New research released by Gravel Watch Ontario, Simcoe County Greenbelt Coalition and Environmental Defence suggest that massive amounts of aggregates for the Bradford Bypass and 413 highways will come from pits in the 905 and the Greenbelt.
Mining these aggregates will have serious impacts on nearby communities and must be addressed in environmental reviews of the proposed highways.
According to the research, building the two highways will require approximately 3 million tonnes of new aggregate, and will increase truck traffic within affected communities by over 130,000 truckloads during construction.
The analysis shows that several communities within the 905 region are more at risk of becoming the future source of the highways’ aggregate because of their proximity to the proposed routes of the highways, the amount of potential aggregate resources available, and concentration of existing permits within particular areas.
This choropleth map is segmented by municipality, and weighted according to a scoring system that combines four scores:
PER_SCORE
For the PER_SCORE the sand and gravel mapping, which were separate files, were combined, the built up areas in the municipality were then subtracted from the combined file, and the result was then measured as a percent of the total area of the municipality. Scores are from 1 to 4, representing 25% increments.
DIST_SCORE
The distance scores are derived from the 20 kilometre and the 50 kilometre distances from the proposed projects. The 50 kilometer radius from the projects is based on a conservative estimate, provided by Gravel Watch Ontario, of the distance from which aggregate resources are normally sourced for projects, with that distance sometimes being expanded outward to 70 kilometers. A score of 2 was given if the municipality was within the 20 kms radius, and 1 if it was within the 50 kms radius. For municipalities within the 20 km radii of both projects a total of 4 was given, and likewise, if a municipality was within the 20 km radius of one project and the 5 km radius of another, it got a score of 3.
TON_SCORE
The tonnage score is based on a decile, with municipalities receiving a score of between 1 and 10, where 10 represents the highest total tonnage permitted within the municipality.
DEP_SCORE
A depth score of aggregate resources based on mapping by the Ontario Geological Survey (OGS) was included to give an additional metric of impact. Depth data are provided by OGS in four categories: Less than 1.5m; 1.5m to 3m; 3m to 6m; and Greater than 6m. DEP_SCORES were apportioned from 1 to 4, with 1 for 1.5m and 4 for Great than 6m.
Sources
“Aggregate site authorized – active”, Land Information Ontario. Info updated November 16, 2018. Data updated December 15, 2021. Downloaded November 25, 2021. (Link)(Data)
Aggregate Resources of Ontario—2020”,Ontario Geological Survey. Downloaded June 30, 2021. (Link)
“Greenbelt outer boundary”, Land Information Ontario. Info updated August 6, 2021. Data updated May 18, 2017. Downloaded January 2, 2022. (Link)
“Mapbox Base Monochrome”, Mapbox (personal account). Created January 10, 2022. Accessed January 11, 2022. (Link)
“Ontario Road Network (ORN) Road Net Element”, Ontario Ministry of Natural Resources and Forestry. Info updated September 27, 2019. Data updated January 5, 2022. (Link)
“GTA_West_RevisedRoute_August2020_Lat_Lon”, Environmental Defence/As The Crow Flies Cartography. Received November 30, 2021.
“Municipal Boundary – Lower and Single Tier”, Land Information Ontario. Info updated June 4, 2019. Data updated April 20, 2021. (Link)
Bryan Smith, of Gravel Watch Ontario, has been long involved with local aggregate issues and knows what kind of burden this will place on the rural communities that could be affected.
“These highway proposals are being touted as a net benefit, but the communities where the pits and quarries would make a Swiss cheese of the landscape will not feel the same. From increased truck traffic, wear and tear on local roads, reduced air quality, to issues with groundwater, aggregate comes at a high cost to the host municipality and its residents. There is no net benefit. Consequently, many municipalities are asking the province to make aggregate pay their fair share.”
The rock, sand and gravel extraction and its impact on communities up to 50 kilometers from the proposed routes is just another example of how the province is pushing forward these highway proposals without a full examination of their costs and impacts.
