"This proposal would not…

"This proposal would not have a significant environmental impact as important rules regarding the management of excess soil remain in place or are clarified. For example, exemptions from waste ECAs are accompanied by regulatory rules to ensure there is no adverse effect to human health or the environment. Options for greater reuse of aggregate material with exceedances include criteria that must be followed to prevent adverse impacts, such as only allowing reuse in specific types of projects."

This quote from the ERO capsulizes the problem with these proposed amendments. Recent past history has clearly shown provincial ministries lack the funds, staff and support to effectively monitor and enforce "important rules", "regulatory rules" and "criteria" (Auditor General's Report 2023 on the Aggregate Industry).
This failure to adequately enforce existing rules, criteria and thresholds is only exacerbated by these proposed amendments to Ont Reg 406/19, which decrease the use of Environmental Compliance Assessments (ECA), increase the "flexibility" regarding soil contaminant thresholds and use of soils with unknown contaminant potential, and increase contamination potential with "in situ" sampling. And all of these amendments that significantly increase the risk to our environment, guaranteed because of ineffective monitoring and enforcement, are for the purpose of reducing industry time and cost by a minuscule percentage of the industry's total soil management time and cost. A time and cost that were factored in when the provincial government first legislated these rules, regulations, criteria and thresholds, little knowing they would never be effectively applied and then further compromised by a new government's amendments.
Let's be clear that excess soil even effectively managed, poses a huge risk to our provincial community's health and economic future. Ineffectively managed as these proposed amendments ensure, guarantees our province will saddle the immediate future with massive, multiple "Walkertons" and with full awareness by the regulatory board's that approve them..

Starting with the 2019 Excess Soil Regulations, then the Soil Rules document and now the amendments, there has been an ever increasing laxity in