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FORCE Submissions

Thursday, May 21, 2009 - FORCE submits objection to MNR and St Marys Cement (CMB) - 45 Day ARA Consultation Period

FORCE submitted objections to the Ministry of Natural Resources and St Marys Cement (CBM), during the offical 45 day public notification and consultation period as outlined in the Aggregate Resouce of Ontario Provincial Standards. The following doucments and experts reports were included with our Communities' submissions:

FORCE Objection Cover Letter (51 KB)
FORCE ARA Community Issues Review Report (374 KB)
Aquatic Environment Review - Aquafor Beech Ltd. (48 KB)
Hydrogeologic Review - Intera Engineering Ltd. (105 KB)
Natural Environment Review - North-South Environmental Inc. (157 KB)<


Thursday, May 23, 2008 - FORCE submits comments to MOE regarding draft PTTW for St Marys CBM

FORCE submitted comments to MOE, on behalf of our communities, regarding the draft Permit to Take Water (PTTW) for St Marys CBM as posted on the Environmental Bill of Rights (EBR) registry in advance of the June 6, 2008 deadline. Read the full FORCE submission (126 KB), Appendix(107 KB) and the expert hydro-geologist report (82 KB).


Monday, May 5, 2008 - FORCE provides feedback on Greenbelt Expansion Criteria

On behalf of our Community, FORCE provided feedback to the Ministry of Municipal Affairs and Housing on April 30th, 2008 regarding proposed criteria to expand the Greenbelt. The proposed criteria have been designed to ensure that expansions to the Greenbelt are supported at the municipal level and represent sound science and policy. FORCE supports the expansion criteria, in principle, but noted that greater flexibility is required with respect to a criteria specifying that expansions must be "next to" the existing Greenbelt. FORCE also made the argument that there is more the McGuinty government should be doing to protect the environmental integrity, source waters and agricultural lands within the boundaries of the existing Greenbelt. Defense of the current Greenbelt is required as strongly as criteria for its expansion. Read details in the full submission (117 KB).


Friday, June 8, 2007 - Application for Review Submitted under Environmental Bill of Rights

Section 61 of the Environmental Bill of Rights (EBR) allows individuals and corporations to apply to have existing policies and laws reviewed and/or to request consideration of new policies and laws. The application for review is made to the Environmental Commissioner of Ontario. On behalf of our communities, FORCE submitted an application for review - for consideration of a new policy or law to provide an early screening evaluation mechanism for development proposals under the Planning Act and/or the Aggregate Resources Act. The application for review was sent to the Environmental Commissioner in February 2007. The Commissioner then sends the request on to the relevant ministries for comment - in this case, the Ministry of Municipal Affairs and Housing and the Ministry of Natural Resources.

We made this application because of the extremely lengthy, technical and costly review processes associated with development proposals. Questions can certainly be raised about how well the existing processes protect our environment and how consistent they are with good democracy. Citizens, who are supposed to be represented and to have the broader public interest protected by governments and public agencies, have to put in extensive personal hours and after tax dollars to advocate for their interests, especially since there is no longer intervenor funding paid by the development proponent to citizen groups.

Even though there have been recent improvements in planning law, that we have supported as steps in the right direction, there is still no early screening evaluation mechanism that would allow municipalities and/or provincial agencies to undertake an early screening of a development proposal - such as the proposed quarry facing our communities - and its attributes and deficiencies - using clear planning tests - to determine if the proposal should proceed through the existing approvals process or should be stopped at an early stage. An early screening evaluation mechanism would adopt an environment/conservation first principle and provide greater certainty for all stakeholders - industry, government and the public.

Read the Cover Letter. (152 KB)
Read the full Submission. (76 KB)

Both ministries responded to our application for review under the EBR in May 2007. Not surprisingly, the ministries reject the need for an early screening evaluation mechanism. Simply put, the Ministry of Natural Resources believes that the Aggregate Resources Act provides a fulsome and fair review of aggregate development proposals. The Ministry of Municipal Affairs believes that it has just completed an extensive consultation process on planning law reform, in which an early screening evaluation mechanism did not surface in a material way, and that reopening the legislation at this time is not warranted.

