The consolidation of a number of policies into consistent direction with respect to licensing and applications under the Aggregate Resources Act is, generally, a worthwhile proposal.
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To Whom It May Concern,
Please find attached a report approved by County of Brant Council.
In addition to the feedback in this Report, the County provides the following recommendations:
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We must keep Safeguards on Aggregate Projects!
Ontario’s proposed updates to aggregate policies are removing key protections for groundwater, wetlands, and community oversight.
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The attached letter details comments and questions from Peel Region staff regarding the proposed amendments. Peel Region staff recommend additional measures be incorporated to ensure long-term protection of groundwater resources and community sustainability.
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The application process for a new aggregate permit site is a burden on the industry.
Those who are already in the business should not have to deal with all the existing requirements to establish a new permit.
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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.
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RE: ERO #025-0216, Updating and modernization of operational policies supporting the delivery of the provincial Aggregate Resources Act program
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The following are my comments on the proposed changes outlined in ERO 025-0216 Updates to Aggregate Policies, using the numbering system MNR used:
1 Purpose
2.0 Considerations in Issuing a Licence
2.1 (a) Effects on the Environment
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RE: ERO #025-0216, Updating and modernization of operational policies supporting the delivery of the provincial Aggregate Resources Act program
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RE: Comments on Aggregate Resources Act Updates
The intent of this correspondence is to provide comments on the proposed updates and modernization of operational policies supporting the delivery of the provincial Aggregate Resources Act program. Our comments are as follows:
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Changes to the ARA to comply with current legislation is an important function of the MNR, and changes to meet the needs of the public are equally important.
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When considering a new quarry license application for extraction below the water table attached to, or adjacent to, an existing license already granted below the water table, the rehabilitation of the existing will be compromised if the rehabilitation included creation of a lake or water body.
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I am a consultant who has worked in the forestry and aggregate sectors in Northwestern Ontario since the 1970s and I’ve been involved in the preparation of aggregate permit site plans and applications for over 25 years.
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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.
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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.
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We must keep Safeguards on…
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