Here are our comments on “A Blueprint for Change – A proposal to modernize and strengthen the Aggregate Resources Act policy framework” (EBR No. 012-5444, October 21, 2015, 36 pp.)

The government’s paper is here.

Our submission comments on 14 of the 42 proposals set out in the paper.

Comments by the Region of Waterloo (authored by an old acquaintance, Chris Gosselin) and a conference call with and draft submission by Gravel Watch Ontario helped enlighten us in dealing with this complex material.

Sometimes basic principles are enough, however.  For example, see these two extracts from our comments:

…under “a” (p9-middle) the paper states that extraction proposals in the vicinity of a municipal drinking water supply will continue to be entertained but would require enhanced water impact studies. It is difficult to imagine how negative impacts can be mitigated, particularly when they continue long after the operator has surrendered the license. When a preferred route of travel for contaminants has been established it is there forever. The better solution is to simply prohibit extraction that is within designated source water protection areas.

…item “b” (p9) proposes new study requirements for extraction on agricultural lands. It is an illusion to think that soil that has taken decades or centuries to be formed can be restored to its previous productivity after having been removed to extract the aggregate below. Again, the better — and only — way to avoid loss of agricultural land is to prohibit aggregate extraction on them. In both this case and for water supply protection, the need is not for more studies by applicants but for better policy by government.

And on a practical level:

Further to proposal “ab” (p22), we suggest that adding a concrete batch or asphalt plant to a site should be considered a significant amendment that triggers prescribed notification requirements.

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Comments by others:

+ From Gravel Watch Ontario

+ From the Ontario Rivers Alliance