Submission to ERO 025-0216:…

Submission to ERO 025-0216: Comments on ERO 025-0216: Updating and modernization of operational policies supporting the delivery of the provincial Aggregate Resources Act program
September 25, 2025
MNRF proposal Summary:
ERO Number 025-0216 proposes to update the Water Report and Cultural Heritage Report a new Maximum Predicted Water Table Report policy proposal, a fourth proposed policy relates to Section 12 of the ARA, which details the specific matters the Minister or the Ontario Land Tribunal must consider when deciding whether to issue or refuse an aggregate licence and rescind 28 policies from the Policy and Procedures Manual.
General Comment:
The aggregate industry, composed of both private companies and the MNRF aggregates staff, have constructed a land use practice for managing aggregate extraction outside of the provisions of the Planning Act since the Pits and Quarries Control Act 1971. The issuance of an ARA Licence is viewed by MNRF as an exemption from all provisions of the Planning Act such as S. 2 Provincial Interests, and S. 3 Provincial Planning Statement 2024.
The separation between the Planning Act and an ARA Licence becomes apparent with ARA Licence Site Plan Amendments. Site Plan Amendments are often used to introduce new land uses outside of the Planning Act, such as asphalt plants, concrete batching plants, recycling of used aggregates, etc., not accessory to the extraction, processing, storage and shipping of aggregates from a gravel or bedrock deposit.
Notes on Jurisdiction of the Planning Act over the Aggregate Resources Act [ARA]:
Planning Act and Aggregate Resources Act [ARA] Policies and comments:
The relevant legislative provisions governing the relationship between the Planning Act and Aggregate Resources Act [ARA] are listed below:
Planning Act, RSO 1990, c P.13, Policy statements and provincial plans
3(5) A decision of the council of a municipality, a local board, a planning board, a minister of the Crown and a ministry, board, commission or agency of the government, including the Tribunal, in respect of the exercise of any authority that affects a planning matter, [emphasis added]
(a) subject to a regulation made under subsection (6.1), shall be consistent with the policy statements issued under subsection (1) that are in effect on the date of the decision; and
(b) shall conform with the provincial plans that are in effect on that date, or shall not conflict with them, as the case may be. 2006, c. 23, s. 5; 2017, c. 23, Sched. 5, s. 80; 2023, c. 10, Sched. 6, s. 2 (1).
From: https://www.canlii.org/en/on/laws/stat/rso-1990-c-p13/latest/rso-1990-c…
Comments: The PPS 2024 establishes the legislative requirement that for all planning matters of any scale, by any authority, including MNRF Aggregates staff, the policies contained in the Statement must be considered and decisions made consistent with them.
The PPS 2024 establishes broad, minimum policy direction for determining the principle of a land use in a location and remain in effect down through zoning and site plans, for all land uses.
No PPS 2024 policy has priority over another. The PPS 2024 must be read in its entirety and the relevant policies carefully reviewed and a balance determined for each planning matter and land use.
Planning Act Conflict
S. 71 In the event of conflict between the provisions of this and any other general or special Act, the provisions of this Act prevail. R.S.O. 1990, c. P.13, s. 71.
Comment: This policy clearly sets the Planning Act and decisions and practices made under its provisions above all other legislation dealing with land use.
No exceptions are provided.
Planning Act: Pits and quarries
34 (1) Zoning by-laws (2) The making, establishment or operation of a pit or quarry shall be deemed to be a use of land for the purposes of paragraph 1 of subsection (1). R.S.O. 1990, c. P.13, s. 34 (2).
Comment: Section 34[1] establishes aggregate extraction as a land use under the Planning Act. ARA Site Plans and Site Plan Amendments remain planning matters subject to the PPS 2024, municipal official plans and zoning by-laws.
Comment: A logical extension of this prohibition is the importation of excess construction soils, “waste aggregate materials”, asphalt and concrete plants, etc., if the zoning by-law does not permit them.
Aggregate Resources Act, R.S.O. 1990, Chapter A. 8 Zoning by-law prohibition on licence
12.1 (1) No licence shall be issued for a pit or quarry if a zoning by-law prohibits the site from being used for the making, establishment or operation of pits and quarries. 1999, c. 12, Sched. N, s. 1 (1).
Comment: The ARA contains similar language as the Planning Act establishing the priority of a permissive zoning by-law prior to an ARA License being issued.
