A Submission to the Joint Board under the Consolidated
Hearings Act for the Application by Dufferin Aggregates, a Division of St.
Lawrence Cement
Ric Holt, RR1, Elora, Ont, 519 846 2298, www.gravelwatch.org, 24 Feb 2004
The author. The author, a Professor at the University of Waterloo, has had extensive interactions with the aggregates business. This includes negotiating gravel pits, going through Ontario Municipal Board mediation, and submitting a Request for Investigation under the Ontario Environmental Bill of Rights (EBR) of alleged environmental damage in a gravel pit. This also includes a current EBR Request for Review, now being carried out by the Ministry of Natural Resources (MNR), on the contention that province-wide, pit and quarry rehabilitation as required by law is commonly not being done. The author belongs to the Gravel Watch group, which maintains a website and a service for Ontario citizens and coalitions who are concerned about the responsible use of aggregates.
The application. Dufferin Aggregates proposes to expand their Milton quarry, which is already the largest aggregate quarry in Canada according to the Aggregates and Roadbuilding magazine. Dufferin Aggregates may appear to be a local operation, but in fact it is controlled from Switzerland, by the Holcim multinational, which controls Holcim USA, which owns 64% of Saint Lawrence Cement, which in turn owns Dufferin Aggregates.
The Milton quarry, currently 470-hectares, is located in the Niagara Escarpment, which is designated as a World Biosphere Reserve by UNESCO. According to the web page for the St. Lawrence Cement Group, the quarry produces up to 8 million tonnes of crushed limestone (gravel) each year, and Dufferin Aggregates provided over 5 million tonnes for paving the new 407 highway, which provides a new ring road for Toronto. Sometimes a song captures the public sentiment, as do Joni Mitchell’s words in Big Yellow Taxi, “They paved paradise and put up a parking lot”. This carting away of a large chunk of the UNESCO World Biosphere Reserve to pave a wide swath of Ontario’s used-to-be farmland seems to be an example of trading paradise for pavement.
We need more and more gravel, or do we? Ontario consumes a huge amount of aggregates. We Ontarians consume about 150 million tonnes of aggregates per year. Ms. Carol Hochu, President of the Aggregate Producers Association of Ontario (APAO), describes this volume of aggregates as follows, “If I could just paint a picture for you about what 150 million tonnes means, picture an area bounded by College Avenue, that is, the front of the Queen's Park building, west over to Spadina, east over to Yonge and down to the waterfront. If you dug 60 feet into the ground in that whole area bounded by those roads, that represents about 150 million tonnes of aggregate product." [Ontario Hansard, February 16, 2000] In other words, each year, Ontario digs enough aggregates to bury much of downtown Toronto under 60 feet of sand and gravel.
This rate of consumption
translates to 15 tonnes per capita each year.
This compares with 9 tonnes per capita in the USA and 4 tonnes per
capita in the UK. This means that on a
per capita basis, we consume almost four times as much as our British
cousins. Why do we consume so much? One
reason is that the Ontario Provincial Policy aggressively promotes exploitation
of gravel by specifying that gravel should be made cheap and should be dug as
close to its target use as possible.
This is as opposed to the UK policy that encourages recycling and
sustainable use of the resources. For
example, recycling should maximize the use of materials from building
demolition as a replacement for virgin aggregates. Another reason is that the Ontario haulage levy is 6 cents per
tonne. In the UK, their levy is roughly
4 dollars. No wonder we Ontarians
consume gravel like it’s free – it almost is, thanks to the policy of our
government.
The proponent’s argument that Ontario has an increasing need for gravel
is a self fulfilling prophecy --- as long as we have cheap gravel it will be
consumed sooner and faster. If the
proposed expansion of the Dufferin Milton quarry is approved, this will set the
precedent for yet more proposals to excavate the escarpment. This cycle of increasing exploitation feeds
other environmentally harmful trends:
· It sends more trucks out on to our highways,
· It produces more highways that encourage more
pollution producing cars as well as increased urban sprawl.
· It implies more production of “Portland
cement”. This involves heating
limestone and pulverizing the result.
This process is a significant producer of greenhouse gases.
· These various sources of increased pollution
will make our commitments under the Kyoto accord more difficult to meet.
