It seems disingenuous to water down regulations that haven't yet been enacted, without input from all steakholders, not just the ones looking to reduce costs.
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I think it would be beneficial to the process to add properties that have acknowledged Record of Site Conditions added to the list of low-risk sites. These properties have already been assessed by a QP and have been approved by the MECP.
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The proposed change to exempt low risk sites adds more complexity in interpreting this regulation with respect to naturally occurring parameters.
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I believe that agricultural sites -, parkland, residential and institutional use are already exempt under section 14 of O Reg 406/19. In addition I have concerns about the definition of low risk projects or projects that are just under the new requirements
I am against this amendment to the regulation. Although the legislation is about excess soil and ensuring topsoil is listed as a re-use, local authorities also see it as a tracking measure to lessen the impacts of improper soil use.
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If my agricultural/residential site is exporting 100,000 m3 of soil to a receiving site, and historical testing confirmed that there were no exceedances, does this characterize my agricultural/residential site as low-risk?
I remain concerned that excess soil rules needlessly restrict reuse of soils excavated during the course of normal routine work on municipal infrastructure. For example, soils removed during the replacement of sewer and water pipes or soils removed to facilitate repair of a main break.
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As part of this proposal, would the MECP be willing to clarify the exemption of Section 8 (planning requirements) for projects outside of an area of settlement (which don't include any of the other 'triggers,' i.e.
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Every year thousands of trucks carry 25 million cubic meters of soil around the province looking for a place to dispose of it (QUANTIFICATION of Excess Construction Soils in Ontario by the Residential and Civil Construction Alliance of Ontario).
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The proposed changes don’t rectify some of the most problematic components of the regulation including:
1. Significant environmental impacts – O. Reg 406/19 yields an estimated increase in CO2E of approximately 90,000 tonnes/year.
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Rescinding the soil regulations for “low risk” sites will allow illegal dumping to continue unabated. Illegal dumping has been a big problem for rural municipalities.
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The OACFP represents most of the bereavement profession’s active operators within the province. Our membership consists of cemetery, funeral home, crematorium, and transfer service operators from across the province as well as many other stakeholders within the bereavement sector.
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The Landscape Ontario Horticultural Trades Association represents over 3,300 businesses in the landscape trades in Ontario. Our members design, build, maintain our green spaces. They grow our plants, shrubs, annuals, perennials, and our trees.
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United Soils recognizes the need for the excess soil regulation to support urban development and projected provincial growth. We are concerned that the proposed changes to the regulation will not adequately control the placement of potentially contaminated soil at unregulated fill sites.
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Dear Ms. Kureishy,
Region of Peel staff have reviewed the proposed amendments to certain requirements under the Excess Soil Regulation and appreciate the opportunity to provide feedback to the Province.
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It seems disingenuous to…
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I think it would be…
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The proposed change to…
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I believe that agricultural…
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If my agricultural…
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I remain concerned that…
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Please see attached…
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As part of this proposal,…
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Every year thousands of…
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The proposed changes don’t…
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I support the proposed…
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The changes made to the…
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Please find enclosed a…
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Rescinding the soil…
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The OACFP represents most of…
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The Landscape Ontario…
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United Soils recognizes the…
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Dear Ms. Kureishy, Region of…
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