1. Purpose of the Construction Plan Report

The Construction Plan Report is a component of an application for a Renewable Energy Approval (REA) under O. Reg. 359/09. This report is required as part of an application for all renewable energy projects that require an REA with the exception of Class 2 wind facilities (those with name plate capacity greater than 3 kW but less than 50 kW). Due to the relative simplicity of Class 2 wind projects, they only require description in the Project Description Report (PDR).

The purpose of the Construction Plan Report is to describe in sufficient detail the project activities undertaken during the construction phase so that all negative environmental effects that will or are likely to occur may be identified. The report must also describe mitigation measures in respect of the negative environmental effects that will or are likely to occur from construction or installation activities.

The Construction Plan Report should contribute to and be consistent with information presented in other reports submitted as part of an REA application. For instance, the report is expected to describe the installation of all project components detailed in the Design and Operations Report. As well, the Construction Plan Report should provide details on how construction activities will be planned to mitigate the negative environmental effects that will or are likely to occur, which should support conclusions around the significance of negative environmental effects presented in the PDR.

An additional function of the Construction Plan Report is to act as a communication tool for consultation with municipalities, the public, Aboriginal communities, and other interested stakeholders. A draft report must be made available to all municipalities (upper and lower tier) in which the project is located at least 90 days prior to the final public meeting, in accordance with section 18 of O. Reg. 359/09. The public must also be provided with a draft report at least 60 days prior to the final public meeting for the renewable energy project, in accordance with section 16 of O. Reg. 359/09. It should be noted that the following facility classes do not require applicants to hold public meetings:

  • Class 2 wind facility
  • Class 1 or 2 anaerobic digestion facility
  • Class 1 thermal treatment facility, if the generating unit of the facility is located at a farm operation
  • Class 2 thermal treatment facility

In these cases (except Class 2 wind, which doesn’t require a Construction Plan Report), the draft report must be provided to all municipalities (upper and lower tier) at least 30 days prior to submitting an application for an REA.

Applicants should note that construction plans may be of particular interest to municipalities, since these plans could have the potential to impact municipal infrastructure and services. Construction plans should be summarized in the applicant’s municipal consultation form either through description on the form or through specific references to the Construction Plan Report.

2. Overview of Construction Plan Report content

The principal content of the Construction Plan Report is defined in Table 1 of O. Reg. 359/09 and provides a description of the planned construction phase activities, including temporary activities/structures at project locations proposed within setback areas outlined in the REA regulation. This would include a description of:

  • details of any construction or installation activities
  • the location and timing of any construction or installation activities for the duration of the construction or installation
  • any negative environmental effects that will or are likely to occur from construction or installation activities within a 300 metre radius of the activities
  • mitigation measures in respect of any negative environmental effects that will or are likely to occur

A Construction Plan Report submitted as part of an application for an REA must contain information on all of the required content.

The structure of the report should be selected by the applicant to provide a clear account of these contents. One approach that could achieve clarity would be to structure the report according to sections that address each of the key required content requirements above. Pertinent sections of other reports, such as the site plan in the Design and Operations Report, can be reprinted or referenced where appropriate.

3. Description of construction and installation activities

The Construction Plan Report must contain a detailed description of all activities that will occur in order to bring the facility into operation. This should cover the construction and installation of all equipment, roads, transmission/distribution lines, transformers, and other ancillary components proposed to be constructed as part of the project including the construction of associated buildings or structures (a more detailed definition of what is included in a renewable energy project is provided in Chapter 1). The use of maps and figures may assist with providing a clear description of where and how construction and installation activities will be conducted. Activities are project-specific but can include:

  • site preparation
  • equipment installation and connection
  • general construction activities
  • post-installation activities such as the restoration of vegetation or impacted water bodies

For each component installed and/or constructed, a number of attributes should be considered in completing the description of activities. These include:

  • a description of the materials brought on site (and how they will be transported)
  • equipment used for constructing or installing the project component
  • the timing and operational plan for conducting the construction or installation
  • whether any land will be affected through a temporary use for the purpose of constructing or installing the component (i.e. construction lay down areas)
  • whether the construction or installation will require a water taking
  • a description of any materials generated at the site (including waste) during construction and how they will be used/disposed of/transported offsite

Details on attributes that should be described are provided in the sections that follow.