Aggregate Resources Act overrides municipal by-laws, etc.
"66 (1) This Act, the regulations and the provisions of licenses and site plans apply despite any municipal by-law, official plan or development agreement and, to the extent that a municipal by-law, official plan or development agreement deals with the same subject-matter as this Act, the regulations or the provisions of a licence or site plan, the by-law, official plan or development agreement is inoperative. 1999, c. 12, Sched. N, s. 1 (4)."
Municipal Act S.O. 2001, Chapter 25: Powers exercised by council
5 (1) The powers of a municipality shall be exercised by its council. 2001, c. 25, s. 5 (1). [emphasis added]
Powers exercised by by-law
5(3) A municipal power, including a municipality’s capacity, rights, powers and privileges under section 9, shall be exercised by by-law unless the municipality is specifically authorized to do otherwise. 2001, c. 25, s. 5 (3); 2006, c. 32, Sched. A, s. 5. [emphasis added]
Scope
(4) Subsections (1) to (3) apply to all municipal powers, whether conferred by this Act or otherwise. 2001, c. 25, s. 5 (4).
Discussion:
The problem with ARA Sec. 66[1] is that in order for a new strip mine to achieve an ARA Extraction Licence there must be a permissive OPA and Zoning By-law Amendment which must stay in effect for the life of the licence, otherwise the land use would be illegal. There are many studies and peer reviews conducted, accompanied by public consultation, on which a Council basis its’ opinion that approval, with conditions, of an OPA >ning for a strip mine meets the tests of “good planning”. Many conditions of approval are attached to the OPA >ning approval, all of which must remain in effect during the life of the strip mine and are included in the ARA Site Plan. The problem is the municipal OPA and Zoning By-law Amendment approving the making, establishment or operation of a pit or quarry are by necessity, by-laws, and necessarily deal with the same subject matter as the ARA licence >te plan and, under plain reading of the text, are thus “inoperative” via ARA 66[1].
If the permitting OPA and Zoning By-law Amendment have, under ARA Sec. 66[1], no moment upon the issuance of an ARA licence, due to ARA 66[1] eliminating any municipal by-law dealing with the same subject matters as the ARA, the subject strip mine becomes an illegal land use under the Planning Act. This is, of course, absurd; however, a plain reading of the two Acts leads to the absurdity.
Planning Act S. 71 clearly solves the absurdity of the ARA S. 66.1 by ensuring decisions made under the provisions of the Planning Act supersede decisions under other legislation.
Day to day aggregate operations: A practical matter exists with the licensed producer’s normal activities of mining, processing, storing and shipping of aggregate needing to make changes such as moving crushing/wash plants, stock piles and internal haul routes requiring a site plan amendment. While the land use remains subject to the Planning Act, the minor changes to a site plan required for normal operations are not a change in land use or a planning matter. However, the aggregate industry/MNRF have taken ARA 66.1 to extremes by making significant site plan amendments independent of the Planning Act and municipal Official Plans and Zoning By-law provisions. Dumping of excess construction fill claimed as rehabilitation, asphalt and concrete batching plants, aggregate recycling, etc. all of which may properly be located in urban industrial areas and are not directly associated with virgin aggregate extraction, are uses not accessory to extracting aggregate. The new uses are planning matters under the Planning Act.
The initiative, Updating and modernization of operational policies supporting the delivery of the provincial Aggregate Resources Act program, continues a practice of MNRF and licensed operators making land use decisions independent of the Planning Act not supported by the legislation. Constructing a set of land use standards outside of the Planning Act creates duplication, costly red tape and confusion with the public over governance roles.
This practice is particularly dangerous and appears like government meddling to facilitate the wishes of an ARA licenced operator. Optics are very concerning. It would have been helpful if, over the decades, the MNRF mineral aggregates section had provided a clear demonstration of arms length independence from the private operators in both inspections and site plan amendments. This would have assisted in clarifying the need for these revisions as the current perception by the public and the agencies is one regulatory capture. MNRF has approved private operators to carry out their own site plan amendments to some level of complexity.
Comments Water Report:
The draft terms of reference contain a vague purpose statement regarding water and aggregate extraction. There is a lack of a problem statement establishing what environmental, social and economic issues are to be solved; e.g. rural areas in Ontario are generally unserved by municipal potable water; all rural areas drink their ground water; aggregate extraction, by its nature, destroys everything on or in the land mined; aggregate mining consumes millions of litres of fuel which must be delivered and transferred into heavy machinery often only 1.5 m above the water table providing no safety buffer; aggregate extraction may cause changes to ground and surface water flows. Consideration of the Water Resources Act must be an essential part of any water report.
