Ministry of the Environment,…

Ministry of the Environment, Conservation and Parks
Environmental Registry of Ontario (ERO) Submission

Subject: Response to Enabling greater beneficial reuse of excess soil
ERO Number 019-9196

On behalf of Oxford County, we are writing to provide feedback on the proposed amendments to Ontario Regulation 406/19, specifically regarding the requirements for wastewater generated from liquid soil (vac truck slurry) and conditions for exempting small liquid soil depots from the need for a waste Environmental Compliance Approval (ECA).
We appreciate the Ministry's ongoing efforts to encourage the sustainable reuse of excess soil while maintaining a strong commitment to environmental protection. Below, we outline our key comments and recommendations regarding the proposed amendments:

Section 2. Small Liquid Soil Depots
This section of the amendment outlines that:

As a condition of exemption from the requirement for a waste ECA, the small liquid soil depot must have appropriate facilities where any wastewater and liquid process residues (i.e., sewage) from dewatering the liquid soil must be collected and that sewage must be discharged to a sanitary sewer or hauled to and disposed of at a wastewater treatment facility governed by a s. 53 ECA.

Oxford County relies on our existing Sewer Use By-law, which has been broadly adopted across Ontario municipalities, to prohibit the disposal of any material that could negatively impact the solid waste stream or compromise biosolids quality. This by-law is a critical tool in safeguarding against contaminants that could render biosolids ineligible for land application, which is a key component of sustainable wastewater management.

We urge the Ministry to prohibit the discharge of materials that may impact the integrity of the collections system, treatment plants, and biosolids if they do not meet the standards specified in the Municipal Sewer Use by-laws. As such, we recommend that soil slurries be directed to landfills or private facilities equipped for treatment and remediation.