The “Aggregate Site Heatmap” is meant to show clustering of aggregate sites. This map uses one source of information shown two different ways – a heatmap, which draws attention to the density of sites, and the sites themselves, shown as polygons.
The heatmap uses data from the “Aggregate site authorized – active” file provided by the provincial government, with the sites, which are provided in polygon form, converted into centroid points. The size of the polygons is calculated into “AREA” and the centroid points are weighted by this metric.
The Greenbelt boundary is included to indicate impacts that aggregate mining may have on an area many Ontarians believe is protected from development, as well as industrial, activity. While development, understood in a strict sense of housing, may be restricted, the knock on effects of road and highway construction, this data shows, are largely not.
A measure of aggregate impact on the Greenbelt was arrived at by calculating the surface area of aggregate mines located within the Greenbelt AND within the study area. The result shows that 29% or the study area is covered by Greenbelt and 39% of the surface area of aggregate pits located within the study area are to be found within the Greenbelt boundaries.
Sources“Aggregate site authorized – active”, Land Information Ontario. Info updated November 16, 2018. Data updated December 15, 2021. Downloaded November 25, 2021. (Link)(Data)
“Greenbelt outer boundary”, Land Information Ontario. Info updated August 6, 2021. Data updated May 18, 2017. Downloaded January 2, 2022. (Link)
“Mapbox Base Monochrome”, Mapbox (personal account). Created January 10, 2022. Accessed January 11, 2022. (Link)
Ontario Road Network (ORN) Road Net Element”, Ontario Ministry of Natural Resources and Forestry. Info updated September 27, 2019. Data updated January 5, 2022. (Link)
“GTA_West_RevisedRoute_August2020_Lat_Lon”, Environmental Defence/As The Crow Flies Cartography. Received November 30, 2021.
“Municipal Boundary – Lower and Single Tier”, >Land Information Ontario. Info updated June 4, 2019. Data updated April 20, 2021. (Link)
Tim Gray, Executive Director of Environmental Defence, is concerned that environmental assessments of the highways won’t be considering the impacts from required aggregate.
“The shocking scale of the aggregate needed to build these highways means impacts will be felt by communities across a number of regions. The federal and provincial governments have an obligation to assess and address these widespread impacts as part of a robust and thorough environmental assessment of the highway projects.”
The mapping also shows that nearly 40 per cent of the aggregate sites likely to supply material for these projects are located within the Greenbelt.
Expansion of those pits puts at risk the crucial ecosystem services the Greenbelt provides, such as clean water, fresh air, healthy food, and habitat for wildlife. These impacts of aggregate extraction on the Greenbelt are compounded by the fact that they are being used, in this case, for projects that run through the Greenbelt, and which will likely lead to increased development pressure on it.
Margaret Prophet, Executive Director of the Simcoe County Greenbelt Coalition, believes that the highway proposals are yet another example of how this government has targeted the Greenbelt on behalf of developers.
“We heard promises that “we’re not going to touch the Greenbelt,” and yet this government wants to run two large highways right through it. The demand for aggregate, and the fact that much of it is likely to come from within the Greenbelt, only makes matters worse. The narrow focus on localized impacts creates a situation in which the Greenbelt is left vulnerable to a death by a thousand cuts. The impact of aggregate mining for these highways is a perfect example of this.”
The coalition’s research shows there is little that municipalities can do to protect citizens and ensure a healthy environment in the face of pressure from the aggregate industry.
Tim Gray adds, “The province is knowingly putting communities and the Greenbelt at risk from increased aggregate extraction to build destructive and unnecessary highways. And thanks to recently passed legislation, they have removed almost every tool municipalities used to have to limit or control these impacts. The communities located in these extraction hotspots need to be aware that if these highways go ahead it will impact them, even if they are far from the highways’ routes.”
There are a lot of misconceptions, myths, and misunderstandings regarding the role that highways and cars play in our economy, and the impact they have on our environment and communities. Many of these are coming to the fore with the Bradford Bypass. Here we address some of them.
