Waterfront Toronto is…

Waterfront Toronto is supportive of the proposed amendments to the On-Site and Excess Soil Regulation. In particular, the following proposals are beneficial to Waterfront Toronto's revitalization efforts:

The proposed amendments affording greater flexibility for the reuse of soil with higher values of salt-related parameters where a suitably qualified professional determines that based on its locations and depth of placement, it will not impair current or planned plant growth, are of benefit. In Waterfront Toronto's experience, landscape architects have provided input on our projects that proposed plantings can tolerate significantly higher soil salinity than is prescribed by the O. Reg. 153/04 Site Condition Standards or Excess Soil Quality Standards. Professionals such as landscape architects are often more able than QPs to make a determination on the effect of salinity on current or planned plant growth, and Waterfront Toronto is supportive of the Ministry's efforts to seek the engagement of these professionals in the soil reuse process.

Waterfront Toronto is supportive of eliminating the current 30 m setback requirement for the temporary storage of liquid soil in proximity to the waterbodies from which that liquid soil originated. The current setback requirements create the potential for difficulties in handling liquid soil over the transport distances required to achieve the setback distance. Management of liquid soil is possible in an environmentally responsible manner within closer proximity to water bodies, using sound engineered controls and best practices, and eliminating the prescribed setback will provide greater operational flexibility.

Waterfront Toronto is also supportive of a relaxation in the requirements for QP certifications surrounding the use of polymers for the solidification of liquid soils, and welcomes options to promote greater acceptance for the use of polymers as solidifying agents for dredged sediments where warranted based on considerations of timing and space availability.

We also encourage the Ministry to consider the viability of introducing site scale-dependent rather than consistent values for parameters such as storage volumes. For example, large sites/project areas may be able to accommodate larger storage volumes without the potential for disruption of adjacent land uses, provided consideration to setbacks and engineered controls are considered.

Waterfront Toronto thanks the Ministry for consideration of these comments, and for its continued efforts to promote the beneficial reuse of excess soil.