Re: ERO 019-4801 Proposed…

Re: ERO 019-4801
Proposed regulatory changes for the beneficial reuse of excess soil at pits and quarries in Ontario
It is the firm opinion of NSERA (North Shore Water & Environmental Resource Advocates Inc.) that these proposed regulations pose significant threats to ecosystems, farmland, and surface water and groundwater.
The following are points of concern:
1. The timeline to respond to this ERO is much too short. Proposed regulations that carry significant impacts deserve extended periods of time to allow qualified scientists, municipalities and interested groups to become informed and properly examine the facts and implications. Our group has questioned local council about these proposed regulatory changes and they have not been properly informed. An extension of at least another 60 days would be prudent.
2. Municipalities should not have to bear the brunt of the pits and quarries within their boundaries. With increased truck traffic, communities can be put at further risk due to noise and reduced air quality due to the movement of this soil over extended periods of time. The financial burden of developing, monitoring and enforcing excess soil regulations and bylaws should fall to the companies that are profiting, not the local taxpayers!
3. Surface and groundwater should be protected at all costs. Pits and quarries typically have groundwater present. Inadequate soil testing before dumping near a water-table has the potential for disaster for the environment and communities. Nearby waterways, drinking water, farmland and natural habitats may be contaminated with these soils. The cumulative impacts of contaminants could have lasting effects upon sensitive ecosystems. Further study is needed to establish controlled scientific testing of excess soils before they are deposited in pits and quarries.
4. Has there been proper consultation with Indigenous groups? A proposed quarry development within our municipality, if approved, will be on unceded territory within Robinson-Huron Treaty Lands. It is unlikely that local First Nations are aware of these proposed changes. As they continue to deal with the damage of an Acid Plant spill decades ago, they may be interested to know that the nearby watershed could be impacted yet again.
5. Stronger municipal oversight and approval of the importation of soil is needed. Municipal by-laws to enforce standards on excess soil should take precedent over self-filing/reporting of license-holders. Oversight should be handled by ‘independent’ qualified persons.
In conclusion, it is the recommendation of NSERA that the proposal presented in ERO 019-4801 should be withdrawn.
Rhonda Kirby
NSERA (North Shore Environmental Resource Advocates Inc.)