This brief contains the comments of West Coast Environmental Law in regard to the
Interim Report of the Advisory Panel on Contaminated Sites, released on September 3,
2002. The panel was appointed by Joyce Murray, Minister of Water, Land and Air
Protection on May 14, 2002 to review the contaminated sites provisions in Part 4 of the
Waste Management Act and the Contaminated Sites Regulation.
Since 1974, West Coast Environmental Law has provided environmental law research,
representation and education services to promote protection of the environment and
public participation in environmental decision-making. West Coast empowers citizens
and organizations to protect our environment and advocates for the innovative solutions
that will build a just and sustainable world.
West Coast Environmental Law is concerned with the lack of rigorous analysis in the
Report, both in terms of its critique of the current contaminated sites regime, and in its
recommendations for a new regime. The lack of rigour in the panel’s recommendations
makes them difficult to respond to as it is often very unclear what exactly is being
Nonetheless, we are very concerned that many of the recommendations will lead to
changes that will reduce the environmental effectiveness of the Contaminated Sites
regime and an increased burden on taxpayers to fund clean up of sites that previously
would have been cleaned up by the parties benefiting from contaminating activities.
This brief begins with a series of general comments, followed by comments specific to the
sections of the interim report.