Cornerstone Standards
Background:
The Cornerstone Standards Council grew out of discussions in the early 2000s 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 in 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) which proposed voluntary standards to exceed Ministry regulations.
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 was not leading towards standards which would adequately address community concerns.
Discussion:
Gravel Watch Ontario was concerned that Cornerstone Standard Council’s Responsible Aggregate Standard, released on January 12th, 2015, claimed to be delivering outcomes that these Standards could not ensure. Gravel Watch cited several concerns with the Cornerstone Standards Council’s program, including:
The language of the Standards was vague and ambiguous, lacking quantitative criteria against which compliance could be measured. There was no way to predict if certified operations would 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 could have set their own targets without regard to broader industry norms or best practices. There was no way to judge if certified applications would perform above current regulatory requirements despite making the claim of superior standards.
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. Some environmentalists would compare this to the “pay to slay” plan in current government environmental plans. This approach creates winners and losers across the landscape. At the local level, it is incomprehensible that communities would be asked to embrace the notion that positive impacts elsewhere can compensate them for negative impacts inflicted locally.
Because very limited field testing, calibration or comparison to existing operational benchmarks or regulatory requirements was done, it was impossible to determine what impacts the Standards may have had. The plan was to certify up to a dozen operations, while at the same time evaluating if the Standards were appropriate. This raised a concern that the Standards would 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,” said Graham Flint, then 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’.”
Shortly after the withdrawal of Gravel Watch, the industry members funding the CornerStone Standards put the project on hiatus where it remains to this day. There is no current industry-wide plan to engage in certification standards on a best-management-plan basis or otherwise. 2020 regulations are in force but, for Gravel Watch, do not represent the kind of desirable improvements which in part the voluntary standards claimed to propose or those desired by communities affected by the aggregate extraction industry.