Comments

Waste Designation

Concerned that the proposed regulation would designate any excess soil as a waste as soon as it leaves the property from which it is excavated, and that the designation would be attached regardless of the quantity and quality of excess soil.

1.The minimum parameter list (page 53 of the proposed regulatory package) should reference parameter groups or method group as they are listed in O. Reg 153/04. {PHCs, BTEX, Metals}

For example, what is the definition of "inorganics"?

I am responsible for Federal dredging contacts in the Great Lakes. I have reviewed the proposed regulation.

Please find below comments on the Excess Soil Management Regulatory Proposal from the Hamilton Conservation Authority (HCA). Please consider these comments in addition to those submitted by our umbrella organization Conservation Ontario. I apologize for the lateness of the submission.

Sanjay Coelho
Senior Policy Analyst
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Land and Water Policy Branch
40 St. Clair Avenue West
Floor 10
Toronto Ontario
M4V 1M2

Re: Record of Site Condition Regulations

Comment will be provided via hard-copy.

[Original Comment ID: 209847]

Why is soil considered a waste material while in transit? Unless it's identified as contaminated, I would consider soil a resource material. There are already regulations in place to deal with contaminated material.

Dumping of soils needs to be regulated at a provincial level. This has been a bit of a hot potato issue as responsibility gets passed back and forth between the province and municipalities.

1) For ESMP implementation, does that QP have to be onsite to watch trucks, or can their designate do it?

Mr. Coelho:

Re: EBR Posting #013-0299 - Amendments to Ontario Regulation 153/04 (Record of Site Condition) and Excess Soil Management Regulatory Proposal

Memorandum

To: Sanjay Coelho Senior Policy Analyst, MOECC From:Michael M. Peterson Date:June 23, 2017 Re:Excess Soil Regulatory Package

A few years ago when attending an information session with regard to Earthworks activities I asked how the MNR would proceed if it seemed the soil being dumped was contaminated.

The following is a list of highlighted concerns identified by OSRTF during our technical review of the Draft Excess Soil Regulations. Please refer to our technical review, dated June 11, 2017, for a complete list of concerns to date.

We appreciate this opportunity to provide our input. Citizens Against Fill-Dumping is a grass-root group in Town of Erin, Wellington County. The area is predominately rural.

A) what is registration process , is it mandatory and who should register - builder as soil generators, transportation companies , receiver and Interim site owners ?

B) what kind of detail needs to be provided by builder, interim site owner and target sites about soil ?

The following are general comments from OSRTF on the Draft Excess Soil Regulations. Our technical review, dated June 11, 2017, was submitted previously.

Dr. Eileen de Villa
Medical Officer of Health
Tel: 416-338-7820
Fax: 416-392-0713
eileen.devilla@toronto.ca
toronto.ca/health

June 23, 2017