OFA provided the Ministry of the Environment, Conservation and Parks with comments on the proposed regulatory amendments to encourage greater reuse of excess soil.
OFA fully supports the overarching principle of beneficial reuse of excess soils in Ontario. We support setting clear rules and procedures to direct the appropriate reuse of excess soils and consistent enforcement when those rules are not followed. Our primary concern is to ensure that agricultural lands remain productive and free from potential contaminants that could threaten our local food safety and supply. Eliminating the risk of contamination to agricultural lands is paramount. While we understand that these amendments are intended to encourage greater reuse of excess soil in the province, we remain concerned with any potential easing of the regulation related to movement of excess soils onto agricultural lands.
OFA recommends that the province also develop setbacks from agricultural areas where salt-impacted soil is not permitted. OFA further recommends that salt-impacted soils continue to be placed on industrial or commercial sites where quality standards can be applied, and not in the agricultural landscape.
OFA supports the proposal for greater flexibility regarding the storage of soil adjacent to waterbodies with the proposed requirements that it is only soil that was excavated from the water body near the shoreline (other soil could not be brought to that area for storage) and that potential adverse impacts to the water body are mitigated.
Previous related OFA submissions:
December 2, 2022 – OFA submission to the Ontario Ministry of the Environment, Conservation and Parks (MECP) regarding proposed amendments to certain requirements under the Excess Soil Regulation (ERO 019-6240)