I am commenting specifically…

I am commenting specifically to proposed changes to Sections 5.2.2.2 and 2.5.2.4.
SECTION 5.2.2.2
Proposed extraction in natural features based on "long-term" rehabilitation does not address the irreparable harm and devastation caused during the undefined destruction period (aggregate extraction operations). As Provincial Policy makers must be aware, aggregate licences are granted in perpetuity based on the amount of material on site and not on any specified timeline. To my knowledge, no zoning bylaw or private land agreement overrides MNRF's ability to control the length of time a property can be licensed. In fact it is forever. Old and abandoned pits and quarries can come back on line years after extraction has ceased, as long as the licence is still valid (they paid the inconsequential annual fee and supplied the annual reports). This means that as long as one cup of gravel remains on site the licence may be valid for perpetuity. We also know that site plans can and are changed by MNRF, with some aggregate operations having numerous amendments over many, many years. Pits and quarries are sometimes never rehabilitated and remain dormant for centuries. For example Guelph Dolime and Glen Christie in Guelph Eramosa Township are quarries that started in the mid 1800's and early 1900's respectively, and after long periods of dormancy, the blasting, dewatering and transportation of product has resumed. If the proposed extraction/devastation in natural features is based on some "long-term" rehabilitation plan, the fact remains that the Minister of Natural Resources and Forests can change the site plan, including the rehabilitation plan. To summarize, there is absolutely no guarantee that rehabilitation will ever occur as this is not controlled by any planning authority, and the initially proposed "long-term" rehabilitation plan can be changed without approval of any planning authority. "Long-term" rehabilitation is not defined, so I am assuming that it refers to perpetuity. Allowing the destruction of any wetland or other provincially significant feature defies common sense. Have Provincial Planners never heard of Natural Infrastructure? These protected areas provide refuge for endangered species, flood control, filtration and storage of our water resources. I can only shake my head and ask WHAT ARE YOU PEOPLE THINKING? A development cannot be approved based on something that may or may not occur at some future date. A development cannot be approved ignoring the ongoing, day to day impacts on the features and their functions.
Section 2.5.2.4
It is my opinion that under the current regime, Municipalities and the public must review every application for zoning and licence based on the probability that the aggregate extraction will go below the water table. Municipalities have attempted to limit the depth of extraction through vertical zoning not based on some wish or hope, but to assure residents that what was proposed cannot be amended at some future date. It is time that MNRF reviewed licensing classes and categories. I recommend that a licence be granted based on depth of extraction, and that depth of extraction be the CLASS of licence. Should an operator wish to change the CLASS, then a new application must be submitted. This industry loophole must be not be condoned by Provincial Policy makers.