RE: ERO #025-0216, Updating…

RE: ERO #025-0216, Updating and modernization of operational policies supporting the delivery of the provincial Aggregate Resources Act program

I have reviewed the changes proposed by the Ministry of Natural Resources. Overall, the primary beneficiary of the policy updates appears to be the aggregate industry rather than the people of Ontario. Many of these updates reduce accountability and further limit public knowledge of changes to pits and quarries, such as below the water table mining.

It is good to see proposed policy changes that require the MNR to issue a licence only if the MNR is satisfied that future aggregate operation will have no negative impacts on groundwater and surface water resources. Additionally, the incorporation of the Agricultural Impact Assessment in prime agricultural areas requiring that negative impacts be avoided or minimized is a welcome update.

That said, language to be included should strengthen the local input and prioritize environmental protections. We should not be causing further harm for proposals that aren't deemed necessary.

Furthermore, in its 2023 report, Ontario’s Auditor General noted the importance of adopting additional enforcement tools needed to address non-compliance as less than 1% of violations were referred for charges under the enforcement branch. According to the report, a lack of enforcement not only undermines the Act’s purpose “to control and regulate aggregate operations,” it also increases the risk of negative impacts on nearby communities and the environment. Retaining and strengthening enforcement and compliance policies under the ARA to minimize risks to communities and nearby residents while at the same time encouraging greater accountability within the industry should be an added goal of this bill.