OFA commented on the proposal to expand the list of changes that can be made to existing Aggregate site plans without ministry approval, and to introduce a policy that would provide direction for changes to licences, permits and site plans where ministry approval is required. While we are in favour of limiting the red tape companies face to conduct their business, we do have some concerns regarding aspects of this proposal.
OFA believes that notification and consultation must (not may) be required “when proposed amendments would result in significant changes to operations and rehabilitation.” OFA is pleased to see that “increase the impact or potential impacts to: ground or surface water resources (and) … agricultural resources” are included as examples of significant changes. We believe that an agricultural impact assessment must be conducted when agricultural lands may be impacted by a proposed amendment.
OFA believes that changes to final slopes and grading should be also subject to increased scrutiny and study. Similarly, any proposed change that has the potential to impact traffic, should also include detailed study and scrutiny to ensure neighbours will not be negatively impacted by this change.
OFA believes that the sketch and draft site plan must be included in the notification package. Related reports should also be included in the notification package.
OFA recognizes that amendments to existing aggregate operations may be necessary at times, and we agree that there are circumstances when requiring complex consultation with landowners is unnecessary. A change of name of the licence holder is one such example. However, there remains circumstances when proposed amendments have the potential to negatively impact landowners. It is in these circumstances that we believe additional scrutiny is required to ensure that these potential impacts are considered and avoided or appropriately mitigated.
Previous related OFA submissions:
September 4, 2018 – OFA letter to Minister Hardeman regarding Agricultural Impact Assessments