3.1. Materials brought on site

A description of materials needed for constructing or installing the project components should be given. The purpose of providing such a description is to define the scale of the construction and installation activities and to ensure the description of negative environmental effects that will or are likely to occur reflect impacts related to bringing the materials to the site. This could be broken down on a component basis or given as an aggregate description of materials required for the project as a whole. The description should provide, if applicable:

  • an estimate of the quantities and types of materials that will be transported onsite for construction
  • the method of transporting the materials, such as by truck, with an estimate of the size and number of trucks
  • the expected overall timeline and operational plan for transporting materials to the site
  • the site locations where materials will be used
  • any plans to temporarily store materials on-site, including the duration of storage

3.2. Construction equipment used

A description of construction and installation machinery should be provided. This could involve equipment to excavate or grade ground, drill footings, or erect structures such as through the use of cranes. The description should provide:

  • the general type of construction equipment expected to be required
  • the approximate size or weight of construction equipment if relevant to describe the negative environmental effects that will or are likely to occur
  • the potential for the equipment to emit noise and dust
  • any chemicals used in the operation of construction equipment including fuel
  • how the equipment will be brought into and out of the site, if relevant for describing the negative environmental effects that will or are likely to occur related to traffic and road infrastructure impacts

3.3. Timing and operational plans

The timing of proposed construction and installation activities must be described. This should indicate:

  • the sequence of events of each construction and installation activity including their expected duration
  • the timing with regard to seasons, if such timing may influence the negative environmental effects that will or are likely to occur
  • the time of day that activities will be conducted, if such timing may influence or mitigate the impact of the negative environmental effects that will or are likely to occur

3.4. Temporary uses of land

Construction activities may result in temporary changes to land surface or grading as well as the installation of temporary structures such as culverts, grading and compaction. This may be due to the construction of temporary access roads or staging areas. Any change to land that occurs during construction and is not reflected in the permanent design of the renewable energy generation facility (i.e. site plan of the Design and Operations Report) should be described. This should include:

  • the extent of the affected area
  • a description of the land use prior to construction
  • a description of the temporary land use during construction
  • a description of how the temporary land use is reasonable for the soil conditions of the project location
  • the timing and duration of the temporary change
  • activities planned to restore the condition of the land, if any

If the project site is agricultural, the Ministry of the Environment, Conservation and Parks (MECP) expects a detailed description of how land capability for agriculture will be maintained or improved following construction activities. For example, soil erosion is mitigated; any topsoil and subsoil removed is stockpiled separately and used to restore any disturbed areas; and drainage and irrigation systems that enhance the productivity of agricultural land are maintained or improved.

Applicants should contact the local conservation authority to assess the need for any permissions which may be required as a result of temporary changes to land surfaces, grading or the installation of temporary structures.

The temporary parking area for vehicles owned or used by construction site workers (not including vehicles directly used in the actual construction of the facility, such as a tractor or crane) is not required to be considered as part of the renewable energy generation facility and therefore the project location for the purposes of the REA. Other applicable municipal permits and/or approvals may be required for the temporary parking of construction workers’ vehicles and each applicant is responsible for obtaining all necessary approvals and making appropriate arrangements.

3.5. Temporary water takings

If the proposed construction or installation of a project component includes the taking of water from a ground or surface water source, such as when quantities of ground water are pumped out to facilitate excavation, the water taking should be described. See section 4.3 below for more detail on the information required for water taking and any negative environmental effects that will or are likely to occur related to the water taking.

