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On January 11, 2019 Ace Auto Parts Inc. pled guilty for failing to register an End-of-Life Vehicle site on the Environmental Activity and Sector Registry (“EASR”) resulting in a fine of $3,000 plus the 25% Victim Fine Surcharge. Ace Auto Parts Inc. was given a period of six months to pay the fine.

We note that new regulatory requirements came into force in September 2016 requiring certain designated business activities to register its business online on the EASR.

Any business activity that results in the release of pollutants into the air, land, or water, or stores, transports, or disposes of waste is required to have an environmental approval from the Ministry of Environment, Conservation, and Parks (“MECP”). Depending on the type of business activity the environmental permit required may be either an Environmental Compliance Approval (ECA), Environmental Activity and Sector Registry (EASR), or Renewable Energy Approval (REA).

An ECA or EASR is essentially an approval to discharge contaminants into the environment.

An EASR is an electronic registration of the business activities that are considered low risk to the environment and human health and utilizes equipment and/or processes that are considered to be “standard” or have known environmental impacts. The following is a summary of EASR eligible facilities: automotive refinishing facilities; commercial printing facilities – lithographic, screen and digital; non-hazardous waste transportation systems (e.g. trucks and other motor vehicles, including vans and cars on public roads); small ground-mounted solar facilities; facilities processing end-of-life vehicles; specific construction-related water-taking activities. To determine whether or not your business activity is eligible for an EASR you should review the Ministry of Environment, Conservation and Parks website.

The steps to meet the EASR requirements includes assessing all emissions from the facility; confirming that the substances have no MECP limits and if necessary, conducting a toxicology assessment; reviewing odour and noise emissions; developing noise and odour mitigation control plans, if required; developing maintenance and operational procedures in addition to establishing a complaint and record management procedure.

If the business activity is not eligible for an EASR it may require an ECA. We recommend retaining a reputable consultant to assist with this process that requires the submission of detailed information to the MECP for review and comment prior to the issuance of an ECA.

The ECA process can be quite lengthy and can take up to 12 and 18 months to complete. The steps for an ECA include evaluation of the pros and cons of an ECA with Limited Operational Flexibility; compiling information to complete the application; scheduling a site visit with a consultant (if necessary); reviewing the Emission Summary and Dispersion Modelling (ESDM) Report; complete dispersion modelling; conduct noise screening, if necessary; and, submitting the information to the MECP.

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