An ERIS Report: The Canadian records review standard for environmental risk assessment.

By Ann White
September 29, 2003

This is Part 2 of a 10 Part CREN series on the 'Green Building Industry'. Part 1 is an interview with Alex Zimmerman President of the Canada Green Council.

In seven short years since launch, Eco Log ERIS has become the only Canadian database service providing property specific Environmental Risk Information. ERIS reports are becoming essential for companies undertaking a Phase 1 Environmental Site Assessment (ESA). Furthermore, property owners (portfolio managers, home owners, concerned neighbours) are buying ERIS reports not only as part of a property transaction but for their own information.

Todd Latham, General Manager of ERIS and Lee Scarlett, Director of Sales met with CREN to tell the ERIS story.

~ Overview
~ The CSA Z768 Standard
~ ERIS History
~ ERIS Launch - February 1999
~ Sources of Environmental Information
~ Building an ERIS Database
~ Site Radius of 250 Meters
~ Types of Environmental Information
~ How Old is the Data
~ The ERIS Reports
~ Who Orders ERIS Reports

OVERVIEW - Back to Top

Eco Log ERIS is a national database service, which provides specific environmental and real estate information for addresses and businesses across Canada. An ERIS Report contains Federal and Provincial public records, as well as private sector information, which may alert property owners to possible environmental liabilities associated with real estate and surrounding neighbourhoods.

Since its launch in March, 1999 Eco Log ERIS's Phase 1 environmental site assessment reports has become an industry standard in Canada. On going addition of new environmental database sources by ERIS, and incremental upgrades to its report delivery system, ensures it is systematically improving its service.

Todd Latham, General Manager of ERIS, explained, "As soon as ERIS was created it raised the bar substantially. In fact ERIS has become the Phase 1 records review standard. It has been referred to as 'Phase Zero', the first phase of a Phase 1 Environmental Site Assessment. "

THE CSA Z768 STANDARD - Back to Top

A Phase 1 records review is the first of three Phases spelled out in the CSA (Canadian Standards Association) Z768 standard for conducting environmental site assessment. In broad terms Phase 1 is information gathering, Phase 2 is site testing and Phase 3 is remediation.

The CSA standard states that a public records review shall be conducted and should provide an assessor with an in-depth understanding of a site’s history. Appropriate measures should be taken to document possible sources of hazardous waste, other sources of contamination and liability. The standard requires that the assessor also consider adjacent properties and any relevant information that is 'reasonably ascertainable'.

Although environmental site assessment is not a legal requirement, according to Todd Latham, the CSA standard has become accepted in Canada as reasonable environmental 'due diligence' for property transactions. It is acknowledged as appropriate environmental 'risk assessment' for real estate investments.

ERIS HISTORY - Back to Top

Prior to ERIS, consultants requesting site-specific environmental data from a Government source through the Federal Freedom of Information Act (FOI) fulfilled the requirements of the CSA standard. Although the information was forth coming within the time allotted by the Act (30 to 60 days) it was not always available by closing. Closings therefore were sometimes achieved by providing the appropriate 'FOI request letter' thereby fulfilling the requirement of 'reasonably ascertainable' information. As concern regarding environmental risk grew this type of practice was increasingly unacceptable.

In the early 1990's an individual involved in an 'ERIS like' site assessment company in the U.S. sold the ERIS idea, and some databases, to Southam Magazine and Information Products Group. From 1996 to its official launch in 1999, Southam assembled the environment data and built the systems to deliver the content.

ERIS LAUNCH - FEBRUARY 1999 - Back to Top

ERIS opened for business in Ontario first, with only 17 databases. There are currently 45 databases in Ontario and 350 across Canada covering every Province.

ERIS has no competitors. Hollinger Inc. now owns ERIS and it is part of the Toronto based trade-publishing group. There is also only one national environmental database site assessment company in the U.S., Environmental Data Resources (EDR).

SOURCES OF ENVIRONMENTAL INFORMATION - Back to Top

ERIS collects any information concerned with "a potential environmental risk". The question of what is 'a potential environmental risk' is debatable and an often discussed issue. For example, Todd Latham asks, "Are fish farms on the coast British Columbia a potential environmental risk?"

Although ERIS gathers primarily government generated information there are also private sources and internal information such as Scott directory, another Hollinger publication. Scotts - scottsinfo.com - catalogues information about Canadian companies and municipalities. Private databases can be national, provincial or regional in scope.

Whereas Federal Government data is consistent across the country, Provincial databases, even when referring to the same environmental hazard, can vary in format and content. The differences are the result of variation in Provincial laws and interpretation of Federal requirements. Also some Provinces collect information unique to their economic base and environmental legislation.

Consequently, ERIS reports differ by jurisdiction according to the nature of the Provincial and local databases available, while national data tends to be more consistent.

BUILDING AN ERIS DATABASE - Back to Top

Building an ERIS databases from another data source is no small task. The first step, if it is Government information, is for ERIS to request the entire database from the Government under the Freedom of Information Act. The database when delivered may be in electronic or paper form. In either event, each record is then reconstructed in a format compatible with the ERIS software but without altering the information.

Once the records are in the ERIS format they are then 'geocoded' so that the environmental data is appropriately cross-referenced in the ERIS geographical information system. Further geographical plotting is then required to correlate the location of environmental information with municipal addresses. Information that is not associated with a specific address, only a general area, is designated as 'unplottable information' but nevertheless included in a relevant report.