3.6. Materials or waste generated at, or transported from, the project location

Some construction activities will result in the generation of materials that have no further use at the project location. This could include aggregates excavated or vegetation removed in respect of installation of a generation facility, among others. Materials may be stored or disposed of on-site or transported offsite. Any materials generated as a result of construction or installation activities should be described, including the following:

  • the estimated quantity and type of material generated
  • if stored or disposed of at the project location, an account of how the storage or disposal will be undertaken
  • if transported offsite, the proposed future use or final disposal of the material. If materials excavated are contaminated their disposal may be regulated under Regulation 347 (General – Waste Management), made under the Environmental Protection Act
  • if transported offsite, the proposed method of transporting the material including an estimate of the type and number of trucks, if relevant

It should be noted that on-site disposal of waste generated during construction or installation may require an Environmental Compliance Approval (ECA) for waste under Part V of the Environmental Protection Act. If on-site disposal of waste generated during construction or installation of a renewable energy generation facility is proposed, project proponents should contact MECP to determine if an ECA is needed for this disposal.

4. Description of negative environmental effects

As required in Table 1 of O. Reg. 359/09, the Construction Plan Report must include a description of any negative environmental effects that will or are likely to occur as a result of construction or installation of the renewable energy generation facility.

The negative environmental effects that may result from construction will also be included in the description of the negative environmental effects for the project in the PDR, as described in section 5 of Chapter 4. Applicants are required to provide this description in both locations to enhance the usability of the REA reports. For instance, the draft PDR generated at earlier stages in the application process will allow for an early discussion of the negative environmental effects that will or are likely to occur from construction. This will also ensure that a stakeholder with a specific interest in construction activities, such as a local municipality, will find a complete account of the construction-related impacts in the Construction Plan Report. Cross references to specific information between the PDR and the Construction Plan Report may be used where it would enhance the clarity of the application.

As in the PDR, when describing the negative environmental effects in the Construction Plan Report, the likelihood of occurrence and the potential magnitude of the effect should also be given. Conclusions drawn about the significance can be based on proposed mitigation measures the applicant will commit to implementing during construction. If mitigation is proposed, the description of these measures must be included in the Construction Plan Report (see section 5), and reference should be made where appropriate to assist the reader in linking the negative environmental effects that will or are likely to occur with related mitigation.

While it is the applicant’s responsibility to include all the negative environmental effects that will or are likely to occur as they relate to the project, the following sections provide guidance regarding common negative environmental effects during construction.

4.1. Dust and noise emissions

Construction activities have the potential to emit contaminants to air. The emission of dust through excavation, drilling or the use of trucks on dirt roads, among others, should be considered for negative environmental effects. Likewise if the operation of heavy machinery could result in noise emissions that may impact neighbouring noise receptors, these emissions should be described. Reference can be made to the Emergency Response and Communications Plan which should provide a description of how the public can report complaints related to noise and dust.

4.2. Destruction of vegetation

The proposed construction and installation activities may cause the destruction/removal of vegetation. Any destruction or removal of vegetation should be described. This description should depict the areas where vegetation destruction or removal is proposed to occur, as well as describe the nature of the vegetation. While vegetation in significant natural features will be subject to the Natural Heritage Assessment, setback distances and/or the submission of an Environmental Impact Study (as per sections 25 to 27, 38 to 41 and 43 to 45 of O. Reg. 359/09), applicants must still determine appropriate steps to evaluate and mitigate the negative environmental effects that will or are likely to occur from destruction of vegetation that is not located in a significant natural feature. Generally, planning construction to minimize destruction and removal of vegetation and to replace impacted vegetation following construction is a recommended approach.

The removal of vegetation may also contribute to other negative environmental effects such as changes to surface water runoff or the production of dust on site. Any removal or destruction of vegetation should also be reflected in the discussion of these impacts if it may contribute to a negative environmental effect.

