This regulation appears to…

This regulation appears to be designed to reduce trucking and find suitable sites closer to construction activities. This is and issue in urban areas and not an issue rural municipalities. Rural municipalities will now have additional administrative, operational and financial burdens as a result of this legislation without realizing the benefits an urban area should see.

The province has made asset management a regulatory requirement and is now a requirement for funding. Undertaking municipal road reconstruction, sewer and watermain replacements, ditching and culvert repairs are activities that may trigger a number of thresholds for the Excess Soils Regulations that have been proposed. These activities are aligned with good asset management practices. The new regulations will add additional costs for rural municipalities at a time when rural municipalities are struggling with funding to keep up with infrastructure needs.

Municipalities should complete soil management in a responsible manner that considers the impact on the surrounding area. As such we would like to recommend the following considerations;

1. That the Province work with municipalities and experts to refine and update guidelines for excess soil placement on third party sites.
2. That the requirement of a “qualified professional” be removed from the regulations once the guidelines are in place
3. That the Province exempt rural municipalities from the new regulations
4. In the event item 3 is not possible, that the Province worth with rural municipalities to revise the volume thresholds that will trigger the requirements of the regulation
5. That the Province exempt ditching, culvert repairs and other general road maintenance activities from the new regulations

Thanks