The Ontario Excess Soils…

The Ontario Excess Soils Regulations do not go far enough to protect the receiving end use of the construction waste soils cycle.
The “Cradle to Grave” approach needs to be the management model that is followed, required.
Those that create the issue need to be responsible for its final resolution. This is consistent with polluter pay regulations.
Specifically, the new project developers that generate the excess soils must be responsible and accountable for its proper and legal final disposal or re-use, including maintaining verifiable records. This approach goes beyond the middle-man soil brokers and processors.
The hazardous waste disposal regulations use a “waste manifest” authorization, control, management and records system which has worked successfully for decades. A similar approach could be used, especially for Brownfield site re-developments containing hazardous materials.

There is a clear and present danger with the depositing of excess soils into pits and quarries that are in or near drinking water sources, namely below the water table pits and quarries, sitting inside groundwater aquifers, thus in direct contact with the groundwaters.
Many of these pits and quarries are importing millions of tonnes of construction project soil wastes. The testing of these potentially contaminated soils is totally inadequate; the care & custody controls over these soils is inadequate; the receiving site soil testing is inadequate, mostly not tested for compliance to Ontario EPA Table 1 standards. Waste soils should actually comply with Table 2 for direct groundwater contact situations.
The lessons of the past are being ignored, thus setting ourselves up for another Love Canal disaster. Unacceptable. Fresh waters are a scarce necessity. We must do everything we can to protect and preserve our life giving waters.

The local Municipalities that receive the excess soils must have jurisdiction and control over the quality and acceptability of these waste soils within their boundaries, especially over soils going into below the water table pits and quarries, and onto regulated lands and prime agricultural lands. Once the pits and quarries are decommissioned, the Municipality will be left with the potential problem of groundwater aquifer contamination, not the MNRF who allowed the importation to occur.

Illegal dumping is a whole other more dangerous occurrence, which requires much stricter controls and enforcement by all levels of government.

With climate change causing dramatic rise in ocean levels, our excess waste soils could serve a much better and needed purpose in flood control dykes around our coastal cities. The middle east and Africa ship desert sands all over the world, why are we not shipping clay-laden soils?

Excess soils are a resource, but only the “clean” soils. The rest are true waste, some is hazardous waste.