Dear Andrew MacDonald, Staff…

Dear Andrew MacDonald,

Staff at the Township of Perry are pleased to review ERO # 019-0556 (the proposed changes to the Aggregate Resources Act) and provide you with several comments for consideration. We note this Proposal only allowed commenting for 45 days, and due to the short time period, it did not provide us enough time to prepare a proper staff report for our Council’s consideration and comment. Regardless, the following is provided to the Province for consideration.

1) The Proposal does not provide specific changes to the Act, nor does it provide appropriate definitions to fully comprehend any new terms or changes to the Act. If there is a commitment to provide these additional details at a later date, it is unclear when this will occur and if the public, including municipalities will have another opportunity to provide comments.

2) The Township of Perry is extremely concerned about the protection of our water resources. Staff are please to see some direction to strengthen the Act to protect this valuable resource. However, it is unclear what applications would be affected (e.g. above or below the water table); how municipalities and the public will be provided with enhanced public engagement when water resources may be impacted; and what additional technical reports/studies are required for applications, or amendments to existing Licences when impacts to a water resource are possible.

3) On a similar note, a municipality should have the ability to make decisions on the depth of extraction through their Zoning By-laws, including amendments to existing Licences. This provides additional protection for a known water table elevation. This should only apply on private property (not Crown lands).

4) Self reporting is not a solution to ensure compliance for approved licences. If it is the goal (theme) of the Province to protect agricultural lands and water resources, additional resources should be provided to ensure proper compliance, monitoring and enforcement.

5) Haul routes should be defined. Small rural municipalities do not have the resources to maintain local road networks used to support heavy truck traffic. Knowing the route will allow proper future capital planning. In addition, known haul routes will also ensure public safety throughout the municipality.

6) Finally, we agree with the proposed direction to streamline and reduce duplication during the Zoning/Licence process, especially when minor amendments are requested. We also agree with the direction to provide clarification to aggregates contained in adjacent road allowances.

We look forward to reviewing the details of the proposed amendments at a later date. Thank you again for the opportunity to provide our comments.
Kind regards.

Beth Morton
Clerk/Administrator
Township of Perry
1695 Emsdale Road, Emsdale, ON P0A 1J0
705-636-5941