Subject: Comments on ERO …

Subject: Comments on ERO #025-0216 – Aggregate Resources Act Policy Updates

I am writing in response to ERO #025-0216 regarding the proposed updates to operational policies under the Aggregate Resources Act (ARA). We appreciate the opportunity to provide feedback and have reviewed the proposed changes in detail.
While we recognize some positive developments, such as the requirement for licences to be issued only when future aggregate operations pose no risk to groundwater and surface water resources, and the inclusion of Agricultural Impact Assessments in prime agricultural areas, we are concerned that many of the proposed updates disproportionately benefit the aggregate industry at the expense of public interest, transparency, and environmental protection.

Below are our specific comments and recommendations:

Matters to Be Considered in the Issuance of a Licence
We recommend the following additions to the list of considerations for licence issuance:
• The effect of blasting on public safety, particularly for blasting quarries
• Potential impacts on local air quality and emissions
Additionally, we suggest revising the language regarding municipal input from “must be carefully considered” to:
“must be consistent with Official Plans and zoning bylaws as they relate to economic, health, and safety matters.”

Cultural Heritage Reporting
This section should receive input from Indigenous Peoples. Where interest or concerns are expressed, operators should be required—not merely encouraged—to engage impacted Indigenous communities during archaeological studies. We recommend changing “may require” to “shall require.”

Expansion of a Licenced Area
Simplifying the expansion process without requiring a new licence or thorough assessment raises concerns about due diligence and regulatory oversight. This change risks environmental degradation and public health impacts. We urge the Ministry to reconsider this approach.

Licence Site Plan Amendment to Extract Within Water Table
Removing the requirement for a site plan amendment and public notification when extracting near the water table is deeply concerning. This change reduces transparency and increases the risk of aquifer contamination and impacts to local wells. We strongly oppose this amendment.

Enforcement and Compliance – Provincial Offences Act (POA)
We support the proposal to consider an applicant’s history of violations. However, rescinding the internal enforcement policy that guides inspectors in escalating violations undermines accountability. Without a structured framework, prosecutions may become rare or nonexistent.
As noted in the 2023 Auditor General’s report, fewer than 1% of violations were referred for charges. Weak enforcement erodes the ARA’s purpose and increases risks to communities and the environment. We strongly recommend retaining and strengthening enforcement policies to ensure meaningful compliance and industry accountability.

Thank you for considering my comments. I urge the Ministry to prioritize public interest, environmental protection, and transparency in finalizing these policy updates.