I understand the desire to…

I understand the desire to streamline approval processes to allow work to commence without delay but if the risks strongly outweigh the benefits, it would be reckless and short-sighted of our province. Any policy that prioritizes development over our environment and the long-term health of our people is not development that is beneficial to the future of Ontario.

The aggregate industry should not be permitted to have requirements for licencing relaxed, as is suggested in these proposed changes. Even with the current regulations, because experts are hired by the applicants, the results of studies and information presented to the MNR are not completely unbiased. Many of these experts rely almost entirely on the aggregate industry for their livelihood so have an incentive to provide results that are not unfavourable to the objectives of those who hire them.

A prime example is an application on the Highland Line in Lanark Highlands by Thomas Cavanagh Construction that is currently going through the application process. Even with the current system, the applicant clear cut and grubbed the land (contrary to Lanark County tree cutting bylaw) immediately before the studies. The site plan does not mention the waterfront community and severely downplays the presence of Barbers Lake, even though the plans call for an outlet from the pit lake to Barbers Lake. The Natural Environment Study did not even include a study of Barbers Lake. Without public consultation and thorough review of applications by the MNRF and the various ministries, there will be very little in place to keep the applicants accountable. Residents of Ontario should have the right to comment on development that will forever change their environment and communities. A ‘qualified person’ hired by the applicant can’t help but be biased.

There are currently staffing shortages for inspectors in a variety of fields, including MNRF inspectors for already licenced pits. Fast tracking the opening of new pits that have had a less stringent application process will require far more inspectors and procedures in place to correct issues. It is much more expensive, ineffective and time consuming to fix a problem after it occurs than to prevent it in the first place. Drinking water contamination and destruction of habitat are prime examples and require careful consideration and protection by third party

A natural and sensitive ecosystem, as represented in the current Cavanagh application, are too complex and important to expect to fit into a standard set of criteria for the applicant to meet. A checklist that works for flat dry land in an industrial or agricultural area would not adequately address all that would be affected. It cannot be left up to the applicant, whose goals are justifiably to operate a business that is as profitable as possible, to protect the environment. How can we teach our children to be good stewards of the environment when the province sends such mixed messages. Why protect the environment by not using a plastic straw while development is permitted to remove wetlands and put groundwater and environmentally sensitive and important areas at risk?

The current application process has allowed Cavanagh to present a proposal that may technically be in line with Ontario regulations but does not respect the sensitive features of the site. The 24/7, million tonne/year, below water table extraction, with two concurrent operations is adjacent to a large sugar bush and tourist destination, wetlands, a cold water creek and a natural spring fed lake. The minimal 30 metre setback to the wetland shores of Barbers Lake with a surface outlet connecting the pit lake to the natural lake does not protect the lake or Long Sault Creek from contamination, increased temperatures or being choked out by silt and fine particles. The effects of temperature changes on spawning of native brook trout in cold water Long Sault Creek was not even addressed. The proposal includes the removal of existing wetlands within the excavation area and no plans to mitigate the predicted drying up of a wetland in the east corner of the site. The natural environment study did not find any Blanding’s turtles on site but there were two documented sightings (by community members) of Blanding’s turtles leaving and entering the site this past summer. The current regulations do not adequately protect these turtles so fast-tracking approvals will not help the situation.

The process that is currently in place appears to be inadequate to protect sensitive features of a site. How can streamlining the process, removing the ability of the public to comment and leaving it up to the applicant to apply online and ‘follow the rules’ be better? If the applicant knows they can start work immediately, they can simply do what is most profitable first and ensure that no traces remain of anything that could put a stop to work if inspectors were to show up.

The Cavanagh application made no mention of the known high levels of uranium in the Barbers Lake pluton which is the granite body that lies beneath the site. No study was done regarding the potential mobilization of uranium into the surrounding groundwater and waterways by extracting below the water table on this site. This is because it is not a requirement of the application process by the province since not all sites have this potential issue. This issue would not be raised without public consultation. Why would an applicant bring forth any potential issues they are not specifically required to address?

Consultation is vital as no checklist can contain every possible scenario that may arise. Public consultation is more important than ever since the province has stripped the conservation authorities of any meaningful input they can provide. It is vital that the public and indigenous communities be notified of any aggregate applications and be given the opportunity to comment, and the conservation authorities should be restored to their original role and authority.

Permissions should not be streamlined or limits removed for water taking and dewatering. Each site is different and as such will be affected differently by water taking or dewatering. Each site should be evaluated thoroughly and individually with input by the local conservation authorities. It seems unreasonable to remove the upper limits on water taking. As population and development continues to move forward at unprecedented rates, forever altering and removing natural environments, what would happen if our water is jeopardized in quantity or quality? Water is more important to our survival than roads or houses and should be treated with the respect and protection it deserves. Making it easier to obtain a water taking permit and allowing the taking of potentially unlimited quantities of water does not do this. Local water supply wells, aquifers and waterbodies must be protected. Cutting red tape to facilitate issuing of water taking permits will put these at risk. No upper limit and possible cumulative effects make this even more threatening.

Aggregate operations should not be eligible for EASR permitting and should be subject to more stringent criteria for licencing and water taking, not less. There is already much more aggregate available in licenced pits in the province than the current demand requires so it is not necessary or prudent to throw caution to the wind and fast track the process. It would be both reckless and short-sighted of the province to go forward with the proposed changes.