This page supports a written submission by Jeff Broomfield to the Aggregates Resources Act Review. (you can find the original letter below)



Demolition and Deconstruction: Review of the Current Status of Reuse
and Recycling of Building Materials (click to open study)
A Canadian report on the reuse & recycling of the main construction components. As you can see, some countries are achieving up to 90% recycling rates. If you want to look at good examples, look to Netherlands, Belgium & Germany.

Various studies regarding the recycling of construction materials. Clicking will open a PDF.


Recycling & Secondary Aggregates

Recycling and use of recycled aggregates

Framework for recycling of wastes in Construction

Use of Recycled Aggregates in Concrete – A Paradigm Shift

Green Guide For Roads rating System




OMB ruling from 1974 regarding the gravel pit in Paris  This document shows that the industry has been talking about running out of aggregates for at least 38 years.

Water Issues

Cumulative Effects Assessment (Water Quality and Quantity) Best Practices Paper for Below-Water Sand and Gravel Extraction Operations in Priority Subwatersheds in the Grand River Watershed
North Dumfries Township Version dated Sept 2010

GRCA draft version dated May 2009

A Finnish study showing the effects that gravel extraction has on an aquifer. Finnish study effect of gravel extraction on groundwater

A study done in Alaska regarding the potential effects that gravel extraction has on an aquifer. Potential hydrologic effects of gravel extraction

This is a document created by the GRCA which predicts a future with dwindling water supplies, drought & water battles. Towards the end of the document (pg 148), you will find the letter (picture to right) from the Source Water Committee where they clearly state that they believe breaching the aquifer places our water supply at risk & that source water protection is incomplete without addressing it. You can find the response from the MOE right after it.










Local news articles that show the drought conditions are now happening. They are considering Level 3 water restrictions meaning the Grand River is close to 1/3 of it’s volume.

GRCA calls for cutback to water use
A relentlessly hot, bone-dry summer with only dribbles of rain or sudden storms with quick downpours, is leading the Grand River Conservation Authority to call for additional cutbacks in consumption across the watershed. The GRCA is also warning that unprecedented mandatory restrictions on water use could be imposed in parts of Brant and Oxford counties, if drought conditions continue.

Lack of rain puts crops in jeopardy
Farmers in the Whitemans Creek area who need to use a lot of water in their crop production are frequently turning their eyes to the sky for signs of storm clouds on the horizon. The fields are getting so bone dry that without a “million-dollar rain” in the next few days, they could be looking at dramatically lower yields this year.

Don’t swim at Pinehurst Lake
The Brant County Health Unit has declared Pinehurst Lake unsafe for swimming, following a preliminary investigation of a bacterial outbreak in the beach area.

Samples of research studies into the transport of E-coli through glacial outwash deposits. So far, I have found nothing that will confirm how much material is needed to filter it & what the role of the unsaturated zone plays in the elimination of E-coli. Most tests simulate conditions within the aquifer under lab conditions.

Transport of Escherichia-coli bacteria through laboratory columns of glacial outwash sediments

Transport of Escherichia-coli bacteria through laboratory columns of glacial outwash sediments

The letter submitted by Jeff Broomfield

In consideration of the review of the Aggregates Resources Act, I would like to submit some of the information that I have found along with some possible resolutions to the issues.
Why recycling of aggregates is not accepted
Solutions for our aggregate issues
Protection of our water & environment

The aggregate industry has been talking about the impending shortage of aggregates for over 40 years now. It was stated in the OMB hearing regarding a gravel pit on Watts Pond Rd. In Paris from 41 years ago. Since the industry has known about this for quite some time, what have they done to find alternative materials, initiate recycling programs, improve the life span of their product or work with developers to remove aggregate from construction sites prior to building?
Since the forestry industry is often cited regarding developing sustainable initiatives, I will draw on my experience in the printing industry. Since we began becoming aware of the effects of deforestation, many of us in the printing industry started taking a proactive approach to recycled paper. In the beginning, many of our customers had no idea about recycled paper and selling this to the public required us to inform our customers of the benefits of using recycled papers. Once word had gotten around about our impact on the environment, customers started to demand recycled content and our government was one of those customers who built in a requirement for recycled content in their printed product. It was the education of the customer by the printing sales reps who were dealing with them that achieved acceptance by the market. The efforts of the individual sales reps was of course backed up with education by the paper merchants and the forestry industry.
The lack of acceptance of recycled aggregates by municipalities would most likely be the lack of effort for the sales reps within the industry who have direct influence in the buying decisions. Sales reps, the ones you buy from, are usually trusted sources of information. Either the aggregate reps do not offer recycled product so it’s never an option and quite possibly when recycled aggregates comes up, unless the rep/company makes more money selling it, it would be brushed off as a bad idea. Sales people generally guide the customer to the decision that they want. It’s true in every other industry, there is no reason it doesn’t happen in the aggregate industry as well. Just ask the industry for their sales material that support recycled sales.
Why is that?
Large companies build an infrastructure around a certain product that achieves their financial goals. The cost of the infrastructure can be staggering and even the supporting infrastructure (suppliers) that support these operations would have significant investments involved. To draw a parallel to the printing industry again, Heidelberg is the largest supplier of offset printing presses in the world. They have invested billions into mining for raw materials, foundries, machining & assembly plants, inventory management & everything else associated with the production of printing presses. It is in their best interest that the industry continues to use offset printing because it supports the infrastructure that they have built. A drop in sales will usually trigger the sell-off of assets at a loss. With the move to digital production including the internet and digital printing, Heidelberg did their best to slow down & prevent the move to digital. Part of this was accomplished through their sales network who deal directly with the printers, another group with substancail investments, by convincing them that digital was just a fad & was not to be considered real printing. Today, there are many printers who still believe that offset will make a comeback as people realize digital is not real print…my brother & father are 2 examples.
Another company that has suffered through this transition is Kodak. Digital basically eliminated many of their revenue streams and being stuck in their old business model made it difficult for them to transition. The point here is that many of the older companies will do everything in their power to hang onto existing business models because that is what they do & what they know. I believe that the aggregate industry is stuck in their old ways and thinking and are doing everything they can do to maintain the status quo & continue operating as they always have. Protection of their core business is essential to their survival and with a seemingly never ending supply of material, why would they change? If the impending aggregate shortage was as bad as they claim, why have they not changed their business practices to suit? What has been done to prevent the collapse of their industry when supplies run out?

