In Ontario, several lower environmental risk facilities may be eligible for a streamlined air & noise permit authorization in form of the Environmental Activity and Sector Registry, or EASR made under O. Reg. 1/17 and issued by the Ontario Ministry of the Environment, Conservation and Parks (MECP). However, facilities registered EASR should not treat the confirmation of registration as the end of their compliance obligations. The EASR is a registration-based approval pathway, but it is not a one-time paperwork exercise. Ontario’s EASR framework gives businesses permission to operate only if they continue to follow the standard activity requirements set out in regulation and supporting Ministry documents.
What’s New?
While the EASR program has been around for some time, in June 2026, the MECP indicated that it has begun conducting closer reviews of existing EASR registrations. Some of these are desktop reviews while others may involve a site inspection. As part of those reviews, MECP is requesting selected registrants to submit among other things, their most up to date Emissions Summary and Dispersion Modelling (ESDM) and ESDM supplement reports, as well as Acoustic Assessment Reports (AARs) where applicable, to confirm technical requirements.
Under the Hood of Air & Noise EASRs
O. Reg. 1/17 is the core regulation for activities requiring assessment of air emissions under Part II.2 of the Environmental Protection Act. Key components of an EASR package include the ESDM report, noise report (typically AARs), and odour screening report. Additional plans or statements may be required depending on the activities at the facility, including combustion equipment statements, fugitive dust best management practices plans, odour best management practices plans, and odour control reports.
The ESDM is the heart of the air evaluation since it is where air emissions are quantified, air dispersion modelling completed to assess impacts of air pollution at the property line, and compliance with applicable air benchmarks assessed. Similarly, the Acoustic Assessment Report (AAR) is the heart of the noise evaluation where noise impacts are quantified, acoustic modelling completed to assess impacts of noise pollution at nearby receptors, and compliance with noise limits assessed.
Life after obtaining the EASR registration approval
Some facilities focus on getting the electronic confirmation of registration and then assume the compliance work is complete. This no doubt is a risky and incorrect assumption that frequently lead facilities to non-compliance and potential actions from the ministry.
After the initial EASR authorisation, if changes or modifications take place at the facility that may have an impact on the ESDM or the AAR, the facility is supposed to reassess these to make sure compliance with all applicable standards can be assured even after the implementation of such changes. The reassessment must be done before a change is implemented onsite and only upon confirmation that all applicable standards will continue to be complied with. The ESDM and AAR are therefore living documents that need to be keep up-to-date reflecting the current operations taking place at the facility. Failure to do so means failure to comply with the regulatory obligations under the EASR program.
What is the ministry uncovering?
Some of the key items that the MECP is consistently finding in their reviews of existing EASR facilities are:
- ESDM reports not kept up to date
- ESDM supplements are incomplete
- Site plans missing or incomplete
- Odour screening reports missing or incomplete
- Registrations not cancelled when no longer required
- Point of reception not identified correctly for noise and/or odour assessments
MECP also stated that non-response or insufficient action by a registrant during the review process may be escalated to Environmental Compliance Officers for compliance or enforcement follow-up. That means a document request should be treated as a serious compliance matter, not as an administrative formality. Facilities should be prepared to show that the registration remains technically accurate and that the required supporting documents are current, complete, and available.
What can you do?
First, make sure you have the complete EASR package which includes the ESDM and the supplement report, emissions summary tables, AAR, odour screening, site plans, operations & maintenance plans, complaint response information readily accessible and available.
Facilities with EASR registrations should also confirm that their registration package still reflects current operations. This includes confirming that emission sources, contaminants, processes, production rates, stack parameters, operating scenarios, site plans, points of reception, noise sources, odour sources, and fugitive dust sources are accurately represented in the supporting reports such as the ESDM and the AAR.
Equipment replacements, formulation changes, new emission sources, altered production rates, revised exhaust parameters, relocated stacks, new neighbours (i.e., changed noise and odour receptors) can all affect whether the original technical basis remains valid. We advise our clients to:
- Have a Management of Change (MOC) protocol in place at the facility that requires notifying the EHS staff of all planned changes as one of the first steps when evaluating potential changes onsite. This review will allow you to thoroughly examine the proposed changes and determine if they may have an impact on the ESDM or the AAR or other elements of the EASR registration and if so, enable you to proactively address updating the affected elements.
- At minimum, perform an annual review of operations onsite against the EASR registration to evaluate if anything has changed that may need updating of the EASR documents. Some facilities set a semi-annual or even a quarterly frequency for this internal EASR health check-up.
How Trinity can help?
Trinity Consultants can help facilities assess whether their EASR registration and supporting documents are complete and accurate to ensure that they are ready for MECP review. Our team can review and help update (if found necessary) the ESDM reports and supplements, emissions summary tables, odour screening reports, noise assessments and AARs, operating and maintenance procedures, complaint response records, and the registration status.
If you would like to discuss your facility’s EASR compliance status or prepare for an MECP registration review, please email Sundar Sadashivam Trinity’s Toronto office or call at 416.391.2527.
