November 04, 2019 Proposed…

November 04, 2019

Proposed Amendments to the Aggregate Resources Act
ERO number: 019-0556
Posted by: Ministry of Natural Resources and Forestry
Notice stage: Proposal
Proposal posted: September 20, 2019
Comment Period: September 20, 2019– November 04, 2019 (45 days)

Thank you for this opportunity to provide comments to the Proposed Amendments to the Aggregate Resources Act
My comments start with concerns on the MNRF news release of September 20, 2019. I find the announcement proposing ARA changes following the outcome of the March 2019 Aggregate Summit with leaving out the public. A survey after the secret Summit did not make up for shut-out. Now that the industry has secured its wish list the public must carry the burden of living ever closer to aggregate operations.

Increased Protection of Water Resources: I am in favor of more protection for water. Making amendment requests should be more transparent. Notice should be more visible and extend to a further perimeter of the pit site. Few details are provided as to how there will be more protections. Who appeals the amendment request? The License holder or the municipality or the public? Water aquifer studies and peer reviews are very expensive and the tax payers are not protected from the costs defending below water table extractions.
Removal of Municipal Authority to Regulate Depth of Extraction: The residents surrounding the pit deserve protection from below water table extraction. The municipality is the protector of the surrounding residents. No details are provided as to who and what responsible agent will be overseeing below water table extraction licenses. Rehabilitation
Haul Routes: These details should be worked out at the time of the application process. Being that “close to market” is so important to the Province and how this effects approval decisions these issues should be resolved satisfactorily with the municipality. The changes proposed do not provide much detail as to how this will be done. Traffic routes and safety should be weighted ahead of the mineral resource location.
Clarification: I find the difficulties in determining many parts of the proposal frustrating because of lack of detail. I therefore have a list for further questioning:
1. Improve Access to aggregates
2. Low risk activities
3. Rehabilitation
4. Uncertainty about the number of opportunities to comment.

I thank you again for this opportunity to comment and look forward to any questions or concerns.