As a Professional Engineer…

As a Professional Engineer in the Civil, Mining, and Environmental sector, I strongly oppose to the proposed Pause to O.Reg 406/19.

1. There is already enough confusion regarding the new implementation. A temporary pause will mean that contractors and businesses will delay making a decision for implementation, and ultimately undermine the legitimacy and consistency of the regulation. A red-light green-light game for this large scale regulation makes it such that affected stakesholders would become even more confused.

2. A lot of local municipalities, specifically small-town rural municipalities, that are the ultimate receiving sites of these soils already implemented O.Reg 406/19. This delay would inevitably cause large trust issues for municipalities, approval authorities, and operators of these receiving sites

3. O.Reg 406/19 was posted in Dec 2019. It has been more than 2 years of steady-state implementation. It is not acceptable for businesses and contractors to claim "delayed implementation" because they didn't know. Everyone in the industry knows, but just gives an excuse to not implement it.