- In comparing soil…

- In comparing soil standards from Table 3 of Part XV.1 of the Environmental Protection Act and Table B of the proposed Excess Soil Regulatory Package, it was noticed that the allowable F1 and F2 petroleum hydrocarbon values, among other parameters, were higher in the former than in the latter. What was the rationale behind the change in the acceptable values of these parameters between both standards? More stringent standards could create significantly increase costs on projects where some concentrations of Hydrocarbons are found.

- A separate conversation with the MOECC indicated that a street located in a residential neighbourhood would be subject to the Industrial/Commercial/Community property use standards, rather than the Residential/Parkland/Institutional Property Use standards. Greater clarity is required to address potential ambiguity associated in determining which standards apply to different elements of a project. Significant costs increases could be incurred on projects should the wrong standards be employed.

- The proposed regulation states that ESMPs are not required if the source site has not been associated with a potentially contaminated activity and if less than 1,000 cubic meters of soil is generated by the site. This could cause concerns for receiving sites who would have no assurance that incoming soils meet the appropriate standard for the site.

- Greater clarity towards which activities constitute regular maintenance, as opposed to large projects, is required, specifically pertaining to ditching, or the replacement of drinking water, sewage and stormwater systems.

- Additional information on the definition of a QP is required, as it pertains to conflicts of interest on projects, specifically as it pertains to projects undertaken by municipalities.

[Original Comment ID: 209830]