The proposed change to…

The proposed change to exempt low risk sites adds more complexity in interpreting this regulation with respect to naturally occurring parameters. If naturally occurring parameters exceeding these new soil standards (for example, shale) is no concern when excavated from a residential/agricultural property, then should it not be a concern if excavated from a commercial/industrial property?

Also, 10,000 m3 limit on stockpile size is still not sufficient when considering the amount of soil produced in residential suburb developments and linear transit projects. Putting a cap on stockpile size in general contradicts the intent of this regulation to reuse soil and forces the contractor to send it off site because of some arbitrary limit that has no bearing on soil quality. Since the concern with large stockpiles appears to be with dust and erosion and sedimentation, dust and ESC control measures on stockpiles should be required for stockpiles exceeding a certain size. This gives the contractor more flexibility to reuse soil on their site.

Finally, I'm disappointed the MECP haven't addressed comments on previous EROs and webinars. Many questions remain for the boots on the ground trying to implement these regulations and it is costing A LOT of Taxpayer/End User money.