The fact is, gravel is a non-renewable resource. It is time to face the reality that gravel
should be used with constraint, and should not be exploited as if it were
inexhaustible.
Who runs the business of aggregates? MNR is responsible for managing and controlling aggregates in accordance with the Aggregate Resources Act (ARA). The fact is, under the Harris government, MNR privatized much of the management of the aggregate industry. A government trust (run by TOARC) was set up to collect the government levies for hauling gravel. A group called MAAP was set up to spend government money to rehabilitate abandoned pits and quarries. Now who do you suppose runs the trust and MAAP? Both are run by the APAO, which happens to be the registered lobbyist for the industry. In short, the government (MNR) is a partner with the lobbyist (APAO) and the two together manage and control Ontario’s aggregates business. This labyrinthine configuration, with many obvious conflicts of interest, can hardly be expected to put the environment first in their deliberations and operations. This configuration has the markings of an Enron, which may look OK from the outside, but the public cannot tell who on the inside has their fingers in the pie. Dufferin Aggregates is well positioned to benefit from this configuration, as Bill Galloway, general manager of Dufferin Aggregates, is the recent Chair of the Board of APAO and serves on the Board of TOARC.
Doesn’t the aggregate business more than pay its own way? This is a question that APAO enthusiastically answers with a Yes, and indeed APAO recently funded a study which agrees with their position. However, it seems unlikely that a levy of six cents can cover the cost of road damage due to gravel trucks. This does not take into consideration the fact that gravel itself has inherent value. In brief, it is not clear that the aggregate business is paying its bills.
Rehabilitation. One place where the aggregate business is apparently not paying its bills is in rehabilitation. According to industry figures, as documented in the author’s EBR Request for Review, in the last ten years, less than half of the land excavated for aggregate pits and quarries is rehabilitated, in spite of the fact that the law requires this rehabilitation. As Ray Pichette of the MNR has said, “The legacies and rehabilitation practices of the past provide an atmosphere of distrust with the general public.”
Dufferin Aggregates received the Award of Excellence for its rehabilitation in the Milton quarry. Doesn’t that show that this particular quarry is treating the environment well? This award deserves a closer look. Recall that the general manager of the Dufferin Aggregates, Bill Galloway, is the recent past Chair of the Board of APAO. APAO, which is a registered lobbyist, invented the Award of Excellence and gave it to Dufferin Aggregates. It seems rather neat that Dufferin Aggregates has this award in hand just as it applies to expand its biggest-in-the-country quarry. It looks like the APAO and Dufferin Aggregates are breaking their arms by patting themselves on the back. The incontrovertible fact remains, Dufferin Aggregates has blasted out and hauled away millions of tonnes of the Niagara Escarpment. When the talking is done, when the explaining is over, when the experts have finished speaking, the fact will still remain that a significant chunk of paradise is gone. If we should decide to exploit more of this paradise, this should happen only when we have a long term plan, that guides our use of our limited resources, over the future decades, in a rational and well thought out way.
A long term plan… Good idea, we should try that. Ontario’s environmental watch dog, Gord Miller, lists aggregates as one
of his “significant issues.” In the 2002/2003 annual report from his
Environmental Commissioner’s Office, he lists the negative environmental
impacts of aggregate extraction, the increasing use of aggregates in roads
without corresponding long term planning, and calls on us to conserve
aggregates. He recommends that “the Ministries of Natural Resources and
Transportation collaborate on a strategy for conserving Ontario’s aggregate
resources. This strategy, which should be developed with public consultation,
should consider both road construction needs and the need to conserve aggregate
resources.” Shouldn’t we be listening? Isn’t it time to take the long view on how
we use this non-renewable resource?
John Prine, in his song Paradise (adapted here), sings
The gravel trucks came with the world’s
largest shovel.
And they tortured the timbers and stripped
all the land.
Well, they dug for their gravel till the land
was forsaken,
And they wrote it all down to the progress of
man.
We only have one Niagara escarpment.
It is time for a careful long term plan for rational use of this
internationally admired feature of our national heritage. Today, digging more gravel may seem like
progress, but tomorrow we may realize that we have paved paradise. As Joni Mitchell put it, “Don’t it always
seem to go that you don’t know what you’ve got till it’s gone.” Our best decision in the meantime is to keep
what we’ve got left of our escarpment.