Bruce County’s comments in…

Bruce County’s comments in review of the proposal, organized across these four areas, are outlined below and approved by Bruce County's Planning and Development Committee (i.e. Bruce County Council). The County’s previous comments related to the Aggregate Resources Act amendments continue to be relevant.

1. How will these proposed changes affect you or your business (e.g. implementation costs and timelines, community impacts and concerns)?

Comment:

Aside from the following specific comments, the proposed changes are reasonable.

A change to note that “Agencies would not be asked to review aspects of applications that are beyond their mandate” may impact the coordination and timing of local government review. In consideration of Planning Act amendments, a fulsome policy review of proposals is undertaken, which outlines consideration of many different aspects, from various domains, to arrive at a balanced recommendation on the merits of the proposal. Through these reviews, identified deficiencies with information and inconsistencies between supporting documents and site plans have been uncovered. These may fall within the technical domain of other agencies but impact the ability of the proposal to demonstrate consistency with policy and effectiveness of mitigation. It is important that applications be reviewed as a whole, and not as the sum of their parts.

2. How effective will these changes be at reducing regulatory burdens while maintaining appropriate levels of environmental protection?

Comment:

Enabling self-filing of routine amendments may free up time for regulatory staff, which should be devoted to audits, monitoring, and enforcement.

We encourage the Ministry to consider how proposed limits on self-filing will be implemented: for example, how to ensure that a condition that was established to resolve objections or concerns it is not removed by a self-filed amendment a few years after the license is granted.

Efforts to streamline site plans by removing reference to required approvals under other legislation and including this in original licensing correspondence may be counterproductive, as the Aggregate Resources Act site plan presents an opportunity for a “dashboard” of all of the operating requirements for a site to be located and referenced on an ongoing basis.

Proposed standardized and fillable reporting forms can offer efficiencies in terms of standard conditions. Quarries are increasingly complex in terms of operational requirements and may have several non-standard mitigation conditions and/or requirements to maintain conformity with the PPS and other policy. Compliance monitoring forms should provide opportunity for operators to review and confirm compliance or issues with these site-specific operational requirements.

Changes to operating requirements for existing licensed extraction offer an opportunity to improve the consistency of the operating environment and could address conflicts from some existing operations.

3. Can you offer suggestions for improvements to these proposals?

Comment:

Recent quarry proposals in Bruce County have struggled to adequately address community concerns regarding impacts to groundwater. It may be appropriate for hydrogeological reporting standards to outline an approach to addressing potential for groundwater impacts in karst environments, such as the majority of Northern Bruce County, as groundwater in these environments can quickly move through conduits to areas that are well beyond conventional study areas.

In quarry clusters, hydrogeological reports for new extraction or changes to extraction depths should be required to incorporate data from surrounding extraction operations and account for data discrepancies.

Water reports and operational standards should outline circumstances where ongoing monitoring of nearby water supplies are required, and actions required by operators if impacts to nearby water supplies are identified.

The proposal to apply a ‘Maximum disturbed area’ in the ‘Protected Countryside’ of the Greenbelt Plan appears logical. It may also be appropriate to apply this concept outside the Greenbelt Plan where extraction is permitted within core areas in a Natural Heritage System.
 
4. Do you have ideas for additional changes or improvements?

Comment:

Consider permitting self-filing for limited accessory uses (ex. landscaping supply, heavy equipment repair), where permitted by zoning by-laws. This could reduce barriers to establishing complementary uses in quarry clusters.

Submission of 3D modeling of final rehabilitation plans for new applications or changes to existing licenses that impact depth or area of extraction or rehabilitation could support comprehensive rehabilitation planning as encouraged by Provincial Policy Statement (i.e. 2.5.3.2 “Comprehensive rehabilitation planning is encouraged where there is a concentration of mineral aggregate operations”).

We encourage the Ministry to ensure adequate resources for monitoring and enforcement, amid streamlining efforts which provide more opportunity for and onus on applicants for self-reporting compliance, self-filing amendments, and self-awareness of applicable legislation.