The proposal that liquid…

The proposal that liquid soil not be authorized for importing under the Aggregate Resources Act does not enhance environmental protection. Hydrovac liquid soils that are received at pits and quarries in Ontario are composed of inert aggregate materials and clean water. The anticipated environmental, social, and economic consequences of the proposal will in fact be negative. This negative impact will be in most profound due to fewer locations for disposition of inert aggregate materials. Fewer locations creates increased travel distances, increased road wear, and higher diesel fuel usage. The combustion of fossil fuels such as diesel to transport clean soil and water will only contribute to that which is the largest source of CO2 emissions as noted by all respected environmental agencies.

The proposal actually detracts from the Pan-Canadian Framework on Clean Growth and Climate Change. In 2016, Canada released the first-ever national climate plan – the Pan-Canadian Framework on Clean Growth and Climate Change – jointly developed by the federal, provincial and territorial governments. The measures in the Pan-Canadian Framework are projected to make significant progress in helping Canada reach its 2030 goal of a 30% reduction below 2005 levels. The plan includes a pan-Canadian approach to pricing carbon pollution, and measures to achieve reductions across all sectors of the economy. It also aims to drive innovation and growth; increase technology development and adoption to ensure Canadian businesses are competitive in the global low-carbon economy.

Not only will disposition costs increase, but there is also an increased risk to the non-destructive hydrovac industry. This regulatory change will drive costs to the industry by approximately 6X. The hydrovac industry in Ontario is proactive in environmental protection procedures such as the use of bill of ladings, which facilitate the “cradle to grave” tracking of materials. Historical analytical data supports the fact that no impacted or contaminated materials have been deposited in pits or quarries.