A guide to the new Environmental Activity and Sector Registry
Sadie Bachynski, Project Manager with Cambium, has written a blog to answer a number of questions about what the Environmental Activity and Sector Registry (EASR) is, who it applies to and what it means to your operations.
What is the EASR?
After quite an extensive process of public consultations and stakeholder input, the Ministry of Environment and Climate Change (MOECC) is now operating the Environmental Activity and Sector Registry (EASR). The purpose of this new registry system is to provide a streamlined and easy approach to registering an activity that an individual or facility might be engaged in that releases any type of emission into the natural environment – as is required by the MOECC. Emissions may include air, noise and odourous emissions from a given site. This new system is an easy-to-access registry that can be found online on the Service Ontario website.
The idea behind this new system is fairly straightforward: if a person or business is emitting anything into the natural environment they must self-register online before they do so. The government of Ontario website puts this as: “O. Reg. 1/17 requires persons engaging in activities that discharge or may discharge contaminants to the natural environment, other than water, to register in the EASR unless the activities do not meet the criteria in the Regulation”.
Who does this apply to?
New and existing facilities are required to register if they make any modification to their emissions related activity. In essence this is a phasing out of the existing ECA process; however, if a person or business submitted an application for an activity outlined in O. Reg 1/17 on or before December 31, 2016 they will have the option of remaining in the current ECA process or withdraw their application and instead register with the EASR. If a facility receives an ECA process approval, the facility will have to register with the EASR by January 31, 2027 or when the modification to the facility/activity occurs. In essence, the MOECC is looking to phase out the ECA process for eligible EASR facilities by 2027 completely.
One of the major criterions of those who must apply to the EASR is the North American Industry Classification System (NAICS) code that they report under – these have carefully been assessed for potential environmental impact. Another major criterion is the complexity of the operations/activity being performed. In essence, anyone is eligible – unless the activity/operation in question is complex in nature and deemed to be a “potentially heavy emitter”. Complex operations remain under the realm of requiring an Environmental Compliance Approval from the MOECC. For more details on who is and is not eligible, see the link below to the full Regulation outline.
What does this mean for reporting?
This in no way alters the way a facility would have to assess, model, and even report on the air, noise and odour emissions. Nothing has changed in regards to registering – it is essentially the same as it would be for a full ECA in the sense that you still require full reports (or at least the associated screening to say that a report is not required). One difference is that the work is now to be signed off on by a professional engineer independent of the MOECC rather than by the MOECC. Specific documents related to a facility’s emissions of air, noise and odour will have to be supplied to the Ministry and the public and the detailed reports and any addendums made over time are to be kept at the facility.