I am pleased to provide…

I am pleased to provide comments and input on proposed amendments to the Regulation.

I am in favour of the intent of the regulation to more effectively govern the management and movement of soil between properties. This will both protect landowners from inappropriate fill placement, but also provide greater confidence for municipalities and developers on the quality and suitability of fill being used. As well as to facilitate responsible beneficial reuse of soil, viewing it as a non-renewable resource.

However, elements of the current Regulation require an unnecessary extent of assessment and testing, introducing a significant additional cost for municipalities, developers and contractors.

The proposed amendments are appropriate to facilitate more efficient soil management and beneficial reuse. I would suggest that the low-risk concept can be reasonably extended to a number of scenarios, which are fairly common within development projects.

Please see attached letter with formal comments.