The provincial government is proposing a highway that would connect the 404 with the 400. The proposed route passes along the northern edge of Bradford, and through portions of the Holland Marsh.
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Residents are fighting to protect what tests have shown is some of the more pure water in the world. The threat? Aggregate mining.
On January 14, 2021, a permit to take water (PTTW) was granted allowing CRH Canada, and more specifically its subsidiary, Dufferin Aggregates, to take nearly 1.5 million litres of water per day to wash aggregate extracted from their mining operation.
On January 27th Tiny Township Council unanimously voted to appeal the PTTW to the Environmental Review Tribunal.
There has been a long fight to protect what some tests have shown to be some of the most pure water anywhere in the world. The primary threat to this water is aggregate mining.
An application to expand the pit was submitted in 2012. You can see the area proposed for expansion, outlined in yellow, on the image below.
Expansion of the quarry would cause an increase in traffic to and from the mine, with an estimated 40 trucks an hour passing through the area. This is nearly one large truck per minute.
The aggregate industry has a terrible record of rehabilitation.
This is something they are required by law to do, but, for the most part, they don’t, and they get away with it.
In their 2006/2007 report, the Environmental Commissioner of Ontario noted that 100 out of 121 operations surveyed had not done the rehabilitation activities required under the Aggregate Resources Act.
The debate around the carbon tax frequently misses its broader economic and environmental benefits. By effectively addressing the externality of carbon emissions, the carbon tax stands as a critical component of Canada’s strategy to combat climate change and promote sustainable growth. Clear communication and understanding of the policy’s benefits, including the progressive rebate program, are vital in navigating public concerns and fostering support for this essential environmental initiative.
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We have grave concerns about the policy direction under the PPS review. As outlined by the Ontario government, the PPS is “the primary provincial land use policy document guiding municipal decision-making.” So the tone, focus and direction given in this document greatly impacts our communities, our environment and our future.
October 21, 2019
Municipal Affairs and Housing
Provincial Planning Policy Branch
777 Bay Street
13th floor
Toronto, ON M5G 2E5
planningconsultation@ontario.ca
RE: SCGC Comments on ERO 019-0279
Please accept our submission to the aforementioned review as it relates to the Provincial Policy Statement (PPS). We appreciate your consideration of our comments.
About Simcoe County Greenbelt Coalition
With our 35 member groups from urban, rural and semi-urban communities, we aim to promote community development that is financially, environmentally and socially sustainable, such that provides a net benefit to residents. A major part of this is to recognize the value that natural heritage, agriculture and water gives to our communities, including the numerous benefits and co-benefits of ecosystem services. Ensuring the people of Simcoe County, and Ontario broadly, continue to receive these benefits requires an approach to economic development that is evidence based, transparent and accountable to the public, and with full consideration of the long-term impacts that communities will either have to deal with or benefit from.
We have grave concerns about the policy direction under the PPS review. As outlined by the Ontario government, the PPS is “the primary provincial land use policy document guiding municipal decision-making.” So the tone, focus and direction given in this document greatly impacts our communities, our environment and our future.
Our general concerns include:
We have more specific concerns as outlined below:
Proposed policy allows mineral aggregate extraction to occur in protected, provincially significant natural features, including wetlands, woodlands, valley lands, wildlife habitats, fish habitats, endangered and threatened species habitats and areas of natural and scientific interest outside of the Greenbelt.
We feel it necessary to remind you that this type of policy adjustment could have large ramifications for Simcoe County residents, our eco-systems, water sources and natural heritage as large aggregate supplies are situated in and around many of our communities, as well as in and around significant groundwater resources and natural heritage areas.
For eight years between 2003-2013 Simcoe County was the largest aggregate producer, by volume, in Ontario. During those years Simcoe County produced 11.64 million tonnes of aggregate, on average, annually. Five municipalities within the County, Clearview, Oro Medonte, Ramara, Springwater and Severn, consistently produce an excess of one million tonnes per year, as seen in Table 1 below.
