1. Documentation describes…

1. Documentation describes that a proposed change to the regulation is to provide a requirement to identify whether or not the aggregate operations will change the vulnerability of the water aquifer. What is required by the applicant if it is identified that the proposed aggregate operations will increase the vulnerability aquifer?

2. Most, if not all of the focus of reports supporting aggregate licensing focus on existing conditions and the affects of the aggregate removal. There needs to be more focus on the rehabilitation plans. It seems that details are light on the rehabilitation because rehabilitation is so far off on the horizon of time that it is not important now and that there is no crystal ball to see into the future. Approvals for all aggregate operations should contain a detailed and robust rehabilitation plan that meets the requirements of the day the control documents (e.g. license) are issued. Also, there needs to be flexibility in the control documents that ensures activities at any point in time are carried out in accordance with the regulations and best practices of the day. Applying terms of licenses over 40 years ago when the standards of the day are much more rigorous is not appropriate.

3. It seems many aggregate mines are operated with the approach that the rehabilitation plan for the entire site will be put in place when the entire site closes. Operational plans need to consider the impact of the aggregate operations at all stages of mining to the environment. Also, there needs to be rigorous enforcement at all stages of the mining operation to ensure there are no windows of time in the operation that puts the environment at risk. Enforcement also needs to keep the rehabilitation caught up to cover mined out areas.