TRACK 2, DAY 2
City of London Guidance Document for CLI ECA Schedule F: SWM Pond Sediment and Excess Soil Beneficial Reuse Evaluations
Francine Kelly-Hooper, GHD Ltd. and Jeff Hachey, City of London
Wednesday, April 1, 2026 | 9:00 a.m. to 9:30 a.m. | Hall F
ABSTRACT
O. Reg. 406/19 (the Regulation) governs the beneficial reuse of soils and stormwater management pond (SWMP) sediment as excess soil. The City of London’s Infrastructure Renewal Program (IRP) is an annual program intended to maintain the lifecycle and operation of municipal infrastructure at an acceptable level of service, and the Regulation is generally not applicable to excess soil that has been generated at IRP project sites, given certain project exemptions.
The Rules for Soil Management (updated October 2025) and Excess Soil Quality Standards (ESQS) allow alternative Environmental Compliance Approval (ECA) “instruments” to identify beneficial reuse options for sediment and soil that cannot be reused as excess soil due to exceedances of the ESQS. O. Reg. 208/19 Environmental Compliance Approval in Respect of Sewage Works, offers an alternative ECA instrument through Schedule F (residue management) of the Consolidated Linear Infrastructure (CLI) ECA process.
At the present time, the Ontario Ministry of Environment, Conservation and Parks (MECP) has not received any Schedule F CLI/ECA applications and there are no guidance documents for how this application process may be completed.
The City of London and GHD Ltd. have developed a guidance document proposing text for Schedule F of the CLI ECA to provide direction for due diligence excess soil sampling and analysis for projects exempt from certain Regulatory requirements to ensure an appropriate and consistent level of sampling and analysis is completed across projects which are governed by the CLI ECA document, as well as provide enhanced opportunities so that excess soils and sediment may be beneficially reused as cost effective and environmentally sustainable alternatives to waste disposal.
Consultation with MECP is underway and any feedback received will be presented.
ABOUT THE PRESENTERS
Francine Kelly-Hooper, GHD Ltd.
Dr. Francine Kelly-Hooper is GHD’s Canadian Sediment Lead and Hydrocarbon Forensic Specialist, with over 20 years of experience in the government and private sectors.
Francine completed her PhD at the University of Waterloo in 2013, where she developed the Biogenic Interference Calculation (BIC) method for identifying petroleum hydrocarbon sources in soils and sediments. Her 20-year Canada wide SWM pond sediment survey has compiled chemistry profiles for 425 samples collected from 140 ponds.
Francine and her team continue to work with government agencies on the development of a new approach to SWM sediment beneficial use evaluations.
Jeff Hachey, City of London
Jeff Hachey is a hydrogeologist, environmental engineer, and the Division Manager of Stormwater Engineering at the City of London.
Jeff is a Qualified Person (QP), as defined by Ontario Regulation (O.Reg.) 153/04 and O.Reg. 406/19, with 20 years of technical experience, spanning both private and public sectors. Jeff obtained a B.Sc.E at the University of Western Ontario in 2003, and an M.Sc.E Degree at Queen’s University in 2006, where his primary research focus was assessing flow and contaminant transport in fractured bedrock groundwater systems
His private sector work experience includes groundwater flow model development, capture zone delineation water budget calculations and analysis, landfill studies, hydrogeological field investigations, environmental baseline studies, and carrying out Phase I, II, and III environmental site assessments (ESAs), and remediation activities at numerous sites across Canada.
Jeff currently holds a position within the MEA’s Excess Soil Working Group and is the City of London’s lead environmental engineer in managing and navigating Ontario Regulation 406/19 requirements.