I learned last week of the…

I learned last week of the introduction of Bill 132 (1st reading) in the Legislative Assembly. It has only recently been listed as a related link on the registry 019-0556. I am shocked to learn that this Bill which includes amendments to the Aggregate Resources Act was written and released within our 45 day commenting period. What is fair and balanced about an approach that has no regard for the comments and concerns of the residents of Ontario? This follows MNRF's Aggregate Summit, an invitation only event which was closed to most municipalities, agencies and the public. The subsequent online questionnaire was clearly written to support the aggregate producer/industry wish list. We live in a democracy, and the public has a voice in these matters. There is a clear lack of regard for both the public participation in this process and for the Environmental Registry of Ontario.

There are few details in the ERO proposal. The language is vague and lacking specifics.

STRENGTHEN PROTECTION FOR WATER RESOURCES
Comments:
Licences must be granted/issued based on the depth of extraction. Going from above to below water table extraction requires a new licence, not a site plan amendment. From the Bill 132 amendment re: depth of extraction, it is clear that municipalities must now review each application as a potential below water table pit from the outset, and operators must provide the detailed scientific reports to support this.

HAUL ROUTES
Comments:
The statement in Bill 142 cannot be supported. The extensive damage to our roads, including the rural system, caused by any development/industry must be considered as part of any and all proposals. Rural Ontarians must not bear the financial burden of subsidizing the aggregate industry as the cost of road repair falls on the rural taxpayers.

MUNICIPAL ROAD ALLOWANCES
Comments:
First, what is an expansion? Should an unopened road allowance be adjacent to a private property, removing that buffer (the required setback as well as the road allowance) would have negative consequences. There would be no appeal, objection or notification. Again, I am shocked by the disregard for and the lack of concern for the residents of rural Ontario.

MORE FLEXIBILITY FOR REGULATIONS
Comments:
Again, there is a lack of specifics. Define and give specific examples of "routine activity" and "low risk". How would annual compliance reports be "streamlined"? Where are the increased fees and what consideration has been given to support MNRF staff oversight of this self-reporting industry.

The Minister may rescind a licence, but this does not happen and sites remain dormant for years. In the absence of Ministerial intervention, there is no incentive to rehabilitate and/or close sites since the cost of rehabilitation can be deferred indefinitely by paying the insignificant annual licence fee. The annual licence fees must be increased. insuring that owners/operators rehabilitate and close abandoned and dormant properties. As long as licences are granted for perpetuity, aggregate extraction is not an interim land use.