RE: ERO #019-7636 Proposed amendments to O. Reg. 406/19: On-Site and Excess Soil Regulation and the Rules for Soil Management and Excess Soil Quality Standards

406/19: On-Site and Excess Soil Regulation and the Rules for Soil Management and Excess Soil Quality Standards The Residential and Civil Construction Alliance of Ontario (RCCAO) is pleased to provide comments to the Ministry of Environment, Conservation and Parks (MECP) regarding the proposed amendments to Excess Soil Regulation in Ontario. [...] We want to commend the government on its work and advancement of this file and implementing a regulatory regime to improve the removal, disposal and re-use of excess soils. [...] 153/04, the Soil, Groundwater and Sediment Standards for use under the Environmental Protection Act and the accompanying Rationale Document (MOE, 2011) for potable groundwater scenario where a stratified soil approach can be maintained. [...] It is understood that this is a result of the primary driver of risk posed by EC/SAR which is outlined in the Rationale Document as being protective of soil organisms and plants. [...] We therefore recommend that the Ministry consider adopting a zonation approach to excess soil reuse sites, where a property can accept multiple soil qualities based on the site condition standards applicable to an area of the site, with appropriate setbacks.