The proposed regulations are mainly positive to continue the improvement of the protection of human health and the environment. The beneficial reuse of excess soils is an excellent direction to take for the MOECC as it should reduce the transportation costs involved with excess soil and subsequent greenhouse gases.
Deeming all excess soils as a waste upon removal from a site is aggressive and will initially be a difficult process for land developers, contractors and municipalities to implement.
Temporary locations for excess soil will be critical to the success of the proposed changes. Without enough appropriately located temporary locations, we could see more soil go to landfill than intended with these modifications to construction projects.
Providing clear definitions will be important for the situation when depositing excess fill to an infrastructure project, if it originates from an infrastructure project belonging to the same proponent. The timing definitions will also be important. (i.e. what if there is a delay between the projects?)
It is good to see that the MOECC is concurrently proposing other amendments that would help to reduce burden and enhance clarity of Ontario Regulation 153/04.
[Original Comment ID: 209757]
Submitted February 8, 2018 1:42 PM