GPO written submission commenting on the Aggregate Resources Act review

Standing Committee on General Government
99 Wellesley Street West, Room 1405
Whitney Block, Queen’s Park
Toronto, ON  M7A 1A2

Dear Committee Members:

I sincerely appreciate the important work this committee is doing to review the Aggregate Resources Act. I am pleased to offer the committee a more detailed and comprehensive list of recommendations for revisions to the ARA, as a follow up to my oral presentation.

There is no doubt that aggregates are essential to our community, economy and quality of life. We need them to construct homes, roads, buildings and other infrastructure.  

It is also clear that pits and quarries are increasingly competing with other land uses.  Aggregate extraction touches many issues that are close to our hearts: clean water, air quality, local food sources, traffic congestion, quality of life and natural heritage.  

It is common for aggregate proposals to be met with strong local opposition. At the heart of this conflict is a growing population with increasing demand for land, water and natural resources.  

This kind of conflict is bad for everyone. It splits communities and is expensive for business.

We need a profitable and sustainable aggregate industry.  

And we need to find innovative, long-term solutions to this conflict that protect our communities, our environment, our water, our food sources, our air quality, and our social and cultural heritage.

This is not an easy task.

As we seek solutions, I think it is essential to think long-term. We need revisions to the ARA that work today and provide the foresight for a sustainable aggregate industry for generations to follow. We need to understand that water, land and aggregates are finite resources that require good stewardship.  

I also believe we need broad thinking that connects the dots across ministries and between various pieces of legislation, even if it extends beyond the narrow terms of reference for this committee. Aggregates affect multiple ministries and pieces of legislation. In order to be responsible stewards, it is important for a review of the ARA to include aggregate regulations, the Aggregate Procedures Manual and other pieces of legislation that affect aggregates, land use planning and air and water quality.

With this in mind, my recommendations are beyond the scope of the ARA alone.

Change the current focus on prioritizing consumption and supply of aggregates to encouraging efficiency, conservation and recycling.  

Aggregates are a valuable finite resource.  It is essential that we use them more efficiently.

For every tonne of stone, sand and gravel we extract, we are using up 2.5 tonnes. This is not sustainable in the short or long term. It is essential that we reduce our per capita consumption.

To do this, Ontario needs a comprehensive Aggregate Conservation Strategy.

1.  We need to design our communities, roads, and other infrastructure so they use less aggregates.  

Given our financial and economic challenges, Ontario cannot afford to fund inefficient, expensive, sprawling growth plans. We need better policies and standards that reduce the quantity of aggregates used in roads and buildings.

2.  We need to support research, commercialization and use of alternative materials. As an example, I was recently at the Paris High School, where the eco club is using materials from recycled tires, instead of aggregate patio stones, to rebuild the school’s courtyard. We need government to provide leadership by supporting and promoting examples like this.

3.  We must do a better job of recycling aggregates.  Ontario’s aggregate recycling rate of only 7% is unacceptably low.  We should set a goal of matching the UK’s recycling rate of 24%.

The UK has a policy framework and pricing structure in place that creates market incentives to make recycling economically viable.  Ontario should do the same.

a.  The Provincial Policy Statement and the provincial standards must be revised to require aggregate recycling, and to mandate minimum standards for increased use of recycled materials in public and private development.

b.  We should require companies to have an aggregate recycling program in place in order to obtain a license to operate (recognizing that this requirement may not be appropriate for all sites).  

c.  Municipalities must remove specifications that do not allow recycled aggregates to be used in construction projects.  This could work in the same way as the province forbids municipalities from banning clotheslines, in order to improve energy conservation.  

Ontario should introduce a landfill tax to encourage the reuse and recycling of construction materials. Lessons from the UK indicate that such a tax can be effective by making recycling the lower cost option.  

As much as possible, the province should introduce incentives to encourage on-site recycling.  On-site recycling will also be a step in the right direction to address concerns about construction fill in places like the Oak Ridges Moraine.

e.  We also need to increase the aggregate levy, as others have suggested, to not only provide more financial capacity to manage, regulate and rehabilitate pits and quarries, but to also provide a financial incentive to encourage recycling.

It is not a coincidence that the UK has such a high recycling rate compared to Ontario when you compare our 11.5 cent per tonne levy to the UK’s levy, which exceeds £2.00 per tonne — equivalent to around $3.20 Can.

You’ve had much discussion about what the levy should be.  I would argue that it needs to be somewhere between the 50 cents per tonne Quebec charges and the $3.20 the UK charges.

f.  Consider establishing a program similar to the UK’s WRAP (Waste & Resources Action Programme) Aggregates Programme.  This program provides capital grants for investments in recycling facilities and equipment, research to address barriers to recycling, and information on best practices.  This program is funded from revenue generated from the aggregates levy.

Ontario must increase regulatory and monitoring capacity and improve the process for approvals.

 In today’s fiscal climate, an increase in the levy is essential to providing the capacity needed for planning, managing, monitoring and regulating aggregates.

1. I agree with the industry’s request that an increase in the aggregate levy not go into general revenue.  However, the levy should cover a broad range of costs associated with managing and planning for aggregates.

a.  Municipalities need revenue not only for the extra infrastructure costs associated with hosting pits and quarries, but also for costs that include planning, review and hearings for aggregates.

b.  MNR needs more capacity to properly regulate and monitor the industry, and to provide long-term planning and stewardship of the resource.

