001-45_EJQR10_FALL26_PT - Flipbook - Page 22
Rising to the challenge of correct ESA identi昀椀cation
These challenges emphasize the value of an Integrated Environmental
Management (IEM) approach that gathers multidisciplinary expertise
and provides a holistic understanding of site conditions. IEM
demonstrates that responsibly identifying an ESA cannot be siloed
as a soil-management exercise but must instead incorporate the
expertise of quali昀椀ed ecologists and/or hydrogeologists to support
and substantiate the QP’s decision-making process. By integrating
specialist QPs early during the project’s lifecycle, project teams
move away from reactive compliance toward strategic planning that
balances regulation, nature, and project budgets.
Bottom line: Correct evaluation of ESAs
to improve project economics
Correct identi昀椀cation of ESAs is not solely about avoiding regulatory
non-compliance; it prevents additional costs of unnecessarily
restrictive and costly soil management decisions when a site is
identi昀椀ed as non-ESA.
Despite the upfront cost, these assessments are often modest compared with
the costs of applying unnecessarily restrictive soil standards or transporting
large volumes of soil to more distant receiving sites. If the evaluation or
re-evaluation of the wetland determines signi昀椀cance, or habitat screening
con昀椀rms the presence of SAR habitat, the project could safely plan for the best
management practices to comply with the ESQS, avoid costs associated with
liability, and prevent adverse ecological impacts. Ultimately, accurate ESA
evaluation is responsible environmental stewardship.
Moving forward, from compliance to integrated strategy
Navigating ESA requirements under O. Reg. 406/19 demands more than a
checklist; it requires understanding how natural systems function, how
regulatory requirements evolve, and when specialized expertise is needed to
support science-based decisions: the sooner, the better. Through accurate ESA
identi昀椀cation, project teams can safeguard Ontario’s natural features while
securing cost-e昀昀ective soil reuse decisions.
Roxana Khoshravesh, PhD, Botanist and
Zen Keizars, P.Geo., Manager of
Hydrogeology, are with Terrapex.
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