May 3, 2018
Laura Blease
Senior Policy Analyst
Ministry of the Environment & Climate Change
Policy and Planning Division
Environmental Policy Branch
777 Bay Street
Suite 700
Toronto ON M7A 2J8
Re: Response to Excess Soil Management Proposal
EBR Registry Number: 013-2774
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What is the rationale for needing an ESMP at all, if excess soil is taken directly to a waste disposal site? What is the rationale for the 100 m3 exemption?
After reading the proposed documents, it becomes clear that there is need for clarification on whether the Regulation is supposed to apply to Spills governed under Part X of the Act. It is unclear whether an excess soil management plan will be required for the clean up of a Spill.
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There's a fundamental flaw in the proscribed process of measuring the levels of contaminants in soils. The Qualified Person is required to collect representative samples for analysis and submit these to an accredited laboratory.
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We were very fortunate in our area that an Site alteration application that had been submitted to our municipality was withdrawn before it went to council. However our work prior to the withdrawal opened eyes.
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Paragraph 7 and 8 of Subsection 7 (3) sets out when a "soil characterization report" is required. However, Paragraph 13 (iii) of the Soil Rules refers to an “excess soil characterization report".
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07 June 2018
Ms. Laura Blease
Senior Policy Advisor
Ministry of the Environment and Climate Change
Policy and Program Division
Environmental Policy Branch
40 St Clair Avenue West, Floor 10
Toronto ON M4V 1M2
Dear Ms. Blease
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Staff recommend that prior to implementation of the Proposed Excess Soil Management Plan and Registry on January1, 2021; the Ministry has additional consultation with stakeholders to ensure the following is accommodated:
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We find that the proposal, in general will be an improvement on the existing system. However, Brampton Brick Limited would like to offer the following comments for consideration.
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Excess Soil Management Regulatory Proposal - ERO No. 013-2774
Municipal Corporation of the County of Renfrew Response
The County of Renfrew has serious concerns regarding the applicability and the associated costs of the proposed Excess Soil Management Regulations.
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The Ontario Society of Professional Engineers (OSPE) is pleased to present the following submission concerning the Excess Soil Management Regulatory Proposal (herein referred to as the Proposal).
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We submit the following comments to the Ontario Environmental Bill of Rights (EBR) posting by the Ministry of the Environment and Climate Change (MOECC) regarding its proposed Excess Soil Framework. The following documents were reviewed:
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May 3, 2018 Laura…
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Excess soil management regulatory proposal
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3970
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What is the rationale for…
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3980
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It appears that the focus is…
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3981
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After reading the proposed…
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3982
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There's a fundamental flaw…
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We were very fortunate in…
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O. Reg. made under the…
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Paragraph 7 and 8 of…
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Excess Soil Comments Our…
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07 June 2018 Ms. Laura…
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Staff recommend that prior…
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Bruce Power Comments to…
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Waste Designation…
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Excess Soil Management…
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We find that the proposal,…
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Excess Soil Management…
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The Ontario Society of…
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We submit the following…
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I wish to submit on behalf…
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