Comments

With regards to the Further Proposed Amendments No.

Waste Management of Canada has reviewed the Excess Soil Regulatory Proposal (EBR Registry Number: 013-0299) and would like to express concerns regarding temporary soil storage.

The proposed regulation states that if after completion of a Phase One Environmental Site Assessment and associated evaluation, rationale and certification by a QP, it is determined that intrusive testing is not required to sample and analyze the quality of the excess soil to be removed from any

Clarification should be made regarding the requirements of one large source site (excess fill exceeding 1000 m3) shipping to multiple small receiving sites (receiving less than 350m3).

Information is required to be registered and maintained in the Environmental Site Registry for storm water pond maintenance, if more than 1000m3 of excess soil is generated. The pond maintenance activity itself is exempt from an ESMP.

Site of greater then 1000m3 that require an ESMP have a very clear requirement regarding record keeping. Clarification should be made regarding the record keeping required by small sites that do not require an ESMP.

[Original Comment ID: 209784]

Records are required to be kept for 5 years by receiving site owners. However, ownership of the receiving site may change multiple times within a 5-year period.

The proposed regulation states that if after completion of a Phase One Environmental Site Assessment and associated evaluation, rationale and certification by a QP, it is determined that intrusive testing is not required to sample and analyze the quality of the excess soil to be removed from any

Clarification should be made regarding the requirements of one large source site (excess fill exceeding 1000 m3) shipping to multiple small receiving sites (receiving less than 350m3).

Information is required to be registered and maintained in the Environmental Site Registry for storm water pond maintenance, if more than 1000m3 of excess soil is generated. The pond maintenance activity itself is exempt from an ESMP.

Site of greater then 1000m3 that require an ESMP have a very clear requirement regarding record keeping. Clarification should be made regarding the record keeping required by small sites that do not require an ESMP.

[Original Comment ID: 209790]

Records are required to be kept for 5 years by receiving site owners. However, ownership of the receiving site may change multiple times within a 5-year period.

Records are required to be kept for 5 years by receiving site owners. However, ownership of the receiving site may change multiple times within a 5-year period.

Overview

Dear Mr. Coelho,

The following resolution was passed at Council's regular meeting held June 21, 2017:

WHEREAS Posting 013-0299 on the Environmental Bill of Rights, entitled “Excess Soil Management Regulatory Proposal”, is posted for public comments until June 23, 2017;

Thursday June 22nd, 2017

Mr. Sanjay Coelho - Senior Policy Analyst Ministry of Environment & Climate Change Land & Water Policy Branch 40 St. Clair Avenue West 10TH Floor, Toronto, Ontario, M4V 1M2

Exp – Markham GENERAL COMMENTS AND POINTS FOR CLARIFICATION

Proposed Excess Soil Regulatory Package-New Proposed Regulation and Amendments to Existing Regulations

We Support Toronto Public Health's call for a streamlined & affordable approach for urban agriculture & community growing initiatives.

The Importance of this Initiative

comment letter to be emailed separately to Sanjay Coelho today.

Cary Clark

[Original Comment ID: 209801]