UDI Lower Mainland submission to Ministry of Environment and Climate Change Strategy.

During UDI's discussions with the Ministry on Protocol 19, a significant problem impacting builders in the Capital Region District (CRD) was identified. Background concentration levels of naturally occurring minerals (e.g., salt) are being treated as contaminated, and require special disposal. This is particularly challenging in the Victoria area because there is a limited availability of fill disposal locations, especially those that can handle contaminated material.

UDI would like the Ministry to explore further changes to the implementation of Protocol 19 that would allow more flexibility for proponents and their Qualified Environmental Professions (QEPs) to recognize naturally occurring minerals when determining thresholds for contamination; and/or potentially adjusting the parameters for salt and other minerals in the CRD (and communities facing similar issues) in Protocol 4. This would reduce the volume of soil that must be relocated to the limited number of sites accepting contaminated materials.