Waterfront Toronto thanks…

Waterfront Toronto thanks the Ministry for the opportunity to comment on this regulatory proposal. We acknowledge that there have been some challenges in the implementation of the planning requirements under the excess soil regulation, and that these primarily relate to understanding the various exemptions that may apply to our projects.

However, to this point we have undertaken best efforts to ensure compliance with the requirements that have come into effect on January 1, 2022. Given that these requirements have been in effect for three months now, and that we have been complying with them, we don't consider there to be value in further pausing the implementation of the planning requirements. It may be likely that the delays would just create confusion within the industry and result in a similar situation in a few months' time.

Instead, we suggest that the Ministry could provide additional assistance to proponents with the implementation of their requirements under the excess soil regulation rather than delaying these requirements. A temporary suspension or phase-in of enforcement actions including a delay in implementation of administrative penalties or fines would buy some goodwill with proponents while we come to an improved understanding of the requirements of our specific projects. It would also be beneficial if the Ministry could provide avenues for project-specific questions to be reviewed and answered in consultation with Ministry staff.

Again, we thank the Ministry for affording us the opportunity to comment, and would welcome the opportunity for further dialogue.