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Publication
Keeping your dawn raid guidance current
Unannounced inspections or ‘dawn raids’ are used by antitrust authorities to obtain evidence when there are suspicions that individuals or businesses have infringed the antitrust rules.
Author:
Canada | Publication | April 2020
The RAP must summarize the contamination at the site, how it will be remediated, the timelines for the remediation and milestones to assess progress. The RAP must include a RAP form, a Record of Site Condition (RSC) and a Phase 2 environmental site assessment (ESA). They must be updated with new information discovered during the ESA, monitoring or the remediation process.
According to the RAP Guide, the RAP form, RSC and Phase 2 ESA should:
AEP may accept alternative forms of the RAP if all the elements have been met through other means. For instance, the elements of a RAP could be in an authorized soil management plan or risk management plan.
The RAP Guide is a welcome document for environmental professionals and others. It provides guidance on AEP’s expectations on affected third-party property considerations, contaminant delineation, risk assessment, applicable clean-up guideline selection, source control, remedial actions and risk management plans.
It should be noted that at this time the RAP Guide has not been adopted by the Alberta Energy Regulator for contamination issues at oil and gas sites.
Publication
Unannounced inspections or ‘dawn raids’ are used by antitrust authorities to obtain evidence when there are suspicions that individuals or businesses have infringed the antitrust rules.
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