October 4, 2017…

    October 4, 2017

  Ala Boyd

 Manager, Natural Heritage Section

 Ministry of Natural Resources and Forestry

 Policy Division

 Natural Resources Conservation Policy Branch

 300 Water Street

 Peterborough, ON

 K9J 8M5

   PLEASE NOTE: ORIGINAL SIGNED LETTER ON COMPANY LETTER HEAD HAS BEEN EMAILED AND SENT BY PUROLATOR TO YOUR ATTENTION.

   RE: EBR REGISTRY NUMBER 013-1014 - CRITERIA, METHODS, AND MAPPING OF THE PROPOSED REGIONAL NATURAL HERITAGE SYSTEM FOR THE GROWTH PLAN FOR THE GREATER GOLDEN HORSESHOE

  Dear Ms. Boyd

  Lafarge is Canada's largest provider of diversified construction materials and a member of the global group, LafargeHolcim. With 6,000 employees and 350 sites across Canada, our mission is to provide construction solutions that build better cities and communities.

  We are pleased to provide the following comments on the proposed regional Natural Heritage System (NHS)  for the Growth Plan within the Greater Golden Horseshoe (GGH).

  Over one half of existing aggregate licenses within the Growth Plan have features of the NHS system mapped within it.  The Technical Report on Criteria, Rationale and Methods does not provide any detail on why the NHS systems are mapped on these lands.  We do not believe it is appropriate to show NHS mapping on licensed sites based on current site plan approvals.

  In defining Natural Heritage Systems, it is stated that in areas where natural features are limited, core areas and linkages may include lands without natural features, but with the potential to be restored to enhanced habitat and connectivity as well as working landscapes that enable ecological functions to continue. Current legislation ensures that aggregate extraction is a temporary land use and that rehabilitation is undertaken to return depleted lands to their initial use or a use that is compatible with the surrounding landscape.  Once rehabilitation is complete, this may be the more appropriate time to consider the inclusion of these lands into the NHS where appropriate.

  The draft NHS mapping also included over 50% of primary and secondary sand and gravel resources and over 75% of the select bedrock resources within the Growth Plan.  The guiding principles within the proposed Growth Plan are clear to “Provide flexibility to capitalize on new economic and employment opportunities as they emerge, while providing certainty for traditional industries, including resource-based sectors.”  Policies must be developed to encourage growth and development in the Province.  The PPS emphasizes that the wise use and management of mineral resources is of key provincial interest.  The PPS is very clear that aggregates, including existing mineral aggregate operations, shall be protected for long-term use and as much of the aggregate resource as is realistically possible shall be made available as close to market as possible. Once a site is licensed, it is protected from incompatible uses by the PPS.  It is not clear that the Province has taken into account the balancing and protecting all resources when mapping the NHS within the Growth Plan Area.

  It is apparent that in preparing the mapping for the proposed NHS, core and linkage features were generated by simply offsetting boundaries of visible natural features, rather than taking into account real topographic variations to better reflect proper natural linkages and boundaries on the ground. Furthermore, areas where there is an existing aggregate deposit with predominantly disturbed land or land that contains limited on-site environmental features are also covered by the proposed NHS. Our expectation is that the Province would further review this mapping, particularly on license sites, and that field verification will be accepted in further refining the NHS mapping within the Growth Plan Area.

  Ontario’s aggregate sector plays a vital role in establishing complete and well-connected communities, managing growth, protecting the natural environment and supporting local and regional economic development. Achieving the growth objectives will require the continuous availability of close-to-market aggregate resources.

  Lafarge looks forward to the opportunity to discuss these points in greater detail with the Province to ensure this resource is protected while balancing the environmental and economic goals of Ontario.

  Sincerely,

  Xavier Guesnu

 Vice President, Aggregates

 Lafarge Canada Inc.

[Original Comment ID: 211102]