Read the MNR Response. (5.5 MB)
Read the MMAH Response. (1.6MB)

The next step in the EBR application review process is for the Environmental Commissioner of Ontario and his staff to review the application request by FORCE and the ministry responses to it. The Commissioner will then make his own comments and recommendations. The ECO comments and recommendations will be found in a forthcoming Annual or special report.

We will keep the community informed of developments as they occur.


Friday, June 8, 2007 - FORCE submits Comments regarding First Phase of Regulations under Ontario Clean Water Act

On behalf of our communities, FORCE submitted comments regarding the first phase of regulations under the Ontario Clean Water Act, 2006. This law is critical for taking a preventative approach to protecting our sources of drinking water - whether groundwater or surface water based. The first phase of regulations address topics such as Source Protection Areas and Regions, Source Protection Committees, Terms of Reference for Source Protection Committees, planned drinking water systems, drinking water systems that cannot be considered in a Terms of Reference, Great Lakes Agreements, and exemptions. The submission commends the government for the general directions proposed in the draft regulations but notes that there are some areas for improvement. These include: the need for province-wide source water protection; flexibility to increase the maximum size of the Source Protection Committee; explicit inclusion of environmental/community non-government organizations on the Source Protection Committee; need for an open and transparent procedure for appointment of the chair and alternate chair; consistent rules of procedure, codes of conduct and conflict of interest policies across all Source Protection Committees; a requirement for early information sharing, including draft material, by the Source Protection Committee; meaningful involvement and consultation with First Nations; a shortened timeframe for completion of the Source Protection Plan and time limits on all phases of its development; and, no undue constraints on municipalities or the Minister for the nomination of private drinking water systems under the Act.

Read the full Submission (124 KB)


Friday, February 2, 2007 - FORCE Submits Comments on Source Protection Committee Discussion Paper

On behalf of our communities, FORCE provided feedback during the latest round of consultation held in January 2007 on the proposed directions for establishing Source Protection Committees under the Clean Water Act, 2006.

Source Protection Committees will be established for each local watershed - based source protection area to undertake the planning work to protect drinking water sources. They will be created by regulation authorized by the legislation. We hope that the Ministry will move expeditiously to bring forward the regulations and begin to implement this important legislation. Read the FORCE Input to the Ministry of the Environment (116.68KB). This work follows up on written submission work and presentations before Committees of the Legislature as the legislation was being developed. To read the summary of the Environmental Registry posting, visit www.ene.gov.on.ca/envregistry/028781ep.htm - File no longer available and to click here (200.34KB) to read the Discussion Paper.


Friday, February 2, 2007 - FORCE Submits Comments regarding Species at Risk legislation

On behalf of our communities, FORCE provided feedback during the latest round of consultations held in January 2007 on the proposed directions for legislation to protect Species at Risk. Reforms to the Species at Risk legislation to protect endangered and threatened species and their habitats is long overdue. We hope that legislation will be introduced and expedited when the Legislature resumes sitting in March.

Read the FORCE Input to the Ministry of Natural Resources (82.47KB). This work follows up on on-line and written submission work undertaken during summer 2006 in response to the Ministry Discussion Paper. To read the Discussion Paper, a summary of Consultation Comments Received, and the Report of the Advisory Committee, visit www.mnr.gov.on.ca/en/Business/Species/.


Thursday, November 30, 2006 - FORCE submits comment to MOE on St Marys PTTW Application

On Thursday November 30th FORCE submitted comments on behalf of our Communities to the Ministry of the Environment concerning the St Marys Cement Permit to Take Water application. The PTTW application was in support of St Marys' large scale field tests of their theoretical Groundwater Recirculation System. This GRS system is St Marys' proposed mitigation method for the unacceptable groundwater impacts identified by their own consultants as resulting from the proposed quarry.

FORCE challenges the application in their submission (277.77KB) in two different ways. First that the proposed testing is premature and secondly that the testing plans are overly intrusive and not appropriate for such a sensitive hydrogeologic area. The FORCE submission is supported by reports from our Community expert Team in the areas of Hydrogeology (89.09KB) and the Environment (40.18KB).

