As part of the Better Regulations for British Columbians initiative, the BC Ministry of Environment and Parks (ENV) has recently amended the Contaminated Site Regulation (CSR) with a few key improvements to reduce the burden of Protocol 19 (P19).
These amendments aim to reduce the regulatory burden when dealing with contaminated sites and came into effect on October 9 and 27, 2025.
The amendments include:
- Provide an exemption from the P19 soil relocation requirements for sites that have a Certificate of Compliance or a Final Determination that the site is not contaminated, provided that the site has not become contaminated since the certification was issued and that the soil and vapour at the source site do not contain any substances with concentrations exceeding the numerical standards applicable to the receiving site.
- Clarify that the exemption for quarries is for those quarries with Schedule 2 uses where the soil was extracted in accordance with a permit under the Mines Act and was not affected by a specified industrial or commercial use or another source of contamination.
- Clarify that soil is exempt from vapour analysis for P19 soil relocation if the soil does not contain any volatile substance with a concentration greater than CSR standards.
- Exempt properties from submitting a site disclosure statement if:
(1) they continue the same Schedule 2 use and are upgrading the site, and
(2) they are applying for development or building permits solely to complete remediation.
Other administrative changes were made to forms and CSR Schedules to bring them into line with the changes above.
- Update Schedules 8 (Soil Relocation Notification Form) and 8.1 (High Volume Soil Receiving Site Registration Form) to make them clearer and align with the new exemptions from the soil relocation requirements.
- Update Schedule 1 Site Disclosure Statement to improve functionality of the digital form.
- Fix incorrect footnotes in Schedule 3.2 to prevent misapplication of standards and provide the correct units for salinity.
- Fix an error in Schedule 3.1 that changed the soil remediation standard for the substance indeno[123-cd]pyrene, making it 10 times lower than intended.
An important consideration for development proponents is the provision to allow any site disclosure statements submitted after October 9 that qualify for the exemptions listed above to be withdrawn by making a request to the Ministry and/or local governments or approving authorities. Applicants may also withdraw release requests made in connection with the withdrawn site disclosure statements without incurring fees. Site disclosure statements submitted prior to October 9, but still in process, can’t be withdrawn; however, the new exemptions will be considered when processing associated release requests.
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Keystone Environmental provides expert support in navigating BC’s regulatory landscape. If you have a project that requires Contaminated Sites services, Keystone Environmental has the expertise to ensure your environmental project meets these new requirements seamlessly. Connect with your Keystone Environmental Project Manager, or one of our Contaminated Sites Department Heads – Kevin Wong or Keree Orso – to learn more.
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Summary written by: Michael Geraghty, M.Sc., P.Geo., CSAP, Senior Technical Manager