November 30, 2023 Ministry…

November 30, 2023

Ministry of Municipal Affairs and Housing
Provincial Land Use Plans Branch
13th Flr, 777 Bay St.
Toronto, ON
M7A 2J3
greenbeltconsultation@ontario.ca

ERO 019-7739, Bill 136 Submission

The Reform Gravel Mining Coalition supports the province returning the fifteen parcels removed from the Greenbelt. But making the Greenbelt whole again is not enough. There are loopholes in the Greenbelt Plan that put the permanence and sustainability of the Greenbelt at risk.

We urge the province to strengthen the Greenbelt Plan by:
● Temporarily prohibiting new gravel mining in the Greenbelt;
● Clarify section 12.2 of the Greenbelt Act to ensure that only Greenbelt expansions are allowed, prohibit land swaps;
● Restrict new 400 series highways throughout the Greenbelt, including Highway 413 and the Bradford Bypass.

The Reform Gravel Mining Coalition, along with 20 Ontario municipalities agree a moratorium on new pits and quarries is needed throughout Ontario. There is absolutely no need for new aggregate mining in the province, since the licensed capacity of existing aggregate extraction operations in Ontario is thirteen times the average total annual production, which includes product exported to other jurisdictions. While aggregate is a needed resource for roads and building, it is a finite resource that must be managed sustainably by the province.

Pits and quarries have a generational impact, Gravel mining is not an interim land use since the process of extraction and rehabilitation takes about 50 years or longer. Accordingly, each new pit and quarry should be carefully sited and only licensed according to need. It is time for Ontario to adopt a supply and demand-based rationale for considering new pits and quarries.

Within the Greenbelt Plan area, a moratorium is needed to pause new gravel mines pending the upcoming Greenbelt review scheduled to begin in 2025. The review is an opportunity to consider the full lifecycle impacts of gravel mining on the future of the Greenbelt. The province created the Greenbelt Plan to permanently protect agriculture and sensitive natural areas within the Greenbelt Plan areas from development. And yet gravel mining is allowed to occur in the Greenbelt, except in natural core and hydrologic features. Gravel mining is not a benign activity. It affects hydrology, and agriculture and farmland can never be fully rehabilitated back to their original use . It is clear aggregate mining is inconsistent with the purpose of the Greenbelt Plan.

Two new highways in the Greenbelt are also poised to destroy farmland and pave over natural areas. Highway 413 will pave over 400 acres of Greenbelt and 2000 acres of farmland. Just like new gravel mines, highway 413 is not needed. New highways impact air quality, facilitate costly sprawl and require massive amounts of aggregate. It is estimated that the Bradford Bypass and Highway 413 would consume over three million tonnes of aggregate resources, an estimated 130,000 truckloads of aggregate.

Natural occurring aggregate resources in the ground play a critical role in the function of ecosystems. Sand and gravel in the ground acts as a filter for groundwater and river systems. Over 80 rivers and streams originate from the Greenbelt’s underground water resources. As the climate warms, managing groundwater systems in Canada’s most important economic area, the Greater Golden Horseshoe, will be essential for a prosperous Ontario.

We encourage the province to say YES to a moratorium on new gravel mining in the Greenbelt. There are enough aggregate resources already licensed to meet the growth needs for Ontario. It is time for the province to say yes to protecting the Greenbelt by canceling the proposed new highways in the Greenbelt and pausing the approval of any new pits and quarries in the Greenbelt.

Yours Truly,

President, Reform Gravel Mining Coalition
Reformgravelmining.ca