Friday, November 20, 2020 I…

Friday, November 20, 2020
I would like to take this opportunity to comment from the perspective of an on-the-ground, grass-root group.
Soil Registry and soil tracking are very important to us. Enforcement of Regulation is essential. Education of these Regulations for all stakeholders is critical.
I appreciate that a Soil Registry will document the management of excess soil in Ontario. Municipal officials and the public will have access to it. Schedule 1 of the Regulation includes specific information from the operator of the source site. That is important. More importantly to us “on the ground” is the information required to be registered for small as well as large “reuse site”. That information, unfortunately, at present, is not specific enough to make it easy for a municipality to use the registry to monitor activities within its jurisdiction.
Specific and detailed information (ie GPS site coordinates, details of any by-laws, permit or other instrument) are required by the operator of a large reuse site but that only applies to sites of at least 10,000m3. In these cases, Municipal officials can easily crosscheck against their records.
Illegal dumping is a very real issue, especially in more rural settings and municipalities. This has been a major issue over the years at the Town of Erin. Time and time again, we have delegated to Council on this issue. To no avail. To address this issue, the soil deposited at any reuse site should be traceable back to the source site(s) and to the persons responsible for the oversight at the reuse site. Ontario Reg 406/19 must be amended to provide more information on the reuse site to address illegal dumping. Additional info would include GPS, type of property use of reuse site ie farm, what the excess soil is used for, what instrument has been issued: by whom, when, to whom and ID #. In this manner, Municipal officials and the public will be able to verify that the reuse sites do have oversight. And this information would also greatly aid enforcement.
I ask that the Soil Registry include as many pertinent identifying information as possible on reuse site and to include the municipal instrument that a site receiving soil is operating under. Municipalities should be allowed to provide oversight of the sites that are in their particular municipality when receiving excess soil. This would be effective and efficient since the provincial oversight basically ends when the soil is dumped at a reuse site. Municipal governments should be held responsible for excess soil management under their jurisdiction.
If the decision is to have RPRA responsible for the Soil Registry, it would be effective and efficient to have an Excess Soil Customer Service Dept. there. The personnel should be knowledgeable about issues, questions on excess soil and the Regs. It would be good PR and a great help to have an “one-stop” shop for the public looking for info on these Regs. The Registry must be user-friendly. Many of our residents are not necessarily tech savvy although they may be the important “eyes and ears” in the neighbourhood and the info source of illegal activities.
I also would like to comment on extending the implementation dates. It is too lenient. The further out the extension, the more people will take advantage of the lag of time before regulations take effect. We have seen a flurry of activities since 2018 with receiving landowners, fill operators, wanting to beat the Regs when they knew “changes are in wind”. Despite COVID-19, the dumping continues in our neigbhourhood and municipalities because of the lack of regulations in the Fill Industry ie at present, residents north of Oshawa are fighting a proposed fill site.
Soil tracking is also a critical factor in soil management. Residents need to know that the soil tracking is done by ethical and professional personnel. Trust will develop for the process with this knowledge. To ensure this, a Qualified Person (QP) should be certified and have gone through professional training. He/she does have a major responsibility.
In the last decade, the Fill industry and fill sites have become a big problem in rural municipalities. There has been little trust between those working in the fill industry, citizens, and politicians. The politicians and those in the fill industry see the bottom line from a financial perspective: development provides revenue for Council coffer and moving fill is a lucrative business. Some large rural landowners also see receiving fill as a lucrative means to an end, not realizing the impact on the environment. A great many residents are affected by the unregulated Fill industry and its environmental impact (topography change, water, air, noise, traffic safety etc) and are against the negative impact on their chosen style of living in a rural setting. Hopefully, with the regulation of the Fill industry, both sides will learn to be more trustful and understanding of each other.
To that end, I believe that a public education process to introduce the Regulations is critical to success. How will that be accomplished? It has to be a multi-pronged strategy to reach municipal politicians and staff, provincial politicians and the general public. Possibly through Community Hall gatherings, Fill conference/symposium, webinars, MEPC staff presenting at Regional/County Councils, newspaper coverage, local community groups? More importantly, this public education process must begin immediately. Jan 2021 is not far off.
Thank you for this opportunity to comment.
Anna Spiteri, Town of Erin resident & member of Citizens Against Fill Dumping