Environmental Compliance Approval (ECA) and Environmental Activity and Sector Registry (EASR)

Any businesses that have the potential to release any pollutants or contaminants into the natural environment are required to prepare and submit an Environmental Compliance Approval (ECA), formerly known as the Certificate of Approval (CofA) application to the Ministry of the Environmental Conservation and Parks (MECP).

Applications are prepared in accordance with Ontario Regulation (O.Reg ) 419/05: Air Pollution – Local Air Quality. When applying for an ECA, facilities have the option of choosing a stand-alone Environmental Compliance Approval or an Environmental Compliance Approval with Limited Operational Flexibility (LOF). A stand-alone ECA is typically good for approximately ten years unless there are facility changes that fall outside of the ECA’s terms and conditions, whichever comes first, in which case, the facility must amend its existing Environmental Compliance Approval to reflect the changes being made. However, an ECA with Limited Operational Flexibility allows the facility to make changes as long as the terms and conditions are still being met. While there is more flexibility for an ECA with LOF, facilities must prepare an Annual Written Summary (AWS) to account for the changes made on an annual basis and submit the report to the MECP. SONAIR Environmental will work with you to determine your needs and decide if a stand-alone ECA or an ECA with LOF would be more suitable for your company.

Environmental Compliance Approvals are site specific approvals and cannot be transferred to another site.

If a company has operations at two or more sites, separate ECAs must be obtained for each site. However, some companies require relocation of its equipment from time to time due to the nature of its operations, such as Ready-Mix Concrete plants. Some are stationary, and others are mobile, in which case a Mobile Environmental Compliance Approval must be obtained to encompass equipment that moves from site to site. Unlike stand-alone ECAs, Mobile ECA limits a facility to only be able to operate the equipment covered under the ECA for no longer than 90 days. Otherwise, a non-mobile ECA must be submitted to the Ministry instead.

Facility equipment which are generally considered low risk, such as natural gas-fired equipment can apply for a separate Environmental Activity and Sector Registry (EASR) in the past to omit these equipment from being assessed and covered under the Environmental Compliance Approval. A Section 20.18 can also be requested to include low-risk equipment in the ECA in order to forgo the need to register for an EASR. In 2017, the Ministry phased-in a new stream of approval, covered under O.Reg 1/17, which allows low risk facilities to register for an EASR instead of an ECA for its activities and operations. While an ECA can take months for the Ministry to review and approve, an EASR eligible facility can instantly receive an approval upon registering for an EASR. Instant EASR approval is only made possible with a Licensed Engineering Practitioner (LEP), such as SONAIR Environmental, who will complete the necessary assessments for the facility, seal all the reports, and request to have the approvals issued, essentially foregoing the Ministry review and approval period.

EASR eligible facilities are generally those with NAICS codes that falls outside of the following:

The difference between an Environmental Compliance Approval and an Environmental Activity and Sector Registry is minimal; however, each stream is governed by different regulations. The following are some of the differences between the two streams: