The proposed changes will…

The proposed changes will definitely help to fast track Records of Site Condition for development projects which are currently being hung up on issues such as de-icing salt which often leads to elevated EC and SAR concentrations exceeding applicable site condition standards which then require detailed delineation and remediation before the RSC's can be filed.

Overall, the requirements for RSC still remain quite prescriptive and onerous and Clients and consultants often get frustrated when engineering judgement is not allowed for. For instance, a mandatory requirement for a Phase II ESA for an on-site PCA, especially if the PCA is an above-ground fuel storage tank or drums or transformer with no visible evidence of any leakage or staining below. Common sense would dictate no testing requirement is warranted for such a scenario, but which is still subject to mandatory testing per current and proposed changes to O.Reg 153/04.

The excess soil rules are good, but the requirement for elaborate Phase One style reports for assessing the material from source sites is going to prolong projects while consultants spend several weeks conducting the studies, such that developers may choose not to re-use soils from such sources unless there is material readily available from an RSC site.

Also, the tracking requirements for soil movement can be onerous and costly for developers. The exemption from soil reports should be extended to at least 3,000 tonnes.