April 11, 2019


Ontario’s Aggregate Reform Online Survey



Q: What is the greatest challenge facing aggregate resource management in Ontario today and in the future?

A:  Establishing fair regulations and environmental policies in spite of the conflict of interest that inherently exists because government is the primary buyer of aggregate with entrenched industry relationships.


Q: What are the best opportunities for managing aggregates resources in Ontario in the next three to five years?

A: Aggregate is a non-renewable resource and we have a responsibility to ensure that we use it to its fullest capacity.  That means encouraging conservation of aggregate and making conservation a priority over approval of new extraction sites.  Conservation can occur through aggregate recycling (such as re-screening road sand) and use of alternative materials.  All three levels of government need to be encouraged to use recycled product.  Reserve virgin aggregate, a non-renewable resource, for use within Canada.  Prohibit aggregate extraction below the water table without a full Environmental Assessment and full understanding of the impact on all areas, near and far.  Prohibit aggregate extraction below the water table in drinking water source areas.  Develop a process and guidelines for identifying and designating new Specialty Crop Areas to safeguard unique agricultural land resources.  Prohibit aggregate extraction in Specialty Crop Areas.  Ontarians demand that food security and clean water availability be top priority. #FoodAndWaterFirst


Q: What are the main barriers to achieve those opportunities? Please provide any examples you may have.

A: (i) The industry will balk at conserving aggregate. But they will jump at the chance to develop the recycling market to clean-up the piles of old asphalt and concrete with which they are burdened.  (ii) Government regulation allows for too many loopholes allowing aggregate development to supersede other priorities which creates a complex approval process.  So create a “Aggregate Master Plan” for industry and public clarity.  (iii) Ontarians have modern capabilities and values.  The foundation for the Aggregate Resources Act, 1990 (ARA) stems from the Pits and Quarries Control Act in 1971.  Almost five decades ago today’s aggregate proposals would not have been possible.  The trucking, technology and infrastructure were not available.  Our capabilities have changed, and the law should be adapted accordingly.  Our values have changed so our laws and policies should reflect that too.

Today important values are:

- Environmentally Protected Spaces – including but not limited to the Oak Ridges Moraine, the Greenbelt, the Niagara Escarpment, the Alliston Aquifer.

- Food Security – partly achieved by the protection of prime farmland (classes 1-4)

- Fresh Clean Water for All – as a human right.  It should be noted that the ARA as it stands is a back-door to owning Canadian water rights.

- Protection/Recovery Plans for Endangered Species

- Resource Conservation and Waste Elimination – through reduction, reuse and recycling.


Q: How can the provincial government support Ontario’s aggregate resource development in the future?

A: Conduct a thorough study of all existing aggregate reserves in Ontario.  We cannot know what we need until we know what we have. Disallow new aggregate mining licenses within environmentally protected spaces until the “Aggregate Master Plan” has been fully approved and accepted by the people and the province.  Align the “Aggregate Master Plan” with existing environmental protection legislation including but not limited to the Greenbelt, the Niagara Escarpment Plan and the Oak Ridges Moraine.



Q: How can Ontario manage aggregate resources more competitively?


Define and analyze the similarities and differences of aggregate production in northern versus southern Ontario.  Create a "Aggregate Master Plan" for industry and public clarity, putting all companies on equal footing. 



Q: Do you have any additional comments or suggestions that would support the reform of Ontario’s aggregate policies?


A: Rehabilitation plans are futuristic fantasy with no weight.  Gordon Miller, Environmental Commissioner of Ontario, stated on May 7, 2012 that “because of the competitive pressure for land, pits now are often rehabilitated to residential or commercial developments.” 


Mr. Rick Bonnette, Mayor of Halton Hills and Vice-Chair of the Greater Toronto countryside Mayors Alliance, noted that “some landowners are very creative when it comes to quarry rehabilitation. Example: In Scugog, one of our communities, new owners of former quarries are claiming depleted sites are aerodromes, thereby using federal aviation legislation to bypass municipal oversight. When concerns are raised over the nature of the fill being dumped in the abandoned pit, municipal staff is told that local bylaws don’t apply since federal aviation regulations superseded them.”