If project activities that include the removal of vegetation will occur within the defined setback distances to water bodies (e.g. within 120 m of a lake), the impact of vegetation removal on the water body should be discussed further in the required supplementary report documenting any additional mitigation measures. Applicants should consult Chapter 8 for details on this report.

4.2.1 Impact to prime agricultural land

Impacts on the productivity of agricultural land should be mitigated during wind turbine or ground-mounted solar construction. For example, drainage and irrigation systems that enhance the productivity of the agricultural land should be maintained or improved.

Applicants should ensure internal roads to facility components (such as wind turbines and ground-mounted solar facilities) are located in a way that minimizes impacts on agricultural land. For example, roads should be placed along property lines or field boundaries to avoid bisecting fields. Width of internal roads should also be considered and not wider than necessary so they do not negatively impact surrounding agriculture.

4.3. Impacts to water resources

In the planning of construction activities, applicants should consult the MECP policies for managing the quality and quantity of surface and ground water. These are outlined in the following documents:

Water Management Policies Guidelines and Provincial Water Quality Objectives, 1994 Publication #3303e
Deriving Receiving Water-based, Point Source Effluent Requirements for Ontario Waters, 1994 Publication #3302e

Several impacts related to water resources should be considered in the Construction Plan Report, including:

Surface water runoff

Construction activities can change land surface properties that may result in a negative environmental effect related to changes in the quantity and quality of surface water runoff. Any activities that alter the surface properties of land or water drainage should be considered as a negative environmental effect that will or is likely to occur. Some examples include:

  • removal of vegetation
  • impervious surface treatments such as concrete or asphalt
  • re-grading land
  • compacting soils through use of heavy machinery

As part of the Design and Operations Report, a conceptual Stormwater Management Plan and Erosion and Sediment Plan addressing the design and operation of the facility is required to be prepared to address any potential for negative environmental effects, and include:

  • a description of any works for the collection, transmission, treatment and disposal of sewage,
  • a description of the expected quantity of sewage produced and the expected quality of that sewage at the project location and
  • the manner in which it will be disposed of, including details of any sediment control features and storm water management facilities.

When preparing the Construction Plan Report, MECP expects the same level of detail in respect of the construction activities.

Alternatively, a Stormwater Management Plan and Erosion and Sediment Plan addressing all project phases can be prepared as a stand-alone document.

MECP may require more detailed, site-specific Stormwater Management Plan and Erosion and Sediment Plan on a case by case basis. More information on Storm Water Management Plans can be found in section 5.3 of Chapter 4.

Impacts on water bodies

Some project components such as roads or transmission/distribution lines may be built in proximity to, or over water bodies. The construction may include temporary culverts, weirs, or diversion of streams, among other things. If such components could negatively affect the water quality and/or quantity, a description of such negative environmental effects is required. For projects where a supplementary report documenting any additional mitigation measures has been prepared, such a report may be referenced to support the description of the negative environmental effects that will or are likely to occur as a result of construction and installation activities. Applicants should refer to Chapter 8 of this guide for further information on the supplementary report documenting any additional mitigation measures.

In addition, the construction of project components near water bodies may trigger additional permit requirements from the federal Fisheries and Oceans Canada, as well as the Ministry of Natural Resources and Forestry (MNRF) and/or local conservation authorities. These organizations, where applicable, should be contacted early in project planning to determine the requirements of any additional permits. If such permits will address negative environmental effects described in the Construction Plan Report, they should be referenced.

Impacts related to water takings

If a project includes a proposal to take water from a ground or surface water source in order to conduct construction activities, such as when quantities of ground water are pumped from excavated areas, potential impacts on water resources must be described. An important negative environmental effect to consider is the potential for the project to interfere with existing uses of the water resource. If no impacts on water resources are expected as a result of water taking activities, a description of how that conclusion was reached should be provided.

Applicants are recommended to discuss any water takings with the MECP local District Office at an early stage in project planning.

