Briefing Note: Concerns with…

Briefing Note: Concerns with Proposed Aggregate Resources Policy Changes

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 framed as modernization, these changes risk weakening safeguards that protect Ontario’s water, communities, and long-term land rehabilitation.

Safeguards Being Removed

Hydrogeological Report Standards (A.R. 2.01.06)

What it required: If extraction was within 1.5 m of the water table for pits or 2 m for quarries, a hydrogeological study was mandatory. A Level 1 assessment identified risks; if risks were found, a Level 2 study examined full impacts and mitigation. Only licensed geoscientists or engineers could prepare these reports.
Why it mattered: Created a clear safety buffer, enforced rigorous science-based review, and ensured accountability before digging near groundwater.

Site Plan Amendment Procedures (Reg. 244/97)

What it required: Operational changes like moving haul routes, relocating fuel storage, or adding equipment required Ministry approval.
Why it mattered: Guaranteed transparency, oversight, and third-party review before modifications were made.

Public Notification and Consultation Standards

What it required: Communities had to be notified and consulted about site changes, even minor ones.
Why it mattered: Protected community input and transparency in decisions with direct local impacts.

Rehabilitation and Cumulative Effects Oversight

What it required: Regular reporting on rehabilitation progress, consultation in source-water protection areas, and cumulative impact assessments.
Why it mattered: Held operators accountable for long-term outcomes and captured broader environmental risks.

What the 2025 Proposal Introduces

The new Water Report Policy aligns with the 2020 Technical Standards. These require:

A Maximum Predicted Water Table Report by a licensed professional using at least one year of groundwater data (or reliable existing data).
A Water Report when excavation is planned below the predicted water table, with methodology, data, and mitigation measures.

While technically sound, the proposal does not preserve the old safeguards:

No clear buffer zone (1.5 m / 2 m) that automatically triggered review.
No two-step Level 1 / Level 2 process that forced deeper study when risks were found.
No clear requirements to consider climate change impacts such as droughts, flooding, or shifting water tables.

Bottom Line

The 2020 standards require expertise and data, but without the clear triggers, layered review, and public oversight of the old rules, enforcement becomes more discretionary.
In plain terms:
The old rules made it hard to dig near water without proving safety.
The new rules replace those checks with flexible standards that may be interpreted inconsistently.
This reduces transparency, weakens accountability, and risks long-term harm to Ontario’s groundwater, wetlands, and community wells.

Conclusion

If Ontario removes these safeguards without replacing them with equally strong provisions, we lose critical checks and balances that protect water supplies, ensure community involvement, and hold operators accountable for long-term rehabilitation. Given these concerns, I am not in support of these policy changes.