CSA Staff Notice 51-333 Environmental Reporting Guidance provides guidance on environmental matters that issuers should consider when preparing their continuous disclosure documents. It is intended to assist in determining what information about environmental matters needs to be disclosed, and enhancing or supplementing disclosure regarding environmental matters, as necessary. The key disclosure requirements with respect to environmental matters relate to: (i) environmental risks; (ii) trends and uncertainties; (iii) environmental liabilities; (iv) asset retirement obligations; and (v) financial and operational effects of environmental protection requirements. For instance, management's discussion and analysis ("MD&A") should include a description of what has been, and is reasonably likely to be, the impact of environmental trends or uncertainties on revenues, expenditures and cash flows, and the impact these have on the issuer's financial condition and liquidity (if any). In addition, an issuer may have potential environmental liabilities that are not reflected in the financial statements because their long-term or contingent nature can make them particularly difficult to quantify or because they are not individually material but, together, may indicate an underlying risk or trend that could be material in the long-term. As such, a discussion of material potential environmental liabilities should be included in the MD&A in order to help investors understand the nature of potential liabilities, their likely timing and magnitude and the probability of occurrence. An issuer should also assess whether, due to the nature of its operations, it needs to describe environmental risks in its continuous disclosure documents, such as annual information forms. CSA Staff Notice 51-333 also provides a number of other examples of disclosure with respect to environmental matters which are not specifically included here that issuers should consider when preparing their continuous disclosure documents.
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