1. Community Standards in…

1. Community Standards in Aggregate Reuse Depots
• Question: What is meant by "community standards" in the context of aggregate reuse depots? Are these standards intended to align with specific tables such as Table 1, Table 2.1, or Table 3.1 in the ESQS?
• Clarification Needed: In Ontario’s soil reuse context, "community standards" typically refer to soil quality criteria based on land use (residential, parkland, agricultural, industrial/commercial) that ensure human health and environmental protection. This aligns with standards in tables like Table 1 (Background Site Condition Standards), Table 2.1, and Table 3.1 (Generic Site Condition Standards) under O. Reg. 153/04, where soil quality must meet the applicable standards for the reuse site’s intended use. However, it would be helpful for MECP to confirm if "community standards" refer specifically to these tables or if other parameters are considered based on community input or local risk factors.

2. Definition of "Engineered Aggregate"
• Question: What exactly qualifies as "engineered aggregate" in the context of aggregate reuse depots?
• Clarification Needed: "Engineered aggregate" typically refers to aggregate material specifically processed or modified for use in construction or infrastructure projects to meet certain structural and durability standards. This may involve mixing materials or treating aggregate to achieve desired strength, stability, or permeability properties, ensuring suitability for specific engineering applications like road base, drainage layers, or construction fill. To be used within regulatory standards, "engineered aggregate" must meet quality criteria for its intended purpose and align with excess soil and aggregate reuse regulations (O. Reg. 406/19).

3. Naturally Occurring Exceedances in Aggregate and Excess Soil
• Question: Should naturally occurring exceedances in aggregate (such as those found in aggregate and Stormwater Management Ponds (SWMP) sediment) be considered for excess soil reuse without restriction?
• Clarification Needed: Naturally occurring exceedances can impact many excess soil projects, not just aggregate and SWMP sediment reuse. Could these naturally occurring background levels be accounted for more broadly, allowing for excess soil reuse where background levels are similar to, or even lower than, those in aggregate or SWMP sediment?

4. Post-Dredging Sampling vs. Ex-Situ Sampling for SWMP Sediment
• Question: How does post-dredging confirmatory sampling differ from current ex-situ sampling requirements, which also requires sediment removal and dewatering prior to sampling?
• Clarification Needed: In the case of SWMP sediment, the additional post-dredging confirmatory sampling requirement seems redundant, as ex-situ sampling typically takes place after removal and dewatering. Could MECP clarify how these two sampling approaches are differentiated and if this process can be streamlined to reduce potential redundancy while maintaining environmental safety?

5. Addressing Naturally Occurring Local Background Concentrations for Short-Term Reuse
• Question: What is the short-term solution to managing naturally occurring local background concentrations of specific substances, given that developing maps and studies is a long-term approach?
• Suggestion for Interim Measures: Could Record of Site Condition (RSC) records, completed and approved in local areas, serve as interim reference points for naturally occurring concentrations? Currently, the lack of allowance for "writing off" naturally occurring local background concentrations places limitations on soil reuse, especially in cases where naturally occurring levels are within safe reuse standards but exceed regulatory thresholds.