Does persistence take into account licensee size and activity?
Answer 4-8: The size and activity of the licensee is not taken into account. Under Directive 019: ERCB Compliance Assurance – Enforcement , there is considerable opportunity for a large company to address the noncompliance. We have included a stage within each of the persistence criteria for High Risk where we would conduct early intervention with industry to prevent licensees being designated as persistent. The goal is for licensees to avoid being designated as persistent in the High Risk category because of early intervention. By publishing the criteria and making the potential consequences known we believe that all licensees will have the opportunity to prevent being designated as persistent.
