PREFACE : The whole emphasis…

PREFACE :
The whole emphasis & focus of these proposed changes are geared to ‘ REDUCE BURDENS FOR BUSINESS’, and plays lip service to protecting the Environment, with total disregard & disrespect of Municipal involvement. It completely ignores the 2017 Environmental Commissioner report ( 2017 ECO report – pages 168-183 re: ARA specifically ) which identified serious shortcomings in the current ARA and offered appropriate recommendations. These proposed changes will aggravate not eliminate or reduce diverse land use conflicts on new or expanded aggregate operations.

COMMENTS:
The application process for new and/or existing pits & quarries should ensure that Municipalities are engaged in the application process & greater coordinating role with the Province. Local municipalities need to be notified earlier in the application process of proposed or pending pit & quarry on Crown & Private land for awareness.
Haul Route agreements with Municipality & Aggregate producer must be mandatory.
Self-filing by Aggregate producer implies putting trust & faith that the Industry will self regulate – this practice MUST NOT be allowed.
Municipal zoning bylaws on both Private & Crown Lands must apply to Depth of Extraction
Safe guarding the water aquifer is of paramount importance as such excavating below the water table must not be allowed on Private & Crown land.
Low risk activities need to be clearly identified on the Site Plans and must be monitored, inspected & enforced for compliance by MNR&F.
Rehabilitation & Recycling Aggregate - please see recommendations in Environmental Commissioner report ( 2017 ECO report – pages 168-183 re: ARA specifically )
http://docs.assets.eco.on.ca/reports/environmental-protection/2017/Good…

FUNDING:
Local Municipalities shoulder the burden of road maintenance. Royalties to local municipalities need to be increased significantly from operators on both Crown & Private lands for aggregate operator’s trucks travelling on Municipal highways. What is required is a full review of the fees and royalties to ensure the added costs to municipalities are fully covered and the importance of the fees and royalties are paid to municipalities. Royalties currently received by municipalities are insufficient to fund the improvement to municipal roads, bridges and infrastructure.

CUMULATIVE IMPACT ANALYSIS:
The Province should implement policies that require Cumulative Impacts of multiple operations in a given geographic area to be analyzed, reviewed and considered as part of an approval process.

SUMMARY:
These proposed changes are totally unacceptable. The Province has not provided any compelling evidence based rationale or justification. It is proposed that that the Province review the 2017 Environmental Commissioner report (2017 ECO report – pages 168-183 re: ARA specifically ) to better serve Ontario, protect the Environment for the Future. It is imperative that Municipal involvement via Local Planning Appeal Tribunal, Official Plans & Zoning bylaws prevail & continue.