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The EASR is an online system that is coming into force on January 31, 2017 to eliminate administrative burdens and allow businesses to register at a faster and transparent way while potentially reducing costs through a one-time fee.  The eligible facilities are now required to register activities and meet operating requirements as stated in Ontario Regulation 1/17 made under the Environmental Protection Act.  The contaminants discharging from a facility to air, including noise and odour, must be assessed, and signed and sealed by a licensed engineer prior to this registration to ensure all comply with the requirements.  Any modifications made after January 31, 2017 must be registered in accordance with the Air Emissions EASR regulation.

Ministry of the Environment and Climate Change (MOECC) has recently added new requirements, and the table below indicates the facilities that are not eligible to register in the EASR.


Table 1:  Facilities not eligible in the EASR
Note:  The exemptions are not only limited to the facilities and activities mentioned below

Primary NAICS Codes
2122Metal Ore Mining*
2123Non-Metallic Mineral Mining and Quarrying
221112Fossil-Fuel Electric Power Generation if greater than 25 megawatts*
221320Sewage Treatment Facilities
31122Starch and Vegetable Fat and Oil Manufacturing (NEW)
31161Animal Slaughtering and Processing (NEW)
321111Sawmills (except shingle and shake mills)
3212Veneer, Plywood and Engineered Wood Product Manufacturing, other than a facility that is part of the class identified by NAICS 321211 (Hardwood Veneer and Plywood Mills)
3221Pulp, Paper and Paperboard Mills*
324110Petroleum Refineries*
32412Asphalt Paving, Roofing and Saturated Materials Manufacturing
324190Other Petroleum and Coal Products Manufacturing*
325Chemical Manufacturing*
326150Urethane & Other Foam Product (except Polystryene) Manufacturing*
3262Rubber Products Manufacturing
327310Cement Manufacturing
327320Ready-mix Concrete Manufacturing
327410Lime Manufacturing
3279Other Non-Metallic Mineral Product Manufacturing*
331Primary Metal Manufacturing *
3321Forging and Stamping
332810Coating, Engraving, Heat Treating and Allied Activities*
332999All Other Miscellaneous Fabricated Metal Product Manufacturing*
336Transportation Equipment Manufacturing*
562110Waste Collection
5622Waste Treatment and Disposal*
5629Remediation and Other Waste Management Services (NEW)
812220Cemeteries and Crematoria

*Schedule 4 or 5 Target Sector

The following activities are not eligible to register in the EASR:

  • A facility engaged to at least one of the following activities:
    • Land disposal of waste
    • Thermal treatment of waste, except for the fuels used in a small wood-fired combustor (subparagraph iii) installed on or after January 31, 2017
    • Wood-fired combustor, except small wood-fired combustor installed on or after January 31, 2016 and used as fuel for at least one of the following that meets the specifications indicated in Chapter 5 in the EASR:
      • Wood briquettes
      • Wood chips
      • Wood pellets
    • Use of cadmium, cyanide, chromium or nickel for plating processes, including chrome plating, electroplating or electroless plating
    • Electrolytic stripping processes to remove cadmium, chromium or nickel from an object
    • Outdoor metal processes, including torching, shearing, shredding or plasma cutting, unless used for maintenance for plant, structure, equipment, apparatus or thing
    • Alternative low-carbon fuel operation as indicated in O. Reg. 79/15 (Alternative Carbon Fuels)
    • End-of-life vehicle waste disposal operation as indicated in O. Reg. 85/16 (Registrations under Part 11.2 of the Act – End-of-life Vehicles)
    • Fossil-fuel electric power generation facility with more than or equal to 25 megawatts electrical power output capacity
    • Use of biogas, biomass, coal, petroleum coke or waste as fuel for combustion or use of fuel derived from biogas, biomass, coal, petroleum coke or waste
      • Does not include small wood-fired combustor operations installed on or after January 31, 2017, and must exclusively use at least one of the fuels described in subparagraph iii
    • Use of combustion turbine

As a part of the Air Emission EASR regulations, odour is now being considered as requirements for facilities that engage in the EASR-prescribed activities, and an Odour Screening Form (OSF) must be completed for potential odour emission evaluations.  If the assessments indicate risk of odour emission, then additional documentation must be completed depending on their potential to cause adverse effects.  For instance, a Best Management Practices Plan (BMPP) may need to be prepared if facilities failed to meet the setback distances or concerns are shown by the Ministry.  Inspection, maintenance and monitoring procedures must be included in the BMPP, along with other training and procedures to minimize the odour emissions.

Facilities have the option to remain under the ECA process or withdraw from ECA process to register on the EASR if their ECA was submitted to the Ministry on or before December 31, 2016.  Nevertheless, the applicants who remain in the ECA process and receive an approval must be on the EASR by January 31, 2027 or before modifications are made to the facility.

The changes to the regulations are not only limited to the ones mentioned above, and they greatly impact all types of industries.  Please do not hesitate to contact Trinity Consultants' Ontario office for more information and resources.  Trinity Consultants has the knowledge, experience and resources to assess the changes and the impacts for your facility.   For more information please contact Suzy Sabanathan at (416) 391-2527 x22, or at