London Brownfield Soil Testing & Remediation Bylaw

Environmental Protection Ontario 4 Minutes Read · published February 12, 2026 Flag of Ontario

London, Ontario property owners and developers must follow municipal and provincial requirements when testing and remediating brownfield soils. This guide explains the typical steps for environmental site assessment, collecting and submitting Records of Site Condition, how remediation options are approved, and where to report or seek permits in London.

Start early: site history and quick screening cut time and cost.

Preliminary Assessment and Planning

Begin with a Phase I Environmental Site Assessment to identify potential contaminant sources from past uses. If potential contamination is identified, order a Phase II site investigation with laboratory soil and groundwater testing. Engage a qualified contaminated sites professional (QSP) or qualified person (QP) recognized by provincial guidance.

  • Schedule a Phase I assessment as part of due diligence before purchase or redevelopment.
  • Retain a QP/QSP to design Phase II sampling and interpret results.
  • Document historical uses, spills, and previous permits.

Soil Testing & Reporting

Collect soil, sediment, and groundwater samples following recognized standards and the provincial guidance for Records of Site Condition (RSC). Laboratory analysis should compare results to applicable Ontario Soil, Ground Water and Sediment Standards. If results exceed standards, the QP will recommend remediation or risk management.

  • Use accredited labs and chain-of-custody for samples.
  • Prepare a technical report summarizing methods, results, and recommended actions.
  • File a Record of Site Condition (RSC) with the provincial Environmental Site Registry when required.Records of Site Condition (RSC) - Ontario[2]

Remediation Options

Remediation choices include excavation and disposal, in-situ treatment, containment, or risk management measures such as engineering controls and long-term monitoring. Choose options based on land use, receptor risks, and cost-benefit analysis prepared by the QP.

  • Select remediation that meets provincial standards for intended future use.
  • Budget for testing, remediation works, disposal, and monitoring.
  • Keep detailed records to support RSC filing or risk management plans.
A clear site history reduces the need for extensive sampling.

Penalties & Enforcement

Enforcement is handled by the City of London (By-law Enforcement and Planning/Environmental staff) for municipal contraventions and by provincial authorities for statutory matters under the Environmental Protection Act. For municipal complaints and inspections contact By-law Enforcement directly.City of London By-law Enforcement[3]

  • Fine amounts: not specified on the cited page.
  • Escalation (first/repeat/continuing offences): not specified on the cited page.
  • Non-monetary sanctions: orders to stop work, remedial orders, site clean-up directives, or court action may be used.
  • Enforcer: City of London By-law Enforcement and Planning; provincial enforcement by the Ministry of the Environment, Conservation and Parks where applicable.
  • Inspections and complaints: submit a complaint or request an inspection to City By-law Enforcement via the official contact page cited above.[3]
  • Appeal/review routes and time limits: not specified on the cited page; provincial appeal or judicial review avenues may apply depending on the instrument.

Applications & Forms

The primary provincial submission for confirmed remediation is a Record of Site Condition (RSC) filed on the Environmental Site Registry. Municipal permits or site plan approvals may also be required for redevelopment.City of London Brownfield Redevelopment[1]

  • Record of Site Condition (RSC): file on the provincial Environmental Site Registry; see Ontario guidance for filing procedures and requirements.[2]
  • Municipal planning/site plan applications: consult London Planning Services for specific application forms and fees.
Keep all lab reports and contractor invoices; they are commonly requested during inspection.

Action Steps

  • Step 1: Commission a Phase I ESA before purchase or redevelopment.
  • Step 2: If required, commission Phase II testing and obtain laboratory results.
  • Step 3: Engage a QP to recommend remediation and file an RSC if standards are met.Records of Site Condition (RSC) - Ontario[2]
  • Step 4: Contact City of London planning or by-law staff early to identify municipal permit needs.City of London By-law Enforcement[3]

FAQ

What triggers a Record of Site Condition (RSC)?
An RSC is typically required when a change to a more sensitive land use is proposed or when provincial standards require confirmation that contamination has been addressed.
Who can prepare remediation reports?
Qualified persons (QPs) or qualified contaminated-site professionals (QSPs) accredited under provincial guidance must prepare technical reports and, where applicable, RSCs.
How long does remediation take?
Timelines vary by site complexity, from weeks for simple excavation to months or longer for in-situ treatment and monitoring.

How-To

  1. Hire a qualified professional to perform a Phase I ESA and review site history.
  2. Commission Phase II sampling if the Phase I identifies potential contamination.
  3. Review lab results and meet with a QP to select remediation options.
  4. Complete remediation works under QP oversight and document outcomes.
  5. File a Record of Site Condition on the provincial Environmental Site Registry when applicable.Records of Site Condition (RSC) - Ontario[2]
  6. Consult City of London planning to ensure municipal approvals and permits are satisfied prior to redevelopment.

Key Takeaways

  • Start contamination assessment early in project planning.
  • Use accredited labs and qualified professionals for testing and reporting.
  • File an RSC when required by provincial rules to support redevelopment.

Help and Support / Resources

  1. [1] City of London - Brownfield Redevelopment
  2. [2] Government of Ontario - Records of Site Condition (RSC)
  3. [3] City of London - By-law Enforcement

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