To describe water takings under 50,000 L/day, applicants should provide the following information in the Construction Plan Report:

  • a description of the water taking (e.g. location, source, quantity etc)
  • any measures proposed to mitigate negative environmental effects that will or are likely to occur
  • conclusions about the magnitude and likelihood of the negative environmental effects

It should be noted that while all water takings must be described, for takings that involve small quantities below 50,000 L/day, an applicant may conclude that the negative environmental effects that will or are likely to occur are insignificant without preparing technical studies.

For water takings over 50,000 L/day, if the water taking is part of a project subject to the REA, the water taking does not also require a separate Permit to Take Water (PTTW) under the Ontario Water Resources Act. However, the description of water taking in the Construction Plan Report for a REA application should provide the information/assessments that would be normally required in respect of a PTTW application.

When an REA is issued, it is based on the information provided in the REA application submitted by the proponent. Therefore, proponents should carefully consider their water taking needs at the application stage, well in advance of applying for an REA. If a proponent anticipates circumstances where water taking could exceed 50,000 L/day, this should be addressed in their REA application. This will allow the MECP to proactively evaluate water taking needs and to consider what types of conditions to impose in the REA.

If a proponent realizes following the issuance of an REA that more than 50,000 L/day will be needed for the project, it may require an amendment to the REA issued for that facility, which could cause project delays. Please refer to Chapter 10 of this guide for details on the project change process.

If a proponent encounters extraordinary conditions (i.e. an infrequent storm event) following the issuance of the REA that necessitate additional water takings (i.e. construction dewatering) beyond what is permitted under their REA, they are advised to immediately contact the MECP's local district office. In this situation, proponents would be expected to provide a description with respect to the additional water taking that specifically describes the proposed measures to prevent impacts to any local water supplies (e.g., by either interfering with existing supplies or inducing mobilization of contaminated groundwater to impact local wells) and how discharge/return flows would be managed to similarly avoid impacts to any water supplies or the natural environment.

Following receipt of this and any other additional information requested by the ministry, MECP will provide the proponent with direction on how to address the situation, through its existing suite of compliance tools, to allow the project to proceed in a timely manner while maintaining environmental protection.

Applicants should use the table below as a starting point to determine the type of information that will be needed to describe the water taking. This table reflects the categories that apply to PTTW applications according to the MECP publication “Permit to Take Water (PTTW) Manual” (2005). Applicants proposing water takings should consult this manual for further direction on what type of studies and/or information must be submitted to the ministry in respect of water takings.

Ground water – Category 1 Surface water – Category 1 General requirements
Renewal (of an existing water taking) Renewal (of an existing water taking) Self-assessment
Ponds (e.g. irrigation and agriculture) Ponds less than 1500 cubic meters in volume Self-assessment
  Great Lakes or connecting channel takings less than 1,000,000 L/day Self-assessment
Ground water – Category 2 Surface water – Category 2 General requirements
Short-term, non-recurring taking less than 7 days (e.g. pumping test and hydro-static test). Great Lakes or connecting channels takings less than the Great Lakes Charter threshold (19,000,000L/day) Engage qualified person to complete screening level evaluation schedules as defined in the PTTW manual
Short-term, non-recurring taking less than 30 consecutive days and less than 400,000 litres/⁄day (e.g. construction dewatering and dust suppression)
  • Takings from sources with previous assessments
  • River and Streams (3rd order or higher order)
  • Transitional Permits
  • Takings and Returns where water is removed for a short time only
  • Lakes and Ponds takings less than 1,000,000L/day twice per week
Engage qualified person to complete screening level evaluation schedules as defined in the PTTW manual
Ground water – Category 3 Surface water – Category 3 General requirements
All ground water takings that do not meet Category 1 or Category 2 criteria All surface water takings that do not meet Category 1 or Category 2 criteria Full technical assessment required as defined in the PTTW manual

Note: A sensitive feature includes a stream and/or wetland and/or dug well or dugout pond owned by a different person.

