Public Consultationt/services/air-ouaIitv/consultation/Paes/default.aspx) Bylaw 1062 and 1083 Amendments

As the authority regulating air quality across the region, Metro Vancouver proposes to make thefollowing changes to Greater Vancouver Regional District Air Quality Management Bylaw No.

10B2, 2003 (Bylaw 1082) and Greater Vancouver Regional District Air Quality Management Fees

Regulation Bylaw No. 1083, 2008 (Bylaw 1083):

• Renewal of permits: Define air quality permit renewals as a process different from new permit

issuance and permit amendment, and set application fees for permit renewals. 082.pdfl

• New administrative fees and fee inflation adjustments: Add fees for certain administrative

tasks, and adjust existing administrative fees for inflation.

• Natural gas/propane fired comfort heating: Increase the natural gas/propane comfort

heating exemption in Bylaw 1082 from 0.1 MW (0.33 million BTU/h) to 0.3 MW (1 million

BTU/h) to reduce the number of commercial/industrial heating units requiring explicit

authorization.

• Residential fireplace fuel clarification:.ftnprove the clarity of Bylaw 1082 regarding the

residential wood burning fuel definition by changing “wood” to “clean wood”, and by

modifying the section into a more readable format.

Additional information on the proposed amendments can be found in the Intentions Paper here

(/services/air-guality/AirQualityPublications/IntentionsPager.gdfl.

Please provide feedback by January 4, 2016 to [email protected](mailto:AQBylaw©metrovancouver.orci)

SITES CONTACT

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ReferencesAir Quality Management Bylaw

1082, 2008t/boards/Bylawsl/GVRD Bylaw 1

Air Quality Management FeesRegulation Bylaw 1083. 2008 -

Unofficial Consolidationt/boards/Bylawsl/GVRD Bylaw 1083%20-%2oUnofficial%2oConsolidation.pdf)

Ij Air Quality Management FeesRegulation Bylaw 1083, 2008(/boards/Bylawsl/GVRD Bylaw 1083.pdfl

Air Duality Management FeesRegulation Bylaw 1135, 2011 -

___________________

Amends Bylaw 1083, 2008(/boards/Bylawsl/GVRD Bylaw 1083%20-%20Amendment 1135.pdfl

FOLLOW COPYRIGHT

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Bylaw 1082 and 10$3 Amendments Page 1 of 2

metrovancouverS R.Vit ES AND SOt U tIONS FOR A LIVABLE REGION

Bylaw 1082 and 1083 Amendments

Home l/Ppges/default.pspx) > Services (/services/Pages/default.sou) > Air pualiW & Climate Change v/r > Public Cgnsltptign

t/services/air-auallrv/consultation/Pa9es/default.aspx) Bylaw 1082 and 1083 Amendments

As the authority regulating air quality across the region, Metro Vancouver proposes to make the

following changes to Greater Vancouver Regional District Air Quality Management Bylaw No. References1082, 2008 (Bylaw 1082) and Greater Vancouver Regional District Air Quality Management Fees

Regulation Bylaw No. 1083, 2008 (Bylaw 1083): Air Quality Management Bylaw1082, 2008

• Renewal of permits: Define air quality permit renewals as a process different from new permit t/boards/Bylawsl/GVRD Bylaw 1

issuance and permit amendment, and set application fees for permit renewals. 082.pdfl

• New administrative fees and fee inflation adjustments: Add fees for certain administrative Air Quality Management Fees

Reoulation Bylaw 1083, 2008 -

tasks, and adjust existing administrative fees for inflation. Unofficial Consolidation(/boards/Bylawsl/GVRD Bylaw 1

• Natural gas/propane fired comfort heating: Increase the natural gas/propane comfort 083%20-%20Unpfficial%

heating exemption in Bylaw 1082 from 0.1 MW (0.33 million BTU/h) to 0.3 MW (1 million 2oConsolidation.odf)

BTU/h) to reduce the number of commercial/industrial heating units requiring explicit

authorizationAir Quality Management Fees

Regulation Bylaw 1083, 2008(/boards/Bylawsl/GVRD Bylaw 1

• Residential fireplace fuel clarification: Improve the clarity of Bylaw 1082 regarding the 083 pdfl -

residential wood burning fuel definition by changing “wood” to “clean wood”, and by

modifying the section into a more readable format. Air Quality Management FeesRegulation Bylaw 1135, 2011 -

Additional information on the proposed amendments can be found in the Intentions Paper here Amends Bylaw 1083, 2008

(/services/air-quality/AirpualityPublications/IntentionsPaper.pdfl. (/boards/Bylawsl/GVRD Bylaw 1

083%20-%2pAmendment 1135.pdfl

We appreciate the feedback received before January 4, 2016.

Please send feedback to [email protected]

(mailto:[email protected]) it will be considered until the date that the GVRD

Board approves the revised bylaws.

SITES CONTACT FOLLOW COPYRIGHT

(learAirtiC. live Chat © Metro Vancouver 2015

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SUMMARY OF MEETINGS


Date Type Organization Name Notes

December 22, 2015 Meeting Neptune Terminals January 18, 2016 Conference call Port Metro Vancouver January 19, 2016 Group discussion Stakeholders that

expressed concerns January 28, 2016 Conference call G3


STAKEHOLDER DATABASE


Bylaws 1082 and 1083 Amendments ‐ Stakeholder Database

Sector Organization Title First Name Last Name 1 Local Municipalities City of Abbotsford Environmental Coordinator Tanya Bettles 2 Local Municipalities City of Abbotsford Environmental Coordinator Pauline Favero 3 Local Municipalities City of Burnaby Assistant Director Engineering and Environmental Dipak Dattani 4 Local Municipalities City of Burnaby Long Range Planner David Clutton 5 Local Municipalities City of Coquitlam Energy Manager Luisa Mora 6 Local Municipalities City of Coquitlam Manager, Environmental Services, Engineering & Public Steffanie Warriner 7 Local Municipalities City of Coquitlam Manager, Utility Programs Dana Soong 8 Local Municipalities City of Langley Manager, Engineering Services Kara Jefford 9 Local Municipalities City of New Westminster Environmental Coordinator Jennifer Lukianchuk 10 Local Municipalities City of North Vancouver Section Manager, Environmental Sustainability Caroline Jackson 11 Local Municipalities City of North Vancouver Manager, Parks & Environment Michael Hunter 12 Local Municipalities City of Pitt Meadows General Manager, Community Development Kelly Swift 13 Local Municipalities City of Port Coquitlam Deputy Director of Engineering and Operations Siu Tse 14 Local Municipalities City of Port Moody Environmental Technologist Rick Saunier 15 Local Municipalities City of Port Moody Manager of Sustainability Margot Davis 16 Local Municipalities City of Richmond Energy Manager, Sustainability Unit Levi Higgs 17 Local Municipalities City of Richmond Senior Manager, Sustainability and District Energy Peter Russell 18 Local Municipalities City of Surrey Acting Manager, District Energy Section Jason Owen 19 Local Municipalities City of Surrey Manager, Sustainability Anna Mathewson 20 Local Municipalities City of Surrey Manager, Utilites Jeff Arason 21 Local Municipalities City of Vancouver Climate Programs Engineer Malcolm Shield 22 Local Municipalities City of Vancouver Renewable Energy Planner Brad Badelt 23 Local Municipalities City of White Rock Director, Operations & Engineering (Environment Committee) Greg St. Louis 24 Local Municipalities Corporation of Delta Manager, Climate Action & Environment Mike Brotherston 25 Local Municipalities Corporation of Delta Senior Environmental Officer Angela Danyluk 26 Local Municipalities District of Maple Ridge Facilities Operations Manager Michael Millward 27 Local Municipalities District of Mission Director of Development Services Dan Sommer 28 Local Municipalities District of North Vancouver Energy Manager Monica Samuda ‐ Poitras 29 Local Municipalities District of North Vancouver Section Manager, Environmental Sustainability Julie Pavey


Sector Organization Title First Name Last Name 30 Local Municipalities District of West Vancouver Business Manager Engineering & Transportation Phil Bates 31 Local Municipalities District of West Vancouver Energy Manager David McKee 32 Local Municipalities Electoral Area A Director Maria Harris 33 Local Municipalities Lions Bay Public Works Manager Charles Partridge 34 Local Municipalities Township of Langley Environmental Coordinator Ryan Schmidt 35 Local Municipalities Tsawwassen First Nation Executive Assistant to the Chief Andrea Jacobs 36 Local Municipalities Village of Anmore Manager, Public Works Kevin Dicken 37 Local Municipalities Village of Belcarra Manager, Public Works Brad Smith 38 Local Municipalities Village of Bowen Island Superintendent of Public Works Bob Robinson 39 Government Agencies BC Housing CEO Shayne Ramsay 40 Government Agencies BC Hydro Sustainable Communities Senior Key Account Manager Robyn Wark 41 Government Agencies BC Ministry of Environment Manager, Air Protection Glen Okrainetz 42 Government Agencies BC Ministry of Environment Regional Manager, Environmental Protection Jonn Braman 43 Government Agencies BC Ministry of Environment Unit Head, Industrial Air Emissions Tony Wakelin 44 Government Agencies Environment Canada A/Head, Air Quality Unit Roxanne Vingarzan 45 Government Agencies Environment Canada Senior Research Scientist Corinne Schiller 46 Government Agencies Fraser Valley Regional District Environmental Services Coordinator Rebecca Abernethy 47 Government Agencies Fraser Valley Regional District Manager, Environmental Services Stacey Barker 48 Public Institutions Port Metro Vancouver Environmental Specialist Gary Olszewski 49 Public Institutions Port Metro Vancouver Environmental Specialist ‐ Air Emissions Christine Rigby 50 Public Institutions Port Metro Vancouver Director, Environmental Program Carrie Brown 51 Public Institutions SFU Univercity Trust Director of Development Dale Mikkelsen 52 Public Institutions University of British Columbia (Biomass Dem Energy Conservation Analyst Joshua Wauthy 53 Public Institutions University of British Columbia (Biomass Dem Alternative Energy Manager Jeff Giffin 54 Public Institutions YVR Manager, Engineering Services James Blake 55 Public Institutions YVR Environmental Specialist Jennifer Aldcroft 56 Public Institutions YVR Director, Environment Marion Town 57 Developers/Landowners Adera Project Manager Wayne Dedio 58 Developers/Landowners Anthem Properties Director of Construction Brent Hawkins 59 Developers/Landowners Aquilini Development and Construction Executive Assistant to Development Group Caryl‐Ann Pastor 60 Developers/Landowners Building Owners and Managers Association Manager, Energy and Environment Daniel Klemky


Sector Organization Title First Name Last Name 61 Developers/Landowners Concert Properties Sustainability and Project Manager Jonathan Meads 62 Developers/Landowners Condominium Homeowner's Association Executive and Strata Advisory Services Tony Gioventu 63 Developers/Landowners GWL Realty Advisors Office Manager Angela Lang 64 Developers/Landowners Ledcor Vice President, Business Development Jeff Thompson 65 Developers/Landowners Millennium Development Project Manager Adam Nour 66 Developers/Landowners PC Urban Development Manager David Fawley 67 Developers/Landowners Parklane ‐ River District CFO Ross Hanson 68 Developers/Landowners Rize Development Manager Andy Tam 69 Developers/Landowners Rize Development Manager Brent Beatson 70 Developers/Landowners Shape Properties Director of Facilties Oscar Kwieton 71 Developers/Landowners Solterra Office Manager Lauren 72 Developers/Landowners Staburn Administrator Celine Nordhoj 73 Developers/Landowners Urban Development Institute CEO Anne McMullin 74 Developers/Landowners Urban Land Institute District Coordinator (Shannon will confirm contact this week) Shannon Paterson 75 Developers/Landowners Westbank Acquisitions & Development Manager Darcey Buxton 76 Developers/Landowners Wesgroup Director, Corporate Development David Wesik 77 Industry Viterra (Cascadia) Project Manager Christina Proseilo 78 Industry Weyerhaeuser Company Limited EHS Joe Ryn 79 Utilities Central Heat Distribution Ltd. President Stacey Bernier 80 Utilities Central Heat Distribution Ltd. Director, Engineering Planning and Energy Services Jim Manson 81 Utilities Corix Utilities Manager ‐ Infrastructure Delivery Travis Kulak 82 Utilities Corix Utilities Director, Special Projects Ivana Safar 83 Utilities Dalkia Canada Fadi Oubari 84 Utilities Deltech VP Product Development Fred Spinola 85 Utilities FortisBC Energy Utilization Manager, Market Development Dan Bradley 86 Utilities FortisBC Director, Market Development Jason Wolfe 87 Utilities Lonsdale Energy Director Ben Themens 88 Utilities Navius Research Senior Managing Partner Chris (Dr.) Bataille 89 Utilities Nexterra Director, Business Development Darcy Quinn 90 Utilities Nexterra VP Sales Carl Dunaway 91 Utilities Nexterra Vice President, Research & Development Cliff Mui


Sector Organization Title First Name Last Name 92 Utilities Viessmann Business Unit Manager, Biomass‐Commercial Simon Köb 93 Utilities Wellons Canada Sales Manager Ken McClure 94 Utilities Wellons Canada Dennis Murray 95 Utilities Wellons Canada Sales Representative Paul Rossi 96 Utilities Western Bioheat Director Herb Feischl 97 Utilities Wunderlin Consulting Thomas Wunderlin 98 Community Organizations Cambie Village Business Improvement Associ Executive Director Rania Hatz 99 Community Organizations Community Energy Association Executive Director Dale Littlejohn 100 Community Organizations Strathcona Business Improvement Associatio Executive Director Joji Kumagai 101 AQ Permitees A‐Z Sponge & Foam Products Ltd Technical Manager Ron Chernenko 102 AQ Permitees ACR Group Inc. Production Manager Glen Tasker 103 AQ Permitees Acuren Group Inc. Lab Services Manager Bill Johnson 104 AQ Permitees Air Canada Chemical Waste Manager Howard Woo 105 AQ Permitees Alliance Grain Terminal Ltd. Systems and Maintenance Manager Dave Mellard 106 AQ Permitees Astrographic Industries Ltd. Operations Manager Aaron Piva 107 AQ Permitees Atlas Roofing Corporation of Canada Plant Engineer Bryan Ekkebus 108 AQ Permitees Avcorp Industries Inc. Manager, Process Lines Randy Duckett 109 AQ Permitees B.C. Roofing Products Ltd. Technical Manager Golnar Riahi 110 AQ Permitees B.W. Creative Wood Industries Ltd. Maintenance Department Darren de Groot 111 AQ Permitees Beaver Electrical Machinery Ltd. President Dave Flumerfelt 112 AQ Permitees Bel‐Par Industries Ltd. Production Manager Ole Anderson 113 AQ Permitees Britco Pork Inc. Maintenance Manager Bob Andresen 114 AQ Permitees British Columbia Hydro and Power Authority Senior Environmental Coordinator Ruth Lofstrom 115 AQ Permitees British Columbia Hydro and Power Authority Manager, Investment Recovery Brian Mills 116 AQ Permitees Cafe Classics President Bill Szeremeta 117 AQ Permitees CalPortland Canada Ltd. Terminal Manager Kristopher McKinnon 118 AQ Permitees Can‐Am Containers Inc. Division Manager Samantha Stewart 119 AQ Permitees Canada Colors and Chemicals Limited Manager, Delta Operations Louie Maione 120 AQ Permitees Canada Metal (Pacific) Ltd. Quality Assurance Manager Laurentiu Bucuroiu 121 AQ Permitees Canadian Autoparts Toyota Inc. Supervisor ‐ Environment, Health and Safety, Facilities Glen Sasaki 122 AQ Permitees Canexus Chemicals Canada Limited Partnership Responsible Care Manager Tony Gutenberg


