The Ontario Soil Regulation Task Force (OSRTF) has been involved with the issue of excess soil since its formation in 2015 by citizens groups that had been dealing since 2010 with the problems of the dumping of excess soil in inappropriate places.
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June 15, 2018
Ms. Laura Blease
Ministry of Environment and Climate Change
Land Use Policy
40 St. Clair Ave. West
Foster Building. 10th Floor
Toronto On M4V 1M2
Attn: laura.blease@ontario.ca
RE: Synertrack Response to MOECC’s Excess Soil Management Regulatory Proposal
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Further to the recent request for comments from Ministry of Environment and Climate Change (MOECC), City of Barrie appreciates the MOECC initiative to address the excess soil issues and the opportunity to provide comments.
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The following comments are provided by the City of Guelph on the Excess Soil Management Regulatory Proposal, EBR# 013-2774:
Comments from City of Guelph - Engineering Services
On-Site and Excess Soil Management
Comment 1- General Comments:
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In addition to our comments submitted on the 1st proposal, we have only one new and significant comment to make on the second proposal that involves the requirement for an Excess Soils Management Plan (ESMP for soil movements between infrastructure projects of the same owner).
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Excess soil management regulatory proposal
We have reviewed the “Excess soil management regulatory proposal”. Our understanding is that the proposal has the following goals:
• Protect human health and the environment from inappropriate relocation of excess soil;
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Ms. Laura Blease
Senior Policy Advisor
Ministry of the Environment and Climate Change
Land Use Policy
40 St. Clair Ave. West
Foster Building, 10th Floor
Toronto, ON M4V 1M2
Attn: laura.blease@ontario.ca
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Comments and questions are as follows:
1) Part IV, first page: Indicates that new Excess Soil Standard Table 1 is same as O.Reg. 153/04 Table 1. Quick cross-check on first few parameters listed show different Standards (i.e. acenaphthylene, anthracene, antimony, etc.) between the two Tables.
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During a UST removal program, it is usually projected that less than 1000 m3 of soil will need to be excavated. However, if remediation extends this to beyond 2,000m3 and the QP has not developed an ESMP, what happens at that point?
Will all receiving sites (for beneficial reuse and waste sites) have to register with MOECC? Can there be a registry for source sites to locate nearby landfill and beneficial reuse facilities and minimize travel distance?
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Waste Designation
If the site alteration permit, pit rehabilitation plan, or other site specific instrument has weaker standards than the provincial standards, it is not acceptable that the weaker standards prevail.
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June 15, 2018
Laura Blease
Land Use Policy (Environment and Climate Change)
40 St Clair Ave W.
Foster Building 10th Floor
Toronto ON M4V 1M2
Re: TRCA Comments on Excess Soil Management Regulatory Proposal (ERO # 013-2774)
Dear Ms. Blease:
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The Ontario Soil Regulation…
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5583
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The following comments are…
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In addition to our comments…
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Excess soil management…
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Ms. Laura Blease Senior…
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Thank you for addressing the…
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1. Rationale Document for…
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During a UST removal program…
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