The City of Brantford is…

ERO number

013-0299

Comment ID

309

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The City of Brantford is concerned about the impacts of the timing of the proposed regulation for the municipalities. It’s financial burden is ambiguous in regards to the proposed process and impact on municipal projects and operations

The following points are concerns related to the financial impact.

•financial impact to capital budgets

•administrative burden and related costs to develop and manage the program

•additional costs associated with soil investigations, prior, potentially during and post

•staff training or new hires that have knowledge of the regulations

•costs to hire a consultant to develop a program

•consideration for a cost recovery fund to help financially subsidize the impacts to comply with the regulations

•lack of a financial analysis with regard to the impacts

The following points are concerns related to implementation.

•lack of time to understand the new regulations

•require a transition period for municipalities to understand the regulations to plan and implement the program

•potential for longer time frame for tendering and delay in scheduling projects( secure approved receiving sites )

•potential delay in projects as a result of a lack of useable sites

•burden for municipalities to find receivable sites, which was previously a contractor responsibility

•time required to evaluate receiving sites to ensure compatibility with the quality of the excess soil

•enforcement of illegal dumping

•impacts on the purchasing process

•risk of non-compliance due to timing for implementation

•difficult to implement as the current budget and design process in place for 2018

•loss of municipal landfill capacity if usable sites are not available

•additional liability to municipalities

These staff comments will be provided to our City Council in August. Additional input will be provided following the City Council meeting on August 22, 2017

[Original Comment ID: 209805]