Water taking EASR

Engaging in some aspects of a renewable energy project may require registration on MECP's Environmental Activity and Sector Registry (EASR) for Water Taking. The EASR is a risk-based environmental approvals program which requires businesses to register prescribed activities in the EASR (such as water taking).

During the renewable energy project, if you engage in EASR eligible water taking activities you may be required to register those activities on the EASR.

To determine if your water taking is eligible for registration on the EASR, see the water taking user guide for environmental activity and sector registry or O. Reg. 63/16.

Common types of projects that may be eligible for registration:

  1. surface water takings that are more than 50,000 L/day and are for highway projects and transit projects purposes that meet specified criteria about the purpose, rate or location of the water taking
  2. construction site dewatering involving more than 50,000 L/day and less than or equal to 400,000 L/day of ground water, where the daily taking limits are applicable to:
    • each area of influence in the construction site if the area of influences do not overlap with each other
    • the combined area of influence in the construction site if the area of influences overlaps with each other
  3. seven-day pumping tests conducted in a 30-day period that take more than 50,000 L/day and less than or equal to 5,000,000 L/day

It is anticipated that conditions of a REA will pre-authorize these activities so that an amendment to a REA is not required.

4.4. Spills

Fuels and other chemicals (including dry materials) used for construction and installation activities can cause negative environmental effects if they are spilled during fuelling or storage. If the planned construction activities present the potential for fuel spills this should be described. Reference can be made to the Emergency Response and Communications Plans included as a component of the Design and Operations Report.

The Environmental Protection Act places specific duties and obligations on persons with respect to spills. Anyone involved in the construction of a renewable energy project should be familiar with their legal obligations in the event of a spill before beginning construction.

4.5. Impacts on cultural heritage (protected properties, archaeological and heritage resources)

In preparing a complete REA application, applicants must determine whether there are any protected properties described in Column 1 of the Table in section 19 of O. Reg. 359/09, on the project location. If it is discovered that the project location is on a protected property, applicants must obtain authorizations by the Ministry of Heritage, Sport, Tourism and Culture Industries (MHSTCI) related to protected properties prior to beginning construction.

Applicants must also identify what archaeological resources, heritage resources and abutting protected properties are present at the project location through the archaeological and heritage assessment processes. Applicants are encouraged to engage a consultant archaeologist and/or heritage consultant at an early stage in project planning to prepare an archaeological assessment and/or heritage assessment that will consider impacts to cultural heritage resources and provide recommendations for appropriate avoidance or mitigation measures.

Applicants may also choose to self-assess for cultural heritage resources by completing MHSTCI screening checklists:

Screening should be undertaken early in the application process in order to ensure that archaeological and heritage resources will not be impacted.

If it is discovered that there is potential for heritage and/or archaeological resources through the screening checklists, an archaeological assessment, heritage assessment, or both, must be conducted that recommends appropriate avoidance, mitigation measures, etc., consistent with O. Reg. 359/09 and guidance from the MHSTCI. Not all renewable energy projects require a heritage assessment. Section 20 of O. Reg. 359/09 outlines the specific conditions that determine if an archaeological assessment is required.

4.6. Impacts on local roads and traffic

The construction phase of a renewable energy project could involve considerable vehicular traffic related to the movement of equipment and materials on and off site. There is potential for negative environmental effects to occur with respect to impacts to the road infrastructure and/or the traffic flow on roads in the vicinity of the project. All negative environmental effects should be described in the Construction Plan Report (and in the PDR, as given in section 5 of Chapter 4).

The applicant may determine that a Traffic Management Plan is the only way to adequately evaluate the impacts on local traffic flow and propose appropriate mitigation measures. A Traffic Management Plan will also assist with consultation with the municipality or municipalities, which may have valuable suggestions regarding the management of traffic based on municipal expertise and knowledge of local traffic issues.

Further guidance on potential content for a Traffic Management Plan is given in section 5.6 of Chapter 4.

