No Need to Show Need

The Provincial Policy Statement 2020 retains the controversial statement that the aggregate industry has “no need to show need” when applying for new aggregate licenses or expansions which had previously appeared in PPS 2014 supported by SAROS 2009, the State of Aggregate Resource Study In Ontario, contracted by the MNRF to Golder Associates, MHBC Planning, Altus Group, LVM-Jegal, and Dionne Bacchus and Associates. It estimates 2009’s and projected use in the Greater Toronto Area and the Golden Horseshoe, and thus, while representing a significant portion of the province’s consumption does not relate supply to demand beyond that area. Further, the data in the SAROS reports focused only on bedrock and stone, excluding sand and gravel. In the intervening years, there have been shifts in patterns, including in 2020 rapidly expanded teleworking instead of commuting for many in the GGHA to office spaces in urban centres.

The SAROS report and especially the summary have been questioned as to how the data bears out the conclusions. There was an accredited geologist’s report in 2009 and 2010 challenging the MNR’s aggregate reserve figures which were deemed skewed to making the case for needing the licensing and opening up of more quarries to meet unrealistic future demand during the final revision of The State of Aggregate Resource in Ontario Study (SOROS). At that time, former directors of Gravel Watch said they challenged the Ministry’s officials and their hired report authors during the meetings but found them set on their assumptions.  A report questioning both the assumptions and the conclusions was written, after careful research and study of the geology of the main quarries in the region. It indicated that more than enough quarries had been already opened to supply Ontario long into the future, somewhere above the 100-year mark. Included in those quarries were 894 with licenses for unlimited amounts which the authors estimated at a conservative 1 million tonnes. They were not alone in this critique.  (See Aggregates Strategy Ontario link below). Subsequently, more than one Gravel Watch constituent group has questioned the “no need to show need” cant and in one case suggested that given even the most limited estimations of supply, Ministry officials could be reassigned from new permits for pits or expansions to two important tasks: measuring the use from licensed pits, active and dormant, against more current and accurate predictions of need for virgin aggregate when reprocessed product and alternatives are entering the market; and, increasing inspections to help resolve issues experienced by communities around pits and quarries or along haul routes. To date, neither the MNRF nor TOARC has engaged in those repeatedly recommended projects.

“No need to show need” remains a problem for communities fighting pits and quarries. They are no allowed to use the available supply as an argument against new proposed pits and quarries. Proponents, however, do speak about “need” in their public statements and/or in LPAT, Local Planning Act Tribunals. Prioritizing this specific phrase in the PPS 2020 seems to be counter to the preamble which suggests that no one part of the Provincial Policy Statement is to be prioritized over any or all others.

Even SAROS paper #1 notes that consumption and demand are not precisely synonymous. Current consumption rates might be different at different price points as price is a factor in demand. The continuing drop in prices for aggregate likely spurs consumption which would diminish were levies, permit costs, etc. significantly higher, and conceivably could push reprocessed product and alternatives into current uses or change the quantities used as current standards in road building or other applications.