Gravel Watch Ontario supports the “recycling of aggregates”, but maintains that “recycling” is in fact the reprocessing of aggregate-laden industrial waste*, and should only be undertaken with appropriate precautions and in appropriate industrial sites.

* See our “definition” of recycling in the Anti-Glossary.

Pro-“Recycling” Facts:

Recycled materials currently account for approximately 7% of all aggregates consumed in Ontario (SAROS 2012 Consolidated Report). In many European countries, this number stands at 20% or greater. If Ontario were to increase its use of recycled materials to match these European rates, we could save approximately 22 million tonnes of virgin aggregates per year – enough to fill a line of fully-loaded dump trucks bumper-to-bumper from Queen’s Park to Vancouver and halfway back! – along with reducing the number and volume of aggregate operations and their associated negative impacts.

“Recycling” Cautions:

PPS 2014 clause “Mineral aggregate resource conservation shall be undertaken, including through the use of accessory aggregate recycling facilities within operations, wherever feasible.” Encouraging the siting of “aggregate recycling facilities” in licensed aggregate properties is in most cases not appropriate and should not be considered “feasible”.

Clause has the potential to render what is considered an interim land use into a permanent or greatly extended one; as without restrictions producers could open recycling facilities and operate them indefinitely, effectively nullifying rehabilitation requirements.

Many pits and quarries are located in close proximity to settlements and sensitive ecological and environmental features. Any adverse impacts from the crushing and processing of construction and demolition materials, including the release of components dangerous to human and animal health, can have damaging consequences. Allowing these industrial processes to occur in licensed aggregate properties, where they are not covered under the Aggregate Resources Act also has the potential to shield them from proper oversight by the Ministry of the Environment and Climate Change.

Gravel Watch Ontario strongly advocates that appropriate regulatory and oversight mechanisms be in place to manage waste reprocessing; and that reprocessing should be undertaken only on sites that can, on their own merits, be zoned as Class III Industrial lands.

The close-to-market contradiction:

Provincial legislation and the aggregate industry promote a close-to-market mantra, citing the cost, damage to infrastructure and environmental impacts of transporting aggregates to market from more distant sources. Reprocessing of aggregate-laden industrial waste tends to contradict this mantra. Most aggregate-laden waste tends to be sourced in urban / industrial areas, transported significant distances to rural aggregate extraction sites, reprocessed, and finally transported significant distances back to urban / industrial sites where they are used. It would seem the argument for reprocessing in extraction sites is largely for the convenience and economic advantage of the aggregate operators.


Increased reprocessing of aggregate-laden industrial waste could significantly reduce Ontario’s consumption of virgin aggregate; resulting in fewer extractions sites, reduced negative impacts from these sites, and conservation of our aggregate reserves. However, such reprocessing must be undertaken in appropriate sites, and under tight controls, monitoring and enforcement.

Links / References:

GWO media release regarding recycling provisions in 2014 PPS

SAROS 2010 Consolidated Report, discussion of recycling pp. 11, 12

Industrial Land Use Classifications