There are over 100 licensed pits and quarries within Simcoe County, with a total licensed area of 3917.16 ha. It was estimated by the Ontario Geological Survey (2013) that Simcoe has a potential unlicensed resource area of 2404 hectares for sand and gravel with roughly 237.7 million tonnes of aggregate resources. Further, the bedrock-derived aggregate resources that are currently unlicensed is a potential resource area of 27,503 hectares, containing 10,928 million tonnes of aggregate resources. Together, that is roughly 30,000 hectares potentially being dedicated to aggregate extraction.
Although Simcoe County is large, we must keep in mind that 30,000 hectares is roughly half the size of Lake Simcoe. Add into that the associated roads and infrastructure which aggregate operations require and clearly large swaths of land could be dominated by aggregate activity.
Most of these deposits and resources are located in the northern part of the county. Although it is less populated than the southern part of the county, it nevertheless has important infrastructure contained within it. The northern part of the county contains most of the connected forest cover, a high percentage of wetlands and many river and stream systems.
Moreover, the population in the northern part of the county is primarily serviced by groundwater wells and has a higher concentration of residents who are similarly serviced by individual private groundwater wells.
Layering the sand, gravel and bedrock resources against source water protection maps shows that most of these identified resources (licensed or unlicensed) are surrounded by or contained within highly vulnerable aquifers – the source of drinking water for most of the population in that region.
One of the main concerns about aggregate extraction is its effect on surface and groundwater. Extraction changes the slope of the land and water drainage patterns. This is a change that is effectively impossible to revert back to an original state, making any claim of full rehabilitation highly unlikely
Further, aggregate resources within an aquifer store the water. If you remove the aggregate the water storage capacity of that aquifer is significantly damaged and reduced. A case study conducted in Minnesota found that while impacts on water were not found in every quarry and pit, declines in aquifer levels were a common occurrence.
Farmland is also impacted by aggregate operations. The quarries and pits and their related infrastructure fragment farmland and the rural economy.
As seen below, the aggregate resources identified in Simcoe County also tend to be surrounded by high class farmland.
Ontario is already losing over 150 acres of farmland per day. Deregulating aggregate to get into areas that jeopardize our local food systems is short-sighted and only further stunts the sustainable economic development of rural communities. Aggregate can provide jobs, but only for a period of time. Agriculture, properly conducted, can provide jobs, as well as food security, climate change mitigation, and cultural benefit year after year after year.
Allowing aggregate to expand and initiate operations in highly sensitive areas such as significant forests, wetlands, valleylands and ANSIs is unconscionable considering that there is no evidence to support a need for increased access to supply.
OSSGA contends that less regulation, such as what is proposed in the PPS and Growth Plan, is needed to increase supply due to a large, expected population growth. We believe that this is an intentionally misleading premise.
First, the demand that OSSGA insists is there is not much more than what they already produce. OSSGA estimates 3.84 billion tonnes of aggregate will be needed by 2041. Per year that works out to 174 million tonnes of aggregate annually, which is only 10 million tonnes more than their average annual production. In some recent years, the industry has produced over 200 million tonnes of aggregate – obviously the capacity to produce more already exists.
This needed increase also assumes that demand for aggregate will not decrease or stabilize. Over 50% of aggregate in Ontario goes towards the building of roads. As we continue to build our communities up, as opposed to sprawling out, the construction of new roads and highways (which, as noted, is where the majority of the aggregate goes) will mean less demand for aggregate. It is quite possible that these changes alone could mean that aggregate demand may only stabilize and hence an increase in production may not be needed at all.
The rationale for the proposed amendment within the PPS rests on the assumption that natural areas destroyed by pits or quarries will eventually be rehabilitated, as required by law. However, it fails to acknowledge that aggregate operations are often open for decades, or that legal requirements to rehabilitate sites are often poorly enforced and routinely ignored. It also fails to account for the loss of significant and/or at-risk animals and plant species and their habitats in the meantime. This loss is likely permanent, too, as sites are rarely returned to their original state.
