Cornerstone Standards

Background:

Cornerstone Standards Council grew out of discussions among community groups, environmental groups and the aggregate industry who met to attempt to develop a more positive approach to resolving conflicts and contention over how aggregate sites are sited and operated. Discussions initially took place two separate groups – the Aggregate Forum of Ontario (AFO) and Socially & Environmentally Responsible Aggregated (SERA). These two groups merged in August 2012 to form the Cornerstone Standards Council (CSC).

In March of 2013, CSC established the Standard Development Panel and Terms of Reference for its work. In June of 2013, the first field test of the Responsible Aggregate Standard was conducted. In January of 2014, CSC released the draft Responsible Aggregate Standard for 75-day consultation, and in November of 2014 a two-year pilot period began.

Gravel Watch Ontario was represented on Cornerstone Standards Council from its inception until the fall of 2013, when it withdrew over concerns the program’s development wasn’t leading towards adequate standards.

Discussion:

Gravel Watch Ontario is concerned that Cornerstone Standard Council’s Responsible Aggregate Standard, released on January 12th, 2015, may claim to be delivering outcomes that these Standards cannot ensure. Gravel Watch cites several concerns with the Cornerstone Standards Council’s program, including:

  1. The language of the Standards is vague and ambiguous, lacking quantitative criteria against which compliance can be measured. There is no way to predict if certified operations will be quieter, produce less dust and noise, consume less water, or reduce any of the inherent negative social and environmental impacts that come from aggregate operations. Under the Standards, applicants can set their own targets without regard to broader industry norms or best practices. There is no way to judge if certified applications will actually perform above current regulatory requirements.
  2. The Standards include a complex concept of “offsets” or “net gain”, meaning that negative impacts on one site can be compensated for by improving land use or quality elsewhere. This approach will create winners and losers across the landscape. At the local level, it is incomprehensible that communities will embrace the notion that positive impacts elsewhere can compensate them for negative impacts inflicted locally.
  3. Because of very limited field testing, calibration or comparison to existing operational benchmarks or regulatory requirements have been done, it is impossible to determine what impacts the Standards may have. The plan now is to certify up to a dozen operations, while at the same time evaluate if the Standards are appropriate. This raises a concern that the Standards will be adjusted to fit these operations rather than vice versa.

“While the over 100 pages of finalized CSC Standards create the impression of a comprehensive program, a thorough review reveals an applicant-and-process-driven program with almost no specific requirements,” says Graham Flint, President of Gravel Watch Ontario. “As the child’s parable tells us, despite what learned people may claim, sometimes upon closer examination ‘the emperor truly has no clothes’. We have grave concerns over whether this program will be able to deliver on its claim to differentiate and identify socially and environmentally responsible aggregate operations. We can’t support a program that potentially inappropriately will reward a poorly performing operation with a ‘gold star’.”

Links & References:

Link to Cornerstone Standards Council website: http://www.cornerstonestandards.ca/

Gravel Watch Ontario comments on Draft Responsible Aggregate Standards, November 2014 (PDF)

Gravel Watch Media Release re Concerns over CSC standards (PDF)