Thank you for the opportunity to comment on the proposed amendments to the ARA in ERO 019-1303.
In Table 1: Proposed Site Plan Amendments Eligible for Self-filing of the Proposals to amend O. Reg. 244/97 and the Aggregate Resources of Ontario Provincial Standards under the Aggregate Resources Act, the Recycling Topic states "For private land only: Allow the importation of concrete, asphalt or other materials (e.g., brick, glass, ceramic) for recycling, provided the following criteria are met: ...~ recycled asphalt will not be stored within 30 m of a water body or within 2 metres of the established ground water table and is not co-mingled with scrap material; and ..."
The restriction on the proximity of 2 metres from the ground water table is understood to be a specific effort to protect ground water from that particular activity. However, the same Table 1 does not have this clause for other activities that have a similar capability to contaminate the ground water, such as a Portable Concrete or Asphalt Plants, Scrap Storage Areas, etc., which have the horizontal restriction, but not the vertical proximity restriction. The restriction has been applied to asphalt recycling, but is silent on any restriction for other materials such as concrete from road construction projects for recycling or blending when that material may be contaminated by de-icing products, accident spillage/leakage, etc.
Table 1 should be revised to reflect other activities, and imported materials, that can potentially contaminate the ground water, and provide restrictions on both the horizontal and vertical separation.
Overall, the proposed ARA amendments are a welcome relief to anticipated relaxation of environmental regulations.
Submitted February 20, 2020 4:48 PM