Concerns with Proposed…

Concerns with Proposed Aggregate Resources Policy Changes

Executive Summary

Climate Action Newmarket Aurora is opposed to the policy changes of the Ministry’s proposal to update aggregate policies and rescind 28 existing ones, as it weakens long-standing checks and balances that protect Ontario’s water.
By removing clear safety buffers, tiered water-impact studies, ministerial oversight of site changes, and guaranteed public consultation, the new approach shifts from enforceable safeguards to more flexible standards. While the 2020 Technical Standards require professional expertise and data collection, they lack the automatic triggers and transparency measures that once ensured rigorous, site-specific protection of groundwater, wetlands, and community wells.

Overview

The Ministry of Natural Resources (MNR) is proposing to update three aggregate resources policies, create one new policy, and rescind 28 older ones. While described as “modernization,” these changes risk reducing oversight of water, community input, and rehabilitation practices.

Safeguards Being Removed

Hydrogeological Report Standards (A.R. 2.01.06)

Triggered a mandatory study if extraction was within 1.5 m (pits) or 2 m (quarries) of the water table.
Required licensed geoscientists or engineers to prepare reports.
Used a two-step process: Level 1 to flag risks; Level 2 to provide full impact and mitigation.

Protection lost: Clear safety buffer, step-by-step review, and accountability through expert-only assessments.

Site Plan Amendment Procedures (Reg. 244/97)

Previously required Ministry approval for operational changes (haul routes, fuel storage, equipment).

Protection lost: Oversight, transparency, and opportunity for third-party review before changes were made.

Public Notification and Consultation Standards

Ensured communities were informed and consulted about site changes, even minor ones.
Protection lost: Community voice and transparency in decisions with local impacts.

Rehabilitation and Cumulative Effects Oversight

Required compliance reporting, cumulative effects review, and consultation in source-water areas.

Protection lost: Long-term accountability for rehabilitation and recognition of broader environmental impacts.

What the 2025 Proposal Introduces

The new Water Report Policy is tied to the 2020 Technical Standards, which require:
A Maximum Predicted Water Table Report with at least one year of monitoring data (or equivalent reliable data).
A Water Report if extraction is proposed below the water table, prepared by a licensed professional with full methodology, data, and mitigation.

These are technically detailed but lack the old safeguards:
No buffer zone (1.5 m / 2 m) that automatically triggered a study.
No Level 1 / Level 2 process requiring deeper review when risks were identified.
No reference to climate resilience (flooding, droughts, shifting water tables).
The 2020 standards provide professional requirements and technical rigour but without clear triggers, layered reviews, or guaranteed public oversight, enforcement becomes discretionary.

In practice:

Old rules made it hard to dig near water without clear proof of safety.
New rules allow more flexibility, reducing transparency and weakening accountability.
This risks long-term harm to Ontario’s groundwater, wetlands, and community wells, while limiting public involvement and independent oversight.

Conclusion

If Ontario removes these safeguards without equally strong replacements, we lose essential checks and balances that protect water supplies, ensure community participation, and hold operators accountable for long-term rehabilitation.