To Whom This May Concern: As…

To Whom This May Concern:

As a contractor in rural Ontario it has been a struggle to find infrastructure in place for excess soils and consultant understand the new regulation.

In our region we have no local reuse sites set-up under the new regulation, with most contractors or municipalities reserved or backlogged in opening any sites. This has created a higher cost and more emissions in sending excess soils to a final site in our last 12 months of construction.

Added time will hopefully help allow sites to catch up to large cities like Toronto, in setting up infrastructure and to mitigate cost and emission moving forward.

It has also been a struggle working with consultants who all seem to have a different interpretation of the new act. During our tendering process each consultant have been setting out different guideline on how to work with excess soils, very seldom have I seen similarity in the tendering guidelines. This process creates frustration in trying to meet the needs of the guideline when there is so much difference in interpretation.

A review, delay can give all consultant time to better understand the new requirements laid out

Contractors Views - Quick Notes

-Owners or municipality not wanting to pay for excess soil requirements- trying to save cost.
- Lack of work force and skill to support new regulation.
- Time it takes to process soil requirement versus small construction timelines
- Lack of or no dumpsite available
-Soil testing timelines are to long for short term construction
-Contractors will find unapproved dump site to save cost to undercut competition.
- Excess soils will be dumped in sensitive location when you make the regulations to difficult. Non-government clients and owners are going to find alternative methods now more than ever to save cost.

In my opinion the Excess Soils Regulation is way more complicated and confusing then it needs to be for just dumping dirt. As a contractor keep it simple for the clients and owners, keep the boots on the ground when reviewing this new regulation. What works in Toronto cannot be compared to what works in rural Ontario. In the last 12 months I have already seen Vac trucks, dumptrucks and soils being dumped in unregulated areas of concern, and how are we going to correct this action when the regulation doesn't have the rural infrastructure or any practicality moving forward?