The Ontario Ministry of the Environment has proposed some modest expansions of its permit-by-rule approval program for low impact activities similar to those already covered by the EASR system. The proposal, Regulatory Amendments to Environmental Activity and Sector Registry (EASR) Regulations to implement a Standard Systems and Equipment EASR, proposes to:
1. Expand the types of activities that are eligible for the EASR to include related activities and equipment, and
2. Draw a sharper line between the EASR program and full scale Environmental Compliance Approvals, so that each site would obtain EITHER an EASR or an ECA, but not both.
3. The amendments would allow more sites that have routine, low impact activities to obtain operating approvals through the EASR so that the ministry can refocus case-specific technical review resources to more complex approval applications. In particular,
- HVAC systems. An expansion on the definition of heating systems currently in O. Reg. 346/12 to also include associated ventilation, cooling and refrigeration equipment such as cooling towers. An HVAC system with cooling towers would be subject to additional eligibility and operating requirements
- Standby power systems. It is proposed that the current EASR be amended by changing mandatory operating requirements for mitigating air and noise emissions into eligibility requirements to allow for greater flexibility while still maintaining environmental protection
- Dust collection systems. Only small dust collection systems at retail locations or schools (schools does not include universities, colleges or trade schools) are proposed to be eligible
- Laboratory fume hoods. Only fume hoods that are used at schools (schools does not include universities, colleges or trade schools) are proposed to be eligible
- Arc-welding equipment. It is proposed to include indoor operation of arc-welding that is restricted in terms of welding rod usage in order to capture light maintenance activities only
- There will also be tweaks to the rules for standby power systems.
4. In pursuit of its “one site, one approval” concept, O. Reg. 346/12 would also be amended to delineate between EASR-eligible sites and those that will require ECAs. O. Reg. 346/12 would only apply (i.e. activities would be required to register in EASR) if all of the activities at the site are EASR-eligible. If there were any other activities that are not EASR eligible (e.g. manufacturing process emissions) requiring a s. 9 approval, all of the activities at the site are no longer prescribed for EASR. This means that more complex sites would require ECAs and entirely EASR-eligible sites would require registration in EASR.
This may not be to the benefit of all companies.