In addition to the formal comments from the FORCE Committee on behalf of the Community at large, a great many residents have submitted comments to the MOE expressing their individual concerns over the application. The MOE public comment period ends on December 1st and concerned residents are encouraged to make the comments before that deadline. Detailed instructions can be found here.

More information on the proposed GRS testing can be found here. FORCE will continue to monitor the application and will inform the Community of any developments.


Thursday, October 12, 2006 - FORCE Participated in Review of Species At Risk Law

During summer 2006, the Ministry of Natural Resources held a public consultation on the law that protects Species at Risk. A discussion paper was released and written/on-line submissions were invited. read the full discussion paper(521 kB). On behalf of our communities, FORCE provided on-line feedback and a companion written submission supporting a strong legal framework to protect species at risk and their habitats and to assist in their recovery. Thanks to Dr. Jerry Bloom for his expertise and work on this initiative!

FORCE Input to the Ministry of Natural Resources (91 KB)


Monday, September 25, 2006 - Work well underway to Reform Land Use Planning and the OMB

The proposed Planning and Conservation Land Statute Law Amendment Act is a key law for reforming land use planning and improving accountability and accessibility to decision makers such as local councils and the Ontario Municipal Board (OMB). The proposed law received the Second Reading in the Legislature during the Spring Session. This led to some important work and developments through the late summer and early fall.

The Ontario Standing Committee on General Government held public hearings during the week of August 7th and received written submissions until the end of August 2006. This work paralleled some consultations held by the Ministry of Municipal Affairs and Housing as a result of Environmental Bill of Rights registry postings. Read the full FORCE submission (475 KB).

In related developments, the Ministry also tabled a broader package of amendments (changes) to the legislation. Directionally, many are consistent with calls by stakeholders such as FORCE. And while further changes would have been beneficial, such as earlier effective dates for the OMB reforms, the proposed legislation will be an important step in reforming land use planning and OMB tribunal work. To read the amendments, please follow the clause by clause debates in the Legislature at the links provided below.

More information on OMB Reform The proposed legislation will be referred back to the Legislature for Third Reading after September 25, 2006.

The legislation is a priority for the government to pass during the Fall Session. Continue to visit www.StopTheQuarry.ca for updates on the Act's passage and development of companion regulations and implementation tools.


Saturday, September 23, 2006 - Work well underway to Protect our Drinking Water with proposed Clean Water Act

The proposed Ontario Clean Water Act is a key law for protecting our drinking water at its source, and the protection of our drinking water source is a key part of the Community's case again this proposed development. The Ontario Standing Committee on Social Policy held public hearings during the week of August 21st. Graham Flint, Chair and Spokesperson of FORCE, represented our communities at the hearing held in Toronto. FORCE emphasized:

For the full FORCE submission, read the presentation deck, Ensuring Clean Water for All (781 KB) and the written submission (460KB).


Monday, February 27, 2006 - FORCE submits comments to Ministry of Municipal Affairs and Housing regarding Planning and Ontario Municipal Board (OMB) Reforms (Bill 51)

FORCE submitted comments, on behalf of the community, to the Ministry of Municipal Affairs regarding the land use planning and OMB reforms proposed in Bill 51 - the Planning and Conservation Land Statute Amendment Law Act. In general, FORCE supports the directions contained in the legislation and the proposed companion administrative reforms. The key omission is the lack of provision for intervenor funding to assist community groups to participate before administrative tribunals, such as the OMB. FORCE has called for intervenor funding to be instated. Cover Letter (70 KB) and FORCE submission (176 KB).


Sunday, February 26, 2006 - FORCE submits comments to MNR regarding Aggregate Policies in Greenbelt Plan

In January 2006, FORCE submitted comments to MNR regarding two documents:

1. Rehabilitation Requirements for Existing Operations in the Protected Countryside of the Greenbelt Plan Area and
2. Establishing the Maximum Disturbed Area for Existing Operations in the Protected Countryside of the Greenbelt Plan Area
.
(260 KB)

FORCE raised questions regarding the policies and implementation, including roles and responsibilities and the level of detail provided. While these proposed policies would apply to existing operations, it is important to establish transparent and clear criteria before any transferability is imparted to new, greenfield applications such as the Lowndes Holdings Corp. (now St Marys Cement Group CBM) proposal.