SITE RADIUS OF 250 M - Back to Top

Once data is entered into the ERIS software, it can be search by any size and shape of area, for information from any of its data sources.

A Phase 1 ERIS report includes properties within 250-metres of the subject property. ERIS set the 250-meter radius to accommodate the CSA standard for inclusion of adjacent properties.

The U.S. has a more rigorous requirement for environmental site assessment of 1 mile from the property. As Todd Latham points out the Canadian standard of adjacent properties (and the ERIS interpretation of 250-meter) satisfies most situations. ERIS accommodates U.S. clients, who feel more comfortable meeting their national criteria as well as any other spatial request.

ERIS has provided site assessment reports for corridor properties including an assessment for SCN Lavalin for highway 407 now constructed across metro Toronto and oil pipelines.

TYPES OF ENVIRONMENTAL INFORMATION - Back to Top

ERIS categorizes their databases according to where they gathered the information (Federal, Provincial or private) rather than by the type of data (hazard, toxic substance, polluter or storage practice). Some databases have names that depict a recognizable purpose such as PCB Inventory, Pesticide Registry, Retail Fuel Tank Storage, Coal Gasification and Waste Disposal Sites. Others refer to polluters rather than pollutants such as Complaints and Convictions, Occurrence Reporting, Orders and Non-compliance reports.

The database that generates the most results in the ERIS demo report for Ontario on its website is the Waste Generators database showing 32 entries in a 250-metre radius of the site. According to the ERIS description of the database, a waste generator is "any site, equipment and/or operation involved in the production, collection, handling and/or storage of regulated wastes. A generator of regulated waste is required to register the waste generation site and each waste produced, collected, handled, or stored at the site." This database contains the contact information of registered generators including the types of hazardous wastes generated. This information along with an understanding of 'regulated wastes' appears to generate a significant and meaningful data flow. (Click here to view a sample report)

ERIS provides a brief description of each database in its reports. The environmental reports however include descriptions of waste material, not defined in the reports, that would require a qualified professional to interpret such as 'aliphatic solvents', 'organic acids' and 'alkaline wastes'.

HOW OLD IS THE DATA - Back to Top

Each database referenced in an ERIS site assessment report has a date range showing when the data was first and last collected.

The first date often corresponds to when Environmental legislation began requiring the data be saved. There are a handful of references to water, sewage, oil and gas well information that are over 100 years old prior to legislated requirements. Most information however, particularly data referring to toxic substances, has been collected in the last 25 years, the greatest proportion in the last 15 years.

The second date refers to when the data was last updated and 2003 dates are rare. The age of the content is a reflection of publication delays between receipt and release of information by Government source, situations where databases are a one-time research endeavor or only infrequent updates are deemed necessary.

THE REPORTS - Back to Top

An ERIS report is a database-derived report that only fulfils part of the requirements for a Phase 1 environmental assessment. The CSA standard also calls for collecting historical information, aerial photographs, title searches and other available information such as fire insurance records. ERIS can provide this information in addition to the database report if requested. Information gathered in a site visit is not an ERIS service.

ERIS reports, with the exception of the basic on-line report, are subject to a manual verification of the data in the report. The verification involves cross referencing a computer generated summary report with the database records and manually reconciling municipal address and data locations in the report to the actual site and neighbourhood.

There are several different reports that range in scope, cost and the extent to which they meet the Phase 1 CSA standard. These are described in greater detail on the Eco Log ERIS website where sample reports are also provided.

Below is a brief summary of their main database report options. The most frequently requested complete report is $295.00 and takes 3-4 days to deliver.

Basic Report On-Line - A single site report, purchased and generated on-line, with no manual verification of data.

Site Report - A single site report with manual verification of data

Basic Report - A report including a 250 m radius of the site with a selection of chosen databases

Complete Report - A report including a 250 m radius of the site with all available databases

Custom Report - Any area including any of the available databases.

WHO ORDERS ERIS REPORTS - Back to Top

The client list displayed on the ERIS brochure has almost every major site consulting and engineering firm in Canada. It also lists municipalities, financial institutions, real estate brokers and others. Most, if not all, land consultants and property owners with potentially 'dirty' sites know about ERIS.

There are 20,000 Phase 1 environmental assessments in Canada and not all of them have an ERIS report. In spite of people knowing about ERIS, Todd Latham says, "lots of people who do property transactions don't even blink when they purchase property. They sign a clause in an agreement accepting or waiving liability for environmental issues. They think they can get away without doing an environmental report." According to Todd Latham, financial institutions are now requesting the reports and peer reviews have flagged Phase 1's as missing the ERIS information"

A sense of urgency associated with property transactions has become a prime driving force behind ERIS product development. Closing dates are getting shorter yet due diligence and liability issues have greater prominence. Increasingly buyers may insist on an environmental site assessment prior to closing even when a Phase 1 study is not an obvious requirement.

Brownfield development has also been good for ERIS's business. ERIS has tailored a site assessment product for municipalities who want to encourage development of vacant urban land with questionable environment records. Pressure to preserve green space is going to further expand this market for ERIS.

Increasingly, in the absence of a property transaction, property owners and portfolio managers are requesting ERIS reports to fulfill due diligence expectations. Homeowners who want more information about the environmental quality of their property and neighbourhoods are also purchasing environmental information.

According to Todd, the future of marketing ERIS products is educating the real estate and financial community to the availability of their service. As he says, "An ERIS report is not only good for property owners, it is good for Canada when we act to clean up our properties."

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