"2Remove requirements for…

"2.Remove requirements for waste Environmental Compliance Approvals (ECAs) for third-party storage and processing of excess soil at aggregate reuse as well as small liquid soil processing sites, with regulatory rules to be followed instead (note: this is a revised proposal from what was previously proposed in October 2023; see ERO 019-7636)."
-more information needs to be provided that explains the research based decision behind why eliminating environmental compliance approvals that were required for very important reasons is now going to be nullified. Where is the science behind why removing environmental approval requirements is beneficial to our overall environment.

"3. & 4. Enable greater reuse of aggregate and stormwater management pond (SWMP) sediment by providing some flexibility related to meeting applicable excess soil quality standards in respect of asphalt-related contaminants and naturally occurring exceedances.
Allow greater flexibility for the reuse of soil, that is not known or likely to be contaminated, between project areas and reuse sites of infrastructure projects of the same type and by the same project leader, being undertaken concurrently, including not subjecting the soil to the waste designation and reuse criteria."
-Many of the proposed amendments seem to reduce and dilute the monitoring surrounding the quality of excess soil. This paired with the proposal that greater flexibility will be allowed for "the reuse of soils, that is not known or likely to be contaminated" seem to enforce a lack and degradation of regulation. The less soil that is properly monitored, the more likely it is that contaminated soil will work its way through operations systems without being identified. More information needs to provided as to the decision making behind these amendments. These amendments feel like they are in complete opposition to the precautionary principle.

"6. Where sampling and analysis is required, allow in-situ sampling of storm water management pond (SWMP) sediment to reduce time and cost associated with its characterization."
- The tradeoffs associated with potentially reducing time and costs associated with in-situ sampling, is that you lose effective and essential water quality monitoring tests as well as increase the risk of fouling and lower quality samples. For a feature that is deeply integrated into the our developed environment and directly tied into our watershed systems, this feels like a misguided amendment. Deteriorating water quality is one of the most imminent crises in our environment and society.