Sector Organization Title First Name Last Name 123 AQ Permitees Canron Western Constructors Ltd. Vice President Terry Burns 124 AQ Permitees Canterbury Coffee Corporation Plant Manager Jeff MacVicar 125 AQ Permitees Cargill Ltd. Terminal Engineering and Maintenance Manager Ray Harmon 126 AQ Permitees Century Pacific Foundry Ltd. Quality Assurance Peter Beier 127 AQ Permitees Certainteed Gypsum Canada Inc. Production Supervisor ‐ Environmental Coordinator Doug Purse 128 AQ Permitees Chevron Canada Ltd. OE/HES Manager Kate Groves 129 AQ Permitees CIPA Lumber Co. Ltd. Director, Operations Manager Tony Shi 130 AQ Permitees City of Vancouver Superintendent Construction Suppplies Jeff Markovic 131 AQ Permitees CKF Inc. Plant Engineer Brett Lovell 132 AQ Permitees Clean Harbors Canada, Inc. Facility Manager Wayne Ma 133 AQ Permitees Cloverdale Paint Inc. Manager ‐ Quality, Safety & Environmental Affairs Ed Linton 134 AQ Permitees Coastland Wood Industries Ltd. Division Manager Dave Powers 135 AQ Permitees Columbia Containers Ltd. Plant Manager Cory Wellicome 136 AQ Permitees Creative Energy Vancouver Platforms Inc. Operations Manager Lori Parker 137 AQ Permitees Crown Corrugated Company Senior Quality Assurance Technician Cindy Chow 138 AQ Permitees Davis Wire Industries Ltd. Maintenance Department Supervisor Garry Burleigh 139 AQ Permitees Delta Cedar Products Ltd. Controller Ajay Sharma 140 AQ Permitees Ebco Industries Ltd. Maintenance Manager Paul Power 141 AQ Permitees Ebco Metal Finishing L.P. Chemist Heather Renton 142 AQ Permitees Esco Ltd. HR & EHS Manager Arne Lorenz 143 AQ Permitees Ethical Bean Coffee Company Production Manager Jason Rennie 144 AQ Permitees Ewos Canada Ltd. Production Manager Bob Naicker 145 AQ Permitees Fibreco Export Inc. Terminal Manager Kerry Lige 146 AQ Permitees Flavelle Sawmill Company Ltd. Manager Bob Wingrove 147 AQ Permitees Flexstar Packaging Inc. President / CEO Marc Bray 148 AQ Permitees Forintek Canada Corp. Team Leader. Facilities Manager Sorin Beschea 149 AQ Permitees FortisBC Energy (Vancouver Island) Inc. Compressor, Electrical and Controls Specialist Brent Masuch 150 AQ Permitees General Chemical Canada Ltd. Manager Bill Davidson 151 AQ Permitees General Paint Ltd. Site Manager ‐ Vancouver Doug Bell 152 AQ Permitees Greater Vancouver Sewerage and Drainage Senior Project Engineer Harvey Choy 153 AQ Permitees H‐S Tool and Parts Inc. Office Administrator Pam Tranelis


A B C D E F 3 Sector Organization Title First Name Last Name

157 154 AQ Permitees Haida Forest Products Ltd. President James Gillis 158 155 AQ Permitees Hal Industries Technical Manager Golnar Riahi 159 156 AQ Permitees Hallmark Poultry Processors Ltd. Senior Consultant Don Scott 160 157 AQ Permitees Harvest Fraser Richmond Organics Ltd. dba Regional Regulatory Compliance Officer ‐ Canada, Harvest Power Scott Kerr 161 158 AQ Permitees Highland Foundry Ltd. Operations Manager Garth McKay 162 159 AQ Permitees Houweling Nurseries Ltd. Energy Manager Al Ram 163 160 AQ Permitees Howe Sound Pulp & Paper Ltd Partnership Operations Manager Brad Bucoviz 164 161 AQ Permitees Hudson, Mitchell & Sons Lumber Inc. Plant Manager Tim Hudson 165 162 AQ Permitees Imasco Minerals Inc. Plant Manager Colin Sosniak 166 163 AQ Permitees Imperial Oil Limited Manager South BC Brian Smith 167 164 AQ Permitees Imperial Paving Limited Manager Plants & Equipment Tim Teichrob 168 165 AQ Permitees Inteplast Bags and Films Corporation Plant Manager Gordon Sedawie 169 166 AQ Permitees Interfor Corporation Production Coordinator Kengo Watai 170 167 AQ Permitees Interfor Corporation Health and Safety Coordinator Mark Bettencourt 171 168 AQ Permitees Intertape Polymer Inc. Operations Manager Gary Bagnell 172 169 AQ Permitees IPEX INC. Maintenance Manager Derek Sephton 173 170 AQ Permitees Jack Cewe Ltd. Mines Manager John J. Mah 174 171 AQ Permitees Kay‐Dee Forest Products Ltd. (dba Valley Kiln and Manager John Black 175 172 AQ Permitees Kemira Chemicals Canada Inc. Plant Manager Onel Lopes 176 173 AQ Permitees Kinder Morgan Canada Terminals Limited Director, Engineering & Environment Andrew Mullen 177 174 AQ Permitees Kruger Products LP Environment and Process Control Manager Cameron Kiff 178 175 AQ Permitees Lafarge Canada Inc. Environment Manager Darren Brown 179 176 AQ Permitees Lafarge Canada Inc. (dba Columbia Bitulithic) Plant Superintendent Reynold Amey 180 177 AQ Permitees Lantic Inc. Manager, Laboratory Services and Environment Jelena Denin Djurdjevic 181 178 AQ Permitees Lehigh Hanson Materials Limited Production Manager Jasper van de Wetering 182 179 AQ Permitees Lehigh Hanson Materials Limited Environmental Manager Eileen Jang 183 180 AQ Permitees Lhoist North America of Canada Inc. Operations Support Manager Steve Markle 184 181 AQ Permitees Marine Plastics Ltd General Manager Peter Binley 185 182 AQ Permitees McAllister Spring Ltd. QA and Purchasing Manager Bill Wiebe 186 183 AQ Permitees McAsphalt Industries Limited Facility Manager Konrad Moskal 187 184 AQ Permitees McKenzie Barge & Marine Ways Ltd. Controller Brian Moffatt


Sector Organization Title First Name Last Name 185 AQ Permitees Metalex Products Ltd. Quality Control Michael Wood 186 AQ Permitees Metrie Canada Ltd. Production Manager Gord Dowding 187 AQ Permitees Microb Resources Inc. [dba Salt Spring Coffee Co] Operations Manager Ross McLeod 188 AQ Permitees Mitchell Press Ltd. Operations Manager David Mitchell 189 AQ Permitees Molson Canada 2005 Chief Engineer Scott Gordon 190 AQ Permitees Montalco Cabinets Ltd. Manager Karen Klassen 191 AQ Permitees Mostad Publications Ltd. Director of Operations Troy Illes 192 AQ Permitees National Silicates Partnership dba National Manager, EH & S Jennie Houle 193 AQ Permitees Neptune Bulk Terminals (Canada) Ltd. Vice President Major Projects and Environment Ron Sander 194 AQ Permitees Nikolai Manufacturing Inc. Administrative Coordinator Taryn Purcell 195 AQ Permitees Norampac Inc. Production Manager Garth Johnston 196 AQ Permitees Nutreco Canada Inc. Maintenance Manager Gary Monson 197 AQ Permitees Otter Farm & Home Co‐Operative Feed Division Manager Vafa Alizadeh 198 AQ Permitees Pacific Coast Cedar Products Ltd. President George Klassen 199 AQ Permitees Pacific Coast Terminals Co. Ltd. Manager of Engineering Andre Olivier 200 AQ Permitees Pacific Fermentation Industries Ltd. General Manager Celine Lee 201 AQ Permitees Pacific Mako (A Div. of Pacific Bronze Ltd.) General Manager Brad Vanderlinde 202 AQ Permitees Pan‐Abode International Ltd. Accounting and Human Resources Brigette Loos 203 AQ Permitees Petro‐Canada Senior Advisor Environment John Elliott 204 AQ Permitees Plasti‐Fab Ltd. Manager, Technical Centre John Brazzale 205 AQ Permitees Precision Heat Treat Ltd. President John Davison 206 AQ Permitees Premier Millwork Inc. Job Foreman Ken Horner 207 AQ Permitees Premium Cedar Products Ltd. President Ed Watkins 208 AQ Permitees R. P. Richmond Industrial Contractors Ltd President Mike Cleeve 209 AQ Permitees Reichhold Industries Limited Technical Manager Amir Hussein 210 AQ Permitees Revolution Environmental Solutions Acquisition Operation Supervisor Susan Wu 211 AQ Permitees Revolution ORS Acquisition GP Inc. dba Terrapure Branch Manager Chris Parent 212 AQ Permitees Richardson International Limited Director of Operations Brad Sutton 213 AQ Permitees Richmond Plywood Corporation Ltd. Chief Steam Plant Engineer York Jung 214 AQ Permitees Richmond Steel Recycling Ltd Safety Coordinator James Botelho 215 AQ Permitees Robar Industries Ltd. Plant Engineer Reg Police


Sector Organization Title First Name Last Name 216 AQ Permitees Ropate Equipment Refinishers Ltd. Owner Ronald Backman 217 AQ Permitees Seabreeze Farm Ltd. Process engineer Claire Allen 218 AQ Permitees Serpentine Cedar Ltd. Manager Tony Wiens 219 AQ Permitees Shell Canada Limited Burmount Terminal Manager Todd McMahon 220 AQ Permitees Shell Canada Limited Shellburn Terminal Manager Elaine Bell 221 AQ Permitees Silver City Galvanizing Inc President Douglas Boychuk 222 AQ Permitees Stella Jones Inc. Plant Manager Brad Baigent 223 AQ Permitees Superior Plus Inc. Technical & Environmental Manager Paul Leyen 224 AQ Permitees Swiss Water Decaffeinated Coffee Company Inc. Process Supervisor Charles Carrier 225 AQ Permitees Teal‐Jones Group Ltd. Mill Superintendant Randy Jackson 226 AQ Permitees Technic Inc. Assistant Manager Keith Law 227 AQ Permitees Terminal Forest Products Ltd. Maintenance Manager Mike Woodland 228 AQ Permitees Thompson Foundry Ltd. President Mike Thompson 229 AQ Permitees Transcontinental Printing 2005 G.P. Maintenance & Project Manager Bryan Smith 230 AQ Permitees Tree Island Industries Ltd. Engineering Manager Alan Walker 231 AQ Permitees Trident Millwork & Display Industries Ltd. Operations Manager Elso Mion 232 AQ Permitees Unifirst Canada Ltd. Production Manager Luis Molina 233 AQ Permitees Univar Canada Ltd. SHE Representative / Sales Assistant Jennifer Melville 234 AQ Permitees University of British Columbia Energy Conservation Manager Jeff Giffin 235 AQ Permitees Vancouver Coastal Health Authority Manager, Energy Centre (Chief Engineer) Ed Florencio 236 AQ Permitees Vancouver Shipyards Co. Ltd. Facility Manager Gary Guelph 237 AQ Permitees VF Clean Energy Inc. Executive V.P. and Chief Financial Officer Stephan Ruffini 238 AQ Permitees Viterra Inc. (Cascadia) Mgr Terminal Eng & Maint Systems Peter Idema 239 AQ Permitees Viterra Inc. (Pacific) Manager, EH&S Vancouver Brian Watson 240 AQ Permitees Waldun Forest Products Ltd. and Twin Rivers Mill Superintendent Ross Holmes 241 AQ Permitees Weir ‐ R. Wales Canada Inc. General Manager Ricky Nolan 242 AQ Permitees West Coast Reduction Ltd. Environmental Manager Paul Faber 243 AQ Permitees Western Cleanwood Preservers Ltd. Plant Manager Scott Locken 244 AQ Permitees Western Drum Recyclers Ltd. Office Manager Dawn Green 245 AQ Permitees Westshore Terminals Limited Partnership Manager, Engineering and Environmental Services David Crook 246 AQ Permitees Weyerhaeuser Company Limited Environmental and Raw Materials Manager Joe Ryn


