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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77034

Commenting on behalf of

Ontario Sewer and Watermain Construction Association

Comment status

Comment approved More about comment statuses
OSCWA has been involved with the MECP and other stakeholder organizations in promoting the environmentally responsible and beneficial reuse of excess soils in Ontario for over a decade. Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77104

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses
The ESQSs for Petroleum Hydrocarbons F2 are too low and have resulted in a significant amount of soil to be managed as waste. The Table 3.1 ICC ESQS for PHC F2 is 26 ug/g, while the Table 3 SCS for PHC F2 is 230 ug/g, which is almost 10 times higher. Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77207

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses
The proposal to eliminate Section 14 from Regulation 406/19 is problematic. Project Leaders as defined in the Regulations are not required to have competencies in determining whether or not a site is potentially contaminated. Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77436

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses
The Government of Ontario Proposed Excess Soil Management Policy Framework document, recognizes that Conservation Authorities (in addition to Municipalities) are a main permitting body for soil receiving sites through regulations made under section 28 of the Conservation Authorities Act. Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77494

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses
On large infrastructure tunnelling projects, the current liquid soils (including solidifided liquid soils) storage capacity limits within a project area pose a major constraint due to the significant volumes of soil generated over a short period of time. Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77502

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses
Requirements of Registry reporting should match the scope of the project. For both large-scale or small projects, the required reporting is not practical and is significantly onerous (assessment of past uses for many kms and properties does not add value to the projects). Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77504

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses
For consideration by the Ministry, although we are aware that it is not the Ministry's intention to require sampling on all projects, the Regulation as written (including the onus on reuse receivers to set and comply with ESQS), requires sampling for the majority of projects generating excess soils, Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77507

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses
Under Sections B,2.(3)14-16 with respect to Sampling and Analysis Plan requirements, "Soil" is the referenced term when setting out the minimum sampling parameters, as well as the in-situ and stockpile sampling requirements. The terms "Excess Soil" or "Crushed Rock" are omitted from these sections. Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77509

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses
When existing asphalt and a proportion of the underlying aggregate are removed from a road during a reconstruction project and sent to a recycler, it is unclear what the requirements are under the Regulation for sampling the aggregate portion of this material, which to our understanding is excess so Read more

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Comment on

Amendments to Certain Requirements under the Excess Soil Regulation

Comment ID

77512

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses
Through the practical implementation of the excess soils requirements, it has been demonstrated that a significant amount of excess soils generated on typical construction/development projects are being classified as "waste", based on exceedances of applicable ESQSs, including the Table 3 small volu Read more

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