Excess Construction Fill: post extraction rehabilitation may use large amounts of excess construction fill which will have different percolation rates than sand and gravel deposits. Contaminated soils may be an additional risk to the water quality. Current MNRF practice is to approve substantial ARA site plan amendments under the notion of rehabilitation for massive fill dumps with little or no precautionary conditions on fill quality or types. Working through the need to address old Brown Field industrial sites, MOECP has developed waste soil tables based on levels of toxicity. Excess construction fill standards arise from the Brown Site program. Due to the high need to protect the quality and quantity of rural ground and surface waters, any fill operation into aggregate extraction sites must be of the cleanest soils possible. Major fill projects become a new land use and must be processed through the Planning Act.
Dewatering: Bedrock quarries must achieve a dry working floor for operations. Dewatering the quarry requires constant pumping of incoming groundwater plus additional capacity to deal with storm events. Access to a receiving stream of sufficient capacity to accommodate the additional base flow without causing erosion is essential. Often bedrock deposits are not located adjacent to adequate receiving streams and piping some distance may be required over private lands or along roadways. The researchers setting the ARIP aggregate potential mapping do not consider the presence of ground waters as a constraint. A policy warning is required to deal with identification of bedrock deposits and the dewatering issue. Identifying bedrock deposits having no adjacent receiving streams causes unjustified land use restrictions on private lands inside and in the areas of influence located outside of the deemed deposits.
The term mitigation is mentioned but no definition is provided. The scale and intensity of potential negative natural environment, social and economic impacts from aggregate extraction require careful management often over decades. The notion of mitigation means some arrangement of risk measures to lessen negative impacts and adverse effects. The Environment Protection Act and Regulations are an important consideration. The terms of such measures must be determined and then applied in an open, traceable manner. Continual monitoring and oversight activities are also required to be open and traceable. MOECP staff and local communities must be involved in drafting any risk management measures.
Qualified Person comment:
The concept of a QP is referenced without a context. The deemed omniscience and omnipotence of such an individual, employed by an aggregate producer, to manage and solve all negative environmental and social adverse effects is astonishing. Life of the ARA Licence QPs, and accompanying liability insurance, accessible by the municipality to fix losses of ground and surface waters quality and quantity, is essential.
Zone of Influence for ground and surface water adverse effects has several general concern areas mentioned but no detailed criteria for how the distance may be adequately determined. Different geologies will have unique characteristics. Continuous dewatering of bedrock quarries, often for over eight decades requires exceptional care to avoid adverse effects extending far beyond extraction property boundaries.
Large removal of ground water may change the flow direction far beyond the property boundaries of a quarry. Discharge must be to a receiving stream of sufficient capacity to accommodate the additional flows without causing erosion or cutting new channels. Often a suitable receiving stream will be a considerable distance from a proposed quarry site.

Pg.3 Refers to the Clean Water Act wellhead protection areas as a special concern. Acceptable as far as that goes, however there are vast areas of countryside and many rural settlements dependent upon individual private wells requiring protection from ground water pollution or loss of quantity.
Pg.4 “Note: An impact is generally considered ‘unacceptable’ when it compromises the use of the water source (e.g., well) by another user or hinders the ecological functions of natural features within the zone of influence. Mitigation actions should include relevant measures for protecting water resources, as per the Provincial Planning Statement and any applicable provincial plans.”
Comment: This is an excellent definition of an unacceptable impact plus citing of the policies of the PPS 2024 and provincial plans. We shall see if this note survives through to a final version.
Comments Maximum Predicted Water Table Report:
Under the purpose section there is reference to ARA Standards as a requirement for the determination of Max. Water Table [Max]. There is no problem statement or establishment of why the Max. Level is of importance. For any building it is important as the basement would fill up with water if not well above the Max. The ARA makes a distinction between above the Max. or below water table but this is an administrative matter not clearly a safety or potential for alteration of an important public good being continuous, clean ground water. The problem statement should articulate clearly the destructive nature of aggregate extraction which destroys everything on or in a landscape for ever and requires the consumption of millions of litres of fuel and grease over decades.
