Regulatory Changes are coming...

Regulatory Changes are coming

​Proposed Environmental Activity and Sector Registry (EASR) Requirements for Plant and Production Processes with Air and Noise Emissions
With a new commitment to reduce review time of Environmental Compliance Approval (ECA) applications, the Ministry of Environment and Climate Change (MOECC) is moving towards using the EASR, an online self-registration system, for approvals of new ECAs and amendments to existing ECAs. The EASR will replace the requirement to submit ECA applications to the MOECC for review and will apply to prescribed manufacturing sectors.

Who will this affect?
The EASR for air and noise emissions will apply to all plants and production processes except high risk/more complex activities.

Does your facility meet the eligibility criteria?
In order to be eligible for this EASR, your facility’s primary NAICS code must NOT be identified as one of the NAICS codes set out in the Schedule of the proposed EASR Regulation.
 
The following activities are NOT eligible for EASR registration:
1.  Any one (1) of the following activities:

• Land disposal of waste;
• Processing of waste via thermal treatment;
• Using wood-fired combustors over 3 MW;
• Plating processes using nickel, chromium, or cyanide;
• Processing metal outdoors, excluding maintenance activities;
• The operation of an alternative low-carbon fuel facility;
• The operation of an end-of-life vehicle waste disposal site; or
• The operation of a stationary combustion turbine that uses fuel derived by gasification/liquefaction of coal 

2.  If a site-specific standard has been requested/issued OR registered for an industry/equipment standard.
3.  Two or more adjacent properties where the boundary of one property touches the boundary of the other that are to be considered as       a single property.
4.  Mobile activities.

What are the operational requirements to register under EASR?
In order to be eligible for this EASR, assessments of air, noise and/or odour emissions from the facility must be reviewed and completed. Operating procedures and maintenance programs for all sources and contaminants must be prepared and implemented as per the proposed EASR regulation. Documentation, including records must be readily available for inspection at the facility.

Will an ESDM Report or Acoustic Assessment Report still be required?
Yes. An ESDM report and/or acoustic assessment report will be required with necessary supporting documentation (i.e. odour screening form, Best Management Practices Plan (BMPP), if applicable) as per regulations and guidelines prior to registration. A BMPP for fugitive dust control will be required if sources of fugitive dust are identified in the ESDM report. The assessments summarized in these reports must be updated once every ten years or to the latest update if modifications are made.

When does the new EASR Regulation come into effect?
A draft of the regulation is currently under review on the Environmental Bill of Rights (click here). The proposed date to put the EASR for plant and production processes in force is January 31, 2017.

Eligible facilities will be given ten years to transition to the EASR. If your facility is currently operating with an ECA and meets the eligibility criteria for the new EASR, the ECA will no longer apply as of January 31, 2027. If you make any modifications, you will be required to register on the EASR prior to this date.

What if an ECA application is already submitted for review?
The MOECC is proposing that applications received on or before December 31, 2016 will have the option to remain in the ECA process or be withdrawn to allow for registration on EASR.

What are the MOECC fees to register on EASR?
The EASR fee for plant and production processes is proposed to be $2,353 with no annual increase.

Find out if your facility is eligible for the EASR registration. For more information contact Connie at Envirolum Consulting Inc. 

Contact Info:
Connie Lum
connie@envirolum.com 


NOTE: Information provided in this fact sheet is subject to change pending on final decisions of the EASR Regulation which is currently in draft and under review by the MOECC.