The poor record of rehabilitation of aggregates operations has been thoroughly covered in past reports of the Environmental Commissioner of Ontario, which have revealed that:
Wetlands are vital to maintaining water supply and water quality, and to enhance landscape and community resilience in an era of climate change as they play a critical role in flood attenuation and act as carbon sinks. They also provide habitat for many of the province’s most imperiled plants and animals. A 2009 study commissioned by the Ministry of Natural Resources estimated that the ecosystem services provided by wetlands in southern Ontario alone were over $51,614,795,000 per year. According to the authors, ecosystem services such as these “are the foundation of human well-being and they also represent a significant part of the total economic value of our landscape and economy.”
South and east of the Canadian Shield (Ecoregions 6E and 7E) at least 72% of wetlands have been lost to development, with losses exceeding 90% in some areas. We are therefore very concerned about the proposed policy 2.1.10:
2.1.10: Municipalities may choose to manage wetlands not subject to policy 2.1.4 and 2.1.5, in accordance with guidelines developed by the Province.
The policy is permissively and vaguely worded and invites an ad hoc approach to wetland management across the province
Further, policies 2.1.4 and 2.1.5 stipulate that site alteration should not occur in wetlands that are deemed significant. The implication of placing management of wetlands not subject to these policies with municipalities is that they are not considered “significant”. This effectively paints all wetlands outside of the significant classification with an extremely broad brush. Since many wetlands have not been evaluated, this generalization is highly likely to cause irreparable damage to wetlands that if evaluated would likely meet the standard required to be classified as significant.
We question why such a policy would even exist based on the substantial amount of science that underscores the importance of wetlands to water quality and quantity, climate and flood resiliency, and habitat for wildlife.
We have come to understand that proposed policy 2.1.10 is intended facilitate wetland offsetting in unevaluated wetlands.
SCGC strongly believes that the precautionary approach – the prudent approach – should govern serve as a formative principle in determining land-use policy. Accordingly, we would argue that all wetlands should be deemed significant until an objective, science based evaluation has occurred that shows a high degree of certainty otherwise.
Furthermore, allowing municipalities to “manage” wetlands as they see fit establishes a scenario in which the treatment of wetlands will be disjointed and inconsistent. Wetland management is key to watershed planning and flood resiliency – both should be declared areas of provincial interest and thus not left in the hands of municipalities with vague wording and non-existant outcomes or targets.
While we strongly disagree with wetland offsetting, if such a policy were to exist it must clearly state the purpose and parameters, including requirements to:
To fully appreciate the scope and potential outfall that such a policy could have, we need look no further than Simcoe County. As demonstrated in Figure 4, the amount of unevaluated wetlands, also known as locally significant, in Simcoe County is large and spread throughout the county, with a notable concentration in the northern region.
As mentioned previously, Simcoe County groundwater systems are pervasive throughout the county and supply the large majority of residents and businesses with their water for daily use. Wetlands are a key element of the water recharge and purification system within a groundwater system. Thus, limiting or destroying a wetland’s function impacts local water systems as well as increases flooding risk.
In Figure 5, it is clear that many of these unevaluated wetlands are enveloped by Highly Vulnerable Aquifers and/or Significant Groundwater Recharge Areas.
No one knows for sure how much change and destruction a groundwater system will tolerate before its function is impaired and therefore unable to provide adequate amounts of potable water. How much risk is the province willing to undertake in the name of aggregate extraction and housing?
New policies allow for greater flexibility for communities to select individual on-site sewage services and individual on-site water when municipal services are not available, planned or feasible in rural settlement areas at the time of Official Plan review or update.
It means that communities can build out in rural areas that, generally, are unable to support complete communities. In Simcoe County in particular, there is a net surplus of development approvals, especially in the more rural areas.