Sector Organization Title First Name Last Name 247 AQ Permitees Winvan Paving Ltd. Plant Supervisor Eric Morris 248 Regulated Sites ( Ag Aljane Farms Manager Mark Van Spronsen 249 Regulated Sites ( Ag Bevo Farms Ltd General Manager Leo Benne 250 Regulated Sites ( Ag Fable Farms Ltd. President Scott Pelton 251 Regulated Sites ( Ag Grootendorst Flowerland Nursery Ltd. Owner Andrew Grootendorst 252 Regulated Sites ( Ag Hollandia Greenhouse Ltd. Owner/Opns Mgr John Duyvestyn 253 Regulated Sites ( Ag Katatheon Farms Inc. Grower & Production Manager Steve Holley 254 Regulated Sites ( Ag SP(Delta) Limited Partnership Maintenance Supervisor Rick Essel 255 Regulated Sites ( Ag Sunnyside Greenhouses Ltd. Owner/Operations Manager Jos Moerman 256 Regulated Sites ( Ag SunSelect Produce Limited Partnership Manager Victor Krahn 257 Regulated Sites ( Ag Westcoast Produce Partnership Owner Ray VanMarrewyk 258 Regulated Sites ( Ag Windset Farms Operations Manager Robert Erwin 259 Current (new) AQ ALS Canada Ltd. Health, Safety and Environment Coordinator Alanna McBride 260 Current (new) AQ Aqua‐Pak Styro Containers Ltd Production Manager Gordon Heimbecker 261 Current (new) AQ Mansonville Plastics (B.C.) Ltd. Plant Manager Edmund Tiu 262 Current (new) AQ Schnitzer Steel Canada Ltd. Senior Environmental/Project Manager Nures Kara 263 Current (new) AQ Polynova Industries Inc President Dennis Wong 264 Current (new) AQ Layfield Poly Films/ Flexible Packaging Maintenance Manager Dave Brandle 265 Current (new) AQ Bureau Veritas Commodities Canada Ltd. Executive Chairman John Gravel 266 Current (new) AQ Western Concord Manufacturing, a Production Supervisor Chris Power 267 Current (new) AQ Glenwood Valley Farms Inc. General Manager, COO Herbert Schlacht 268 Current (new) AQ Fraser Surrey Docks LP Manager, Engineering/Maintenance Jurgen Franke 269 Current (new) AQ ZCL‐Dualam Inc. Plant Manager Kesar Nagra 270 Business Association BC Business Council President/CEO Greg D'Avignon 271 Business Association BC Chamber of Commerce President/CEO Jon Garson 272 Business Association West Vancouver Chamber of Commerce Executive Director Leah Gabriel 273 Business Association North Vancouver Chamber of Commerce Chief Executive Officer Louise Ranger 274 Business Association Vancouver Board of Trade President/CEO Iain Black 275 Business Association Burnaby Board of Trade President/CEO Paul Holden 276 Business Association Richmond Chamber of Commerce Executive Director Matt Pitcairn 277 Business Association Tri‐Cities Chamber of Commerce Executive Director Michael Hind


Sector Organization Title First Name Last Name 278 Business Association Delta Chamber of Commerce Executive Director Ian Tait 279 Business Association New Westminster Chamber of Commerce Chief Executive Officer Cori Lynn Germiquet 280 Business Association Surrey Board of Trade Chief Executive Officer Anita Huberman 281 Business Association South Surrey‐White Rock Chamber of Comm eExecutive Director Cliff Annable 282 Business Association Greater Langley Chamber of Commerce Executive Director Lynn Whitehouse 283 Business Association Abbotsford Chamber of Commerce Executive Director Allan Asaph 284 Business Association Cement Association of Canada Vice President, Environment & Marketing (Western Region) Ken Carrusca


To: Climate Action Committee From: Esther Bérubé, Program Manager, Bylaw and Regulation Development

Roger Quan, Director, Air Quality and Climate Change Planning, Policy, and Environment Department

Date: January 25, 2016 Meeting Date: February 3, 2016 Subject: Amendments to GVRD Air Quality Management Fees Regulation Bylaw No. 1083,

2008 RECOMMENDATION That the GVRD Board:



PURPOSE This report seeks Board approval of a proposed amendment to the Greater Vancouver Regional District (“GVRD”) Air Quality Management Fees Regulation Bylaw No. 1083, 2008. BACKGROUND At its meeting on October 7, 2015, the Climate Action Committee received for information the report titled "Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008", dated September 10, 2015. The report presented proposed amendments on which staff intended to initiate consultation. The proposed amendments addressed, among other items, changes to the application fees concerning air quality permits and approvals. The consultation process, a full list of items consulted on, and a summary of stakeholder feedback received are presented in the accompanying report 5.2 (“Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008”) in the February 3, 2016 Climate Action Committee agenda. All of the proposed amendments on which consultations were held will be presented for consideration to the Climate Action Committee in the coming months, except for one specific amendment regarding application fees for air quality permits and approvals. The specific amendment to application fees is being presented to the Committee now to facilitate its timely consideration, as there are permits that will be expiring and those operators will be required to pay application fees before consultation on the other amendments can be completed. This specific amendment is the subject of this report.

5.3


Amendments to GVRD Air Quality Management Fees Regulation Bylaw No. 1083 Climate Action Committee Meeting Date: February 3, 2016

Page 2 of 5 REGULATORY FEE PRINCIPLES The following principles guide the development of fees in connection with Metro Vancouver’s service of air quality management and air pollution control (the “Service”):

• Cost recovery – Revenues from air quality regulatory fees should be sufficient to fully recover the cost of the Service and activities that support the Service.

• User/Discharger pay – Operators should pay in accordance with the level of effort required to regulate their operations, and payments recovered from operators should be related to the environmental impact of the contaminants that those facilities discharge.

• Equity – Costs should be apportioned in an equitable manner across regulated operations. • Impact Weighting – Fees for air contaminants should be weighted according to the potential

impact of that contaminant. • Incentive to Reduce – Fees should be based on the quantity of contaminants discharged to

provide an incentive to operators to reduce their contaminant discharges. • Efficiency – The desire to be fair and effective must be balanced with simplicity in the

administration of fees, both from Metro Vancouver’s perspective as the regulator and for operators.

Cost Recovery The cost recovery principle is particularly important to the discussion on fee levels and is central to the amendment proposed in this report. Consistent with this principle, staff work to ensure that all types of fees charged, taken together, generate enough revenue to recover the full cost of the Service, which includes the:

• development of air quality bylaws and regulations; • development, review and issuance of air quality permits; • sampling of air emissions discharges from operators and monitoring of ambient air quality in

the vicinity of those operations; and • efforts undertaken by staff to promote and enforce compliance.

Metro Vancouver charges three types of fees: fees associated with each facility’s annual authorized emissions; fees to register emission sources (e.g., non-road diesel engines); and application fees. Application fees are intended to reflect the costs that Metro Vancouver incurs in processing the applications for permits and approvals, as well as amendments. Key tasks include reviewing application materials (including independent assessments), assessing the need for additional studies, and liaising with applicants. Revenues from application fees comprise approximately 1% of the total fee revenues for the Service. Much of the workload involved in providing the Service is in carrying out the various aspects noted above, and as such, the vast majority of fee revenues are attributable to annual fees charged to existing permit holders for authorized emissions, fees assessed for sources authorized under emission regulations, and for registration of sources. Historically, the combined fees have led to full cost recovery of all of the activities associated with the air quality regulatory program. PROPOSED AMENDMENTS The amendments to application fees proposed in Bylaw No. 1230 are outlined in the Attachment to this report. The proposed amendments introduce revised fees to recover the costs of processing applications for permits and approvals, and amendments to permits and approvals.



Page 3 of 5 The amendments are summarized in the following table:

GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008

GVRD Air Quality Management Fees Regulation Amending Bylaw No. 1230, 2016

8. The application fees payable to the District are as follows:

8 (1) The application fee payable to the District for an application for a permit or approval is the lesser of the following: (a) $200 plus twice the total emission fees

payable for the emissions specified in the application; and

(b) $50,000.

(1) For an application for a new permit or approval, $200 plus twice the total emission fees that would be payable for the emissions specified in the application; or

(2) For an application for an amendment to a permit or approval, $200 plus twice any increase in the total emission fees that would be payable for the emissions specified in the application.

8 (2) The application fee payable to the District for an application for an amendment to a permit or approval is the lesser of the following: (a) $200 plus twice the increase, if any, in the

total emission fees payable for the emissions specified in the application; and

(b) $50,000. Under the current fee bylaw, an operator whose permit is expiring or who wishes to make an amendment to a permit or approval must pay an application fee that can range from $250 to over $750,000, because the amount of the fee payable is based on each particular facility’s annual emissions. Metro Vancouver estimates that the air quality program incurs, on average, approximately $50,000 in costs to review applications for complex facilities with multiple emission sources, provided that they follow the “Metro Vancouver Air Quality Authorization Process”. A maximum fee set at $50,000 would cover the estimated 500 hours (at an average rate of $100 per hour) that the District Director and staff dedicate to the review of a typical application concerning a complex facility. A new fee structure with the $50,000 maximum is the proposed amendment. Facilities with lower emissions will continue to pay application fees that are based on their annual emissions. It is worth noting that there are a number of provisions within the existing Air Quality Management Bylaw No. 1082, 2008 that allow the District Director to require an applicant to conduct additional studies, report information, supply plans and specifications, or respond to an information order. Moreover, under Bylaw 1082, the District Director may recover Metro Vancouver’s costs for doing anything that a person is obliged to do under the Bylaw, or a permit, approval, order or regulation. Timing Metro Vancouver staff began the process of amending Air Quality Management Bylaw No. 1082, 2008 and Air Quality Management Fees Regulation Bylaw No. 1083, 2008 in the summer of 2015. It was recognized at that time that certain operators have air quality permits with expiry dates in the first half of 2016, including one that expires at the end of March 2016. Metro Vancouver staff prepared an Intentions Paper that would inform the consultation process. The intentions paper was considered by the Climate Action Committee at its October 7, 2015 meeting. The February 3, 2016 Climate Action Committee meeting is the first opportunity following consultation on the Intentions Paper to present the proposed bylaw amendment related to application fees.



Page 4 of 5 ALTERNATIVES 1. That the GVRD Board:



2. That the Climate Action Committee receive for information the report titled, “Amendments to GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008” dated January 25, 2016 and provide alternative direction.

FINANCIAL IMPLICATIONS If the Board chooses Alternative 1, the application fees that Metro Vancouver charges would be the lesser of an amount based on each particular facility’s annual emission fee or a maximum amount of $50,000. This change in determining the amount of the fee payable supports many of the principles that are in place to guide the development of fees as noted above, including the principle of cost recovery. While the change may reduce the amount collected for some applications, it would not have a significant impact on the total fee revenues collected that are necessary to fund the Service. The portion of total revenues attributable to application fees is relatively small. If supported, the proposed amendment to the application fees would have financial implications for complex facilities with multiple emission sources, with permits that will expire in early 2016. The proposed amended fee structure, with the application fee based on a particular facility’s annual emissions or to a maximum of $50,000, would result in lower fees payable for these complex facilities. However, the fees will reflect the costs that Metro Vancouver incurs to process applications. SUMMARY / CONCLUSION At its meeting on October 7, 2015, the Climate Action Committee received for information the report titled "Consultation on Amendments to GVRD Air Quality Management Bylaw No. 1082, 2008, and GVRD Air Quality Management Fees Regulation Bylaw No. 1083, 2008", dated September 10, 2015. The report presented proposed amendments on which staff intended to initiate consultation. All of the proposed amendments on which consultations were held will be presented for consideration to the Climate Action Committee in the coming months except for one specific amendment regarding application fees for air quality permits and approvals. The specific amendment to application fees is being presented to the Committee now to facilitate its timely consideration, as there are permits that will be expiring and those operators will be required to pay application fees before consultation on the other amendments can be completed. Under the current bylaw, an operator whose permit is expiring or who wishes to make an amendment to a permit or approval must pay an application fee that can range from $250 to over $750,000, because the amount of the fee is based on each particular facility’s annual emissions. Metro Vancouver estimates that the air quality program incurs, on average, approximately $50,000 in costs to review applications for large or complex facilities, provided that they follow the “Metro Vancouver Air Quality Authorization Process”. A maximum fee set at $50,000 would cover the estimated 500 hours (at an average rate of $100 per hour) that the District Director and staff dedicate to the review of a typical application for complex facilities. Facilities with lower emissions will continue to pay application fees that are based on their annual emissions.

The proposed bylaw amendment is presented as Alternative 1. Staff recommend Alternative 1.



Page 5 of 5 Attachment: Greater Vancouver Regional District Air Quality Management Fees Regulation Amending Bylaw No. 1230, 2016 (Doc #17273465). References: Bylaw 1082 and 1083 Amendments website http://www.metrovancouver.org/services/air-quality/consultation/bylaw1082-1083-amendments/Pages/default.aspx Metro Vancouver’s Air Quality Authorization Process http://www.metrovancouver.org/services/Permits-regulations-enforcement/PermitRegulationEnforcementPublications/AirPermitApplicationGuidance.pdf 17356965




http://www.metrovancouver.org/services/Permits-regulations-enforcement/PermitRegulationEnforcementPublications/AirPermitApplicationGuidance.pdf

http://www.metrovancouver.org/services/Permits-regulations-enforcement/PermitRegulationEnforcementPublications/AirPermitApplicationGuidance.pdf

Greater Vancouver Regional District Air Quality Management Fees Regulation Amending Bylaw No. 1230, 2016

A Bylaw to Amend "Greater Vancouver Regional District Air Quality Management Fees Regulation

Bylaw No. 1083, 2008" WHEREAS: A. The Board of Directors of the Greater Vancouver Regional District has adopted "Greater

Vancouver Regional District Air Quality Management Fees Regulation Bylaw No. 1083, 2008" to establish fees for the service of air pollution control and air quality management; and

B. The Board of Directors of the Greater Vancouver Regional District wishes to amend "Greater Vancouver Regional District Air Quality Management Fees Regulation Bylaw No. 1083, 2008".

NOW THEREFORE the Board of Directors of the Greater Vancouver Regional District, in open meeting assembled, enacts as follows: 1. "Greater Vancouver Regional District Air Quality Management Fees Regulation Bylaw No. 1083,

2008" is hereby amended by deleting section 8 in its entirety and replacing it with the following:

8 (1) The application fee payable to the District for an application for a permit or approval is the lesser of the following: (a) $200 plus twice the total emission fees payable for the emissions specified in the

application; and (b) $50,000.

(2) The application fee payable to the District for an application for an amendment to a permit or approval is the lesser of the following: (a) $200 plus twice the increase, if any, in the total emission fees payable for the

emissions specified in the application; and (b) $50,000.

2. This bylaw may be cited as the "Greater Vancouver Regional District Air Quality Management

Fees Regulation Amending Bylaw No. 1230, 2016". READ A FIRST, SECOND AND THIRD TIME this __________ day of __________________, 2016. PASSED AND FINALLY ADOPTED this __________ day of ___________________, 2016.