 We should have a fund for intervener status to support citizen’s groups to participate in the application and OMB process.

d. We must ensure that adequate resources are in place to responsibly fund rehabilitation.

 We should provide funding to support research, recycling, best practices, and commercialization and use of alternative materials.  

2.  I agree with industry’s call for a more efficient approval process that provides clarity, certainty and solutions for all parties. I believe the first step is a proactive planning process that engages multiple stakeholders.  

a. Develop a master aggregate plan, with input and participation from diverse stakeholders, that identifies areas for extraction, possible extraction and no extraction.

b. Past planning practices in Caledon provide a possible example of how best to proceed. In the late 1990’s, Caledon created a planning group with multiple stakeholders that mapped available aggregate resources in the area and then agreed on places where aggregates would be approved now, maybe in the future and not at all.

This is a way to make the process more efficient for proponents while also protecting community and environmental interests and enabling long-term community planning.

c.  In order to plan proactively, Ontario should conduct a thorough study of all existing aggregate reserves in the province.

d. We need an early screening process to identify inappropriate locations and proposals that should not proceed.

3. We need more citizen and community participation early in the application process, and I believe the following changes would help:

a. Require early public notification of an intent to submit a license application.

b. Increase the public notification period from 45 to at least 120 days. Consider a tiered application process with longer comment periods for larger and more complex proposals.

c. Extend the notification area beyond 120 metres.

d. Require municipal approval of significant amendments to the license and site plans after zoning approval.

e. Adopt best practices for community engagement and participation from other jurisdictions and industries.

Revise policy and planning priorities, and provide better long-range planning and coordination with other legislation.

Some of the policy changes include:

1.  Apply sunset clause to licenses. I recently visited Paris, Ontario where a company is moving forward with a 38 year old license. That license was granted at a very different time, and the social, environmental and economic circumstances have changed.

2.  If we are going to consider pits and quarries to be “interim use” of the land, then we must apply time limits on extraction.

3.  It is essential that we consider the need for a particular aggregate application before we are asked to sacrifice a rare element of our natural or culture heritage or approve developments that compromise water quality or farmland. Unfortunately, the legislation currently prohibits this common sense approach.

4. When considering new licenses, it makes sense to consider the cumulative impacts of pits and quarries in the area.

5.  At a minimum the ARA should require a full Environmental Assessment for aggregate applications that meet the Ministry of Natural Resource’s definition of a mega quarry (currently 150,000,000 tonnes) and/or propose to dig below the water table.  

6. Ontario should strengthen legislation for source water regions. We should prohibit aggregate mining in source water protection areas.  

7.  Now is the time to reconsider the close-to-market policy. Good stewardship requires us to balance shipping costs with extracting aggregate where it is most appropriate and least harmful. Preserving our farmland and protecting clean water must be a higher priority than close-to-market quarries.

We know that we are going to run out of aggregate close to the GTA anyway, so now is the time to plan and invest in the rail and shipping infrastructure to efficiently move aggregate from further away.

8.  Related to this, we also need to understand how the Places to Grow Act, which places 80% of Ontario’s growth in the GTA, is driving demand for aggregates in sensitive natural areas such as the Niagara Escarpment and Oak Ridges Moraine and with competing land uses for farming, water and natural heritage. Ontario should revise our growth plans to encourage balanced development in communities across the province.

The aggregate industry is not increasing demand for aggregates: Ontario’s growth plans are driving demand for new aggregates in sensitive close-to-market locations.

9. The ARA must conform with other legislation such as the Oak Ridges Moraine Conservation Act, the Niagara Escarpment Planning and Development Act, the Greenbelt Act, among others.

10. Our Provincial Policy Statement (PPS) must place a greater emphasis on preserving precious farmland. While we have a close-to-market policy that prioritizes aggregate extraction in the Greater Golden Horseshoe, we don’t have a food security policy that prioritizes the preservation of farmland and farmers.  

This must change. Ontario needs to change the PPS to protect class 1, 2, 3 and 4 farmland from development.  

11.  The provincial government should put in place purchasing policies that support sustainable aggregate mining and green gravel certification. The aggregate industry and NGOs that are developing sustainable aggregate standards. They deserve credit for this effort, and I believe government should support their efforts with purchasing policies.


Your work is profoundly important. The conflict over aggregates is essentially a competition over the necessities of life: water, food, land and shelter.

Ontario has a provincial interest in aggregates; there is no doubt about it.  But we also have a provincial interest in providing the people of Ontario with local food and clean water.  

The location of aggregate resources is fixed.  But the location of farmland and clean water is also fixed.  

If this review accomplishes nothing else, it is essential that we rebalance the conflicting needs over land for water, food and shelter — in that order.

I believe this effort transcends partisan politics.  And I look forward to working with members of all political parties to ensure that present and future generations have access to clean water, local food and aggregate resources.

Updating the outdated ARA is essential.  I believe it is important to complete this committee’s work and have legislative changes made within 18 months.

It is time to ensure that access to clean water and the preservation of farmland are given a higher priority than aggregates in provincial policy.

Thank you for your time and consideration.


Mike Schreiner