OSWCA Submission on Proposed Site Alteration Bylaw in Whitby
Published on: 05/01/2016
Attached is the final OSWCA submission made to the Town of Whitby during its consultation process for its proposed Site Alteration Bylaw (the Town's bylaw proposal is also attached for reference). The bylaw proposal is the most recent in a string of municipal regulations that seek to curb the disposal of excess fill from construction sites in the Greater Toronto Area (GTA).
The proposal put forward to stakeholders by the Town of Whitby selectively adopted some of the strictest provisions from other recent municipal fill bylaws (i.e. Scugog, CLOCA, Burlington, and Stouffville). Many items in the proposal would be extremely difficult to implement in the field or would create a much more significant administrative burden to local fill site operators and those utilizing these fill sites. Interim amendments made to the municipal Fill Control Bylaw as a "stop-gap" solution, while the Site Alteration Bylaw is being developed, has already imposed a $1/m3 tax (or $10 per dump truck load) on all fill sites in Whitby.
OSWCA has made a number of specific recommendations on the proposal, and have made the general recommendation that the Town of Whitby hold off on moving forward with the Bylaw until a much more fulsome discussion can be had with industry stakeholders to ensure that local contractors and fill site operators are not adversely affected by this proposal. Particularly given that the Ministry of Environment and Climate Change (MOECC) are working on this very issue, we believe that it is necessary to wait and work with the MOECC outcomes.
If you have any questions or comments about the proposed Whitby Site Alteration Bylaw, please contact Patrick McManus (905-629-7766 ext. 222 or firstname.lastname@example.org).
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