____________________________________ Greg Moore, Chair

_____________________________________ Chris Plagnol, Corporate Office

5.3 ATTACHMENT

Greater Vancouver Regional District Air Quality Management Fees Regulation Amending Bylaw No. 1230, 2016 Page 1 of 1


5.4

To: Climate Action Committee From: Derek Jennejohn, Lead Senior Engineer

Planning, Policy and Environment Department Date: January 13, 2016 Meeting Date: February 3, 2016 Subject: Partnering Agreements and Funding for Metro Vancouver’s Wood Stove Exchange

Program RECOMMENDATION That the GVRD Board: a) authorize the participation of wood burning appliance retailers in Metro Vancouver’s wood

stove exchange program; b) direct staff to publish Metro Vancouver’s intention to work with wood burning appliance

retailers listed in (c) below to carry out the program; c) authorize the Greater Vancouver Regional District to enter into a partnering agreement with

each of the following retailers to establish the terms and conditions of the services they would provide to Metro Vancouver as part of the program:

i. Alpha Home Energy Centre Ltd., Abbotsford, BC ii. B.C. Fireplace Service Inc., New Westminster, BC iii. Big Valley Heating & Sheet Metal Ltd, Maple Ridge, BC iv. Bowen Building Centre Ltd., Bowen Island, BC v. Bridge Fireplace Group, Port Coquitlam, BC vi. Dagg’s Gas Gallery, Abbotsford, BC vii. Delco Fireplaces Ltd., Langley, BC viii. Fireplace by Maxwell, North Vancouver, BC ix. Fireplaces To Go Manufacturing Distributors Ltd., Coquitlam, BC x. Gasland Equipment & Fireplaces Inc., Surrey, BC xi. Hilltop Plumbing & Heating Ltd., White Rock, BC xii. Mainland Fireplaces, Langley, BC xiii. R.E. MacDonald Stoves and Stones Ltd., Langley, BC xiv. The SHP Fireplace Warehouse, Richmond, BC xv. The Olde Stove Works, Mission, BC xvi. Vaglio Fireplace Ltd., Vancouver, BC xvii. Warm Hearth Heating Centre, Maple Ridge, BC;



PURPOSE To seek Board authorization to formalize the continuing participation of wood burning appliance retailers in Metro Vancouver’s Wood Stove Exchange Program, add additional retailers and request that the Board send a letter to the BC Minister of Environment in support of continued funding for the Provincial Wood Stove Exchange Program.


Partnering Agreements and Funding for Metro Vancouver’s Wood Stove Exchange Program Climate Action Committee Meeting Date: February 3, 2016

Page 2 of 4

BACKGROUND The Metro Vancouver Integrated Air Quality and Greenhouse Gas Management Plan includes actions to reduce emissions from residential wood burning. Wood smoke is composed of fine particulate matter (PM2.5) and a mix of chemicals that can lead to concerns about health, environmental, and nuisance impacts. Human health impacts can include increased risk of heart and lung diseases such as asthma and emphysema, and increased susceptibility to illness. Residential wood smoke contributes about 25% of regional PM2.5 emissions and data from Metro Vancouver’s air quality monitoring network has identified wood burning emissions as a contributor to short term elevated concentrations of PM2.5, particularly at the local neighbourhood scale. At its November 4, 2015 meeting the Committee received a report on Metro Vancouver’s new system of issuing air quality bulletins during cool weather months. In late November 2015, Metro Vancouver issued an Air Quality Bulletin due to intermittent high concentrations of fine particulate matter. Smoke from local sources, such as wood stoves, fireplaces and open burning, was believed to have caused elevated PM2.5 levels in parts of affected municipalities. Wood Stove Exchange Program Since 2008, the BC government has operated the Provincial Wood Stove Exchange Program, which provides funding to local governments, non‐profit organizations or airshed/air quality management organizations in BC. From 2009 to 2014, Metro Vancouver received over $110,000 in funding to operate its regional Wood Stove Exchange Program (the program). In November 2015, the Province awarded Metro Vancouver additional funding of $19,250 to support continuation of the program, for a total of approximately $130,000 in funding since 2009. The Wood Stove Exchange Program aims to reduce wood smoke impacts by accelerating replacement of older wood‐burning appliances with units that are more energy efficient and meet more stringent emissions standards. New, certified wood stoves, if operated properly, can lead to as much as 70% reduction in PM2.5 emissions. Provincial funding is used by the program to: • Provide rebates of $250 as an incentive for residents who replace an uncertified wood burning

appliance (e.g. fireplace or older wood stove) with a new, lower emission appliance (including a certified wood stove, pellet stove, electric insert or high efficiency gas stove/fireplace);

• Provide education and outreach materials on how to burn wood more cleanly (in certified and uncertified appliances), and workshops aimed at promoting proper wood burning practices; and

• Provide a mechanism for permanent removal through recycling of old wood stoves collected during the program.

To date, over 350 exchanges have taken place within the region, resulting in replacement of older high‐emitting wood stoves and open‐hearth fireplaces with new, clean wood‐burning or natural gas appliances. These exchanges have resulted in ongoing PM2.5 reductions of more than six tonnes per year, and improved air quality for the neighbourhoods where the exchanges occurred. Staff are assessing additional programs to address residential wood smoke, and as noted in Report 5.1 in this Committee agenda package, staff will be seeking direction from the Committee on these programs as part of the 2016 work plan.


http://www.metrovancouver.org/services/air-quality/projects-initiatives/Pages/wood-stove-exchange.aspx


Page 3 of 4

The Province has indicated that funding for 2016 is uncertain, and that the ability to fund a program in 2017 is undetermined. Due to the importance of this program in supporting Metro Vancouver’s Integrated Air Quality and Greenhouse Gas Management Plan, and in achieving reductions in PM2.5 emissions in residential neighbourhoods, staff recommend that the Board indicate its support for continued funding of the Provincial Wood Stove Exchange Program to the Minister of Environment. New Partnering Agreements for Participating Retailers To operate the Wood Stove Exchange Program, the steps below were identified as necessary requirements to formalize participation of wood burning appliance retailers. Participating retailers play an important role in the program, by confirming eligibility of homeowners for rebates, ensuring removal of uncertified wood stoves, and distributing educational materials. 1. The program will provide limited assistance to participating retailers by advertising their names

on program promotional materials. Under the Local Government Act, the Metro Vancouver Board may provide assistance to an industrial, commercial or business undertaking only under a partnering agreement.

2. An additional requirement under the Local Government Act is that the Board must publish its intention to provide certain kinds of assistance, including assistance under a partnering agreement. This notice must be published before the assistance is provided.

Metro Vancouver’s Wood Stove Exchange Program has operated since 2009 and includes 22 participating retailers across the region, all of whom have formally entered the program following the two steps above. Of these, agreements for 15 retailers expired at the end of 2015, and staff seeks authorization to enter into new partnering agreements with these retailers. Additionally, with increasing public awareness of the program, there are ongoing requests from retailers to be added the program. Staff has received requests from 2 additional retailers expressing interest in joining the program, which would bring the total number of retailers to 24. Accordingly, this report seeks authorization to add these additional retailers to the program, including directing staff to publish Metro Vancouver’s intention to work with wood burning appliance retailers as required under the Local Government Act, and authorizing the Greater Vancouver Regional District to enter into partnering agreements with individual wood burning appliance retailers. ALTERNATIVES 1. That the GVRD Board:

a) authorize the participation of wood burning appliance retailers in Metro Vancouver’s wood stove exchange program;

b) direct staff to publish Metro Vancouver’s intention to work with wood burning appliance retailers listed in (c) below to carry out the program;

c) authorize the Greater Vancouver Regional District to enter into a partnering agreement with each of the following retailers to establish the terms and conditions of the services they would provide to Metro Vancouver as part of the program:

i. Alpha Home Energy Centre Ltd., Abbotsford, BC ii. B.C. Fireplace Service Inc., New Westminster, BC iii. Big Valley Heating & Sheet Metal Ltd, Maple Ridge, BC iv. Bowen Building Centre Ltd., Bowen Island, BC v. Bridge Fireplace Group, Port Coquitlam, BC vi. Dagg’s Gas Gallery, Abbotsford, BC



Page 4 of 4

vii. Delco Fireplaces Ltd., Langley, BC viii. Fireplace by Maxwell, North Vancouver, BC ix. Fireplaces To Go Manufacturing Distributors Ltd., Coquitlam, BC x. Gasland Equipment & Fireplaces Inc., Surrey, BC xi. Hilltop Plumbing & Heating Ltd., White Rock, BC xii. Mainland Fireplaces, Langley, BC xiii. R.E. MacDonald Stoves and Stones Ltd., Langley, BC xiv. The SHP Fireplace Warehouse, Richmond, BC xv. The Olde Stove Works, Mission, BC xvi. Vaglio Fireplace Ltd., Vancouver, BC xvii. Warm Hearth Heating Centre, Maple Ridge, BC;



2. That the GVRD Board direct staff to consider additional or different courses of action to reduce residential wood smoke emissions and report back.

FINANCIAL IMPLICATIONS Metro Vancouver has recently received $19,250 in additional funding from the Province to support the continuation of its regional wood stove exchange program. This amount of funding could support as many as 77 additional exchanges. Administration of the program in Metro Vancouver is accommodated within existing budgets and the program can be continued without any additional financial implications. Under Alternative 1, 15 retailers would continue to participate in the program, and 2 additional retailers would be added. BC Ministry of Environment staff have advised that future funding for this program is uncertain. If funding is not made available from the Province later in 2016 or 2017, additional funding sources would be required to continue a regional exchange program. In this case, staff could be directed to investigate the use of air quality reserves, or propose funding in subsequent budget years. SUMMARY / CONCLUSION Residential wood burning appliances are significant contributors to fine particulate matter emissions, representing a quarter of the region’s PM2.5 emissions. Metro Vancouver has operated a Wood Stove Exchange Program since 2009, with ongoing funding from the provincial government, and has reduced PM2.5 emissions in over 350 neighbourhoods, ultimately improving local air quality for residents. Staff seeks to continue with partnering agreements for 15 participating retailers, and add 2 additional home heating retailers to the Wood Stove Exchange Program. Alternative 1 is recommended, whereby staff seeks GVRD Board authorization to formalize the participation of these wood burning appliance retailers in the program, and for the Board to write to the Minister of Environment to request continued funding of the program. 17188973


5.5

To: Climate Action Committee From: Allan Neilson, General Manager Planning, Policy and Environment Department Date: January 20, 2016 Meeting Date: February 3, 2016 Subject: Manager’s Report RECOMMENDATION That the Climate Action Committee receive for information the report dated January 20, 2016, titled “Manager’s Report”. Climate Action Committee 2016 Work Plan The Climate Action Committee 2016 Workplan was the subject of Report 5.1 of this agenda package. Beginning with the March meeting, the 2016 Workplan will be attached to the Manager’s Report each month, with updates on the status of the items in the workplan, listing them as ‘pending’, ‘in progress’, or ‘complete’. Attendance at 2016 Standing Committee Events Participation at external events provides important learning and networking opportunities. The following events that fall under the purview of the Climate Action Committee were included in the 2016 Leadership and Engagement budget:

Air & Waste Management Association AWMA Annual Conference and Exhibition 2016 • Place and Date: New Orleans, Louisiana, June 20-23, 2016 • Number of attendee(s): 1 • The Air & Waste Management Association (AWMA) is a professional organization that

provides a forum for information exchange on air quality and waste management issues.

FCM Sustainable Communities Conference 2016 • Place and Date: Ottawa, Ontario, February 9-11, 2016 • Number of attendee(s): 1 • The Sustainable Communities Conference is one of the Federation of Canadian Municipalities’

(FCM) key knowledge sharing activities on the topic of municipal sustainability. One of highlighted themes this year is climate change. The conference includes workshops, plenary and training sessions, and study tours, as well as networking opportunities.

Globe 2016 Conference and Innovation Expo • Place and Date: Vancouver, British Columbia, March 2-4, 2016 • Number of attendee(s): 2 • The GLOBE Series is the longest running corporate environmental business event in North

America. Having been around since 1990, GLOBE is known as the quintessential gathering of


Manager’s Report Climate Action Committee Meeting Date: February 3, 2016

Page 2 of 3

global senior business and government representatives who meet to network and to advance the issues at the nexus of global business and sustainability agendas. Climate change will be a prominent theme at this year’s conference, including a session on “The Road From Paris”, and outcomes of COP21, the 2015 Paris Climate Conference. In addition to the conference, Metro Vancouver will have a booth at the GLOBE 2016 exhibition, which has been narrowed in scope this year to focus on clean technology solutions.

Quality Urban Energy Systems of Tomorrow QUEST 2016 Conference • Place and Date: Calgary, Alberta, October 17-19, 2016 • Number of attendee(s): 2 • QUEST is a non-profit organization that conducts research, engagement and advocacy to

advance Smart Energy Communities in Canada - communities that improve energy efficiency, enhance reliability, cut costs, and reduce greenhouse gas emissions. Their annual Conference is expected to bring together all levels of government, utilities & energy service providers, and the real estate sector to build partnerships, profile best practices, and explore ongoing opportunities for advancing smart energy communities.

Climate Change Adaption Conference 2016 • Place and Date: Toronto, Ontario, October 9-10, 2016 • Number of attendee(s): 1 • Climate Change Adaptation 2016, the 5th international conference, is an interactive platform

to connect colleagues around the world to learn about best practices, and establish network with future collaborators in the Climate Change domain.

Please notify the Committee Chair as soon as possible, but no later than May 4, 2016, if you are interested in attending any of the above-noted events. As the funds for these events are budgeted in general government, the Intergovernment and Finance Committee has approved the events, but final approval on attendance rests with the Board Chair. Mobile Air Monitoring Unit (MAMU) in Lions Bay Metro Vancouver’s Mobile Air Monitoring Unit (MAMU), the mobile air quality station used to make air quality and meteorological measurements throughout the region, was installed at Lions Bay Community School on December 21, 2015 for a two month specialized monitoring study in the Village of Lions Bay. MAMU is making continuous measurements of fine particulate matter (PM2.5), nitrogen oxides (NOX), sulphur dioxide (SO2), carbon monoxide (CO) and other air contaminants. Wind direction, wind speed, temperature and relative humidity instruments on MAMU’s 10 metre mast are also gathering data. The information from this study will allow staff to assess baseline air quality in Lions Bay and the influence of various sources of air emissions in the area, including residential wood burning and traffic. MAMU is part of the Lower Fraser Valley network of air quality monitoring stations, located from Horseshoe Bay to Hope. The network consists of 29 monitoring stations, including 23 in Metro Vancouver and 6 in the Fraser Valley Regional District. The newest station, in New Westminster, became operational in October 2015.


