The proposed pause will be a…

ERO number

019-5203

Comment ID

60529

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed pause will be a big relief for Municipalities and other Construction Industry. There are several multi year contracts in construction for which grandfather is required and the pause will serve the purpose. This regulation has resulted in a significant cost escalation, claims due to uncertainties and soil disposal companies taking a position that they do not want to respect grandfathering provided by MECP. The pause will help several contracts in construction that did not completed testing and planning during design in compliance with the new legislation.

2025 no soil to landfill deadline similarly should be extended by a couple of years in advance to provide sufficient time for soil processing industry to develop. Double or triple handling of soil will be required in some cases to move soil from one location to other and there will be storage fees charged by soil contractors to store the excess soil if there is no disposal site available. The cost to dispose excess soil may increase drastically and will result in construction cost increase for new housing and infrastructure. Affordable housing and infrastructure cannot be constructed with such limitations.

MECP shall also complete assessment for the anticipated volume of Excess Soil that is anticipated to be generated in GTHA and across Ontario due to ongoing push for infrastructure and housing and assess if supply of excess soil from construction will be more than the demand to use it. MECP should also provide through provincial lands or otherwise, large scale soil storage facilities in GTHA to manage a buffer between supply and demand as it is likely that demand may not be the same as supply and at the same time as supply, requiring soil to be stored some where. High rise developers and some municipalities do not have property to store their excess soil.

The planning component of the regulation must be reviewed further and simplified and the pause provides an opportunity.