I am strongly opposed to the…

I am strongly opposed to the Ontario government‘s proposal to pause the implementation of the latest phase of the excess soil regulation. Indeed, I already viewed the timing of the introduction of this regulation on Jan 1 of 2022 as being long overdue. I write from the perspective of someone with an up-to-date knowledge of the literature on current and emerging environmental pollutants as a scientist active in this area. A recent occurrence close to my home provided a further incentive for this statement of protest regarding the proposed change.
Our home, in a rural area, is within three hundred meters of the location of a well known hydro-excavation company. This site has been used for disposal of at least some of the material excavated by their trucks. As a result, concern had been rising during the past two or three years in the neighborhood about a potential for contamination of local wells. A neighbour contacted the local office of the Ontario Ministry of the Environment, Conservation and Parks but this did not result in any obvious action. Personally, I wasn’t unduly worried since only a few loads per day were being pumped out of the trucks. However, in October of 2021, I learned that many hundreds of dump truck loads of fill, emanating from the widening of highway 401 in the Cambridge area, were being dumped at this site even during the night. This immediately raised a “red flag” for me. Over the past two decades there has been a steadily growing alarm in the environmental field about the serious threat of “tire-wear-compounds” to organisms inhabiting streams adjacent to highways that become exposed to these compounds. Well over a hundred publications have highlighted the importance of the problem, emphasizing that loss of tread from billions of tires adds up to staggering quantities world-wide. Similarly, the associated potentially toxic compounds, such as curing accelerators and anti-oxidants and the products derived from them by degradation, amount to thousands of tons. In Canada, the lethality of one of the compounds, especially to Coho salmon, has garnered wide attention. Indeed, one very recent relevant paper by Canadian authors included the work of scientists from the Laboratory Services Branch of the Ontario Ministry of the Environment, Toronto. I quote from their publication; “Samples were originally collected in the fall of 2019 and winter of 2020 in the Greater Toronto Area of Canada from the Don River, a highly urbanized watershed in close proximity to several major multi-lane highways.” These compounds can leach out when dissolved in runoff water, but also as constituents of floating nanoparticles. The soils removed for road widening will, of course, be contaminated with these compounds and particles and other pollutants including asbestos from brake pads, heavy metal salts, and substances derived from hydrocarbon combustion such as the extremely dangerous polycyclic aromatic hydrocarbons (PAHs). Surely such soils cannot be viewed as “clean fill” in Ontario. I was hopeful that there would be procedures aimed at regulating their disposal. I was also hopeful that those responsible for monitoring the removal and disposal of this type of fill would be cognizant of these current concerns.