Download the full FORCE submission. (110 KB)


Sunday, February 26, 2006 - FORCE submits comments to MNR regarding the Updating of Aggregate Resources Act (ARA) Policy and Procedures Manual - Late Posting

In August 2005, FORCE submitted comments to MNR regarding the ARA Policy and Procedures Manual. The Policy and Procedures Manual is an important tool to assist MNR staff in their duty to execute the intent of the ARA. FORCE believes it is important to update the manual to reflect not only the latest statutory changes to the ARA from the late 1990s, but also to reflect the most recent statutory and regulatory changes across government initiatives. FORCE focused its comments in the areas of MNR's role in providing a comprehensive review of aggregate applications, interpreting the ARA and the discretion exercised by staff in the absence of public review, the need to reflect the Provincial Policy Statement (PPS) 2005, the need to involve Ministry of the Environment (MOE) staff up front with respect to surface and ground water analyses and to consider the Permit to Take Water (PTTW) early, and the need to engage other ministries appropriately to fulfill their duties, among other issues. Download the full FORCE submission (107 KB).


Saturday, February 25, 2006 - FORCE submits comments to Ministry of Public Infrastructure Renewal regarding Greater Golden Horseshoe Growth Management Plan

FORCE tabled a submission with the Ministry of Public Infrastructure Renewal (PIR) regarding the Greater Golden Horseshoe Growth Management Plan. The Plan is an important first step towards more sustainable urban development patterns in the Hamilton/Halton region.

FORCE's comments build on those made in its September 2004 submission (150 MB) to PIR regarding the draft Plan. We believe that the Plan should incorporate a stronger focus on the completion of an ecologically viable permanent Greenbelt and greenways network in the region. In addition, the protection of agricultural land is limited with its focus on prime and specialty crop areas and lack of attention to near urban agriculture.

FORCE indicated that the Plan appears to place greater emphasis on managing the demand for aggregates than did the draft Plan and than some other recent government discussion papers. We noted that it falls short of the type of comprehensive conservation framework called for by the Environment Commissioner of Ontario in recent annual reports and by the Pembina Institute (Rebalancing the Load - January 2005 - 2.5 MB). The Plan fails to articulate specific strategies to achieve its &wise use& goals and these specific strategies - to reduce demand for aggregate materials and to better balance aggregate extraction with other competing land uses, such as source water and natural heritage protection - are also lacking in corollary government initiatives, such as the draft Provincial Policy Statement. A strong 3Rs conservation framework is provided in the Plan for energy and waste management and FORCE has recommended that something similar be required of aggregates.

Download FORCE's full submission (59 KB)


Tuesday, July 25, 2005 - FORCE submits comments to the City of Burlington Planning Department regarding the White Paper on Sustainability, the Environment and the Burlington Official Plan

Friends of Rural Communities and the Environment (FORCE) thanks the City of Burlington for the opportunity to input to the White Paper on Sustainability, the Environment and the Burlington Official Plan.  http://www.burlington.ca/clerks/cal/2005apr/PL49-05.pdf (366 KB) Planning staff is using this Paper as the basis for discussion regarding sustainability as part of the review and updating of the municipality’s Official Plan.    Download FORCE's full submission (137 KB)


Tuesday, February 15, 2005 - FORCE submits comments to the Ministry of the Environment regarding the Source Water Protection Implementation and Technical Expert Committee Reports

FORCE tabled its final submission on the Source Water Protection Implementation and Technical Expert Committee reports with the Ministry of the Environment on February 14, 2005. The government will be using the recommendations from these 2 reports and the feedback to the draft Source Water Protection legislation released during summer 2004 to develop comprehensive Source Water Protection legislation. The goal is to prevent any future Walkerton tragedies from happening by protecting drinking water quality and quantity as a priority. Passage of the Source Water Protection legislation and the implementation of local Source Water Protection Plans will significantly add to our case against the proposed quarry. Download the full submission (116 KB)


Wednesday, February 2, 2005 - FORCE Chair Makes Presentation to Ontario Standing Committee on General Government in Grimsby regarding Bill 135 - the Proposed Greenbelt Act

The Ontario Standing Committee on General Government (711 KB), one of the Committees of the Ontario Legislature, is holding public hearings regarding Bill 135 - the Proposed Greenbelt Act. The Bill has received both First & Second Reading in the house and is before the Committee for review and amendments within the spirit of the legislation. The Bill is to be referred back to the Legislature for Third Reading and passage by March 9, 2005 when the current Greenbelt study area legislation is now set to expire.

