The Ministry of the Environment and Climate Change has created an online registry, the environmental activity and sector registry (EASR), to provide instant approvals for businesses whose ‘low-risk’ activities or sectors qualify. The ministry continues to make more activities and sectors eligible for EASR, saving additional businesses the time and money associated with applying for an environmental compliance approval.

The second generation of the online registry, which is currently under development, will include a feedback mechanism to allow stakeholders to provide feedback to improve these services.

Currently 9 eligible activities and/or sectors have generated more than 4,600 registrations.

Reduce environmental compliance approval timelines

Status: Action in progress

What we heard

The environmental activity and sector registry and environmental compliance approval processes take a long time, slowing down the implementation of proposed projects. Equipment transfers need full environmental compliance approval.

Our plan

The Ministry of the Environment and Climate Change is working to improve the approvals process. By 2017, the government will reduce air and noise environmental compliance approval review time by at least 50%, and will speed up the approval process for high-risk projects by making decisions within one year.

Improve Section 20.18 of the Environmental Protection Act

Status: Action in progress

What we heard

The environmental activity and sector registry was supposed to make compliance with section 9 of the environmental compliance approvals process easier. But Section 20.18 still complicates the process.

Our plan

The Ministry of the Environment and Climate Change’s new electronic environmental compliance approval system (eECAS) will make it easier for businesses to request Section 20.18 exemptions. This system improvement will be in place by the end of 2016. The ministry will also develop guidance material to better explain the process and the options businesses have under the Environmental Protection Act.

Update biomass equipment standards

Status: Action in progress

What we heard

Environmental compliance approval requirements for biomass industries are outdated and have not adapted to recent technological changes.

Our plan

The government is working to streamline approvals for biomass and small wood combustors by making them eligible to use the environmental activity and sector registry (EASR).

The ministry is currently consulting on proposed conditions for air emissions from small wood-fired combustors. A decision is expected by the end of 2016.

Review air dispersion modelling requirements

Status: Action in progress

What we heard

Complex air dispersion modelling may be unnecessary.

Our plan

The Ministry of the Environment and Climate Change is in the process of updating guidelines for the air quality regulation, including procedures and guidelines for preparing emission summaries and air dispersion modelling reports.

Automate greenhouse gas emissions reporting

Status: Action in progress

What we heard

Currently, facilities are required to manually report on greenhouse gas emissions.

Our plan

Ontario will work with Environment and Climate Change Canada to investigate options for businesses to upload data files directly to the single window greenhouse gas emissions reporting system. Opportunities should be identified by the end of 2016.

Harmonize the process for greenhouse gas emissions reporting

Status: Action in progress

What we heard

Annual greenhouse gas emissions must be reported separately to both the provincial and federal governments.

Our plan

Ontario has recently updated reporting requirements to better harmonize with Quebec and California to support linking Ontario’s cap and trade program.

The Ministry of the Environment and Climate Change will continue to collaborate with other provinces and the federal government to identify opportunities to harmonize reporting requirements. This work will build on the current single window reporting system that prepopulates the federal greenhouse gas emissions report form with previously submitted Ontario emissions data.

Simplify waste disposal procedures

Status: Action in progress

What we heard

Regulation 347 on general waste management processes is overly complex, with too many waste classes and uncertainty about differences.

Our plan

The Ministry of the Environment and Climate Change will improve current waste management programs and guidance materials to clarify the existing waste classes and treatment requirements.

The ministry used simplified design techniques to improve understanding and compliance when it created materials for waste pharmaceuticals and sharps, as well as for the end-of-life vehicle program.

The ministry will use this approach when developing guidance materials around the implementation of its Waste-Free Ontario framework to ensure new requirements are easy to understand and comply with.

Clarify Environmental Protection Act regulations

Status: Action in progress

What we heard

Regulation 347 on general waste management is written in a way that is overly complicated and unclear.

Our plan

The Ministry of the Environment and Climate Change is working to make new waste management requirements easier to understand and comply with.

As the ministry develops guidance to assist in the implementation of its Waste-Free Ontario framework, it will also consider such simplified approaches to help ensure that new requirements are easy to understand and comply with.

Improve waste regulations under the Environmental Protection Act

Status: Action in progress

What we heard

Regulation 347 on general waste management lacks the flexibility required to accommodate process innovations.

