June 15, 2018 Ms. Laura…

June 15, 2018
Ms. Laura Blease
Ministry of Environment and Climate Change
Land Use Policy
40 St. Clair Ave. West
Foster Building. 10th Floor
Toronto On M4V 1M2
Attn: laura.blease@ontario.ca

RE: Synertrack Response to MOECC’s Excess Soil Management Regulatory Proposal
EBR Posting# 013-2774 April 16, 2018

Synertrack is responding to the MOECC’s request for responses on the final draft of the Excess Soils Management Regulatory Proposal (Ontario EBR #013-2774). Synertrack is a supporter of the regulation and has been actively involved in the feedback and development of this regulation. Synertrack will respond only to tracking and registry requirements and how they raise the bar on sustainable practices.

Synertrack Regulatory Support and Feedback:

Synertrack has worked diligently in developing digital solutions and services to enable adoption of certain MOECC proposed regulations and to enable the beneficial reuse of soil in Ontario. In doing so, Synertrack has come to the opinion that the regulatory details surrounding tracking that others see as onerous, can be achieved with a minimum amount of digitization with little impact to existing processes. Synertrack’s product, SoilFLO, has been seamlessly adopted by those owners and contractors who maintain their position on the “cutting edge” of innovation and by those who hold themselves to higher regulatory and environmental standards.

Synertrack supports the implementation of regulation and believes that it is an opportunity to provide a traditionally outdated industry with resources that improve control and accountability, enable beneficial reuse, increase logistical efficiencies, reduce greenhouse gas emissions, mitigate liability and save money.

Synertrack is looking forward to conducting pilot programs with the MOECC to prove the value of soil ticket digitization and the positive effects it can have for regulatory adoption. Synertrack would like to maintain the stance that all tracking requirements for both on-site movement and off-site movement are easily captured using SoilFLO. Furthermore, Synertrack firmly believes that live, minute-by-minute GPS Tracking is costly, unnecessary, and relies on the most volatile part of the construction process – haulers. Any mandatory requirement for live GPS tracking will see intense resistance from industry and lead to non-compliance with regulation and slower adoption (we have seen this personally). SoilFLO utilizes geolocation checks to protect soil movers and ensure that trucks are being sent from the proper location; Synertrack has found that such minimal GPS utilization has provided tremendous value and the controls to effectively understand soil movement and utilization.

Finally, Synertrack would like to see more finalized details on what the registry will look like from a technical and governance perspective. Synertrack believes that this software needs to be open to data feeds such as SoilFLO, to easily integrate into the system for seamless data upload. Again, this will enable earlier adoption of the pending regulation. Synertrack appreciates being invited to the Data Standardization meeting in April 2018 and would like to continue to be involved in the development of the minimum data standard surrounding the regulation, as well as the tendering process for developing the registry’s infrastructure. Synertrack sees itself as a strong ally in developing this registry and intimately knowledgeable about the regulation, the problems it is solving, the earthworks market, and the development of software technology.