The proposal to eliminate…

The proposal to eliminate Section 14 from Regulation 406/19 is problematic. Project Leaders as defined in the Regulations are not required to have competencies in determining whether or not a site is potentially contaminated. The fact that the site may be agricultural does not preclude the possibility that manure, fuel, long-lived herbicides or some other hazardous chemicals may have been used, applied or spilled and remain a hazard at the site. As well, in the case of residential and institutional use sites, heating oil, and herbicides may have been applied or spilled and remain in the soil. As a minimum, a Phase 1 Site Condition Assessment should be carried out by a qualified person as prescribed by MECP and, depending on the results, actual field sampling and analysis conducted and documented by a qualified professional, again to the standards set by MECP.

It wasn't that long ago that the potable water supply of the town of Walkerton ON was contaminated by manure runoff from an agricultural field adjacent to one of the town's supply wells and led to the death of a number of residents. Land developers and aggregate companies are lobbying to have excess soil regulations weakened so that excess soil can be more easily disposed of in mined aggregate pits, at great profit to both parties. Without proper controls such practices can lead to groundwater contamination of regional water supplies and individual wells. We as a society need to proceed with caution not agree to every demand that developers and industry make.