Some of the proposed changes…

Some of the proposed changes to the PPS are regressive and harmful. They will encourage the aggregate and development industries to expand with less regulation and to bypass environmental approvals and rules that were painstakingly put in place, for good reason. Water protection should be paramount.

Re 2.1.5, 2.5.2.2, and 2.5.4.1: According to the Ontario Aggregate Resources Corporation, there is a legacy of unrehabilitated and unrestored lands — 8,110 abandoned pits and quarries! Permission to operate an aggregate mining site must come with enforceable responsibility and accountability for the full life cycle of the operation and beyond.

A previous dearth of regulation as well as a lack of enforcement of rules led to numerous aggregate operators not complying with their moral and legal rehabilitation obligations. This is a result of having no strong financial security measures that ensure timely environmental rehabilitation or restoration once mining operations are completed. A pit or quarry applicant should be obliged to make annual rehabilitation payments into an escrow account, but the value of such payments must relate to the projected cost of rehabilitation. As well, those costs should not be minimized by the applicant, who may be judgment-proof by the time the pit is exhausted.

It’s also time to impose sunset clauses to stop the practice of operators who keep near exhausted sites active enough to avoid rehabilitation expense.

Agricultural rehabilitation in particular has been largely unsuccessful. If extraction is permitted on agricultural lands, there must be a feasible plan for providing alternative food resources.

Re 2.1.8: There is abundant scholarly evidence indicating that mineral extraction and heavy dump truck traffic next to wetlands result in increased pollution in wetlands, loss of plant species, changes in water quality and flow patterns, loss of wildlife habitat, and increased salinity. The proposed policy implies that extraction and its equipment would be permitted adjacent to the Niagara Escarpment. Ecological sensitivity of wetlands does not abruptly end a few meters away from their NEC border.