Waste Connections of Canada…

Waste Connections of Canada Response to Excess soil regulatory proposal and amendments to Record of Site Condition (Brownfields) Regulation
Ministry of the Environment, Parks and Conservation
ERO Number: 013-5000

Introduction

Waste Connections of Canada welcome’s the Ontario Government’s environmental consultation as we share the common goals of protecting the environment while remaining economically competitive. We share the common goal with the Government of strengthening Ontario’s economy while protecting the environment. To achieve this, businesses need policy and regulatory certainty.

Waste Connections of Canada and its Role

Waste Connections is the premier provider of solid waste collection, transfer, recycling and disposal services in primary and secondary markets across the US and Canada. We serve millions of customers daily across North America. Whether it is single or multi-family residences, commercial institutions, industrial locations, construction sites, special events or providing natural disaster relief, Waste Connections can provide the service.

Waste Connections of Canada, a subsidiary of Waste Connections, is traded respectively on both the TSX and NYSE, and is the 3rd largest industrial traded company in Canada. In the US we have exposure in 33 of the 50 states. We own and operate 2 landfill sites in Ontario and employ over 1200 people across the Province in approximately 20 locations.

The main facility, the Ridge Landfill, receives non-hazardous industrial, commercial and institutional waste from across the province as well as residential waste from local municipalities. The Ridge employs 23 people and an additional 40 employees who live in surrounding communities and who work in collection operations in the Municipality of Chatham Kent.

Waste Connections of Canada is currently completing an Environmental Assessment to add capacity to the Ridge Landfill, so that we can continue to serve our customer’s needs and support the demands of Ontario’s growing economy.

General Comments

Waste Connections of Canada generally agrees with the burden of relief that is currently proposed with the amendments to the Record of Site Condition (Brownfields) Regulation.

Supply and Demand Imbalance and Pit/Quarry Rehabilitation

Waste Connections of Canada believes that the amount of excess soils is much greater than demand. The result in a large volume of soil that could have a beneficial reuse, that if permitted, excess soils could be used for rehabilitation purposes. The current standards require the use of virgin soil in Aggregate Resource facility rehabilitation. We would suggest that one remedy for this could see the Ministry of Environment, Conservation and Parks (MECP) work closely with the Ministry of Natural Resources and Forestry (MNRF) to find ways to align policies and increase the opportunity for excess soil to be used for pit and quarry rehabilitation.

Landfill Disposal

WCC generally agrees with the intent of avoiding the disposal of excess soil at landfills. However, excess soils have a beneficial reuse in landfill operations as daily cover and for the construction of landfill features like roads, ramps and liners. Excess soils slated for this purpose should be exempt and permitted to go to landfill for these purposes. Additionally, there is a significant opportunity to allow for more excess soil to be utilized for rehabilitation purposes. These beneficial reuses of excess soil should not count towards total capacity, as they are not waste and necessary for operations.

Conclusion

Waste Connections of Canada again thanks the MECP Policy and Operations teams for their extensive consultation work of late and we continue to look forward to working with the Province. With regards to soils we agree with the intent of avoiding the disposal of excess soil at landfills so long as they have no beneficial reuse. Waste Connections of Canada are willing to offer their advice and resources to the Ministry to assist in streamlining all processes. We appreciate the ability to provide our comments and welcome any additional opportunities to discuss our ideas further.