Being an active practitioner…

Being an active practitioner (QP) in the field of excess soils, I still find it fairly unworkable and, overall the regulation is having a detrimental effect on the environment. This is related to several factors: 1) the staggering increase in trucking of soils since reuse sites are hard to find (hauling soil longer distances), 2) large increase in the testing of soils (major increase in the number of sample bottles, solvents; much more drilling and digging to collect samples; more driving to collect and deliver samples), 3) not much change (maybe an increase) in landfill disposal since this is so much easier than finding a reuse site, 4) construction of unsightly berms around the countryside, 5) staggering increase in the cost of infrastructure projects (when money could be spent better elsewhere to improve the environment).

I would suggest easing restrictions on reuse of salt-impacted soils. They are present everywhere in the province anyway, so why make it so difficult to reuse them - burying soil 1.5 m deep in a field is not practical and very damaging to the environment. I know lots of snow dumps which are salt-laden and the crops grow fine in the summer. I feel that a QP and project leader could designate more reuse sites in rural, unserviced areas that would still be protective of the environment without having to follow all the nonpotable site rules.

Testing requirements must be more at the discretion of the QP. For example: on long stretches of remote highway, there is no need to keep collecting hundreds samples to find salt and metals (natural) at concentrations above ESQS, but nothing else of concern.

Tracking is important, but for many small projects, could it not just be done by project? For example, report that 5000 m3 of soil moved from project area xx to reuse site yy and just have both sites sign off (still use the Registry).

The four reports are painful and not really useful for long linear infrastructure project areas. The APU following the O.Reg. 153/04 process for a Phase One ESA is not really sensible for long stretches of highway. A simpler process would provide the same result. In practice, there are many road and bridge projects which should actually have multiple APU, SAP, SCR and ESDAR reports according to the Regulation, but they don't.

The SAP and SCR are also very difficult to execute exactly according to the Regulation on many projects, because there are separate excavation areas over a single project area. Following the Regulation exactly would result in much more testing, but probably no more useful results.

I feel that there should still be a full exemption from all the requirements of the Regulations for project areas within low risk land uses (residential, agricultural land uses for example) with volumes of less than 2500 m3 or so whether in settlement areas or not. Permission from property owners accepting soil would still be required, but nothing else.

Certain Ministries and Agencies should be exempt from most of the Regulatory requirements based on project area type (e.g. rural roads in undeveloped areas).

The QP should also be allowed to modify the basic minimum requirements (e.g. not test for PHCs/BTEX in undeveloped areas).