Can I Complete an Air & Noise ECA or EASR Myself?

 In Environmental Compliance

We get asked this question a lot. We get it. Most businesses, especially small-scale operations on a budget would try to do everything themselves. Why not, especially if you have the time and resources. The answer is simple, but first, let us explain why it would not be a good idea to complete an air and noise Environmental Compliance Approval (ECA) application or Environmental Activity and Sector Registry (EASR) registration yourself.

Facilities with activities and operations that have the potential to emit contaminants into the natural environment are required to prepare an Emission Summary and Dispersion Modelling (ESDM) report in support of the ECA application or EASR registration. ESDM reports are extensive and detailed and must be prepared in accordance with O. Reg 419/05 as well as Guideline A-10: Procedure for Preparing an Emission Summary and Dispersion Modelling Report. It describes the different on-site processes, activities and any associated pollutants emitted into the environment. Estimating emissions from facility operations using publicly accessible data is part of it, but determining the point of impingement concentration by using an atmospheric air dispersion model in accordance with Guideline A-11: Air Dispersion Modelling Guideline for Ontario require knowledge and experience.

An Acoustic Assessment Report (AAR) is also required if the facility does not meet the primary or secondary noise screening. If your facility is located in close proximity to sensitive receptors, such as a residential dwelling, day care center, hospital, place of worship etc, chances are you are required to assess the noise emissions generated on-site and the cumulative impact it has towards the various point of reception identified in the vicinity. Noise data can be obtained from sound measuring devices or specifications from equipment manufacturers. Knowing how to use the data is crucial in determining accurate sound levels. Acoustic Assessment Reports are prepared in accordance with NPC-300 and a noise propagation software is used to establish the sound level at each sensitive receptor. Modelled sound levels are compared against Ministry prescribed noise limits to determine compliance and whether noise mitigation measures are required.

If you are eligible to register your facility’s activities and operations under the Environmental Activity and Sector Registry process, ESDM and AAR reports in support of the registration must also be sealed by a Licensed Engineering Practitioner (LEP) to verify that the information within the reports are correct and accurate. Unless you are a Licensed Professional Engineer, you will not be able to seal these reports.

Unlike the EASR route, applying for an ECA does not require an LEP to seal the reports. To determine if it would be acceptable for you to complete the application will depend on whether or not you are considered a qualified person by the Ministry with the required technical expertise and well-versed with the applicable Ontario regulations and guidelines. On top of this, are you willing to purchase expensive software and spend the time to learn these models just for the purpose of submitting this one application?

Now, in answer to your question: Yes, you may be able to complete the applications and registrations yourself. However, aside from spend thousands of dollar in software purchases, whether or not your application and registration is considered acceptable to the Ministry will ultimately depend on your experience and qualifications.

Not fully knowing how to assess facility emissions and simulate air and noise impact using advanced models can create potential liability and financial harm to your company. Learning how to put an entire application together by yourself can also end up costing your company more at the end. Leave it to the experts and let us help you with your ECA or EASR, to save you both, time and money. At SONAIR, we offer competitive pricing with a quick turnaround time. Our engineers will take care of the entire application and make the process as easy as we can to get the approval you deserve.

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