The term mitigated, discussed above, is of concern and requires careful definition. The way mitigated is used is often a signal to treat adverse effects as merely technical. An open, traceable process for discussing and deciding on adverse effects is essential.
The draft document, fails to reference the Planning Act, S. 2 Provincial Interests and S. 3 PPS 2024 roles in making decisions about land use in Ontario.
Re-evaluation of a Max. must be made during a large, below water table, concession wide extraction as water will seek its own level to affect a lower up current level and higher down current level. This phenomenon is important when considering depositing excess construction fill into below water table extraction sites wherein the fill acts as a type of ground water dam and slows the rate of ground water travel, raising the previously established water table to unexpected Max table levels or reduction.
Under 2.3 Ground Water Recharge the statement. “As a result, the ground water table also varies seasonally, and from year to year.” While under 3.1, “Maximum predicted water table elevation must be determined based on water level measurements taken from onsite ground water monitoring wells or test pits, over a period of at least one year…” Oh come on, only one year required but levels vary over years? The whole exercise of establishing a Max. water table is problematic. Extraction proponents want the minimum evaluation while reality requires many years, perhaps over a decade of monitoring.
“It may not be necessary to determine the exact position of the ground water table if it is substantially below the anticipated final depth of the proposed excavation. By drilling a well to a depth of at least 2.5 m below the proposed maximum depth of extraction (typically a site sump or pond), a QP may determine that the proposed excavation will remain above the ground water table.” Pg.3
The test at 2.5 m below the proposed max depth of extraction is unsatisfactory. Firstly, which comes first - the Max determination or the desired extraction depth? Secondly, what rationale, does MNRF use to justify a mere 2.5 m [8.2’] is adequate to confirm a natural phenomenon such as a fluctuating water table elevation in a sand and gravel deposit? Annual fluctuations of the water table in the Caledon outwash channel have been observed at 4.6 m.
Cultural Heritage Report:
The draft paper on Cultural Heritage is well done, citing the relevant legislation and guidelines. Special guidelines must be developed to address the First Nations engagement and consultation process for new ARA extraction licences and significant site plan amendments. PPS 2024, 4.6 Cultural Heritage and Archaeology policies provide a high level of direction for the preservation and protection of cultural heritage and archaeology but not meaningful engagement and respect of First Nations.
MNRF and the aggregate industry must refer to the state obligations set forth in paragraphs 87 and 88 of EMRIP’s 2020 publication, “Repatriation of ceremonial objects, human remains and intangible cultural heritage under the United Nations Declaration on the Rights of Indigenous Peoples” (UN. Human Rights Council. Expert Mechanism on the Rights of Indigenous Peoples, A/HRC/45/35 << https://digitallibrary.un.org/record/3876274?ln=en>&gt;).

Matters to be Considered in the Issuance of a Licence:
1.1. Purpose refers to evaluation of an application for a licence. The general impression of MNRF staff reviews has been more of ticking boxes to determine a complete application as opposed to a thorough reading of supporting reports. Aggregate extraction is destructive of the site landscape and generates of multiple adverse effects to surrounding land uses and along haul routes. The notion of evaluation raises several concerns with the process:
• Quality of technical reports required to be reviewed
• Expertise of MNRF staff suitable to review technical reports
• Ability of MNRF staff to perform arms length, independent opinions on applications.
• Ability to perform as expert witnesses at Hearings.
2.1 Effects on Environment: refers to “municipal agencies”. This title demeans the most important level of government to residents and businesses in Ontario. Municipalities are not subordinate agencies to MNRF staff.
A list of provincial plans is provided, but omits reference to the Planning Act S. 2 Provincial Interests and S. 3 P.P.S. Municipalities work with the relevant policies of these plans and Planning Act provisions in making land use decisions refusing or approving the principal of use and essential conditions for aggregate extraction on a property.
MNRF seems to define natural environment as air, land and water or any combination thereof. Living things are not referred to as relevant. Aggregate extraction sites exist in a living, functioning landscape ecology. As a minimum, the existing ecology of both the proposed extraction site and surrounding landscape must be measured and potential adverse effects documented and assessed. A confirmatory, publicly accessible monitoring program must be carried out over the life of the ARA licence.
