Thank you for the…

Thank you for the opportunity to provide comments on the proposed updates to operational policies under the Aggregate Resources Act (ARA). While I recognize the ministry’s efforts to clarify requirements and improve efficiencies, I must express strong concern with the proposed retirement and rescission of several key policies.

The characterization of these policies as “outdated” is misleading. Many of them continue to serve vital functions for environmental protection, enforcement, and community rights. Removing them without clear replacement risks weakening accountability and undermining the transparency and fairness the ministry claims to uphold.

In particular, I wish to highlight the following:

• A.R. 1.00.07 – Designation of Inspectors: Removing this policy creates uncertainty about who holds inspection authority and how enforcement powers are exercised. Inspector designation is fundamental to ensuring consistent and accountable compliance.

• A.R. 4.04.01 – Site Plan Amendment to Extract Within Water Table: While the new Maximum Predicted Water Table Report and updated Water Report provide stronger technical requirements, rescinding this policy erodes clarity around amendment procedures, consultation obligations, and thresholds for ministerial review, all critical safeguards for protecting groundwater and habitats.

• A.R. 4.08.00 – Procedural Guidelines for Hearings: Clear hearing procedures are essential to due process. Without them, affected communities, including First Nations, face diminished ability to effectively exercise their rights and participate in appeals.

• A.R. 5.00.19 – Management of Abandoned Aggregate Properties (MAAP): Abandoned pits and quarries present real and ongoing risks to ecosystems, public safety, and cultural heritage. The absence of clear policy direction on rehabilitation and long-term accountability would leave a dangerous gap.

• A.R. 7.00.00 – Enforcement: General and A.R. 7.00.01 – Provincial Offences Act Charges: Enforcement is the backbone of any regulatory framework. Rescinding these policies without replacement risks weakening deterrence, creating ambiguity in compliance expectations, and ultimately undermining the integrity of the ARA.

These policies are not redundant; they are central to protecting water, cultural heritage, Treaty Rights, and the public interest in the face of industrial development pressures. I strongly urge the Ministry to either maintain these policies or, at minimum, clearly identify where their substantive provisions will be carried forward in regulation, updated policy, or consolidated guidance.

I appreciate the opportunity to comment and trust that the Ministry will carefully consider the impacts of these rescissions. These decisions will have long-lasting consequences for environmental stewardship, Indigenous Rights, and community confidence in Ontario’s aggregate management.