Our plan

Recent regulatory requirements allow for flexibility and innovation, such as those that make it easier to accommodate new waste management processes by recognizing opportunities where a “waste” product can be considered a “resource”.

Modernize hazardous waste system reporting

Status: Action in progress

What we heard

The manifest system used to log the handling of hazardous materials under the hazardous waste information network is outdated and cumbersome.

Our plan

The Ministry of the Environment and Climate change is working on replacing the existing hazardous waste information network with a modern online reporting system. Full implementation is expected by January 2019.

Review reporting requirements for acetone

Status: Action in progress

What we heard

Outdated regulation for tracking and reporting of acetone.

Our plan

The Ministry of the Environment and Climate Change will review acetone reporting requirements.

Harmonize toxics reporting

Status: Action in progress

What we heard

Toxics Reduction Act Regulation 455 overlaps with the requirements under the federal National Pollutant Release Inventory (NPRI), creating additional unnecessary administrative requirements.

Our plan

The Ministry of the Environment and Climate Change will continue to work closely with the federal government to harmonize reporting requirements, and changes made to NPRI are made to the Toxics Reduction Act (TRA). For example, 20 substances deleted from NPRI for 2016-17 have been removed from the TRA requirements.

The ministry will also continue to explore ways to improve how the program currently operates and to provide clarity for businesses regulated under the act.

Clarify Waste Diversion Act requirements

Status: Action in progress

What we heard

The Waste Diversion Act has unclear requirements and retroactive penalties for non-compliance. The Ontario Electronic Stewardship provides poor customer service and requires businesses to submit time-consuming monthly sales reports.

Our plan

Under the recently passed Waste-Free Ontario Act 2016, the Ministry of the Environment and Climate Change will overhaul Waste Diversion Ontario and will aim to establish clearer requirements and higher service standards. The ministry will also consult with the Ontario Electronic Stewardship to improve customer service.

Reduce waste diversion audits

Status: Action in progress

What we heard

Enforcement of the Waste Diversion Act involves an unnecessary amount of costly and time-consuming audits.

Our plan

The Ministry of the Environment and Climate Change will review current waste diversion audit practices as part of the Waste-Free Ontario strategy. This review will consider using risk-based approaches, changing audit requirements and streamlining where appropriate. Any regulatory changes made as a result of the review could be implemented by 2018.

Review environmental compliance approval rules for equipment being transferred within Ontario

Status: Action tracking

What we heard

Previously approved equipment needs a full environmental compliance approval if it is transferred between facilities in Ontario.

Our plan

By fall 2017, the Ministry of the Environment and Climate will have cut the average air and noise approval time in half.

This means that approvals, including those related to moving equipment between sites or to new locations within the same facility, will be granted faster. Also, stakeholders can approach the ministry if approval is required to meet project deadlines.

The ministry is also exploring opportunities for qualified persons (e.g. engineers) to sign off on approval applications, including those related to equipment moves. This sign-off will improve the quality of the application so that the approval time can be further reduced.

Recognize environmental management standards

Status: Action tracking

What we heard

Some organizations currently have to undergo ISO 14001, internal audits, and Ontario Government waste audits annually. Harmonization could significantly reduce the number of audits.

Our plan

The Ministry of the Environment and Climate Change will continue to review how to better align the current risk-based inspection and audit processes with international standards.

Review Toxics Reduction Act classifications

Status: Action tracking

What we heard

Ontario is the only jurisdiction that has declared substances like copper, zinc, chrome, and nickel toxic and it requires companies to reduce usage.

Our plan

Companies are required to assess options for reducing usage, but are not required to reduce usage. Any decisions to reduce usage are voluntary, and dependent on each individual company’s circumstance.

Industrial stakeholders, including regulated facilities, have an opportunity to trigger a toxic substance’s removal from the prescribed toxic substances under the Toxics Reduction Act through the Ministry of the Environment and Climate Change Living List process.

Making a substance nomination under the Living List is a straightforward process that facilities can undertake individually or as a sector (e.g. those facilities with the same NAICS codes) if there are common substances that a sector would wish to have removed from the prescribed list of toxic substances.

Improve toxic reduction plan requirements

Status: Action tracking

What we heard

Businesses have to prepare unnecessary toxics reduction plans for manganese, zinc and chromium even though these elements are essential components of steel.

