Dear Sirs: The Ontario…

Dear Sirs:

The Ontario Rivers Alliance (ORA) is a Not-for-Profit grassroots organization with a mission to protect, conserve and restore riverine ecosystems all across Ontario.

The ORA is grateful for this opportunity to comment on the proposed amendments to Ontario’s Aggregate Resources Act (ARA).

For several decades, the ARA has been used to licence and regulate the establishment, expansion, operation and rehabilitation of pits and quarries in Ontario. The 2017 ECO Report made reasonable recommendations for improvements designed to decrease the need for new extraction sites, to review and amend the operations of existing sites when deemed advisable, and decrease the environmental impact at end-of-use sites.

Unfortunately, Ontario’s proposed ARA revisions do not reflect any of the Environmental Commissioner of Ontario’s recommendations, but instead we have outlined a number of proposed changes that are concerning, i.e.:
1. A revised application process for aggregate operations that propose to excavate below the water table;
2. Removing the application of municipal zoning by-laws relating to the depth of aggregate extraction;
3. Municipal zoning on Crown land would not apply to aggregate extraction;
4. Restricting the ability to impose ARA conditions that require agreements between municipalities and aggregate producers regarding haulage routes;
5. Streamlining compliance reporting by aggregate operators;
6. Allowing aggregate operators to “self-file” changes to site plans for unspecified “routine activities”; and
7. Enabling unspecified “low risk” activities to occur without an ARA licence if regulatory conditions are followed.

In order to strengthen the ARA and its protections ORA strongly recommends rejecting the above and instead:

1. Adopt procurement policies across all ministries, agencies and Crown corporations that prioritize the use of recycled aggregate;
2. Review existing licensed aggregate sites with an aim to mitigate any operating conditions to ensure the environment is protected; and
3. Include clear timelines for progressive and final rehabilitation within the ARA policy framework

These ARA amendments are likely to intensify rather than reduce divisive land use conflicts involving new or expanded aggregate operations.

Municipalities and other stakeholders must have a say in where and how pits are developed in their communities.

Respectfully,

Chair
Ontario Rivers Alliance