Changes are Coming to the Site Profile System in BC

And You Need to Know About Them

By: Tom Berger, P.Geo.
Tberger@pggroup.com

Changes are coming to the Site Profile system in BC and you need to know about them. These are regulatory changes that will take place once passed in the legislature, likely in the spring of this year.

Site Profiles have been a part of the furniture of development applications, just another form required a municipal approval or permit. Municipalities use them to identify sites or properties that could be contaminated. Flagged sites are frozen for civic approvals and permits, and only the Province can release them.

Site Profiles use something called Schedule 2 of the Contaminated Sites Regulation. Schedule 2 is a list of land uses that are considered likely to contaminate a site’s soil, soil vapour, and/or groundwater.  A known Schedule 2 use in a site’s history is the initial flag.  Then a set of yes/no questions determine if a site will be frozen.  So, basically the existing Site Profile provides a kind of “loophole” from being flagged as a potential contaminated site if you have a Schedule 2 use but have all “No” answers on the questionnaire.

The Site Profile system will be called the Site Identification system. The big changes coming are not the name change but the elimination of the questions, elimination of the option for municipalities to “Opt Out” and changes to the list of Schedule 2 Activities.  Any Schedule 2 use will lead to the site being frozen and drawn into the Ministry process. Fortunately, if you don’t have a Schedule 2 use, you’re still not going to be flagged. A link to the proposed revision of Schedule 2 is linked at the bottom of this article. Notable is the inclusion of “contaminated soil, including relocated fill material”.

Another change is the need to provide a summary of the plans for the Site and the information used to complete the Site ID.  The Ministry is looking for a Phase 1 or Stage 1 report.  You will have to list the records that were searched, like business directories, aerial photographs, insurance maps, title searches, and so on.  Ideally, your consultant will have done all this and will fill out the Site ID for you, correctly.

So, if you are doing your due diligence using a Phase 1 or Stage 1 prepared by your consultant which identifies a Schedule 2 use on your site, it will be captured under the new Site ID form and will be subject to the requirements under the Environmental Management Act and Contaminated Sites Regulation before the local government turns over any permits.  Having a consultant that can guide you through this process and understands your needs will be an asset.

Links
Proposed Site Identification Form 
Revised Schedule 2 – Industrial or Commercial Purposes or Activities