I am commenting on behalf of…

I am commenting on behalf of Fowler Construction Company Ltd, located in Bracebridge Ontario. First I would like to mention that Fowler is an active member of the Ontario Stone Sand and Gravel Assocation and supports the comments made by OSSGA in regards to the ammendments to the Aggregate Resources Act (ARA) (ERO #019-0556). There are however a couple of items I would like to reinforce. Item 1 Water Resources, I would like to reinforce OSSGA's comment on appeals not having any scientific basis. Appeals and objections regarding aggregate applications are all too often the target of unsubstantiated claims, and general distrust of the professionials who have put together scientific studies and plans supporting an application. I believe the comment about appeals with no scientific basis is important and needs to be considered when discussing appeals as they apply to the technical aspects of an application. Item 4 Haul Routes. In regards to haul routes I would like to state what may already be obvious. I believe time is of the essence in dealing with the haul route issue as several aggregate applications have been held "ransom" by haul route agreements with local or upper tier government not permitting an application until a haul route agreement which includes monies paid to a local or upper tier government. Some traction has been made by municipal governments to institute haul route agreements. ARA fees are meant to cover the costs of wear and tear to haul routes and these agreements operate outside of the intent of the ARA fees. I believe this item needs to be dealt with swiftly to ensure no further agreements are put into place, and would even go as far as saying they should be retro actively examined and potentially dissolved. The final item(s) are mainly in regards to self regulation, filing, and compliance assessment. Fowler supports any means of creating efficiency in the processes involved in regulating, filing and compliance assessment as long as it is a level playing field for all operators. It is Fowler's opinion that the current MNRF aggregates program is underfunded leading to less than desirable inspection frequencies and as well as unreasonable workloads for inspectors. Therefore any reasonable changes that can make an operator and inspector's task more efficient has our support.
Sincerely,
James Gordon
Materials Manager
Fowler Construction Company LTD
Bracebridge, ON
P1L 1T9
705-645-2214