To Whom it May Concern,
In reviewing the recently approved Provincial Policy Statement, 2014 (PPS), I was troubled to note some key changes that appear to be contrary to the best interests of Ontario’s citizens, species at risk and our environment.
The PPS is a powerful document that guides land use in the province, with a stated goal to “enhance the quality of life for all Ontarians”. Unfortunately, there is an imbalance within the document caused by several clauses that place the importance of development and resource extraction above the protection of prime farmland, water, natural heritage sites and public health and safety.
I would be happy to provide a comprehensive list of concerns, but for now I will highlight two of particular importance.
Very concerning is clause 184.108.40.206 “Mineral aggregate resource conservation shall be undertaken, including through the use of accessory aggregate recycling facilities within operations, wherever feasible.” While the finite nature of Ontario’s aggregate resources and the adverse impacts caused by industrial resource extraction require us to be forward-thinking in our re-use of materials; siting recycling facilities in licensed aggregate properties without proper health, safety and environmental regulations and protections is not an appropriate solution.
Aggregate operations are granted licenses by the Ministry of Natural Resources, according to the Aggregate Resources Act. Extraction is recognized as an interim land use, and site plans require specific rehabilitation to restore some measure of value to the spent land. Clause 220.127.116.11 would render this temporary land use a permanent one, as companies would open industrial recycling facilities and operate them for an unlimited timespan, effectively nullifying site rehabilitation requirements.
“Aggregate recycling” is a misuse of ARA terminology meant to denote only sand, stone and gravel in the province. The intention under the PPS 2014 appears to more accurately be inclusive of the recycling of construction and demolition waste. Due to the varied nature of Ontario’s geology, many pits and quarries are located in close proximity to settlement areas and sensitive ecological locations. This would mean any adverse impacts from the crushing and processing of construction materials, including the release of particulate containing silica, asbestos, lime dust and other components dangerous to human and animal health, could have damaging consequences. Additionally, the siting of these industrial processing facilities in sensitive areas such as fractured bedrock aquifers could mean construction debris and asphalt would be inappropriately stored, presenting a danger to source water quality and community drinking water resources.
Allowing these facilities in licensed aggregate properties, where they are not covered under the Aggregate Resources Act and would be shielded from proper oversight by the Ministry of the Environment, is a risky and dangerous plan that is neither sustainable or in keeping with the creation of resilient communities. As a province, we can and we must create policies that are more protective of the health of our children and all citizens.
While the PPS 2014 purports to promote the “vitality of settlement areas”; the adverse economic impacts on municipalities with a high concentration of industrial resource extraction operations are many. These include increased infrastructure costs, reduced property values and in many cases, increased health care costs. With no sunset clause for rehabilitation under the ARA, and a PPS that now has the potential to render site plans as null, communities within these regions will continue to bear undue economic and social costs.
I’m a strong supporter of recycling of aggregates. And I’ve called for policies, including landfill levies, to divert construction waste from landfills. As much as possible the recycling of aggregates and construction materials should happen on demolition sites. When this is not possible, recycling of such materials should take places in licensed and regulated facilities. Simply allowing this activity to take place in pits and quarries without responsible regulations or protections is irresponsible.
Last year, Ontario’s Endangered Species Act was diluted to the point of it being rendered ineffective and un-protective of our province’s wildlife and plant species. Disappointingly, changes to the PPS 2014 also removed important consideration for the protection of Ontario’s most vulnerable, threatened and endangered species. Clause 2.1.4 no longer includes the prohibition of development in “significant habitat of endangered species and threatened species”. These changes are shortsighted and the negative ramifications will be long-term, as industry is allowed to take precedence over species at risk and their sensitive habitats.
Additionally, I’m concerned that the public consultation undertaken by the Ministry of Municipal Affairs and Housing regarding the PPS 2014 was not inclusive of the above changes. By only including these key clause changes in the final pre-approved version, interested Ontario citizens were not able to comment directly on policies that have a potential for adversely impacting their health, property values, and the state of the natural environment within the province.
I hope that prior to the PPS 2014 coming into effect on April 30th your Ministry will consider the merit of the concerns expressed by myself and the many individuals, citizen groups, farm associations and other interested groups who have commented on the document.
Leader, Green Party of Ontario
To Whom it May Concern,