Advocacy on behalf of local brownfield proponents has sent a Toronto propsal back to the committee level to re-evaulate how the City deals with modified generic risk assessments (MGRA) for contaminated lands.
The Canadian Brownfields Network, the Ontario Environment Industry Association and the Building Industry and Land Development Association called on Toronto City Council to not approve the modified land conveyance policy at its August 26, 2014 meeting until more discussion can take place.
The proposal from the City’s Public Works and Infrastructure Committee expresses concerns that clean-up crews will not adhere to full-depth site condition standards under MGRAs, leaving the natural environment, people and wildlife potentially exposed to contamination. The committee is also opposing stratified site condition standards
“Our discussions have been productive and we are of the view that further consultations would result in an improved policy which will be to the benefit of both the City and stakeholders,” states a letter to council on behalf of the stakeholder groups.
The City committee also has concerns that the MGRA approach is limited because it can only be applied to a short list of contaminants.
The municipality often requires an applicant to transfer lands to the City for new roads, road widenings and parks. Before this can occur, the City requires the applicant to show that the lands meet applicable standards for soil and groundwater quality, a requirement seen as unnecessarily challenging with the stratified and MGRA approaches, in the committee’s view.
The City of Toronto has proposed to only accept a Record of Site Condition acquired by meeting full depth site condition standards.
Toronto’s own standards for the transfer — or conveyance — of a risk-assessed property were last updated in 2007, prior to the MOE introducing the MGRA.