Manager’s Report Climate Action Committee Meeting Date: February 3, 2016

Page 3 of 3 Update on Trans Mountain Expansion Project On January 12, 2016 Metro Vancouver filed its written argument to the National Energy Board (NEB) regarding the Trans Mountain Expansion Project (TMX). As previously reported to the Committee, Metro Vancouver has been engaged, along with 400 other intervenors, in the review process for the Trans Mountain Expansion Project which is an application from Kinder Morgan Canada to expand its existing 1,150-kilometre petroleum products pipeline that runs from Edmonton to Burnaby, tripling its capacity from 300,000 to 890,000 barrels per day. Metro Vancouver’s written argument follows up on its submission of evidence to the NEB in May 2015, outlining reasons why the Metro Vancouver Board has taken a position of opposition to the proposed pipeline. One of the key points of opposition is related to concerns about the potential for oil spills from tankers operating in the Burrard Inlet, and as reflected in the positions of many intervenors, the capacity for oil spill response. The project proposes an increase in oil tanker activity from five to approximately 34 tankers per month, as well as expansions to an existing tank farm and marine terminal in Burnaby. Metro Vancouver’s submission is based on three key points: the environmental assessment and therefore the project application is incomplete, and does not provide adequate information for the NEB to make a decision; the project will result in significant adverse environmental effects; and the project is not in the public interest. Staff have also provided comments and recommendations on the list of conditions put forth by the NEB, if the project is approved. Oral hearings will occur in January – February (including Metro Vancouver’s presentation of its oral summary argument on January 27). After the close of the hearing record in February, the NEB will have until May 20 to reach its decision and release its report to the Federal Government (Governor in Council and Minister of Natural Resources). References: 1. Air and Waste Management Association Annual Conference and Exhibition

http://ace2016.awma.org/ 2. FCM Sustainable Communities Conference http://www.fcm.ca/home/events/sustainable-communities-conference.htm 3. GLOBE 2016

http://www.globeseries.com/ 4. Quest 2016 http://www.questcanada.org/quest2016 5. Climate Change Adaption Conference 2016

http://www.globalclimate.info/ 17175463


http://ace2016.awma.org/

http://www.fcm.ca/home/events/sustainable-communities-conference.htm

http://www.globeseries.com/

http://www.questcanada.org/quest2016

http://www.globalclimate.info/

6.1

2015 October 27

Chair Greg Moore Metro Vancouver Board 4330 Kingsway Burnaby, BC V5H 4G8

DearCba~M

CITY OF BURNABY OFFICE OF THE MAYOR

DEREK R. CORRIGAN MAYOR

FILE: 2410-20

SUBJECT: CLIMATE CHANGE WARNING LABELS ON GAS PUMP NOZZLES

Burnaby City Council, at its Open Council meeting held on 2015 October 26, received the above noted report and adopted the recommendations contained therein:

1. THAT Council consider future opportunities for public communication about climate change in the context of the regional and municipal sustainability policy framework, including Burnaby's Environmental Sustainability Strategy and Community Energy and Emissions Plan.

2. THAT copies of this report be provided to John Nguyen representing Our Horizon, to the Metro Vancouver Climate Action Committee and to Metro Vancouver member municipalities.

As directed in recommendation #2, a copy of the report is attached for your infonnation.

Yours truly,

~~ Derek R. Corrigan MAYOR

4949 Canada Way, Burnaby, British Columbia, VSC 1M2 Phone 604-294·7340 Fax 604-294-7724 [email protected]


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• ~ Cityof _)~Burnaby

Meeting 2015 October 26

COUNCIL REPORT

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ENVIRONMENT COMMITTEE

HIS WORSHIP, THE MAYOR AND COUNCILLORS

SUBJECT: CLIMATE CHANGE WARNING LABELS ON GAS PUMP NOZZLES

RECOMMENDATIONS:

1.

2.

THAT Council consider future opportunities for public communication about climate change in the context of the regional and municipal sustainability policy framework, including Burnaby's Environmental Sustainability Strategy and Community Energy and Emissions Plan.

THAT copies of this report be provided to John Nguyen representing Our Horizon, to the Metro Vancouver Climate Action Committee and to Metro Vancouver member municipalities ..

REPORT

The Environment Committee, at its meeting held on 2015 October 13, received and adopted the attached report responding to Council's request for a report on the issue of cl imate change warning labels on gas pump nozzles, based on the delegation from the non-profit group Our Horizon.

Copied lo: City Manager Director Planning & Building Director Engineering Director Finance

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Respectfully submitted,

Councillor A. Kang Chair

Councillor S. Dhaliwal Vice Chair

Councillor P. Calendine Member

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• ~ Cityof ~Burnaby

Meeting 2015 Oct 13

TO: CHAIR AND MEMBERS ENVIRONMENT COMMITTEE

COMMI'ITEE REPORT

DATE: 2015 October 8

FROM: DIRECTOR PLANNING AND BUILDING FILE: 33000 01 Re/ere11~: E""irorimenlal Factors

SUBJECT: CLL'\ilA TE CHANGE WARNING LABELS ON GAS PUMP NOZZLES

PURPOSE: To respond to Council's request for a report on the issue of climate change warning labels on gas pump nozzles, based on the delegation from the non-profit group Our Horizon.

RECO'MMENDATIONS:

1. THAT Council consider future opportunities for public communication about climate change in the context of the regional and municipal sustainability policy framework, including Burnaby's Environmental Sustainability Strategy and Community Energy and Emissions Plan.

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2. THAT copies of this report be provided to John Nguyen representing Our Horizon, ) to the Metro Vancouver Climate Action Committee and to Metro Vancouver member municipalities.

REPORT

At the Regular meeting of Council on 2015 July 6, a delegation from the non-profit organization Our Horizon requested that Burnaby support affixing warning labels about climate change to gas pump nozzles. Arising from the discussion, Council requested that staff report on this matter. Tills report responds to that request

1.0 BACKGROUND

Our Horizon is a national non-profit organization campaigning to raise awareness about the need for action on climate change through public education that uses warning labels on vehicle fuel ("gas") pump nozzles. The proposed warning messages are based on the model of cigarette health warnings which the proponents state have been effective in changing people's behaviour. Our Horizon has drafted example label designs which depict images, such as a caribou cow and calf, along with text. such as "Warning - use of this fuel contributes to climate change which may put up to 30% of species at a likely risk of extinction." The labels aim to co1U1ect these climate change effects to the specific personal action of filling a vehicle tank with gasoline in order to encourage people to take action. The representatives requested that Burnaby support the campaign and endorse a resolution to the Union of BC Municipalities (UBCM).

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To: Environment Committee From: Direclor Planning and Building Re: C/Jmale Change Warning Labels on Gas Pump Noulu 20 I j October 8 ........................ ........................................... Page 1

1.1 Support to Date for Gas Pump Warning Labels

As of the end of August 2015, warning labels on gas pump nozzles have been supported by local government actions as outlined below:

• In January 2015, the City of West Vancouver supported drafting a resolution to the Union of BC Municipalities (UBCM) and Federation of Canadian Municiphlities (FCM) to require all gas stations in Canada to display warning labels on pump nozzles. Subsequently, the City of Colwood advanced a slightly different draft resolution entitled "Warning Labels for all Fossil Based Liquid Fuels" (see Appendix J, attached).

• Between January and July 2015, the City of Moncton NB, City of Guelph ON, District of Saanich BC, Association of Vancouver Island and Coastal Communities, City of Waterloo ON, and City of Oakville ON, voted to support the UBCM resolution.

• In June 2015, the City of North Vancouver voted to bring fotWard a bylaw requiring all public gas stations in the City to install climate change warning labels. This would apply to all six stations currently operating. as well as any future additional stations. At this time, North Vancouver has given first reading to a Business Licence Bylaw amendment and is proceeding with Public Hearing.

1.2 UBCM Resolution

The District of West Vancouver passed a resolution, (see Appendix 1, attached) requesting that all retail petroleum vendors in Canada be required to affix warning labels onto gas pump nozzles, on the basis that: a) combustion of vehicle fuel contributes to climate change. and b) that health labels are required on tobacco products.

The resolution forwarded to the UBCM at their September 15th, 2015 Convention was sponsored by the City of Colwood, and was entitled "Warning Labels for All Fossil Based Fuels," (see Appendix 1, attaclled). This resolution also noted the contribution of vehicle fuels to climate change, and added the concern of sea level rise impacts on coastal conununities, but did not include the reference to tobacco labeling.

The resolution (No. B 112) was endorsed with a minor amendment to read:

THEREFORE BE IT RESOLVED that UBCM support, and that member local governments will implement where possible, legislation to require retailers of petroleum products to provide plastic sleeves (nozzle toppers) with warning labels on pwnp handles for all fossil based liquid fuels.

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To: Environment Committee From: Director Planning and Building Re: Climale Change Warning Labe/1 on Gas Pump Nozzlu 1015 October 8 .......... _, ...................................................... Page 3

2.0 DISCUSSION

2.1 Jurisdiction

At this time, the authority of local or national governments tQ legislate gas pump warning labels has yet to be tested in court. Our Horizon partnered with the University of Victoria Law Society on a legal backgrounder on this issue. The backgrounder outlines a rationale in support of the issue being within local government jurisdiction, for example as the basis to enact a bylaw, but also states that legal challenge by petroleum businesses is likely and advises that local goverrunents seek their own legal opinion. Due to the potential for a legal challenge to the City and the associated costs of a potential challenge, as well as for other reasons discussed below, it is not recommended that the City pursue a bylaw on this matter at this time.

2.2 Business Perspective

Consultation with fuel vendors is not reported to have been undertaken in jurisdictions where support or action is proposed for warning labels. Business associations representing vehicle fuel vendors in other jurisdictions have voiced opposition to legislation requiring gas pump warning labels1 on the basis that it unfairly portrays the industry in a negative light, has associated costs and may reduce sales and/or compete with advertising revenue if they already use nozzle signage for product promotion.

2.3 Communicating About Climate Change

Climate change has been called a ''wicked" problem: it is complex, with diffuse impacts that occur at a range of scales from local to global; it is difficult to clearly define (different stakeholders have different views of the nature of the problem and appropriate responses); and it crosses governance boundaries2

• Solutions to climate change are not simple. This means, among other implications, that it can seem overwhelming and distant to an individual person' s everyday decisions. Making the connection between a person's actions - in this case, the action of filling up a vehicle fuel tank - and climate change impacts could help to personalize the issue so that some people feel more compelled to change their behaviour. However, this approach should be carefully considered for various reasons including those listed below3.

• Gas pump labels would not distinguish between consumers with different patterns of vehicle fuel consumption, motivations, or reasons for driving. Negative messaging that relies on fear and guilt may cause some people to feel angry and distance themselves from consideration of the issue, or may generate other unintended reactions.

1 Huffington Post (online): "Gas Retailers Line Up Against Climate-Change Warning Labels On Pumps" 20 I 5-05-26, accessed August 2015: http://www.huffingtonpost.ca/201 5/05126/climatc-change-wamings-gas-pumps n 7441534.html i For example, see Chris Reidy, "Climate Change is a Super Wicked Problem", accessed August 2014: http://chrisriedy.me/2013/05/29/climnte-chaoge-is-a-super-wicked-problem/ >These points draw on literature sources including: .\.farsha/I, G. Don't Even Think About /1 - Why Our Brains are Wired 10 Ignore Climate Change. Bloomsbury USA. New York. 2014.

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To: Environment Committee From: Director Planning and Building Re: Climate Change Warning Labels on Gas Pump Noufes 2015 October 8 ................................................................... Page I

• Research has shown that many people continue to ignore or 'disbelieve' in climate change and its impacts, not due to an absence of information, but rather for societal, culturally influenced and other reasons. Presenting infonnation in the absence of a frame that addresses these complex issues may not support further consideration of this significant issue.

• Climate change has vast social justice, international security, economic and ecological impacts. Framing climate change as an "envirorunental" issue, for example using imagery of polar bears, caribou and other "charismatic megafauna,. as typically employed by environmentalist groups (including Our Horizon), may not resonate well with those who do not identify with this imagery.

• Portraying climate change as something occurring in distant places, for example droughtstricken farmers in an African country (as shown in one of the Our Horizon labels) can frame the issue as having little relevance to people here, further 'distancing' the issue from a local context, and as such may detract from the .intent of the ads.

Although the example label designs proposed by Our Horizon could be tailored to convey the message using different images than those described above, detennining the best approach requires further consideration.

Finally, Our Horizon equates climate change warning labels with cigarette health labels. However, cigarette smoking is a different kind of issue: it is a relatively simple problem where the cause (smoking) is closely and directly tied with a very personal negative effect (disease), and the solution (quitting smoking) is obvious and can be immediately acted upon by a person, with immediate benefits. Climate change is a complex problem with diffuse impacts that requires society working together in creative ways that break down cultural and societal barriers. As such, the approach used for cigarette labels may not serve as an appropriate model for communicating about climate change.

In light of these factors, messaging and communication about climate change needs to be Wldertaken carefully and strategically.

2.4 Considerations for Climate Change Messaging Approaches

Climate change can be communicated in many different ways. Our Horizon is promoting gas pwnp labels as a low-cost, opportunistic approach, to support broader dialogue on the issue. Regardless of the medium for communication, factors to consider that may address some of the concerns outlined above include the following.

• The type of messaging approach should be carefully considered and framed, and based upon evidence for its effectiveness, in order to overcome social and cultural barriers specific to the issue of climate change. Research could be undertaken to better address these concerns, for example using stakeholder focus groups and other accepted methodologies .

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To: Environment Committee From: Director Planning and Building Re: Climate Change Warning labels on Gas Pump Nozzles 20/ 5 October 8 ................................................................... Page 5

• Approaches could draw upon other successful public infonnation campaigns undertaken in the region involving complex social and behavioural issues, such as recycling, food scraps, composting and drinking water conservation.

• Approaches may need to be adaptable and tailored to the local context, in order to communicate views on climate change that best support municipal and regional greenhouse gas (GHG) reduction objectives, and to appeal to the particular values held by people in different cities and towns, in order to span a diversity of views and opinions.

• Positive messaging approaches could be considered and provide infonnation about specific things people can do to reduce GHG emissions. This could include encouraging walking or cycling more, facts about the benefits of using transit and fuel-efficient vehicles, and promoting programs and incentives such as for electric vehicles and car-sharing.

These considerations are just some examples of the context within which effective public communication on this complex issue could be undertaken.

