I am the Executive Director…

Numéro du REO

019-5203

Identifiant (ID) du commentaire

60204

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

I am the Executive Director of Landscape Ontario Horticultural Trades Association. We represent 3, 600 companies that design, install and maintain landscapes. Soil is the foundation for all of our activities and our members strongly agree with actions that conserve soil and promote best practices, however the way that the legislation currently reads has the unintended consequences of shutting down a 3 billion dollar sector. The reason for this is that the receivers of fill and soil were sending notes to our members telling them that they would no longer be accepting fill and soil without testing. The vast majority of our members are moving small amounts of fill on a regular basis as part of the excavation process for building landscapes. They rarely meet the 2,000 cubic metre threshold of the regulation however their normal functions will be impacted. Our suggestion is to completely exempt small quantities from the legislation and make it clear to receivers of fill and soil that small quantities do not impact their compliance activities. We also suggest that a communications and consultation campaign targeting receivers of fill is necessary in order to understand the consequences of the regulation. Thank you for putting a pause on the regulation. We would be pleased to participate in the consultation process.