2.2 Effects on nearby Communities references two distances from sensitive receptors, 500m for quarries and 150m for pits as a base level of concern with adverse effects on sensitive land uses. PPS 2024 S.3.5 deals with major facilities and sensitive land uses. Definitions include aggregate extraction as a major facility. Determination of areas of influence may require careful study beyond the MNRF prescribed distances. Prevailing winds carry heavy dust materials several kilometres beyond an aggregate extraction site boundary.

Adverse effects are defined in the PPS S. 3.5 and in the Environmental Protection Act, means one or more of:
a) impairment of the quality of the natural environment for any use that can be made of it;
b) injury or damage to property or plant or animal life;
c) harm or material discomfort to any person;
d) an adverse effect on the health of any person;
e) impairment of the safety of any person;
f) rendering any property or plant or animal life unfit for human use;
g) loss of enjoyment of normal use of property; and
h) interference with normal conduct of business.
Consideration of the eight broad effects extends far beyond dust, noise and vibration. MNRF aggregate staff must be reminded of the extent of adverse effects listed in PPS 2024.
Adverse effects arising through cumulative, massed aggregate extraction licences of several thousand acres must be a community consideration.
Adverse effects related to “fly rock” have not been listed nor considered by MNRF.
A generic blast design report must be submitted with a bedrock licence application to avoid the implicit assumption that the dust, ground vibration and air pressure force associated with blasts are not a trivial matter. An additional requirement for each blast which addresses specific details of the rock formation being blasted prepared by licensed blast designers. Provincial inspectors must monitor blasting quarries on a regular basis to confirm that approved plans are in fact being followed and have the desired effect of reducing adverse effects to acceptable levels.
2.3 Comments from Municipalities. The section above, Notes on Jurisdiction of the Planning Act over the Aggregates Resources Act, are relevant to the role of municipalities under the Planning Act. A MNRF/Industry practice has evolved to assume municipalities are subordinate to the ARA in dealing with site plan amendments which is not supported by a plain reading of the legislation. Comments on proposed ARA site plan amendments must be included as conditions.
2.4 Rehabilitation Plans. Rehabilitation plans are a determination of final land use following the end of extraction and are a planning matter under the Planning Act. Final rehabilitation plans must be approved, not merely commented, by the host municipality. Generally aggregate extraction has taken a viable economic land use and destroyed it. Rehabilitation policy intention is to restore the “original and/or surrounding land use”. This rarely occurs. Current ARA Site Plan Rehabilitation amendments are approved as technical changes and involve the importation of vast quantities of excess construction fill [14 million cu. M. and up] either over the estimated 1.5m above water table or into ground water lakes created by extraction. The rationale is claimed to be restoring agriculture. Excess fill quality matters a great deal as aggregate extraction occurs in rural areas unserved by municipal potable water, and groundwater is drunk by residents and agriculture. The lower quality, polluted fill raises higher tipping fees, an incentive for pit owners to devise manipulation of MOECP Soil Tables to permit polluted soils into their excavations as a new revenue source.
MNRF must develop a robust protocol to govern the importation of excess construction fill into ARA Licenced sites.
The notion of progressive rehabilitation during aggregate extraction has become a common condition of recent ARA site plans. Once again, provincial inspectors must review rehabilitation progress against the site plan conditions.
2.5 Effects on Ground and Surface Water: see comments above on Water Report and Water Table Elevation.
2.6 Effects on Agriculture: Aggregate extraction, by its nature, destroys agricultural potential. Rehabilitation to farming is very rare. The goal of not having “any potential negative impacts be minimized mitigated” from an aggregate operation without extensive and expensive rehabilitation is fanciful.
2.7 Planning and Land Use: See introductory comments in Notes on Jurisdiction of the Planning Act over the Aggregates Resources Act above.
The ARA Licence approval process conducted by MNRF is adversarial. A proponent files an application based on maximizing profit and externalizing adverse effects. Principles of good planning are raised by the host municipality and affected members of the public. Finding the planning matters raised by the municipality and residents would affect profitability, the proponent refers the matter to a tribunal where very expensive lawyers and expert witnesses compete to have the tribunal find in their favour. Most small municipalities cannot afford to defend their landscapes and communities from large, often international, corporations. There is little confidence in the adversarial tribunal approval process and its regard for good planning.
