In December 2015, the Ministry of Environment sent notices to permit holders informing them that they would now need to e-report. The notices went out to 210 permit holders, all of which had annual fees of more than $20,000 or security/reclamation bonds greater than $100,000.
One of the reporting mechanisms, the Annual Status Forms (ASF), requires the permit holder to list all permit requirements and, for each requirement, what the permit holder has done to achieve compliance. The Ministry of Environment has positioned the ASF as just an administrative change. However, this change may require some permit holders to report on conditions which they did not previously report on. This reporting should be handled carefully to ensure it does not create exposure to penalties.