County of Brant Council weighed in on Ontario’s proposed policy updates to modernize the Aggregate Resources Act (ARA) Program during its regular Council meeting on Tuesday, September 9, 2025.
Michelle Schaefle, the County’s Senior Environmental Planner, told Council that many of the ARA’s (essentially a rulebook for gravel pits and quarries) policies and procedures have not been updated since 2006, and that the Ministry of Natural Resources (MNR) is now proposing some updates and asking for feedback.
“Aggregates are a growing issue …and we wanted to bring this forward to Council in order to submit comments and just provide that background information. There’s basically two processes that deal with aggregates; we have our zoning process where the County will ask for studies and we’ll do the review, and then there’s an Aggregate Review Act which really looks at the site plan level and the details,” said Schaefle. “The Ministry also has their requirements. So as part of that, they have no shortage of documents on their website on how they have to implement the Aggregate Resources Act; they have an overall document that’s fairly recent from 2023 and that kind of outlines all the different studies they can ask for, similar to the County of Brant. They also have policies and procedures that go into a little bit more detail, so those were last updated in 2006 so it’s been quite a while and that predates Source Water Protection.”
The senior environmental planner went on to say the MNR is now trying to update and provide more standards on how water is collected, how the water table is determined, updating the cultural heritage standards.
Shaefle’s report provides the following list of the MNR’s proposed changes:
- A new policy for the Maximum Predicted Water Table Report: The new policy provides more detailed requirements on topics such as data collection, report requirements, and best practices. The intent is to provide standard direction to determine the water table. One-year of ground water monitoring of wells or test pits is required unless alternative data is available to account for seasonal variations in elevations. In particularly dry or wet years, applicants may be required to consider multi-year data and/or additional monitoring.
- A new Water Report is proposed to replace three policy standards on Hydrogeological Report Standards created in 2006. This report is only required where an operation is proposed to operate below the water table. The Water Report provides direction to assess the impacts of a proposed aggregate operation on ground and surface water and the uses they support (e.g., drinking water supplies and aquatic ecosystems).
- A new Cultural Heritage Report is proposed to replace previous requirements created in 2006. It contains updated definitions; references to the Provincial Planning Statement and Ontario Heritage Act; and provincial standards and guidelines for archaeologists, evaluating archaeological potential, archaeological assessments, evaluating built heritage resources and cultural heritage landscapes, cultural heritage evaluation reports, and avoiding and protecting resources.”
Shaefle’s report also provided information regarding a policy on matters that the Minister or the Ontario Land Tribunal (OLT) must consider:
“A new policy on Matters to be Considered in the Issuance of a Licence was created to provide direction on how the Ministry of Natural Resources evaluates a licence application,” she said. “The Report makes reference to the 2023 Technical Reports and Information Requirements, what needs to be evaluated, and ensures recommendations from the reports on avoidance and mitigation are included in site plans.”
Specific topics covered include:
- Effects on the Environment
- Effects on Nearby Communities
- Comments from Municipalities
- Rehabilitation Plans
- Effects on Ground and Surface Water
- Effects on Agriculture
- Planning and Land Use
- Haulage Routes and Truck Traffic
- Quality and Quantity of Aggregate
- History of Compliance, and
- Other Appropriate Considerations
“Additionally, the province is proposing to rescind 28 outdated or inaccurate policies such as notice requirements that now form part of the ARA and are therefore no longer required as part of a policy procedure,” read Shaefle’s report. “Examples include delegation of authority, MNR Representation at Ontario Municipal Board [OMB] hearings, annual statistical reporting, records retention, enforcement, and schedule of fees.”
The senior environmental planner’s report noted that staff agree with the MNR’s updates, they also suggest the following recommendations:
- That ground water monitoring be increased to a minimum of two years to determine the Maximum Predicted Water Table.
- That an Agricultural Impact Assessment be required in all prime agricultural areas regardless of whether the operation is proposed within or outside a provincial plan area.
- That the province require and provide direction on best practices for assessing and mitigating for the cumulative effects of mineral aggregate operations when combined with historical, existing and proposed future operations.
Later, Councillor David Miller, said he was happy to see some direction on the cumulative effects of mineral aggregate operations, but wanted to see just a bit more specifics.
“I think, as far as cumulative effects, I think you need to maybe address what you’re referring to, and obviously, all the problems associated with a pit, such as water impacts, water use, air quality and traffic because if you have a lot of pits opening up, you’re going to have a lot more traffic, right?” he said. “…I’d like to see more effort put into encouraging these pit operators to stay above the water table, especially where there’s class one or two agricultural land. I think that’s really important, because at the end of the day, when they go below the water table, it’s municipalities that lose at the end.”
After a few other comments, Council voted unanimously in favour of sending their recommendations to the MNR registry.
Kimberly De Jong’s reporting is funded by the Canadian government through its Local Journalism Initiative.The funding allows her to report rural and agricultural stories from Blandford-Blenheim and Brant County. Reach her at kimberly.dejong@brantbeacon.ca.
