Rescinding the soil…

ERO number

019-6240

Comment ID

73111

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Rescinding the soil regulations for “low risk” sites will allow illegal dumping to continue unabated. Illegal dumping has been a big problem for rural municipalities. Without the soil registry and tracking, how can we expect a receiver of soil, and the municipality enforcing its site alteration bylaw, be assured that the thousands of truck loads came from a “low risk” source site? If the soil can not be traced back to the responsible parties the unsuspecting land owner is responsible for all cleanup costs and fines. If a site is truly low risk, an assessment of past uses is not any more onerous or expensive than any other planning or study that should be undertaken before developing a property. Registering a site in the Excess Soil Registry (https://rpra.ca) is done online and is effective immediately. Commercially available load tracking systems provide additional business benefits and can be implemented in 20 minutes (http://soilflo.com). The regulations do provide exemptions from the registry and tracking and other sections for very low risk sites and operations. Abiding by the soil regulations is not a significant
cost or delay to the development of land that is truly low risk.

These supposed “low risk” lands in agricultural, residential, parkland, or institutional use were included in the soil regulations after much research, consideration, and collaboration. The accompanying rationale document is 107 pages long and references 183 scientific publications. The soil regulations must not be tossed out on the request of a few developers. Rescinding the soil regulations for “low risk” sites may provide a small savings to a developer excavating the soil but only by passing all the costs and all the out-sized risks to the land owner and to the municipality receiving the soil.

The Provincial Government must dump this proposal.