Comments are from experience…

Comments are from experience in operating a fill site at a former sand and gravel pit:
1. Site soil should be used to establish grade above the water table, before excess soil is imported.
2. Any site-specific standards for a reuse site should be reviewed by experienced risk management staff at the MECP.
3. The cost of having a QP develop a fill management plan and review potential source sites should be incorporated into tipping fees - no matter what the size of the reuse site is.
4. The regulation should require financial assurance and minimum environmental insurance of any reuse site.
5. The regulation needs to strongly require reuse sites obtain approvals from other regulatory agencies with jurisdiction.
6. There is a strong need for site inspections, not just document review, as part of the oversight.
7. Any permitting should be for a limited time (one year) so that permits can be terminated if environmental protections are not followed.
8. Municipalities without strong site alteration by-laws should be provided support and guidance to set these up, before a fill site is located in their area.