On behalf of the City of Mississauga, please find attached our comments on MECP's proposed amendments to O. Reg. 406/19. The City is generally supportive of most of the proposed changes and would like to present further points for consideration for greater clarity and transparency.
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Ministry of the Environment, Conservation and Parks
Environmental Registry of Ontario (ERO) Submission
Subject: Response to Enabling greater beneficial reuse of excess soil
ERO Number 019-9196
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November 20, 2024
Reema Kureishy
Environmental Policy Branch
Ministry of the Environment, Conservation and Parks
40 St. Clair Avenue West, 10th Floor
Toronto, ON M4V 1M2
Dear Ms. Kureishy:
RE: ERO 019-9196 Enabling greater beneficial reuse of excess soil: Niagara Region Comments
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Enbridge Gas Inc. commends the Government of Ontario for its proactive and collaborative approach to enhancing the beneficial reuse of excess soil.
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United Soils Management Ltd generally agrees with the intended changes, but does have some comments and concerns. Our letter with these is attached.
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The Ontario Sewer and Watermain Construction Association (OSWCA) submitted comments welcoming a number of provisions that will help to facilitate the reuse of excess soil excavated from construction sites and infrastructure projects, while also highlighting concerns around the two-year delay on land
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Please find attached Conservation Ontario's comments on "Enabling greater beneficial reuse of excess soil" (ERO 019-9196).
Conservation Ontario thanks the Province for the opportunity to comment on this proposal.
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RE: ERO Registry Number 019-9196
Proposed amendments enabling greater beneficial reuse of excess soil
Dear Mr. Lompart:
These comments are provided by Peel Region staff, who have reviewed the proposed amendments and appreciate the opportunity to provide feedback to the Province.
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The Township of Puslinch is submitting the attached comments with respect to ERO 019-9196, regarding amendments to Ontario Regulation 406/19 (the Excess Soil Regulation) and the Rules for Soil Management and Excess Soil Quality Standards,.
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On behalf of the Ontario Federation of Agriculture, please find attached our submission with respect to the consultation on enabling greater beneficial reuse of excess soil (ERO # 019-9196).
Kindest regards,
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Based on current wording of O.Reg. 406/19, it is understood that if any part of the project area is an enhanced investigation area, then the entire project area is treated like an enhanced investigation project area.
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Proposed Amendment 6: Please clarify if post-dredging confirmatory sampling of SWMP sediment is required in some fashion in all cases? We propose the QP be given discretion to determine whether additional sampling is necessary based on the in situ results and means and methods of excavation.
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Proposed Amendments 4 & 5:
Where these proposals relate to large road/highway projects that have a fill requirement or are able to manage their excavated soils between local and similar projects, Dillon sees a benefit to the MECP's proposed flexibility from the current excess soil requirements.
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Please consider removing the 25,000m3 limitation on the quantity of material that can be stored at an aggregate reuse depot. In our experience, large projects and/or multiple projects will exceed the 25,000m3 limit in a short period of time.
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We are in support of the MECP's proposal to permit the establishment of aggregate depots that will not require an ECA as this is anticipated to bring the regulation into better alignment with current industry practice to treat engineered aggregate material as a resource while understanding that this
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Obtaining representative sampling results of aggregate materials, where required (i.e. from PCA/APEC) is not possible. Exceedances are expected in this material - where sampling is required, it will generate waste where it would otherwise be suitable for reuse in a similar environment.
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Enbridge Gas Inc. commends…
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United Soils Management Ltd…
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The Ontario Sewer and…
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RE: ERO Registry Number 019…
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The Township of Puslinch is…
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122048
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Based on current wording of…
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Proposed Amendment 6: Please…
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Proposed Amendments 4 & 5:…
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Please consider removing the…
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We are in support of the…
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Obtaining representative…
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