Our plan

Environmental Management Systems (e.g. ISO 14001 EMS) are voluntarily-adopted processes that allow facilities to focus on improving specific aspects of their environmental performance. The Ministry of the Environment and Climate Change (MOECC) allows facilities to use documents prepared for their own ISO 14001 EMS, or for other purposes, when preparing and submitting to the ministry a toxic substance reduction plan, so long as all requirements under the Toxics Reduction Act are met.

Industrial stakeholders, including regulated facilities, also have an opportunity to trigger a toxic substance’s removal from the prescribed toxic substances under the Toxics Reduction Act through MOECC’s Living List process.

Modernize tire disposal administration

Status: Action tracking

What we heard

Organizations must submit reports to the Ontario Tire Stewardship even if they have no claims for tires, adding unnecessary burden on these businesses.

Also, the Stewardship can only issue funds electronically, which some companies are not equipped to accept.

Our plan

The Ministry of the Environment and Climate Change will work with the Ontario Tire Stewardship and Waste Diversion Ontario to reduce unnecessary reporting requirements and provide more payment options.

Streamline on-site co-generation facilities approvals process

Status: Action tracking

What we heard

Implementing renewable on-site co-generation facilities requires a renewable environmental assessment approval, creating additional burdens, uncertainty, and delay for firms looking to invest in renewable energy.

Our plan

The Ministry of the Environment and Climate Change will consult on technical guidelines to allow facilities to co-generate renewable energy on-site. This would be the first step in determining if on-site co-generation is a candidate for the streamlined Environmental Activity and Sector Registry. If it is, then on-site co-generation would not need to apply for an environmental compliance approval.

Review effluent water monitoring programs

Status: Action tracking

What we heard

The current water effluent monitoring programs are outdated and need to be retired.

Our plan

MOECC has no plans in the near future to undertake a review of any of its 9 Industrial Effluent monitoring and limits regulations, or the wastewater works approval process for industrial facilities.

Given the complexity of updating these regulations, a measured approach in reviewing the regulatory framework is required.

Review regulations under the Clean Water Act for sampling frequency

Status: No action recommended

What we heard

Under the Clean Water Act sampling is too frequent.

Our plan

The Safe Drinking Water Act and its regulations require frequent sampling and testing of water to ensure safe potable drinking water.

To protect the public interest, no action will be taken.

Review equipment testing requirements under the Environmental Protection Act

Status: No action recommended

What we heard

To receive an environmental compliance approval to operate in Ontario, constant testing and retesting for carbon monoxide and acoustics for particular pieces of equipment may be required.

Our plan

Continuous emissions monitoring for contaminants is only required in select instances to help ensure the protection of the environment and human health.

This type of monitoring is currently required in fewer than 2% of the current approvals we issue. This is a requirement the ministry imposed to ensure ongoing compliance with ministry discharge requirements. Therefore, no further action will be taken.

Review the need for third party validation of greenhouse gas emissions reporting

Status: No action recommended

What we heard

Ontario’s environmental laws require independent external validation of greenhouse gas emissions reporting, while reporting at the federal level does not.

Our plan

The Ministry of the Environment and Climate Change reviewed this suggestion closely.

Third-party validation of greenhouse gas emissions is necessary for cap and trade. It’s a crucial component of emissions reporting currently required by other Western Climate Initiative members, such as California and Quebec, as it ensures a level playing field for all businesses participating in cap and trade. Therefore, no action will be taken at this time.

Standardize wastewater treatment goals

Status: No action recommended

What we heard

Different levels of government have opposing priorities in the treatment of wastewater.

Our plan

The Ministry of the Environment and Climate Change has reviewed this suggestion. Wastewater effluent from Ontario auto parts manufacturing is regulated by one regulation, O. Reg. 562/94, and the site, by specific requirements mandated in an Environmental Compliance Approval under the Environmental Protection Act. There are no applicable federal regulations.

No action will be taken at this time.

Analyze Toxics Reduction Act third-party review

Status: No action recommended

What we heard

Businesses need to have licensed planners review toxics reduction plans, which increases compliance costs.

Our plan

In line with modern regulatory approaches and to reduce approval turnaround time, the Ministry of the Environment and Climate Change needs independent third parties to review and approve toxics reduction plans. This review is done by licensed planners.

The ministry has trained and licensed 295 planners. Planner licences are valid for 5 years.

To protect the public interest, no further action will be taken.

Updated: June 15, 2022

Published: February 16, 2017