I work for an established…

Numéro du REO

019-5203

Identifiant (ID) du commentaire

60626

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

I work for an established beneficial reuse site. In accordance with Ontario Regulation 406, we put in place registration and truck tracking methods. We may not be 100% on every front, but we have set up the necessary systems and are working at improving on them. To remove these requirements at this stage would derail the efforts spent to date.
My general thoughts are:
1. The source site contractors that we work with have made the effort to provide reporting in accordance with the regulation and have implemented tracking on projects where this has been required (contracts in place after January 1, 2022).
2. This regulation was first issued in December 2019. There was a delay due to COVID to January 1, 2022. There has been plenty of time for the industry to understand the regulation and start implementation. As with our site, not everyone would be 100% on every front, but the efforts have been undertaken and the intent is to get to compliance.
3. A pause in the regulation at this stage would not be in effect until after June 2022 and would only be effective for 6 months. Anyone intending to comply with the regulation would have to have their systems in effect before January 1, 2023, so relaxing the regulation would really only be effective for 3 or so months. The confusion that would result in the change would be worse than continuing with the current schedule.
4. It would be better if enforcement officers used the time between now and January 1, 2023 to issue "education tickets", letting proponents in the industry know where improvements need to be made. Then in January 2023, full enforcement could begin. Don't take away the need to establish compliance.