Comment
1) From page 5, regarding expanding the placement of salt-impacted soils. The first bullet states that as an example “a licensed landscape architect” could decide on the placement of salt-impacted soils at community, institutional, parkland or residential use sites. I don’t believe that a licensed landscape architect has the knowledge to decide if “salt-impacted soil can be used without affecting existing or future anticipated vegetation, and the acceptable concentration of the salt-related contaminants in these areas”. This role should be only for a QP-RA as defined by O. Reg. 153/04. I believe that the licensed landscape architect can pick the vegetation but not the soil contaminant concentrations.
2) From page 6, regarding the volume of dry soil to be exempt from hauling records. I think the volume should be increased to 10 cubic metres, as the typical volume of one dump truck load is 10 cubic metres. This would make estimating the volume of the load much easier and more practical.
3) From page 8, regarding the use of a Phase Two ESA as a SCR. Can you definition be expanded to include all O. Reg. 153/04 Phase Two ESAs, not just reports from an RSC site, i.e., none RSC sites?
Submitted November 28, 2023 11:09 AM
Comment on
Proposed regulatory amendments to encourage greater reuse of excess soil
ERO number
019-7636
Comment ID
94938
Commenting on behalf of
Comment status