Some municipalities have a…

Some municipalities have a policy for acceptance of conveyances, generally for road widenings, requiring Ministry acknowledgment of a RSC. We have submitted some of these where the only PCA and APECs were related to winter maintenance, which now has a S.49 exemption. It should be made clear that winter salt related PCAs and APECs alone, which a QP has considered and deemed to comply, should not themselves trigger an RSC requirement.

Municipalities do not need a RSC acknowledgement in any case, because they already do or can engaged peer reviews at applicant cost, and the reviewers actually receive the full Phase 1 and 2 documents, which the Ministry does not. Municipalities generally try to force an RSC submission to generate a Ministry review, because most do not have in-house capability for considering and dealing with environmental matters relating to soil and/or groundwater. and treat an RSC acknowledgement as some sort of Ministry rubber-stamp approval.

An RSC requirement by municipalities prior to site plan approval delays the plans-approvals process because municipalities know site plan approval is their last point of leverage to enforce conveyances, and some hold back site plan approval until there is an RSC acknowledgement in hand. The RSC acknowledgement can even be a "tick the box" requirement. Without one in hand, site plan approval submissions are considered incomplete and are not circulated by some municipalities.