In Section 11 of the…

ERO number

013-5000

Comment ID

32440

Commenting on behalf of

Crosslinx Transit Solutions - Constructors

Comment status

Comment approved More about comment statuses

Comment

In Section 11 of the Proposed Ontario Regulation: Before depositing specified excess soil, landfilling site or dump

This Section is interpreted that reusable excess soil is restricted from being deposited in landfills or dump sites. Implying that this may be subject to fines or penalties. Although landfills and waste sites are not and should not be the primary solution for reusable excess soil, it can occasionally be the only solution at times, when reusable fill sites are shut down for maintenance, afterhours work/weekends, or due to weather constraints. In large infrastructure projects, the main driver is schedule and when this becomes compromised, alternate disposal options are crucial and necessary in keeping up with strict construction production.

As a potential alternative, I recommend the following amendment to Section 11:

(4) Despite subsection (1), the deposit of excess soil described in subsection (2) is permitted at a landfilling site or dump if all reusable fill sites approved to accept the excess soil from the Project are temporarily out of service, closed for maintenance, closed during afterhours and weekend shifts, or other reasons of the like. The project leader will inform the qualified person of the decesion, and if the qualified person agrees with the rationale, the excess soil may be deposited at a landfilling site or dump.