2.5 Relationship to Burnaby's Community Energy and Emissions Plan (CEEP) and Environmental Sustainability Strategy (ESS)

Burnaby is developing a Commwlity Energy and Emissions Plan (CEEP) which will outline a

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target for reducing community GHG emissions, with supporting goals, strategies and actions. A ) high level summary of the proposed approach for the CEEP, including targets, goals and strategies, is anticipated to form part of the public consultation for Burnaby's Environmental Sustainability Strategy (ESS) in 2016, pending Council approval of Phase 3 - Draft ESS. A draft CEEP would then be shared publicly, prior to seeking Council approval of the final CEEP in 2016.

Burnaby's ESS addresses climate change and GHG emissions reduction through several of the ten broad themes and related goals:

• Breathe (Climate and Air Quality) -A community resilient lo climate change, with clean air and low carbon emissions.

• Live (Land Use Planning and Development) - A network of compact and complete communities, within a fabric of healthy ecosystems.

• Move (Transportation) - A walkable, bikeab/e, and transit-supported city !hat supports a healthy community and environment.

• Build (Buildings and Energy) - Buildings and infrastructure rhar have a positive impact on the environment.

The ESS framework of goals, strategies and actions has been developed based upon extensive public and stakeholder engagement, and a Draft ESS is currently being prepared for a final phase of public consultation.

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To: Environment Committee From: Director Planning and Building Re: Climate Change Warning Labels on Gas Pump Nozzles 2015 October 8 ................................................................... Page 6

Once adopted by Council, implementation of both the ESS and CEEP presents an opportunity to highlight opportunities for action on the part of the City, other levels of government, and individuals. This will provide a further context for communicating about climate change in a way that addresses the City's broad goals for sustainability. Specific approaches for communicating and engaging people on this issue, which could include communication approaches as described in Section 2.4., can be considered as part of future ESS and CEEP implementation. ·

3.0 CONCLUSION

Climate change is a critical and complex problem with social, economic and environmental impacts occurring at many different scales. Therefore, strategies for communication about this issue need to be carefully considered to ensure they engage the community and serve the directions set by the City.

The specific approach proposed by Our Horizon presents some concerns as outlined in this report. Nevertheless, gas pump nozzle signage in general, as a medium for communicating about climate change, presents an option for future consideration.

Therefore, it is recommended that Council consider future opportunities for public communication about climate change in the context of the regional and municipal sustainability policy framework, including Burnaby's ESS and CEEP.

LT/sla/sa Attachmtnt

cc: City Manager Director Engineering Director Finance City Clerk

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17139753

APPENDIX 1

WEST VANCOUVER RESOLUTION AND COL WOOD-SPONSORED UBCM RESOLUTION

1. West Vancouver Resolution:

RECOMMENDED THAT:

Council support the following resolution be advanced for consideration at the September 21/25, 2015 Union of British Columbia Municipalities (UBCM) conference and the June 5/8, 2015 Federation of Canadian Municipalities (FCM) convention:

Whereas there Is evidence that combustion of petroleum products such as gas and diesel in vehicle engines contributes to greenhouse gas emissions that affect natural systems in ways that are injurious to human health and the environment, and

Whereas point-of-sale warning labels have been required for other consumables, such as tobacco products, which has effectively curbed use of harmful products,

Therefore be It resolved that all vendors of retail petroleum products in Canada be legislated to provide warning labels on all pump handles (pump talkers), and that those companies who do not have this feature on their pump handle be obligated lo fit them with the plastic sleeves which will allow warning labels to be displayed.

2. City of Colwood Resolution to UBCM

8112 WARNING LABELS FOR ALL FOSSIL BASED LIQUID FUELS Colwood

WHEREAS there Is evidence that combustion of petroleum products such as gas and diesel used in vehicles contribute to greenhouse gas emissions that affect natural systems in ways that are injurious to human health and to the natural environment upon which we all depend for food and life;

AND WHEREAS sea level rise resulting from greenhouse gas emissions will cause significant harm to coastal communities:

THEREFORE BE IT RESOLVED that UBCM suppon, and will implement where possible, legislation to require retailers of petroleum products to provide plastic sleeves (nozzle toppers) with waming labels on pump handles for all fossil based liquid fuels.

Amended version of Resolution No. 8112 (endorsed): THEREFORE BE IT RESOLVED that UBCM support, and that member local governments will implement where possible, legislation to require retailers of petroleum products to provide plastic sleeves (nozzle toppers) with warning labels on pump handles for all fossil based liquid fuels.

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Reference: 290991

October 23, 2015

Greg Moore, Chair and Directors

Metro Vancouver Board 4330 Kingsway Burnaby BC V5H 408

Dear Chair Moore and Directors:

Thank you for your letter of September 11, 2015, regarding public comment on the Climate Leadership Plan Discussion Paper.

I appreciate that you have taken the time to submit these comments to the Climate Leadership Plan public comment process. I assure you that your letter and submission will be considered along with the others received on the plan.

I would also like to inform you that there will be a second opportunity for input in December, after government releases its draft Climate Leadership Plan.

Thank you again for writing. Your input is greatly appreciated.

Sincerely,

Mary Polak Minister

cc: Jordan Sturdy, MLA, West Vancouver- Sea to Sky, and Parliamentary Secretary for

Ministry of

Environment

Energy Literacy and the Environment

Officeof1hc Minister

Mailing Address: Parliament Buildings Vic1oria BC V8V IX4

Telephone: 250 387-1187 Facsimile: 250 387-1356


6.3a metrovancouver ~ SERVICES AND SOLUTIONS FOR A LIVABLE REGION

December 15, 2015

Debra Myles, Panel Manager - Roberts Bank Terminal 2 Project

Canadian Environmental Assessment Agency

22nd Floor, 160 Elgin Street

Ottawa ON KlA OH3

Via Email: RobertsBan [email protected]

Dear Ms. Myles,

1 e: CP-0 7-01.:uIO

RE: Roberts Bank Terminal 2 Project - Metro Vancouver Comments on Completeness of Marine Shipping Addendum to the Environmental Impact Statement

In accordance with the Canadian Environmental Assessment Agency's invitation to comment on the completeness of the Marine Shipping Addendum to the Environmental Impact Statement for the proposed Roberts Bank Terminal 2 Project, attached please find comments from Metro Vancouver staff. Metro Vancouver staff have participated in the consultation process and provided previous comments to CEAA as well as to Port Metro Vancouver on the proposed Project as it has advanced through the review process.

The proposed Roberts Bank Terminal 2 Project will have far-reaching impacts on land use, transportation, the economy, and the environment in the region. Metro Vancouver works with a wide range of authorities at the municipal, regional, provincial, and federal levels to collaboratively address issues of regional significance based on the goals and objectives expressed in the Board Strategic Plan, Metro Vancouver 2040: Shaping Our Future, the regional growth strategy, as well as other regional plans such as the Integrated Air Quality and Greenhouse Gas Management Plan. Effective planning for major projects requires close coordination among all levels of government, businesses, institutions and residents.

In accordance with your Agency's instructions, at this stage we have limited our comments to the completeness of the Marine Shipping Addendum to the Environmental Impact Statement. These comments are in addition to those Metro Vancouver staff previously submitted on June 11, 2015. We understand that once a Review Panel has been appointed, Metro Vancouver will be afforded the opportunity to comment on the technical aspects of the Project, whether the information is correct and whether or not we agree with the proponent's conclusions.

Metro Vancouver appreciates ongoing consultation with regard to this Project. For further information, please contact the undersigned at 604-451-6556 or [email protected].

Yours truly,

. Af\.,J.A _ 't ~ Elisa Camp~elf 'C -Director, Regional Planning Planning, Policy and Environment Department Metro Vancouver

4330 Kingsway, Burnaby, BC, Canada VSH 4G8 • 604-432-6200 • www.metrovancouver.org

Greater Vancouver Regional District• Greater Vancouver Water District• Greater Vancouver Sewerage and Drainage District• Metro Vancouver Housing Corporation


Roberts Bank Terminal 2 Project Environmental Impact Statement – Marine Shipping Addendum

November 16 – December 16, 2015

Additional Comments on the Completeness of Information in the Environmental Impact Statement (EIS)

GENERAL COMMENTS Metro Vancouver’s sustainability tenet is a commitment to achieving the highest quality of life embracing cultural vitality, economic prosperity, social justice and compassion, all nurtured by a beautiful and healthy environment within the region. Major infrastructure decisions are made by municipalities, Metro Vancouver, TransLink, the Province, Vancouver International Airport, Port Metro Vancouver, and private entities. In order for these decisions to cumulatively move this region forward, it is necessary that these decisions be contemplated relative to the comprehensive values and objectives established in the region.

We understand that through the Project, the Port wishes to meet growing demand for containerised trade, improve the efficiency of goods movement at Roberts Bank, provide economic and employment benefits to the region and the nation, and advance federal and provincial trade strategies, while considering environmental, social and economic factors. The proposed Project is a significant capital undertaking that will have long-lasting effects for the region, the province, and the nation. It is critical that the Project fully consider and address impacts, both positive and negative, as it advances through the consultation, design, assessment, and approval processes.

The Marine Shipping Addendum to the EIS provides additional information about the potential marine shipping-related impacts associated with the Project and an estimation of cumulative conditions from certain and reasonably foreseeable projects and activities. However, we have identified several gaps in this assessment and therefore request additional information.

SPECIFIC COMMENTS

In addition to those submitted to CEAA on June 11, 2015, Metro Vancouver staff has the following comments: Issue

(if possible, please include reference to the relevant section of the

EIS Guidelines)

Reference to EIS

Requested Completeness Information Rationale

Air quality modelling

approach (Updated EIS

Guidelines, Section 17

Anticipated Level of

Effort – 2nd Paragraph)

Appendix

7.1-A,

Section 7.1

Pg. 7.1-2

The Technical Appendix to Marine Shipping Supplemental Report Air Quality Assessment (Appendix 7.1-A) should include CALPUFF dispersion modelling of marine transportation emissions along the transportation route, either at a number of discrete locations in addition to the RBT2 terminal location, or over the entire route length.

For the Marine Shipping Air Quality Effects Assessment (Section 7.1, Appendix 7.1-A), the proponent has interpreted the EIS Guidance to mean that new air dispersion modelling is not required. Instead, the results of the air dispersion modelling previously performed for the Roberts Bank Terminal 2 port facility are generalized to “generic concentration versus distance curves”, which are applied to the entire marine transportation route.




The proponent has applied a simplified approach employed in Appendix 7.1-A. We reference the more comprehensive dispersion modelling methodology employed in the Marine Transportation Air Quality and Greenhouse Gas Technical Report for the Trans Mountain Expansion (TMX) Project, which was submitted to the National Energy Board in 2013 (https://docs.neb-one.gc.ca/ll-eng/llisapi.dll/Open/2393542), with updates submitted in 2014 (https://docs.neb-one.gc.ca/ll-eng/llisapi.dll/Open/2481886, https://docs.neb-one.gc.ca/ll-eng/llisapi.dll/Open/2578729). The TMX assessment included CALPUFF dispersion modelling of project-related ship emissions for the entire marine transportation route from the Westridge Marine Terminal in Burnaby to the 12 nautical mile limit of the territorial sea. The incremental shipping traffic and emissions associated with the proposed RBT2 project are similar in magnitude to those associated with the TMX project, but the proponent has not provided an adequate explanation of why a less comprehensive effects assessment approach is acceptable.

At a minimum, the RBT2 Marine Shipping Air Quality Effects Assessment should include CALPUFF modelling at a number of discrete locations (in addition to the RBT2 facility location) along the transportation route, supplemented by the “generic concentration versus distance curves” between modelling locations. Ideally, CALPUFF modelling should be performed for the entire marine shipping route. The recent TMX assessment referenced above established this approach as the best practice for such assessments, and demonstrated that it is technically feasible. Given the transboundary / multijurisdictional nature of the air quality impacts associated with RBT2 marine emissions, Metro Vancouver believes that a rigorous air quality modelling assessment is warranted.


https://docs.neb-one.gc.ca/ll-eng/llisapi.dll/Open/2393542







Clarification of Emission Control Area (ECA) emission reduction benefits to air quality (Updated EIS Guidelines, Section 17.1.1 Valued Components)

Appendix 7.1-A, Section 2.0 Pg. 2 - 8

We request the addition of an air quality modelling scenario which clearly illustrates the air quality changes associated with the implementation of ECA requirements, separately from the Project. A recommended approach would be to use the activity level of 2012 with ECA emission factors for SOx, NOx and PM.

The combination of ECA emission reductions with the higher emissions from the Project into one scenario makes it difficult to differentiate the magnitude and direction of potential air quality impacts.

Transboundary emissions from Canadian shipping into the United States (Updated EIS Guidelines, Section 17.1.2 Marine Spatial Boundaries)

7.1.2.1 Temporal and Spatial Boundaries, Pg. 7.1-2

Please provide the air quality boundary conditions for Segment A.

It is unclear as to whether emissions which occur in Canada have been considered.

Vessel size distribution and representativeness

(Updated EIS Guidelines, Section 17.3.2 Existing Human Environment)

Page 4-5

Page 4-5 describes the expected future size distribution of vessels and proposes a “representative” container ship based on estimates that 65% of the container ships will be 8,000-10,000 TEU in size. Please comment on the likelihood of larger container ships and the potential implications on intermediate and valued components that could be expected if container ships >10,000 TEU become the norm.

Assumptions about vessel size will heavily influence the emissions and wakes produced by each vessel.

Compliance with international marine vessel regulations (Updated EIS Guidelines, Section 17.3.2 Existing Human Environment)

N/A Provide statistics on vessel compliance with International maritime organization regulations (e.g., air emissions, ballast and bilge water, etc.).

Compliance statistics will validate assumptions about emissions and effluents incorporated within air and water quality modelling.

Baseline ecosystem population characterization or rationale for species proxies (Updated EIS Guidelines, Section 17.3.1 Existing Marine Environment)

N/A

Provide a characterization of aquatic populations (e.g. marine invertebrates such as crabs and bivalves, fish, marine mammals), migratory and non-migratory birds found in, or migrating through, the study area. Alternatively, provide specific rationale for how the existing conditions (baseline) for representative species within each sub-component are an appropriate

Baseline ecosystem information was not provided in the original EIS, Port Metro Vancouver’s October 26, 2015 response to CEAA, nor the Marine Shipping Addendum.




proxy for each of the species considered within those subcomponents.

Impacts on overall ecosystem health (Updated EIS Guidelines, Section 17.4.1 Effects on Marine Environment)

N/A

Provide an assessment of impacts of the Project and certain and reasonably foreseeable projects/activities on overall ecosystem health. Describe all assumptions and methodology limitations.

