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Feedback Form: Proposed Amendments to Air Quality Permit and Regulatory Fees in Metro Vancouver

Metro Vancouver seeks your feedback on proposed amendments to its air quality permit and regulatory fees to:

  • achieve health and environmental benefits associated with the reduction of harmful emissions and improved air quality,
  • ensure fees promote continuous improvement, and
  • recover the costs of monitoring and enforcement while maintaining Metro Vancouver’s commitment to discharger-pay, equity, and fairness principles.

We would appreciate your feedback by April 30, 2021.

Background information, the proposal summary, and details on other engagement opportunities to provide feedback are available here.

If you represent a permitted or regulated facility in Metro Vancouver and would like to receive an estimate of proposed fees for your facility, please contact Metro Vancouver at AQBylaw@metrovancouver.org to request an estimate.

This feedback form should take 15-20 minutes to complete. Your time and input are valued.

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Funding Approach for Fees

Proposed fees for air emissions are based on the amount and potential health impact of the air contaminants emitted, and intended to achieve health and environmental benefits through reduction of harmful emissions and improved air quality. These fees are also intended to recover the cost of reviewing applications and developing requirements for new permits and approvals or amendments, as well as ongoing compliance assessment and enforcement costs.

1. Do you represent a facility that currently pays emission fees to Metro Vancouver (i.e., for an air emissions permit or emission regulation)?

2. Do you agree that funding for the Metro Vancouver air quality regulatory program should come mostly from emitters, rather than from tax payers in the region through property taxes?

Please provide any comments (optional).

3. Do you agree with scaling fee rates for emitters based on the amount and harmfulness of the air contaminant?

Please provide any comments (optional).

Proposed Fees for Air Contaminants

Of the air contaminants emitted by businesses, fine particulate matter (PM2.5), nitrogen oxides (NOx), sulphur oxides (SOx) and photoreactive volatile organic compounds (VOC) collectively represent the greatest air quality health burden to Metro Vancouver’s residents. Increased fees are proposed for these air contaminants, to better reflect the health impacts and encourage emission reductions.

4. Do you agree with increased fees for the air contaminants PM2.5, NOx, SOx and VOC?

What changes to the proposal would increase your level of support? (Optional)

Metro Vancouver currently charges fees for a range of other air contaminants, including coarse particulate matter, non-photoreactive volatile organic compounds, hazardous air pollutants, diesel particulate matter, greenhouse gases such as methane, and a broad category of “other” air contaminants. Emission fees haven’t changed since 2008.

All businesses that discharge air contaminants in Metro Vancouver are required to comply with a Metro Vancouver permit, regulation or approval. Metro Vancouver expends substantial resources in developing and promoting compliance with permits and regulations but air quality permit and regulatory fees have not substantially changed since 2008. However, since that time the costs of regulatory services have dramatically increased, in part due to the increasing volume of complaints. As a result, taxpayers have been funding the difference between the cost of delivering air quality services and fees charged for emissions. To better protect human and environmental health, an increase in fees for these air contaminants is proposed.

5. Do you agree with an increase in fees for air contaminants?

What changes could be made to the proposal to increase your level of support? (Optional)

6. If you represent a business that emits authorized air contaminants, do you agree that the proposed increases in fees would encourage your business to reduce its emissions?

What changes could be made to the proposal to increase your level of support? (Optional)

Proposed Fees for Odorous Air Contaminants

Odorous air contaminants are responsible for the majority (more than 80%) of complaints, which comes at considerable cost to taxpayers as fees are not currently charged for odorous air contaminants. A new emission fee is proposed for odorous air contaminants, based upon either permitted or measured emissions.

7. Do you currently measure odorous air contaminants from your facility?

8. Do you agree with creating a new emission fee for odorous air contaminants?

What changes could be made to the proposal to increase your level of support? (Optional)

Timeline for Proposed Changes to Fees

Due to the magnitude of the proposed fee increases for some air contaminants, some changes are proposed to occur in two steps, one in 2022 and the second in 2025.

9. Do you agree with the phased rollout of the fee changes?

Do you have any comments about the timing of the proposed fee changes that have been scheduled for 2022 or 2025? (Optional)

Proposed Changes to Application Fees

Application fees for new permits and amendments include a $200 base fee and a variable fee, and have not changed since 2008. The base fee is for minor administration costs, while the variable fee is based on the type and amount of requested emissions, and reflects the level of complexity of the review of potential health and environmental effects of requested emissions. It is proposed to increase the base fee for most applications to better reflect the actual administrative cost.

The variable portion of the fee is currently capped at $50,000. Metro Vancouver’s costs to review and process applications far exceed the current cap, due to increased public concerns around permitted emissions, associated information requests and technical studies, and appeals related to some permits. The current system also unfairly favours larger emitters as review costs for those emitters are more likely to exceed the $50,000 cap, and they therefore pay less per tonne of emissions for their applications to be processed.

10. Do you agree with increasing the $200 base fee for permit applications, to better reflect the actual administrative cost?

What changes could be made to the proposal to increase your level of support? (Optional)

11. Do you agree with removal of a $50,000 cap on variable emission fees, for applications for new permits or amendments, to better recover costs associated with reviewing these applications?

What changes could be made to the proposal to increase your level of support? (Optional)

Proposed Discontinuation of Measured Discharge Program

The Measured Discharge Program is proposed to be discontinued. The program was created to allow permitted dischargers in compliance with permit and bylaw requirements to pay less in fees when it could be demonstrated that measured emissions were less than permitted levels. Analysis of permit emissions data has shown that measured emissions from permitted facilities are typically about 25% of the authorized emissions, regardless of whether a facility participated in the Measured Discharge Program. The system also unfairly favours larger dischargers because they are more likely to have expensive continuous emission monitoring equipment needed to demonstrate eligibility for the program. Thus, larger corporations have been paying less per tonne of emissions than smaller dischargers.

12. Do you agree with discontinuing the Measured Discharge Program?

What changes could be made to the proposal to increase your level of support? (Optional)

Additional Information

13. Choose which best describes you:

If "other", pleasy specify:

14. If you represent a business that currently pays emissions fees, or will likely pay emissions fees in the future, which air contaminants is your business emitting? Check all that apply.

15. If you wish to provide your name, contact information, permit number, or emission regulation, please provide that information here:

Name

Organization

Email (if we have clarifying questions about your comments):

Permit number (if applicable)

Emission regulation (if applicable)