Policies are great but they…

Policies are great but they really don't work in real development situations. Furthermore, I don't feel these policies make a huge difference on the environment. Let me explain. The main issue that I've noticed is the definition of waste and the stringent levels being used. Most of the native soil and even some of the shale bedrock fail this standards and are usually considered impacted and require special off-site disposal approaches that add significant costs to a new development. Where the soil has naturally occurring impacts that exceed Excess Soil standards, the QP can make the argument that the soil can be disposed as clean material. However, receiving sites may refuse this material and the owner has no choice but to dispose of the material at an approved waste disposal facility adding significant costs to the development that gets passed on to the consumer. Furthermore, landfill space starts to get occupied by clean and relatively clean soil which defeats the purpose. The following suggestion is provided: 1 - Allow the QP to provide a rationale and justification for considerer soil with naturally occurring impacts to be considered clean. A letter from the QP would be recognized by the MECP and the receiving site when considering this justification. 2 - The Excess Soil standards are too stringent. We need to redefine them and permit more soil to be considered as clean material.