The Marine Shipping Addendum provides an assessment of potential impacts on select valued components and sub-components, but does not assess how the overall ecosystem is likely to respond to the possible impacts. In addition, it does not account for the more difficult to study/low occurrence species that may be at risk or of concern.

Consideration of climate change on various intermediate and valued components (Updated EIS Guidelines, Sections 17.4.1, 17.4.2, 17.4.3)

N/A

Provide additional information regarding the potential for climate change to augment the impacts on each intermediate and valued component, including potential accidents and malfunctions.

Climate change impacts (e.g., sea level rise, increased wave height, greater risk of flooding, more frequents extreme weather events and emergencies) may confound the impacts of marine shipping on intermediate and valued components. Now within the mandate of Environment and Climate Change Canada, climate change “may cause changes to the environment that are directly linked or necessarily incidental to federal decisions”.


December 9, 2015

Dear Mr. Moore:

G3 Terminal Vancouver (G3) has submitted a Project Permit Application for the proposed grain terminal at Lynnterm West Gate in the City of North Vancouver at Port Metro Vancouver (PMV).

As part of PMV’s Project and Environmental Review, G3 will be conducting a 20 business day public consultation period beginning January 4, 2016 and closing February 1, 2016. A public Open House will take place on January 9, 2016 at the Holiday Inn & Suites in North Vancouver from 1-5 p.m. We welcome your participation in this process.

The purpose of the application consultation will be to share detailed information about the Project Permit Application and its timelines, and to share the studies and analyses G3 has undertaken. Comments received by Port Metro Vancouver during this phase of engagement will be reviewed and considered as part of PMV’s Project and Environmental Review process.

Our goal is to provide opportunities for all interested parties to ask questions, share comments, or voice concerns about the Project Permit Application. Comments related to the project application should be directed to Port Metro Vancouver, Tim Blair, Senior Planner at (604) 665-9378 or email: [email protected].

Information regarding Port Metro Vancouver’s Project and Environmental Review Process is available at www.portmetrovancouver.com/g3terminal.

For more information about the project, and the results of G3’s preliminary consultation on the proposed project conducted between September 9 and October 7, 2015, please visit www.g3terminalvancouver.ca or feel free to contact me directly.

Yours truly,

Karl Gerrand, G3 CEO

[email protected] P: (204) 272-6606

Cc: Brett Malkoske, Vice President, Business Development G3

6.4



http://www.portmetrovancouver.com/g3terminal

Location of proposed export grain terminal at Lynnterm West Gate in North Vancouver

Site schematic for proposed export grain terminal at LynnTerm West Gate in North Vancouver showing rail loop and silo placement


2

Proposed export grain terminal on LynnTerm West Gate site in North Vancouver

Proposed export grain terminal on LynnTerm West Gate site in North Vancouver


From: Brett Malkoske [mailto:[email protected]] Sent: Wednesday, December 09, 2015 11:28 AM To: Chair Moore Cc: Karl Gerrand; McCallum, Elisha; Blair, Tim Subject: G3 Terminal Vancouver – Public Consultation Period

Dear Mr. Moore,

As you likely already aware, G3 Global Holdings, together with our joint‐venture partner Western Stevedoring are exploring the feasibility of constructing a new port terminal at the Lynnterm West Gate site in North Vancouver. On behalf of our CEO, Karl Gerrand, I am reaching out to you today to let you know that we will begin a 20 business day public consultation period on January 4, 2016. A public Open House will take place on January 9, 2016 at the Holiday Inn & Suites in North Vancouver from 1‐5 p.m.

More detail on how you can participate in this process is included in the letter that you will find attached to this email, and below my signature.

Best wishes over the coming Holiday Season!

Brett Malkoske Vice‐President Business Development p 204 272 6611 c 289 795 6476 [email protected] www.g3.ca

December 9, 2015

Dear Mr. Moore:

G3 Terminal Vancouver (G3) has submitted a Project Permit Application for the proposed grain terminal at Lynnterm West Gate in the City of North Vancouver at Port Metro Vancouver (PMV).

As part of PMV’s Project and Environmental Review, G3 will be conducting a 20 business day public consultation period beginning January 4, 2016 and closing February 1, 2016. A public Open House will take place on January 9, 2016 at the Holiday Inn & Suites in North Vancouver from 1-5 p.m. We welcome your participation in this process.


The purpose of the application consultation will be to share detailed information about the Project Permit Application and its timelines, and to share the studies and analyses G3 has undertaken. Comments received by Port Metro Vancouver during this phase of engagement will be reviewed and considered as part of PMV’s Project and Environmental Review process.

Our goal is to provide opportunities for all interested parties to ask questions, share comments, or voice concerns about the Project Permit Application. Comments related to the project application should be directed to Port Metro Vancouver, Tim Blair, Senior Planner at (604) 665-9378 or email: [email protected].

Information regarding Port Metro Vancouver’s Project and Environmental Review Process is available at www.portmetrovancouver.com/g3terminal.

For more information about the project, and the results of G3’s preliminary consultation on the proposed project conducted between September 9 and October 7, 2015, please visit www.g3terminalvancouver.ca or feel free to contact me directly.

Yours truly,

Karl Gerrand, G3 CEO

[email protected] P: (204) 272-6606

Cc: Brett Malkoske, Vice President, Business Development G3

17257938 Climate Action Committee - Page 192

6.5

..__ 13HITISH

C OLU:. IBI A

December 23, 2015

Emai I: caro I [email protected]

Carol Mason Commissioner/CAO Metro Vancouver Regional District

Dear Carol Mason:

The Province, led by the Ministry of Forests, Lands and Natural Resource Operations (FLNR), is developing Implementation Plans for two priority species at risk on the coast of British Columbia: Northern Goshawks, laingi sub-species (NOGO) and Marbled Murrelets (MAMU). These Implementation Plans will represent a provincial government commitment that prioritizes management actions that are informed by science and also consider socioeconomic factors.

The intent of the Implementation Plans are to meet the Province's commitment for these species at risk under the Accord.for the Protection of Species at Risk in Canada, and the Canada - British Columbia Agreement on Species at Risk. Implementation Plans are developed when existing management and protection does not meet species at risk recovery objectives and where meeting those recovery objectives may have significant socio-economic implications. Please refer to the attached information packages for more information regarding the development of Implementation Plans for NOGO and MAMU.

A portion of the proposed NOGO and MAMU conservation regions, where further management actions may occur, is located within your Regional District. Please see the maps in the information packages. As such, the Province would like to provide the opportunity for local governments within your Regional District to provide input into the proposed management approaches. The results of this engagement will play an important role in the development of the Implementation Plans.

As an efficient means to distribute this information to local governments we respectfully request you to distribute to the local governments within your Regional District as soon as possible. If this is not possible, please let us know so we can make alternate arrangements. Between January and February, 2016, engagement sessions will be held at several provincial government offices across coastal British Columbia (see Table I for locations and dates).

Ministry of Forests, Lands & West Coast Rebtion Natural Resource Operations Resource Sttwardship

Mailing ddn:ss: 2000 Labieux Road Nanaimo HC V9T 6J9

Page lof 2

Telephone: 250 751-3100 l~csimilc: 250 751 -3103


17310505

Metro Vancouver Regional District

The Province will also be seeking input from First Nations, environmental organizations and the forest sector to provide an oppo1tunity to discuss the details and implications of the proposed management approaches and provide a forum for asking questions and providing input.

Engagement sessions will include: • Information on the proposed provincial management approach including:

• proposed population and distribution objectives; • other proposed management actions; and • supporting rationales.

• Background information on NOGO and MAMU; • A summary of the species recovery planning to date; • Information on existing management and protection; and • Useful links providing additional information.

Input received from the engagement sessions will inform recommendations for the Implementation Plans to be presented to Senior Government in May, 2016. It is expected that the plans will be finalized prior to the end of 2016. Once the Implementation Plans are finalized, statutory decisions will need to be made as a result of these plans. These decisions are expected to be made in 2017, and will be subject to formal consultation as directed by existing legislation and agreements.

If you are interested in attending one of the scheduled engagement sessions please register by the registration dates in Table 1 by contacting Laura Body at [email protected] or (250) 751-7102. This will help us ensure our facilities are adequate for these sessions.

If the scheduled information sessions are not convenient for you to attend, please contact Darryn McConkey, Ecosystem Biologist, at Darryn.McConkeytalgov .be.ca or (250) 751-3104 to provide input, request additional information or ask questions about the proposed management approaches.

Your input is very important to this process. To ensure your input is available to inform management of these species in British Columbia, please provide written feedback by March 31, 2016.

Yours truly,

Steve Gordon, MSc., RPBio. Manager, Biodiversity & Old Growth Resource Management Objectives Branch

Attachment(s): Engagement Sessions Schedule NOGO and MAMU Information Packages

Page 2of2


Date Time City Address Registration Deadline

12-Jan-16 10am -12pm Terrace

Coast Mountains Natural Resource District, #200 - 5220 Keith Avenue, Terrace, BC, V8G 1L1, Phone: (250) 638-5100 4-Jan-16

14-Jan-16 9:00am - 11:00am Victoria

Pacific Forestry Centre, 506 West Burnside Road Victoria, BC, Canada, V8Z 1M5Phone: (250) 363-0600 7-Jan-16

20-Jan-16 1pm - 3pm Squamish

Sea to Sky Natural Resource District, Suite 101-42000Loggers Lane, Squamish BC V8B 0H3, Phone: 604 898-2100

13-Jan-16

25-Jan-16 1pm - 3pm Nanaimo

Arrowsmith Room, Ministry of Forests, Lands andNatural Resource Operations, 2080A Labieux Rd, Nanaimo, BC, V9T 6J9 18-Jan-16

28-Jan-16 9am - 11am Queen Charlotte City

Haida Gwaii Natural Resource District, 1229 Oceanview Drive, Queen Charlotte City, BC, V0T 1S0

21-Jan-16

10-Feb-16 1pm - 3pm Powell River

Sunshine Coast Natural Resource District, 7077 Duncan Street, Powell River, BC, V8A 1W1, Phone: (604) 485-0700 3-Feb-16

18-Feb-16 9-11 am Bella CoolaMinistry of Forests, Lands and Natural Resource Operations, 1681 Airport Road, Bella Coola 17-Feb-16

18-Feb-16 1pm - 3pm Surrey

Ministry of Forests, Lands and Natural ResourceOperations, Suite 200, 10428 - 153 St, Surrey, BC, V3R 1E1, Phone: (604) 586-4400 11-Feb-16

22-Feb-16 1pm - 3pm Campbell River

Campbell River Natural Resource District, 370 South Dogwood Street, Campbell River, BC, V9W 6Y7, Phone: (250) 286-9300 15-Feb-16

Northern Goshawk and Marbled Murrelets Implementation Plan Engagement Session Dates

6.5 Attachments


24-Feb-16 1pm - 3pm Port McNeill

North Island - Central Coast Natural Resource District, 2217 Mine Road, Port McNeill, BC, V0N2R0, Phone: (250) 956-5000 North Island - Central Coast District Mailing Address: Box 7000 Port McNeill V0N2R0 Physical Address: 2217 Mine Road Port McNeill 17-Feb-16


Ministry of

Forests, Lands and

Natural Resource

Operations

Developing the British Columbia Implementation Plan for Coastal Northern Goshawks (Accipiter gentilis laingi)

[1]

Background Northern Goshawks, laingi sub-species (NOGO) are raven-sized

raptors (birds of prey) that live in mature and old-growth forests in coastal B.C., including on Vancouver Island, Haida Gwaii and the mainland coast (Figure 1).

A NOGO home range consists of a breeding area where they nest and rear young and a larger surrounding foraging area where they hunt for prey (Figure 2).

NOGO are a species at risk and are listed as Threatened under the federal Species at Risk Act (SARA) (COSEWIC 2013), and are provincially Red listed. Their at-risk status is due mainly to their small population size and the loss and fragmentation of their nesting and foraging habitat.

Figure 1. Conservation Region and Range map for Northern Goshawk, Accipiter gentilis laingi (Northern Goshawk Accipiter

gentilis laingi Recovery Strategy 2008)

Photo credit: Erica McClaren


Ministry of

Forests, Lands and

Natural Resource

Operations


[2]

Figure 2. Conceptual diagram (not to scale) of coastal goshawk home range, including alternate nest sites, nest area, post-fledgling area (PFA), breeding area, breeding home range and non-breeding/annual home range (McClaren et al. 2015) Recovery Planning The provincial NOGO recovery strategy was posted in 2008 and the Management Plan was posted in 2013. Several drafts of the federal NOGO recovery strategy have been released, but a final version has not yet been posted to

the SARA public registry. The federal recovery strategy sets an overall population objective to maintain 444 NOGO home ranges across British

Columbia and sets home range targets for the four Conservation Regions (see Table 1). The federal strategy identifies Critical Habitat for breeding and foraging habitat for 108 known home ranges without

consideration of socio-economic implications, and implies additional Critical Habitat will be identified as new home ranges are discovered.

Federal Critical Habitat for breeding areas is described as an approximately 200 hectare reserve, which includes all known nests at least 252 m away from (potential) edges.

Federal Critical Habitat for foraging habitat is described as maintaining between 45% and 61% suitable foraging habitat within a home range (depending on the Conservation Region).

Under SARA, the federal government expects the province to demonstrate effective protection of NOGO Critical Habitat.


Ministry of

Forests, Lands and

Natural Resource

Operations


[3]

Existing Protection There are currently an estimated 680 - 780 potential Northern goshawk laingi subspecies home ranges in B.C. Although not all specific nesting locations are known, existing protection for NOGO in British Columbia (Figure 3) was

determined by estimating the number of home ranges that are likely to be protected under the following circumstances: 1) in existing Parks and Protected Areas and other conservation designations and, 2) when existing land use planning is fully implemented (e.g. Landscape Reserves in the Great Bear Rainforest).

A NOGO territory model developed by the provincial Northern Goshawk Recovery Team that projects theoretical home ranges consisting of both breeding and foraging habitat was overlaid with protected areas to estimate existing protection.

Figure 3. Estimated existing protection of modelled NOGO home ranges in B.C. and additional protection required to meet

proposed provincial home range targets.