We firmly believe that a change in the servicing hierarchy to include communal and private servicing would proliferate a sprawling built form. As a result, this sprawling built form spreads municipal and provincial resources thin as there are more roads to maintain, operate, etc. with a small tax base to cover costs of upkeep. Costs related to infrastructure, it should be noted, will almost certainly increase with the impacts of climate change, and so planning should proceed accordingly. Further, sprawl locks in high emission lifestyles for decades, increasing the challenge, already considerable, of meeting the needed, science-based targets of net-zero carbon emissions by 2050.
Another concerning component to this proposal is that communal wells and private wells are not covered under Source Water Protection Plans. Therefore, encouraging growth that knowingly builds water systems not properly protected is a huge risk to public health and abdicates the caretaker role of government.
Including terms such as “market based” housing and extending the planning horizons are also troubling, as noted above. Both of these items only encourage the maintenance of the current housing mix and provide more opportunities for land banking for future greenfield development. Land banking is now thought to be one of the primary drivers of the housing affordability crisis.
It is unclear why this would be considered at a time when we need to fully confront how damaging our built form is to the climate and environment at large.Ontario’s main emission source is from individual transportation and Ontarians are driving more than ever, as noted below.
The main reason behind our increasing driving trends is how and where we build our communities. Roughly 75% of Ontarians live in car dependent neighbourhoods – places where the distance between daily needs, such as grocery stores, work places, schools, and medical care, is beyond that easily walked, and/or transit is not established well enough to entice people out of their cars.
Unfortunately, that trend is continuing to rise in Ontario as well as across Canada. Consider that between 2006 and 2016, car dependent growth (rural and suburban) accounted for 85% of the population growth in Canada. In the GTA specifically, 83% of growth occurred in car dependent neighbourhoods rather than active cores where walkability and transit are well established.
This has a huge impact on our environment, health, community design, transportation and climate change. Our building patterns set our carbon footprint and climate risk for decades to come. If anything, considering the financial, social and environmental costs of this type of building pattern, the province should be using this opportunity to move Ontario’s growth even more towards more compact development.
Further, changing demographics also need to be considered before proposing policies that promote sprawling growth patterns. Car dependent, rural communities are generally only accessible for people of a certain age, stage and income – namely, middle class and middle age. By 2031, it is estimated that 42% of people in car dependent suburbs around Toronto will no longer have a driver’s license. This means that to effectively “age in place” and to make our communities accessible for all, residents either will have to have options for transit or live in walkable communities.
In Simcoe County, specifically, our communities will need to be better designed for seniors – especially if the province is serious about “aging in place” to deal with long-term care bed backlogs. By 2041, the population of seniors 65 years and older in Simcoe Muskoka is projected to surpass 218,800, which is more than double the number of seniors from 2011.
Figure 7 indicates that all senior age groups will increase in population. The largest increase will occur among the 90+ age group, which will increase by 346% from 4,345 in 2015 to 19,380 in 2041. How will these people be encouraged to “age in place” if we keep building remote, car dependent neighbourhoods? Becoming an age friendly community means ensuring accessibility. Policies such as what is proposed in the PPS encourage low density, car dependent neighbourhoods which will not be sufficient to support our aging population. This only puts more of a strain on our public health system and other supports for seniors.
The members of SCGC want to see a fair balance between growth and the environment. Further, there needs to be more consideration for our natural environment and water when considering aggregate and growth policies. As a mainly rural/suburban region, we are highly dependent on our groundwater resources, and our economy is inextricably linked to our lakes, farmland and natural environment. Changes to policy, such as what is proposed in the PPS, impact our way of life and our economy.
In times of dwindling water resources, a changing climate and mass biodiversity loss, we want the province to have the will to put forth policies that address these losses – policies that correct our course and move us towards solutions. Unfortunately, we do not see any measurable steps outlined in these policy proposals that will correct our course, only make matters worse. We strongly implore the province to reconsider the direction and vision that it is now offering within the proposed PPS.
Sincerely,
Margaret Prophet
Executive Director, Simcoe County Greenbelt Coalition
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