2.8 Haulage Routes and Truck Traffic. ARA S. 12 (h) the main haulage routes and proposed truck traffic to and from the site is a topic required to be considered by the Minister. In rural areas where aggregate deposits are likely to be located, the roads have been developed and maintained for local residential and agricultural uses. Upgrading such roads to movement of heavy loads, often for some miles, requires significant capital investment. Aggregate operations, while being heavy industry, are not considered development for development charge levies. The capital improvements for haul routes must be paid out of general property tax revenues of the host or neighbour municipality. Having the residents and businesses subsidize private enterprise aggregate production through their property taxes is unsatisfactory.
Aggregate haul routes often include residential and small business settlements along the route to markets. Aggregate truck traffic causes noise, vibration, congestion, exhaust fumes and considerable added risk to other light vehicle traffic. These adverse effects are externalized by the aggregate industry and not meaningfully considered by MNRF. Instead, local municipalities are forced to either increase capital investment or increase maintenance costs and cope with the adverse effects. Reducing haul route studies to traffic counts and “road capacity” calculations is unsatisfactory.
2.9 Quality and Quantity of Aggregate: What are the justification tests for approving or refusing a licence based on “sufficient quality and quantity of material”? Having to prove market need for materials in a proposed ARA licence area is forbidden under the PPS 2024. By creating unlimited numbers of aggregate extraction licences an area can quickly come under considerable cumulative adverse effects.
2.10 History of Compliance: It has been difficult to find a source for the listing and solving of ARA Site Plan conditions. If an aggregate inspector determines an infraction on a site the process seems to be conducted behind closed doors. Developing a publicly accessible listing of non-compliance and remedies would encourage public confidence in the MNRF Aggregate Program.
Given the findings of the Auditor General in their 2023 report on aggregates, MNR rarely does inspections of operating pits and quarries, or charge operators with penalties for infractions; this is not a deterrent for bad actors! As a result, most applications are likely rubber stamped when it comes to history of compliance!
2.11 Other Appropriate Considerations:
Comment Identification of Aggregate Resource Potential:
The identification of potential areas of aggregate resources in municipal official plans involves the removal of development rights to lands inside the identified resource areas and large areas deemed to be in areas of adverse impact influence. There is no requirement for notification of land use reductions or compensation to affected land owners. RECO, the real estate industry governing body, now has a requirement for full disclosure of any conditions of a property affecting the property’s value. Title searches and property inspections do not uncover the burden placed on the use and enjoyment of aggregate identified lands.
“Big picture” Outlook comment:
MNRF must look at the “big picture” and consider the long-term sustainability of the current aggregate planning and approval regime, (Aggregate extraction is a provincial priority.] The need for specific new pits does not need to be justified regardless of available licensed supply. Mined land in prime agricultural land is lost to this category and productivity for centuries. Potential impacts on drinking water supply amount and quantity continue to be concerns particularly if extensive construction fill is imported into pits and quarries. MNRF must revamp its entire planning, review, approval, inspections and enforcement processes, with a long-term focus on the sustainability of the province.
Fly rock from bedrock quarries comment:
A draft definition: Fly rock is material that is ejected from the point of blast in a controlled explosion in mining operations or construction sites. Fly rock is an inevitable by-product of blasting rock (can include pebbles, stones, car-sized boulders, mud, sand, tree trunks, building materials, water, blasting mats, etc.). Of concern are rock and other debris launched beyond the construction site or boundaries of the mining site, causing injury, permanent disability or death to people or non-human forms of life, and damage to personal or real property.
Draft fly-rock policies:
Fly-rock produced by explosive blasts designed to break and loosen bedrock may reach airborne speeds of hundreds of miles per hour and shall not leave the quarry site causing danger to life and property. Ontario Aggregate Resources Act (ARA), O. Reg. 244/97,1, 28. “A licensee or permittee shall take all reasonable measures to prevent fly rock from leaving the site during blasting if a sensitive receptor is located within 500 metres of the boundary of the site.”
Fly-rock meets criteria as a contaminant under the Ontario Environmental Protection Act and shall be treated as an adverse effect under Provincial Policy Statement #1.2.6
Any bedrock quarry operation based on blasting shall be treated as a permanent use of land under the Town’s Official Plan according to Planning Act S. 34 1(2) “The making, establishment or operation of a pit or quarry shall be deemed to be a use of land for the purposes of paragraph 1 of subsection (1).”
Permanent zoned onsite 500-meter setback of 500 meters shall be required for all blasting operations in the Quarry site
Permanent offsite minimum separa