5. Mitigation measures

For each negative environmental effect that will or is likely to result from construction and installation, the applicant is required to describe any mitigation measures proposed. Mitigation measures can include:

  • modifying the types of construction activities engaged in
  • installation of additional treatment technologies such as those that remediate or contain discharges of contaminates
  • changing the schedule or operational practices of construction activities

Any mitigation measures proposed should support conclusions about the magnitude or likelihood of the negative environmental effect they are proposed to mitigate. The mitigation measures should be described in sufficient detail so that they can be reviewed by the MECP to determine their adequacy. Where appropriate, applicants are recommended to include details on any risks to the efficacy of a mitigation measure. For instance, a storm event may pose a risk to sediment control measures proposed.

Mitigation measures will also be discussed in consultation with municipalities to determine potential impacts on provision of municipal services. See Chapter 2 for more information on consultation requirements and guidance on preparing the Consultation Report.

The examples below illustrate different approaches to mitigation and the information that could be presented to describe them:

Modification to construction activities

An example of a modification to a construction activity is where horizontal directional drilling is used to install a subsurface transmission/distribution line as opposed to a trench installation. This technique may mitigate impacts on water bodies or natural features under which the line is installed. If such a mitigation measure is proposed, the information required in the Construction Plan Report to describe the measure would include a description of the equipment used for installation and any additional negative environmental effects that will or are likely to occur as a result of the horizontal directional drilling equipment itself.

Treatment technologies

An example of the use of treatment technologies is the use of sediment containment structures such as siltation fencing or storm water management ponds to mitigate negative environmental effects on a water body due to storm water runoff. In this case, the structures/equipment should be defined with respect to their location, technical specifications, and duration of installation. Information on how these structures will be monitored, operated and maintained must also be provided. The report must also describe how any repairs required to address construction-related damage to structures such as storm water management ponds will be made. If the equipment is designed to achieve a performance objective such as a concentration limit, the applicant should describe how the technology will be monitored and maintained to ensure proper function. In some cases, the treatment technologies used for mitigation will be more fully described in a supplementary report documenting any additional mitigation measures or a Storm Water Management Plan or another report, as applicable. Details of mitigation measures contained in these other reports can be referenced in the Construction Plan Report, where applicable.

Scheduling and operational changes

Examples of how scheduling and operational aspects of construction and installation activities can mitigate impacts include:

  • conducting excavations on days with low wind to prevent dust emissions and using water to control the dust
  • operating loud machinery during daytime hours only
  • planning material and equipment deliveries outside of rush hour periods to mitigate traffic flow impacts
  • timing construction activities in wildlife habitats to be outside of periods of wildlife use (e.g. breeding period, migratory period)

When describing these measures, the specific criteria for determining the timing of activities should be discussed (e.g. what would constitute a windy day?) and rationale should be given for such determinations.

6. Environmental monitoring

Environmental monitoring of the identified negative environmental effects that will or are likely to occur from construction should be proposed in addition to the mitigation measures. Where the likelihood of a significant negative environmental effect is low, the applicant may also propose a monitoring approach in lieu of a mitigation measure.

While an Environmental Effects Monitoring Plan (EEMP) is not a specific requirement of the Construction Plan Report, it is a requirement of the Design and Operations Report as described in Table 1 of O. Reg. 359/09. If monitoring related to a negative environmental effect that will or is likely to occur from construction is proposed, the details should be added to the EEMP of the Design and Operations Report. Applicants may consider referencing the Design and Operations Report in the Construction Report Plan where relevant, to describe monitoring.

Any monitoring approach proposed should be described in sufficient detail, including:

  • methodologies to be used
  • sampling protocols (where and when, quality assurance)
  • performance objectives used to evaluate effectiveness

The description should also identify, where applicable, what actions will be taken if monitoring reveals that negative effects are occurring, as well as a contingency plan should mitigation measures fail.