Maintaining Your Environmental Obligations During Difficult Times

Posted by on Apr 17, 2020 in Blog | 0 comments

What are Canadians concerned about as we are dealing with COIVD-19?  According to Statistics Canada, 84% of us are concerned about overloading the healthcare system and 54% are concerned about the health of a loved one.  However, we are being proactive.  92% of us are washing our hands more frequently and 87% are maintaining social-distancing requirements.

Environmental Obligations Remain

If you are in charge of environmental compliance/management, you may have other concerns as well, including maintaining compliance.   Based on our understanding, there has been no change in any of the Ontario Provincial or Federal environmental obligations.

As we pointed out in our update on March 25, 2020, Premier Doug Ford stated that among the list identified as essential workplaces/workers are Environmental Consulting Firms, Professional Engineers, and Professional Geoscientists.

Further, on April 3, 2020, the Government of Ontario issued a reduced list of essential services.  These essential services include, “Environmental rehabilitation, management and monitoring, and spill clean up and response.”

Based on our understanding, there has been no change in any of the Ontario Provincial or Federal environmental obligations.

To our knowledge, Federal reporting requirements, including National Pollutant Release Inventory (NPRI) reporting, have not changed.  The NPRI Report is due June 1, 2020.  The only note currently on the Government of Canada’s website with respect to NPRI is:  “Due to the COVID-19 pandemic, the 2018 NPRI data will be available for download at a later date.”

Working Remotely and Maintaining Compliance

We have continued to stay in close contact with our clients by phone, email, and video conference to make sure they are in compliance with their monitoring and reporting obligations.  While working from our home offices, we have also completed necessary fieldwork while closely adhering to safe practices, including social distancing.

Helpful Resources

In addition to the immediate obligations, we have continued to share appropriate resources to help you with your various environmental obligations.  This includes our monthly environmental newsletters and two webinars in the past two weeks:

Plans for Post-Pandemic Activity

Beyond your reporting and monitoring obligations, you may want to consider the environmental assessment or remediation programs that you anticipate later this year.  You may be able to lay some important groundwork now, including getting work plans, cost estimates, etc. in place.  We have done this for our clients, and we are ready to get these projects underway as soon as federal/provincial/municipal guidance allows.

Finally, Gowling WLG has put together an excellent summary that may be helpful (Keeping Up With Environmental Obligations In The Time Of COVID-19).

My colleagues and I are continuing to work out of our home offices and doing the necessary fieldwork to help our clients maintain compliance.  If you do have questions or concerns, the best way to reach me is by email, and I will get back with you promptly.

Stay safe, healthy, and in compliance!

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