FORCE requested to appear before the Committee to address how the Greenbelt Act and Plan will be transitioned. FORCE feels that it is important to ensure that rural use applications which will have a significant footprint impact on the hydrogeological and ecological integrity of the Greenbelt, such as the Lowndes Holdings Corp. application, are caught by the legislation or its companion regulation. FORCE was selected as one of the stakeholder groups the committee chose to hear.

FORCE Chair, Graham Flint, was invited and spoke to the Committee at its Grimsby public hearing on February 2, 2005. Based on its previous submission to the Ministry of Municipal Affairs and Housing regarding Bill 135 and based on the oral presentation to the Committee, FORCE has also made a written submission to the Committee. Read remarks (89 KB) for Graham's presentation and download the full FORCE submission (122 KB) for information.


Monday, December 20, 2004 - FORCE submits comments to the Ministry of Municipal Affairs and Housing regarding the Draft Greenbelt Plan

FORCE tabled its final submission on the proposed Draft Greenbelt Plan with the Ministry of Municipal Affairs on December 20, 2004. Passage of the Greenbelt legislation and implementation of the Greenbelt Plan will significantly add to our case against the proposed quarry.  Of particular interest is how and when the Act and Plan will be applied.  FORCE supporters are also encouraged to complete the e-consultation survey on the Greenbelt that the Province still has underway.  Download the full submission (143 KB).


Saturday, November 27, 2004 - FORCE tables final submission on proposed Greenbelt Act with the Ministry of Municipal Affairs and Housing

FORCE tabled its final submission on the proposed Greenbelt Act with the Ministry of Municipal Affairs on November 27, 2004. Passing of the Greenbelt legislation and implementation of the Greenbelt Plan will significantly add to our case against the proposed quarry.  Of particular interest is how and when the Act will be applied.  FORCE will be submitting comments on the proposed Greenbelt Plan prior to the December 12, 2004 deadline.  FORCE supporters are also encouraged to complete the e-consultation survey on the Greenbelt that the Province has underway.  Download the full submission (117 KB).


Tuesday, September 21, 2004 - Submission To The Ministry Of Public Infrastructure Renewal

“Places To Grow - Better Choices. Better Future. Draft Growth Management Plan For The Greater Golden Horseshoe” discussion paper. Download complete submission (150 MB).


Tuesday, August 31, 2004 - Friends of Rural Communities & The Environment (Force) - Final Submission To The Ministry Of Municipal Affairs Re: Planning Reform Discussion Papers #1-3

Friends of Rural Communities and the Environment (FORCE) thanks the Ministry of Municipal Affairs for the opportunity to input to the key discussion papers regarding planning reform. This submission builds on the presentation made by the FORCE chair, Graham Flint, at the Ministry open house in Oakville on July 13, 2004. Download complete submission (175 KB).


Friday, July 16, 2004 - FORCE make formal submission to the Greenbelt Task Force

FORCE makes a formal submission that follows presentation to the Greenbelt Task Force made in May. Download the complete submission: FORCE_greenbelt.pdf (64 KB)


Tuesday, July 13, 2004 - FORCE Chair makes presentation on planning process and Ontario Municipal Board

FORCE Chair makes presentation on planning process and Ontario Municipal Board reform at Ministry of Municipal Affairs Town Hall Meeting on July 13. For complete details read the final presentation at FORCE_MA.pdf (78 KB).


Monday, June 21, 2004 - FORCE provides input to the City of Hamilton's response to the Provincial Greenbelt Task Force recommendations

This matter is up for consideration by the City of Hamilton's Planning and Economic Development Committee on June 22, at 9:30 a.m. Read the the FORCE letter: FORCE_Rawlings_062104_1.pdf - 473 KB (Adobe Reader required)


 


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