I am curious as to why at…

I am curious as to why at the time of excavation for new dwellings, landscape construction at existing dwellings, etc. the government is so concerned about soil contamination given the prior opportunities in the planning/development process to ensure that site soils are not contaminated.
Subdivisions and developments are typically subject to applications for Official Plan Amendments, Zoning By-law Amendments; followed by application for Draft Plan of Subdivision, or application for Site Plan Approval, depending on the nature of the development. At each of these stages, the beforementioned applications under the Ontario Planning Act ask for confirmation that the site soils are not contaminated and if so that they be cleaned up and a clean Record of Site Conditions be provided as part of the application PRIOR to any municipal/provincial approvals of the development. That is a potential of THREE times for the question on contamination to be addressed. The excess soil management legislation that has now been put on hold seems to be unnecessary overkill if the processes under the Ontario Planning Act are indeed working. And if the goal was to eliminate illegal dumping of soils, if anything the legislation as it stands now would increase illegal dumping as it leaves landscapers and excavators with no where to dispose of the soils given the fact that most pits are simply saying "no soils accepted" to protect themselves (the pit owners) from non-compliance with the legislation. Aside from these points, the required testing is costly and will increase the costs on projects that we need to pass along to the customer. How is that working for economic development and support of Ontario business?
I would suggest that the various ministries within the Ontario government consult with one another to prevent the overlap shown by this legislation and the requirements under the Ontario Planning Act; and that all stakeholders be consulted before the legislation is drafted. Enhancements to the roll out of this legislation would have proven helpful in determining what has just been discovered now as we are on the threshold of the new construction season.
I would recommend that with the exception of Brownfield developments, the legislation be scrapped, not just delayed for a year.
Thank you for the opportunity to comment.