Thank you for the…

Thank you for the opportunity to provide comments on the proposed changes to Ont. Reg 244/97, of the ARA; in reference to expanding self filing activities.
Our comments are as follows:
1- We note that one of the proposals for consideration for changes that are not significant is "Extraction within 30 Metres of a road or highway when the applicant can demonstrate that the relevant road authority supports the change". We suggest that the reduction of a 15 M or 30 M setback adjacent to a neighbour, where there is written agreement between the parties, should also be included in the minor amendments section for self filing. This would allow for utilization of scarce resources.
2 - Minor changes to phasing of extraction such as allowing approved below water extraction to be carried out in conjunction with progressive extraction of above water materials, should be included in the minor amendments section for self filing. This is especially important where various materials are necessary for blending aggregate.
3 - Off setting of fencing inside a licenced area (with proper demarcation of licence boundaries) should be included in the minor amendments section for self filing, to negate problems such as snow buildup on adjacent roads, or to allow adjacent neighbours to maintain lawns, trees or shrubs.
4 - Regarding the importation of aggregate for blending or resale, licenced operators have to be in the position to be able to offer their customers with the products they require. This often requires purchasing certain aggregate products from aggregate storage depots that receive aggregate by ship or other transportation methods. We suggest that rather than setting a maximum of not more than 20'000 tonnes or 20% of the maximum annual tonnage for the site, which ever is less; that any amount may be imported as long as the total of imported aggregate and the amount of extracted aggregate from the pit or quarry; does not exceed the tonnage limitation for that licenced site.
The above additional proposed minor operational changes will have no adverse effect on the environment, and will reduce red tape and costs to the operator.