EJQ6 - Fall 2025 - Journal - Page 40
“Thisregulatoryin昀氀exibilityisnotjustfrustrating—it’s
counterproductive.Itunderminescon昀椀denceinthe
system,slowsredevelopment,andneedlesslysends
reusablesoiltoland昀椀ll.”
New guidance documents continue to be developed:
The Best Practices Guidance for Reuse Sites, issued by QPCO.
A draft Tunneling Guidance Document by the Ontario Environment Industry Association (ONEIA), addressing analytical hurdles speci昀椀c to
tunnel spoils.
A national Excess Soil Reuse Guidance published by the Canadian Council
of Ministers of the Environment (CCME), applicable across Canada.
The compliance challenge
A major source of frustration among environmental professionals is compliance—or
lack thereof. While many practitioners are working hard to meet regulatory expectations, non-compliant projects are signi昀椀cantly harder to track. The MECP has been
conducting inspections for several years, but it’s unclear how many are triggered by
projects that properly 昀椀led notices on the Excess Soil Registry versus those identi昀椀ed
through complaints.
Meanwhile, illegal dumping continues across the province. As an extra insult, the
costs of cleaning up after these activities have increased under the regulation for
those following the rules, as additional testing and reporting is required. A troubling
trend is the misrepresentation of reports; QPs are strongly encouraged to reach out to
one another directly to verify documentation and uphold integrity in the system.
Naturally Occurring Exceedances: Waste or resource?
One of the most persistent technical frustrations is the presence of naturally elevated
parameters—in both soil and bedrock. These are often region-speci昀椀c and have long
posed issues for municipalities and developers. The current framework, however,
frequently treats these as unacceptable exceedances, resulting in the often-unnecessary disposal of otherwise benign material.
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