Environmental Compliance Approvals
Do you own or operate a facility? Whether Industrial, Commercial, or Institutional, chances are you will need a regulatory approval prior to construction, building modifications, adding new equipment, or process changes.
Formerly known as a Certificate of Approval (CofAs), approvals now come in two forms: Environmental Compliance Approval (ECAs) and Environmental Activity Sector Registry (EASR). Depending on the type of operations at your facility you may need one or both.
In 2011, the Ministry of Environment (now the Ministry of Environment & Climate Change) amended the Environmental Protection Act (EPA) and Ontario Water Resources Act (OWRA), in what was called the ‘Modernization of Approvals’. The MOECC established a two-path process for environmental compliance. Depending on the nature of operations, businesses have two compliance pathways available to them: EASR, or an ECA.
Environmental Compliance Approval (ECA)
The Environmental Compliance Approval (ECA) process is similar to the former Certificate of Approval (CofA), which has been phased out. In fact, any Certificate of Approval that is currently still valid will have been converted into an Environmental Compliance Approval in the eyes of the MOE.
Who needs an Environmental Compliance Approval?
Essentially, every business/facility that creates a discharge to the natural environment requires an Environmental Compliance Approval. The Ontario Environmental Protection Act stipulates that:
No person shall, except under and in accordance with an environmental compliance approval:
- use, operate, construct, alter, extend or replace any plant, structure, equipment, apparatus, mechanism or thing that may discharge or from which may be discharged a contaminant into any part of the natural environment other than water; or
- alter a process or rate of production with the result that a contaminant may be discharged into any part of the natural environment other than water or the rate or manner of discharge of a contaminant into any part of the natural environment other than water may be altered
Simply put: if you generate a release to air, your facility will likely require an Environmental Compliance Approval.
The ECA Process
In order to obtain an Environmental Compliance Approval from the MOECC, a complete application needs to be submitted, which includes:
- Environmental Compliance Approval Application Form
- Emission Summary and Dispersion Modelling Report (ESDM)
- Noise Screening or Acoustic Assessment Report (AAR)
- Payment of MOECC fees
The MOECC maintains a 46-page form that must be completed with every application. It includes various administrative information about the facility, contact information, and a description of the nature of the operations.
The Emission Summary and Dispersion Modelling report is the bulk of the application. It details the emissions inventory of the facility which breaks down all substances & chemicals released onsite, and the processes or operations which release them. Its objective is to show the impact of these contaminants off-property. In order to facilitate this, a model of the facility must be created which shows the location (typically stack location) of the discharge points, and the conditions under which the contaminants are released (discharge velocity, temperature, etc.). Once the emission rates and locations have been specified, an atmospheric chemistry dispersion model must be run. The modeling uses local meteorological data to predict the impact of emissions from the facility at the property line.
In O. Reg 419/05, the MOECC has specified air quality limits for most common contaminants discharged. In cases where no standards, or guideline values exist, a request for toxicology review must be included with the Environmental Compliance Approval application. The MOECC will assess the predicted off-property impact and determine if it possesses any health risks prior to granting Environmental Compliance Approval.
Environmental Compliance Approval applications also require completion of the noise screening form, or a completed Acoustic Assessment Report. Environmental noise in Ontario is regulated by NPC-300, which stipulates allowable off-property noise impacts. The regulation defines “sensitive receptors” such as houses, schools, daycares, churches, hospitals, hotel/motel, etc.; essentially, areas where people will be occupying/congregating for extended periods of time to enjoy the space.
If there are no sensitive receptors close to your facility, then typically completion of the screening form is sufficient. However, depending on the nature of operations at your facility, if there is a sensitive receptor located nearby (typically 300-1000m), then a complete Acoustic Assessment Report (AAR) is required. AAR’s require that any noise generated be modelled for its impact at the nearby sensitive receptor. The results of the noise modeling are compared against NPC-300 guidelines which establish criteria for day, evening, and nighttime hours that must be met.
Lastly, depending on the number and type of operations at your facility, the MOECC will require you pay a fee directly to offset the cost of their review.
Environmental Activity Sector Registry (EASR)
Below is a list of equipment and operations that are currently eligible to be EASR registered:
- Comfort heating systems (O. Reg 346/12)
- Automotive Refinishing (O. Reg 346/12)
- Standby Power Systems O. Reg 346/12)
- Small ground-mounted solar systems (O. Reg 350/12)
- Lithographic, screen and digital printing (O. Reg 349/12)
- Non-hazardous waste transportation systems (O. Reg 351/12)
Verification that the activity meets the EASR eligibity requirements as set out in the regulation is the first step in the EASR process. If it is determined that the activity is eligible, then the activity can be registered online. Registering equipment takes places through the Ontario government’s Service Ontario portal. Once completed, an electronic confirmation is issued.
Ever feel like your environmental consultant just doesn’t understand your operations? Stuck relying on the output of a computer model that just doesn’t make sense? Our staff come from industrial backgrounds and have experience commissioning a wide variety of plants and processes. They are here to help bridge the gap between what you do, and what you need. Let’s face it, there is a lot of conservative environmental information out there, but the majority of it isn’t tailored to your operations. Concerned about how new equipment, proposed expansion or a nearby property development might impact your environmental compliance obligations? We can assist by providing a Risk Assessment that takes all of this into account, and provides you with a feasible strategy to successfully implement changes that comply with the MOECC’s regulations.
Seasoned experts with a strong working relationship with local regulators; Rubidium Environmental can help you prepare complete and detailed applications that result in a more timely approvals process. Contact Rubidium Environmental to start moving your company towards achieving compliance through obtaining your environmental compliance approval or environmental activity sector registration.
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