Ministry of

Forests, Lands and

Natural Resource

Operations


[4]

Proposed Provincial Management Approach The goals of the provincial management approach are to:

o Maximize conservation benefit and likelihood of meeting recovery objectives; o Minimize socio-economic impacts; and o Maximize the likelihood of meeting SARA expectations

Population and Distribution Objectives Table 1 shows the proposed provincial population and distribution objective for NOGO in British Columbia. With the exception of Haida Gwaii, the province is proposing to establish B.C. population and distribution targets that

are largely consistent with the federal targets. In Haida Gwaii, the province considers the federal target of 58 home ranges to be unrealistic as it exceeds the

estimated current number of 19 home ranges in the Conservation Region. Table 1. Proposed federal and proposed B.C. population and distribution objectives for NOGO home ranges (the proposed B.C. population objective is shown in parentheses where it differs from the federal approach)

Vancouver Island South Coast North Coast Haida Gwaii Total home ranges in

British Columbia

184 122 80 58 (25) 444 (411)

Breeding Area Management The proposed B.C. management approach for breeding areas is to, by 2020, protect 95 new NOGO breeding areas

around occupied nests: 30 new breeding area Wildlife Habitat Areas in each of the North Coast, South Coast and Vancouver Island

Conservation Regions, and 5 new breeding area reserves in Haida Gwaii (95 total). The proposed management approach for breeding areas is similar to the current provincial design standards for

establishing NOGO wildlife habitat areas under the Identified Wildlife Management Strategy (McClaren E.L. 2004). Currently in Haida Gwaii, all newly discovered NOGO nests on Crown land receive a 200 ha breeding area reserve under

the Haida Gwaii Land Use Objectives Order. Longer-term, options will be assessed regarding implementation of measures to achieve the proposed population and

distribution objectives outlined in Table 1. Foraging Habitat Management The science to support foraging habitat management requires further investigation. NOGO home range size and foraging habitat requirements vary across the species range. Foraging habitat management requires maintaining a proportion of a home range in a suitable foraging condition to

support NOGO prey species in order to provide adequate hunting opportunities to sustain local populations. Managing NOGO foraging habitat may have significant socio-economic implications. The proposed provincial approach is to facilitate additional research on NOGO foraging habitat requirements and, by

2020, develop provincial foraging habitat management recommendations.


Ministry of

Forests, Lands and

Natural Resource

Operations


[5]

Additional Proposed Actions in 2016

Develop research partnerships to investigate the genetic basis of NOGO sub-species designations and their range. Engage with private land holders to encourage shared stewardship of Northern Goshawks on non-Crown land,

particularly in the Vancouver Island Conservation Region. Key work required to develop the Implementation Plan The proposed population objective and home range targets are less than the estimated number of home ranges that

currently exist (approximately 730 home ranges coast wide). A key aspect of the Implementation Plan will be to determine which home ranges are protected.

References and information links COSEWIC. 2013. COSEWIC assessment and status report on the Northern Goshawk Accipiter gentilis laingi in Canada. Committee on

the Status of Endangered Wildlife in Canada. Ottawa. x + 56 pp. http://www.sararegistry.gc.ca/default.asp?lang=En&n=99FC419D-1 Haida Gwaii Land Use Objectives Order. 2010. https://www.for.gov.bc.ca/tasb/slrp/pdf/lrmp/haidaGwaii/ Ministry of Forests, Lands, and Natural Resource Operations and Ministry of Environment. 2013.

Management plan for the Northern Goshawk, laingi subspecies (Accipiter gentilis laingi) in British Columbia. B.C. Ministry of Forests, Lands, and Natural Resource Operations and B.C. Ministry of Environment, Victoria, BC. 30 pp. http://www.env.gov.bc.ca/wld/recoveryplans/recovery_doc_table.html

McClaren E.L. 2004. Queen Charlotte Goshawk Accipiter gentilis laingi. In: Accounts and Measures for Managing Identified Wildlife – Version 2004. B.C. Ministry of Water, Land and Air Protection, Victoria, B.C. http://www.env.gov.bc.ca/wld/frpa/iwms/documents/Birds/b_queencharlottegoshawk.pdf

McClaren, E.L., T. Mahon, F.I. Doyle, and W.L. Harrower. 2015. Science-Based Guidelines for Managing Northern Goshawk Breeding Areas in Coastal British Columbia. Journal of Ecosystems and Management 15(2):1–91. Published by the Journal of Ecosystems and Management: http://jem-online.org/index.php/jem/article/viewFile/576/506

Northern Goshawk Accipiter gentilis laingi Recovery Team. 2008. Recovery strategy for the Northern Goshawk, laingi subspecies (Accipiter gentilis laingi) in British Columbia. Prepared for the B.C. Ministry of Environment, Victoria, BC. 56 pp.http://www.env.gov.bc.ca/wld/recoveryplans/recovery_doc_table.html


http://www.sararegistry.gc.ca/default.asp?lang=En&n=99FC419D-1

https://www.for.gov.bc.ca/tasb/slrp/pdf/lrmp/haidaGwaii/

http://www.env.gov.bc.ca/wld/recoveryplans/recovery_doc_table.html

http://www.env.gov.bc.ca/wld/frpa/iwms/documents/Birds/b_queencharlottegoshawk.pdf

http://jem-online.org/index.php/jem/article/viewFile/576/506

http://www.env.gov.bc.ca/wld/recoveryplans/recovery_doc_table.html

Ministry of

Forests, Lands and

Natural Resource

Operations

Developing the British Columbia Implementation Plan for Marbled Murrelets (Brachyramphus marmoratus)

[1]

Background Marbled Murrelets (Brachyramphus marmoratus) are small seabirds that typically nest in old-growth forests within

30km of the coast including on Vancouver Island, Haida Gwaii, and the mainland coast of B.C. (see figure 1). Marbled Murrelets (MAMU) are a species at risk listed as Threatened under the federal Species at Risk Act (SARA)

(COSEWIC 2012) and are provincially Blue listed. Their at-risk status is due mainly to the loss and fragmentation of their old-growth nesting habitat and due to threats in the marine habitats where they feed (e.g. oil spills, fisheries by-catch).

Figure 1. Marbled Murrelet Conservation Regions in British Columbia


Ministry of

Forests, Lands and

Natural Resource

Operations


[2]

Recovery Planning In 2002, the Canadian Marbled Murrelet Recovery Team

(CMMRT) released a conservation assessment of MAMU in B.C. (Burger A.E. 2002)

In 2003, the CMMRT released a scientific advisory document regarding conservation and management of MAMU in B.C. (CMMRT 2003).

Environment Canada posted a draft recovery strategy for MAMU in Canada on January 7, 2014 and a revised strategy on June 3, 2014. It is anticipated that the federal recovery strategy will be amended in the future.

The federal recovery strategy sets a short term overall population objective that requires retention of MAMU nesting habitat at 70% or greater of 2002 levels coast-wide, and a long term objective to stabilize MAMU nesting habitat at 70% or greater of 2002 levels.

The federal recovery strategy identifies potential terrestrial Critical Habitat that is described by biophysical attributes related to nesting habitat and is to be retained as minimum amounts within six Conservation Regions1. It is recognized these amounts are likely to change as better habitat mapping and other information becomes available.

Critical Habitat is identified in federal recovery strategies without consideration of socio-economic implications. Under SARA, the federal government expects the province to demonstrate effective protection of MAMU Critical

Habitat. Existing Protection Through various types of conservation designations (e.g., Parks and Protected Areas, Land Act Reserves, legal Old

Growth Management Areas (OGMAs), Wildlife Habitat Areas and Ungulate Winter Ranges) B.C. has considerable protection of MAMU habitat already in place.

Additional MAMU habitat will be maintained in B.C. when existing land use planning is fully implemented (e.g. Landscape Reserves in the Great Bear Rainforest and OGMA planning on the coast) and boundaries of reserves are legalized. The contribution of these future designations to MAMU habitat conservation is included in the existing protection in Figure 2.

Figure 2 shows in six Conservation Regions: the amount (area in Hectares) of protected MAMU habitat in B.C.; the amount of MAMU habitat on Crown land that does not contribute to timber harvesting; the amount of MAMU habitat on Crown land that is part of the Timber Harvesting Land Base (THLB); and the federal minimum habitat threshold 1) applied to all lands and 2) applied to Crown land only.

Figure 2 also shows the remaining THLB that is not considered suitable MAMU habitat in the six Conservation Regions. MAMU habitat in Figure 2 is represented by several methods of habitat mapping ranging from what is considered to be

most accurate to least accurate: low-level aerial survey, air photo interpretation, CMMRT model and baseline thematic mapping.

In most Conservation Regions, B.C. meets or comes close to meeting the federal minimum habitat threshold applied to provincial Crown land only through existing protection and MAMU habitat on Crown land that is not part of the Timber Harvesting Land Base (THLB).

1 A habitat suitability model for the Alaska Border Conservation Region has been developed and it is anticipated that recovery objectives will be set for this Conservation Region.

Photo credit: Jenna Cragg


Ministry of

Forests, Lands and

Natural Resource

Operations


[3]

It is estimated that an additional 210,000 hectares of MAMU habitat would have to be protected in order to achieve the federal minimum habitat thresholds applied to provincial Crown land only.

Proposed Provincial Management Approach The goals of the provincial management approach are to:

o Maximize conservation benefit and the likelihood of meeting recovery objectives; o Minimize socio-economic impacts; and o Maximize the likelihood of achieving general expectations under SARA

The proposed provincial management approach for MAMU is to:

o Engage with First Nations and stakeholders on the development of a habitat management approach for MAMU that meets the expectations of the federal recovery strategy for provincial Crown land.

o Complete existing land use planning, including implementing legal landscape reserves in the Great Bear Rainforest and legalization of Old Growth Management Areas and priority Wildlife Habitat Areas on the coast.

o By 2017, issue a Land Use Objectives Regulation Order under the provincial Land Act to protect specified amounts of MAMU habitat in a suitable condition for Crown land for the six Conservation Regions (see Table 1).

o Employ both spatial and aspatial2 management approaches.

Population and Distribution Objectives Minimum habitat thresholds for each Conservation Region have been calculated using the methodology in the federal

recovery strategy and applied proportionately to all lands and to provincial Crown land only (Table 1). Table 1 shows the federal minimum habitat thresholds for MAMU on all lands and applied only to Crown land. These

amounts are likely to change as better habitat mapping and other information becomes available. The difference between the threshold for all land and for crown land only is due to MAMU habitat on non-crown land

(First Nations treaty lands, other government lands and private lands). In the East Vancouver Island Conservation Region, the province considers the minimum habitat threshold to be

unachievable in the short term due to habitat loss. Table 1. Federal minimum habitat thresholds (% of 2002 levels and hectares) for MAMU among six provincial Conservation Regions for all lands and applied to provincial Crown land only.

Northern Mainland

Coast

(68%)

Haida Gwaii

(68%)

Central Mainland

Coast

(68%)

South Coast

(85%)

North & West

Vancouver

Island

(68%)

East

Vancouver

Island

(90%)

Total Area

(70%)

All Lands 292,822 153,631 221,500 103,602 184,416 77,728 1,033,700

Crown Land 265,872 151,565 220,984 99,152 179,265 38,013 954,851

2 Aspatial habitat management (i.e. targets that are not explicitly mapped) provides increased management flexibility while spatial habitat management (i.e. mapped legal reserves) provides more certainty for conservation by addressing issues of habitat fragmentation, edge effects, patch size and distribution.


Ministry of

Forests, Lands and

Natural Resource

Operations


[4]

Figure 2. Hectares of Marbled Murrelet habitat in six Conservation Regions: 1) protected under existing management (blue); 2) on Crown land that doesn’t contribute to timber harvesting (green); 3) on Crown land that is part of the Timber Harvesting Land Base (THLB) (grey); remaining THLB that is not MAMU habitat (orange); the federal minimum habitat thresholds for all lands (red dot) and the federal minimum habitat thresholds applied to Crown land only (yellow dot).

Additional Proposed Actions in 2016 Improve habitat mapping in areas where MAMU habitat is characterized using the CMMRT model or baseline thematic

mapping. This will affect total habitat amounts, the location of habitat and regional minimum habitat thresholds. Conduct inventories to confirm MAMU nesting in the Interior Cedar Hemlock (ICH) biogeoclimatic zone in the Northern

Mainland Coast Conservation Region. Engage with private land holders to encourage shared stewardship of Marbled Murrelet habitat on non-Crown land,

particularly in the East Vancouver Island Conservation Region.


Ministry of

Forests, Lands and

Natural Resource

Operations


[5]

Key work required to develop the Implementation Plan

Collate results of First Nations and stakeholder engagement sessions to inform the provincial management approaches. Clarify to what extent, and at what scale, mapped spatial reserves will be defined in the Implementation Plan. Determine how to manage and track habitat targets that apply across large areas (such as a resource district or

Conservation Region). Clarify how recruitment of MAMU habitat will contribute to meeting long-term recovery objectives, especially in the

East Vancouver Island Conservation Region.

References and links to information

Burger, A. E. 2002. Conservation assessment of Marbled Murrelets in British Columbia: a review of the biology,populations, habitat associations, and conservation.http://www.sfu.ca/biology/wildberg/bertram/mamurt/PartA.pdf

Canadian Marbled Murrelet Recovery Team. 2003. Marbled Murrelet Conservation Assessment 2003, Part B:Marbled Murrelet Recovery Team Advisory Document on Conservation and Management. Canadian MarbledMurrelet Recovery Team Working Document No. 1.http://www.sfu.ca/biology/wildberg/bertram/mamurt/PartB.pdf

COSEWIC. 2012. COSEWIC assessment and status report on the Marbled Murrelet Brachyramphus marmoratus inCanada. Committee on the Status of Endangered Wildlife in Canada. Ottawa. xii + 82 pp.http://publications.gc.ca/collections/collection_2013/ec/CW69-14-238-2012-eng.pdf

Environment Canada. 2014. Recovery Strategy for the Marbled Murrelet (Brachyramphus marmoratus) in Canada.Species at Risk Act Recovery Strategy Series. Environment Canada, Ottawa. v + 49 pp.http://www.registrelep-sararegistry.gc.ca/document/default_e.cfm?documentID=1290

17316421 Climate Action Committee - Page 206

http://www.sfu.ca/biology/wildberg/bertram/mamurt/PartA.pdf

http://www.sfu.ca/biology/wildberg/bertram/mamurt/PartB.pdf

http://publications.gc.ca/collections/collection_2013/ec/CW69-14-238-2012-eng.pdf

http://www.registrelep-sararegistry.gc.ca/document/default_e.cfm?documentID=1290

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