I have serious concerns with…

ERO number

019-9310

Comment ID

122158

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

I have serious concerns with the removal of the requirement to submit a record of site condition (RSC) prior to development of lands.
Essentially, it comes down to how you don’t know what you don’t know. Except that it is important to know what is in the soil to avoid negatively affecting the health and safety of Ontarians and of biodiversity.
I will share three examples in Hamilton that demonstrate why it was important to do an environmental site assessment and provide an RSC for a site prior to development.
Through and ESA, a residential development was surprised to find out that the soil it was building on was contaminated. It was not in an industrial area. The site was previously a building in the hospitality sector. Without an ESA and the resulting RCS, the development would not have known to take precautionary measures to address the contamination, prevent it from leeching, and protect the health and safety of the future inhabitants of the residential development. This process did not delay the construction of the development. In fact, using this information, a second development on the site was expedited because they knew what was in the soil right away.
Another development needed to know about the site condition to make sure that it would not dig and disturb the polychlorinated biphenyls in the soil for its development project. The owners of the property did not know about the contamination when they purchased the land. The land is adjacent to residential. How would they have known without doing an ESA and prepared an RSC?
A third potential temporary development was cancelled, and rightfully so, when an ESA determined that the site was leeching methane in the air. This would have been a serious risk to the health of the residents and a serious fire hazard.
I recognize that addressing pollution may be costly, especially if it was not factored into the budget of a development. However, it is short sighted to put our head in the sand. Information and access to historical uses of a site can get lost in history. Contaminants can leech away from their original source and affect neighbouring sites. It is imperative that we know what is in the ground. We call before we dig to avoid hitting utility lines; it’s just as important to check to avoid disturbing contaminants in the soil.