The proposed regulations are…

The proposed regulations are a step in the right direction, however I feel the industry is very capable of ducking and weaving.

The regulations must be strong and inforcable and funded through fees on the source site owners to encourage on site reuse of soil. If the dig and move option is the cheapest it will prevail and increases the danger of spreading pollution and downstream costs to the public realm. More stringent source site analysis is key. Excess Soil Management Plans ESMAS should be enforced by MOECC enforcement staff routinely.

The regulations on soil remediation facilities should be just as comprehensive and enforceable. We have seen that these companies cannot be relied upon to stop contaminated soil from reaching deposition sites time and again. Enforcement again is key and should be funded by the industry. Sample, sample, sample. Spot sampling and testing for specific chemicals can be quick and affordable. Once the bad stuff gets out, there is little evidence that anything will be done about it. This too could change and be a disincentive if the fines were appropriate. But avoiding the legal battles should be the aim so increase the requirements and enforcement first.

We don't know the human health costs of poor regulation and creeping public exposure to a myriad of man made chemicals when unregulated soil gets into areas of high aquifer vulnerability (HAV). Not to mention the affects on wildlife and trees. The review of the management plans for the ORM, NE and GHGB has identified these areas and they could be completely protected.

[Original Comment ID: 209813]