Or sometimes pits never seem to get rehabilitated – like the Lafarge pit in New Lowell.  Since there is no forced closing of a pit, a few truck loads of aggregate can be withdrawn on an annual basis so that the expense of rehabilitation does not have to be undertaken. 


Further, Mr. Miller notes: 


“There were changes in the fees some years ago, in 1997, to provide more fees, more money, for a number of things, including rehabilitation, but it remains a challenge to rehabilitate these aggregate sites. It remains a challenge to get the inspectors out there to site them or to give them rehabilitation orders, because there aren’t enough.


One special account of rehabilitation: When the fees were set aside back in 1997, they took a half cent per tonne and they gave it to an organization referred to as TOARC. Their job is to take that half cent per tonne and rehabilitate historic sites that were not rehabilitated back in the day. Now, these are sites which are often orphaned, if you like. They’re on people’s land, but the people who own it didn’t cause the problem. They were never closed, back in the day when we didn’t require them to be properly rehabilitated.


This is a good program. I cast no aspersions on it, other than: A half cent is not doing the trick. A half cent gets you about 45 sites a year. There are thousands of these sites. Increasing that to two cents would give you four times as many sites or more. It’s not a lot of money relative to the price of aggregate, but it’s certainly an area that could do with a lot of improvement. We could get a lot more of these scars on the landscape cleaned up.”


In 2017, the half cent was increased to $.009, less than one penny per tonne, which is definitely not enough.


Finally, according to the Canadian Environmental Law Association (CELA) “Depending upon whether you accept that there are only 2,700 sites that require rehabilitation, which is the position of the Ministry of Natural Resources, or 6,900 sites, which is the position of the Environmental Commissioner of Ontario, based on MNR’s own numbers, as the number of sites needing rehabilitation, the time it will take to achieve their rehabilitation ranges from about 90 years to 335 years, based on the current annual rate of rehabilitation.”


Q: Do you have any suggestions to help Ontario manage aggregates with regards to land use planning?

A: Fundamental questions must be answered:

-       Why is “need” for aggregate assumed in law? 

-       Why does the approval process for aggregate licences avoid a “need” analysis? (Do we need the product or is there already ample supply?)

-       Why is Lafarge Manitoulin quarry shipping “a significant percentage” of product to the USA if Canada is in such dire need?

-       Why does the State of the Aggregate Resource of Ontario Study (SAROS) (Feb-2010) neglect to take Ontario’s largest quarry, Manitoulin, into account?

-       Why does the aggregate industry alone have a legal requirement for “close to market” product?  Why isn’t agriculture afforded the same economic monopoly? As Wayne Roberts of NOW Magazine writes: ““Close to market,” a stand-alone piece of stupidity that would be laughed out of court if applied to uranium, computers, steel or coal, let alone food.” 

-       Why are aggregate operations being allowed on protected green-space?

-       Why are aggregate operations taking priority over prime farmland and food security?

-       Why are aggregate operations allowed to go below the water table in source water areas?

-       Who is looking at the “big picture” of consolidated and cumulative impacts?

Over the years the aggregate industry has lobbied to put very favourable regulations into effect.  Now, with increasing population and less available land mass, the industry is striving to secure it's future by buying land today for tomorrow – land that should be off-limits.  Thus, they are lobbying for less restrictive regulation.  However, this does not work in the favour of Ontarians who need to live, breath, eat, or simply survive next door to these operations.  An unbiased, big, long-term and balanced view is necessary.



Thank you for sharing your experience and insights. Your feedback will help us cut red tape to create jobs and a sustainable aggregates industry.



Disclaimer:  The above information has been provided through private amateur research for the purpose of representing the advocates of the Food & Water First movement in responding to the Government of Ontario’s aggregate reform online survey initiative.  While the information is believed to be reliable, accuracy cannot be guaranteed.













Submission from North Dufferin Agricultural and Community Taskforce (NDACT):




Submission from The Ontario Headwaters Institute: