Why is soil considered a…

Why is soil considered a waste material while in transit? Unless it's identified as contaminated, I would consider soil a resource material. There are already regulations in place to deal with contaminated material.

Developers treat all excess material as resource. The are also economically fiscal and do their best to avoid additional costs, such as truck material across the City. Partnerships are created between contractors and developers who have excess soil with those who are short nearby. Market conditions prevail, ensuring the material is used locally. Regulations are already in place requiring external soils to be tested and meeting certain standards to be used as backfill. Why add additional regulations? It will become more red tape to go through, adding additional costs to housing when constructing subdivisions and further delays delivery these homes. What if no site can be found because it wasn't formally approved? Yet there are places that could use fill that are prevented from making a deal to obtain fill? Again, contaminated material has to be dealt with appropriately and is recognized as falling under other regulations.

If the process of moving fill from one development site to another nearby site becomes to onerous, developers may decide to treat excess soil as a waste material and have it trucked off to an approved dump site further away. Doing exactly the opposite of what this regulation desires, reducing trucking and emissions.

What is the end purpose of this regulation? Of what I can see, it states to keep track of fill movement. But for what purpose is needed to keep track of clean material? What is the end goal?

It should not be responsibility of the source site owner to ensure the trucker fulfills their contract and deliver to the correct site. Everyone involved must be accountable for their part in the contract, and fulfill their duty to follow the plan. Contractors often use, subs who are subs of subcontractors for trucking. It's very difficult for a site owner to ensure all the subs follow what is in the contract. The only way to do that is to make them just as accountable to outcome.

If this is to be implemented, the Ministry must spend time looking at ways to simply the process such as bulk movement and record keeping. Development sites can take 10 to 15 years until they are fully constructed. Cut/fill operations are planned looking at the entirety of a project. If the processes is too onerous, this will lead to the 'good developers' who would normally respect and follow the rules being forced to becoming the 'bad guys' and hiding excess material. Increasing the problem rather than solving it.

Housing affordability is a huge concern in Ontario. Added costs to register soil movement, the administration of management movement of soil to the degree spelled out in this regulation will be passed down onto home owners, further increasing the cost of affordability. It's important to look at the big picture and ensure it's understood what the real purpose of the regulation is, ensure it's simple to implement and follow at very little cost because these things have an impact on other Provincial initiatives.

[Original Comment ID: 209848]