Increase the Exemption threshold for Low Risk Micro Systems to 1 MW. Additionally, require these installations to include a declaration or attestation by a Licensed Engineering Practitioner (LEP) to be kept onsite, confirming that compliance of the Ministry’s NPC-300 noise limits is met as demonstrated by noise propagation modelling.

Regarding the requirements that micro-systems be California Air Resources Board (CARB) certified in order to qualify for an exemption, we understand that only CHP systems that are to be installed in California can legally be called “CARB-certified”. In order to still reference the CARB certification for systems to be installed in Ontario, we recommend the Ministry instead use language to say that to qualify for the exemption systems must be “CARB equivalent” or something similar.

We recommend that if a CHP that would qualify for an exemption at a stand-alone facility was to be installed at a small hospital or other such facility with an existing Environmental Compliance Approval (ECA), that a formal amendment to their existing approval not be necessary and instead a note to file in their ECA be sufficient.

We understand that the Ministry intends to update the Environmental Activity and Sector Registry (EASR) Publication to include Lower-Risk Small CHP Systems and that the testing requirements included in the updated Guideline A-5 will be incorporated into the EASR Publication. We recommend removing the requirement for a 2-year performance assessment when elements of Guideline A-5 will be applied in the EASR Publication. Instead, we recommend that a performance test is required to be conducted whenever major servicing of the CHP system is required, typically 5 to 10 years after installation.