TAMRMS#: B06
9.1
Information Item Only
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Analysis on Addition of Construction Debris Management Plan to Development Agreement
Presented by: Johnathan Reid, Manager, Development Engineering, Engineering Services
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SUMMARY
During the construction debris presentation to council on April 07, 2026, a new motion was introduced to analyse a requirement for developers to include a Construction Debris Management Plan in the development agreement for new subdivisions.
Administration reviewed the proposed Construction Debris and Site Management Plan by examining the City of Leduc’s requirements as requested, a scan of other municipalities in the province, St. Albert’s current Development Agreement requirements, St. Albert’s Community Standards Bylaw, and other applicable regulations. The review found that many of the elements contained within Leduc’s plan are already addressed through existing legislation, bylaws, agreements, and municipal standards. While consolidating these requirements into a single Construction Debris and Site Management Plan could improve clarity and reinforce expectations for developers, the practical effectiveness of such a requirement would be limited by its scope and enforceability. If adopted, the requirement would apply only to future developments and would not affect existing or active Development Agreements.
Administration does not recommend the adoption of a Construction Debris and Site Management Plan as an addition to the Development Agreement as the intent behind this motion is being met through existing provisions without creating this additional administrative document which would provide negligible meaningful incremental benefit.
ALIGNMENT TO COUNCIL DIRECTION OR MANDATORY STATUTORY PROVISION
On April 07, 2026, Council passed the following motions:
(BL-26-008 - Reducing Construction Debris in Neighbourhoods (Amendment #4 to Bylaw 21/2014)
That Administration provide Council an update for how Construction Debris Management Plans will be part of any new or existing Development Agreements with costs and impacts to Council for consideration by July 14, 2026.
BACKGROUND AND DISCUSSION
A review of the various components of this request was completed, including the comparison of requirements from the City of Leduc, the current City of St Albert Development Agreement requirements, the Community Standards Bylaw, and other applicable regulations. No other municipalities in the Edmonton region that were contacted had a separate agreement for a Construction Debris Management Plan, but instead used their Community Standards Bylaw, Construction Standards Bylaw, or their Development Agreements to address any concerns with regards to construction debris.
The City of Leduc’s sample Construction Debris and Site Management Plan (Attachment #1) outlines the areas to be addressed by the developer, including:
• Site regulations
• Site housekeeping
• Street cleaning
• Semi-annual community cleanup
• Garbage receptacles
• Hazardous materials
• Existing infrastructure
• Clean fill and concrete dumping
• On-site music
• Pets on site
• Washroom facilities
• Safety
While these plans demonstrate a commitment to maintaining a clean neighbourhood, their applicability is limited to lands governed by the Development Agreement. They do not extend to lands owned by builders or those already transferred to the City. As such, the requirements apply directly to the developer, who would be responsible for ensuring builder compliance. The City retains the ability to clean and recover costs; however, this is limited to road rights-of-way and boulevards, excluding private lands and City-owned parcels.
Many of the listed requirements are already addressed through both the City of St Albert’s and Leduc’s existing frameworks, including Occupational Health and Safety legislation, Community Standards Bylaws, the Development Agreement, Engineering and Environmental Standards, and the Street Cleaning Agreement.
The City of Leduc’s Sample Construction Debris Management Plan - Stage 8 (Attachment #2) created by a developer for the City of Leduc outlines construction processes, including limiting the number of builders, maintaining architectural controls, and conducting cleanups on an as-needed basis. However, cleanup frequency is left to the developer’s discretion rather than being defined by the City. Although it references two major cleanups annually, this again applies only within lands governed by the Development Agreement. Areas outside this scope-such as stormwater management facilities, parks, and roadways already turned over to the City-are excluded.
Additionally, the management plan would only remain in effect for the duration of the Development Agreement. Construction occurring after issuance of the Final Acceptance Certificate (FAC) would fall outside its scope, leaving no mechanism for developer-led enforcement or cleanup. This gap is already evident in completed areas with vacant lots. Beyond the FAC, the Community Standards Bylaw could still be utilized where applicable.
Within the language of St. Albert’s Development Agreement, the provisions to keep clean the area within the agreement already exist. Any new language that is added via a new document could add a layer of complexity to the agreement. This layer of complexity, if not aligned with the existing template, could cause a new issue of enforceability from a legal position and may end up having unintended consequences. A review of the current Development Agreement (Attachment #3) identifies the following requirements under section 9.6:
9.6 The Developer must ensure that:
(a) the Development Area is kept in a reasonably clean and tidy condition including mowing the grass on the Development area and eliminating weeds, refuse, litter and undesirable vegetation, all as the City Engineer in the City Engineer’s sole discretion may require;
(b) no debris or garbage from the Development Area goes into the City’s storm sewers, the Sturgeon River or any other watercourse; and
(c) all reasonable steps are taken to limit mud and dust from leaving the Development Area, including, in the case of mud, being tracked onto Public Lands.
These provisions are similarly limited to the Development Agreement area and do not extend beyond its defined boundaries. While they do not prescribe specific cleanup frequencies, they provide the City with authority to require maintenance as deemed necessary by the City Engineer, effectively addressing the intent of a Construction Debris Management Plan. As noted previously, beyond the FAC, the Community Standards Bylaw could still be utilized where applicable. Refuse or debris that ends up on city-owned land would be the responsibility of the City to clean, however.
STAKEHOLDER COMMUNICATIONS OR ENGAGEMENT
Engagement with the City of Leduc confirmed that its management plan primarily serves as a consolidation document for existing requirements rather than having introduced significant new obligations.
Responses from representatives of BILD indicated a desire to implement the tools at hand (e.g. development agreement, Community Standards Bylaw) within St. Albert rather than to create a new consolidating document.
ALIGNMENT TO PRIORITIES IN COUNCIL’S STRATEGIC PLAN
The proposal aligns with the City’s Corporate Business Plan intent under Community Well-Being - supporting cleanliness, accountability, and clearer expectations - but its impact is limited by scope and lack of enforceability. The measures proposed do not change any existing rules and are limited by the scope of the Development Agreement. The measures proposed could also result in confusion related to enforceability.
Initiative aligned with Strategic Plan:
Not Applicable
ALIGNMENT TO LEVELS OF SERVICE DELIVERY
The implementation of the proposed requirement would add additional cost and time resources in drafting a consolidation document. Benefit to the City is anticipated to be negligible.
It should also be noted that if adopted, this requirement would apply only to new developments. Existing or active development agreements would not be affected.
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Report Date: July 14, 2026
Author(s): Johnathan Reid, Manager, Development Engineering
Department: Engineering Services
Department Director: Dawny George
Managing Director: Adryan Slaght
Chief Administrative Officer: William Fletcher