i am in the environmental…

i am in the environmental consulting and contacting area for over 30 years primarily in the contaminated site area, have been heavily involved in the excess soil since the inception of this new Regulation on several aspects.
i understand the push back from industry especially the development community as this new regulation does push costs and timelines higher and longer both of which are highly undesirable.
i do agree that the new regulation pushes the industry to comply in a much better way but may need some refinements such as when soils quality becomes marginal such as Table III and above
too many consulting engineer era on extreme caution and will not accept these material when they could or should at some receiving site. Municipalities are also at fault in these overly cautious approaches to these soil qualities.

The MECP need to provide a hugely improved education to all aspects of the industry as to the various aspects of the regulation. I personally have attended several to attempt to understand but find the components complex at times. While the QP community are the main tool of the MECP they are not all and be all to solve the issues and need to work alot more closely to others ie contractors and trucking companies.

i have noted a complete lack of understanding or maybe a desire on the part of the MECP to eliminate some aspects of people to aid in managing the excess soil market. a couple of times it was noted new businesses are attempting to develop soil matching services (while concept was well received), this is not new, there have been a huge network of soil brokers ie soil matching services do this for many years with the aid of QP services at the centre to ensure the added aspect this could ensure much better compliance with the new regulation. I know this as i am in the middle of this component of the regulation. i know the soil brokers aspect or soil matching services have not always had a good reputation but do play a key role to ensure all areas of the industry can work smoothly

now to the reason for the pause, while i understand the desire to provide more time to developers, they have had more than two years to embrace these regulations. for those whom plan to comply they will already be working with the marketplace to comply. under the current framework i feel that no delay in pause should be allowed but some extra leniency in enforcement and a heavy push to education and support from MECP should be the focus

i have had conversations with variety of people in the industry that have basically said that until they need to comply, bending the rules or more will occur until ......

so i restate no pause should be allowed at this time but MECP needs to look to other method to support a huge construction industry and the economy of Ontario

we will at this time next year be in same boat after a pause and non compliance will still be occurring at a high level