December 3, 2022 Regarding…

December 3, 2022

Regarding 019-6240, and proposed amendments to Certain Requirements under the Excess Soil Regulation

Healthy soil is the basis of our agriculture, and the principal support of our food, forests, plant and animal life, and has been for millions of years. I am concerned that the proposed changes appear to be in response to concerns raised by unnamed stakeholders (I have to guess major developers), and not in the interests of the general public or a healthy ecosystem. Removing the requirement to sample, handle and track soil that is removed from these “low-risk” sites excavations around institutions (only schools are mentioned, but the word “institution” could cover many things), could lead to serious environmental consequences. The regulation includes many tables of contaminants that are found in soils, and lists the acceptable levels for agricultural soil, and safe levels near environmentally significant areas. Removing these protections puts the safety of our farmers, our food, and our vulnerable native species at risk. Where is the science backing up this change? Are the interests of the general public being protected?

Increasing the amount of soil that can be stored in a pile on development sites from 2500 cubic metres to 10,000 cubic metres again seems to be in response to the unidentified “stakeholders”, and not based in good science. Such a change would surely have impacts, but these are not identified. Why is this change being made? What is the justification, apart from “cheaper for developers”? How is this change in the public interest?

I am asking that these amendments be retracted, and that the regulation remain as it was previously until and unless it can be conclusively shown, with input from soils scientists, that there will not be an impact on our agriculture, significant natural areas, or public health as a result of these proposed amendments.