It is my observation that the current & increasing demand for virgin aggregates is only good for business. Lack of competition or arrangements between suppliers is the only way to prevent all out price war and an erosion of profits that we see in most industries today. How competitive is the aggregate industry?

Solutions for creating a demand for aggregate recycling.

Increase extraction rate

The main reason for continuing to use virgin aggregates is the price. 11.5 cents per tonne is basically getting it for free. The communities that have the aggregate subsidize the costs associated with the production and delivery and that includes product shipped out of the province and product used by private investors, home builders etc. If the extraction rate properly compensated the host communities and even allowed then to make a profit, it would drastically change the dynamic of the indusrtry. I suggest a rate around $3 per tonne.
Some of this money would go to the municipality, some would go to the province to support the MNR & the oversight of the industry and some should go into studies that protect the natural environment and assure that aggregate operations do not harm water supplies, especially considering the number of operations along the Grand River.

Charge for disposal

Considering that we are running out of aggregate, no usable material should be disposed. A dumping fee should be levied against anyone who is dumping this material & it should be dumped into locations where it is available for recycling. Maybe they could be paid a small fee for delivery to a recycling facility or, like what happened in the print industry, you may find that companies are created for the collection of the material.

Improvements to product

It seems to me that new roads do not last very long and we are constantly repaving. 28% of the tax bill for the county of Brant is road work. Of course, there is no incentive to increase the lifespan of the product and it would actually reduce sales if they were to do that. I would ask the industry what research they have done in this regard. My guess is very little.

Better land usage

In Brant County, we have many pits already. Duffering is trying to open their pit, others are expanding and several new applications are in the works.
We have recently built a new arena right beside a pit and a new business complex is in development and it is quite a bit higher than the road. A new subdivision is also on the table in this industry. Considering that the area, which is close to the Grand River, is probably a rich aggregate area, why do they not remove a portion of the aggregate before developing the property? The aggregate could be processed right on site and used for the construction. As close to market as possible should mean right on site. Of course, you would not be able to remove all of the aggregate, you would need to leave some above the water table…studies should show what the safe amount should be.
Instead, we have an all or nothing scenario where the resource is tied up under buildings or we have a piece of land that is mined out & usually not good for much.
At least in areas rich with aggregate, all development should take place in aggregate deposits that can be mined.

Regeneration of farmland

There is quite a bit of conflict between aggregate & farming usage. Some farms may benefit from having a certain amount of aggregate removed and the land improved. I’m not talking about full scale extraction but optimizing the land and removing the excess material while at the same time, improving soil conditions.
Waste management
We also have problems with waste material, garbage. What material could be sorted from our waste & utilized in road construction or as filler material?

Water issues

The County of Brant is home to 1000’s of acres of aggregates. It is also one of the world’s richest fresh water resources. Long term, our water is a much more valuable resource and it should be treated as if it was a diamond mine that hasn’t quite matured yet. The future is fresh water.
The GRCA has identified that we will be facing water shortages in the near future and predict periods of drought. We can see today that their predictions are accurate.
Dufferin wants to open their pit which is located on the wellhead protection area for Paris. Research has indicated that the research to ensure that our water will remain safe has not been done. The industry seems to have the opinion that because we cannot prove they cause negative effects that it is all right. The difficulty is that the aggregate industry would have most of the data that would prove what the actual effects are and ordinary citizens would have no access to this information. How can a citizen prove anything or even make a decision without the data? They can’t. Lack of evidence is not proof. It is just something that is not measured.
The GRCA has created a study that would assess the cumulative affects of aggregate operations and this should be manditory for all new licences. The entire Grand River watershed seems to be a target for aggregate operations and we must be careful that we do not negatively impact our water supplies. There are many examples around the world where rivers and lakes have dried up due to bad management practices including diversion of water for industrial applications. The Aral Sea in China and many examples across Canada show that we must be more careful with our water.
After the Walkerton disaster, threats such as E-coli are common knowledge however studies to show how much aggregate over top of an aquifer is needed for optimal filtration have not been done. Considering that our site is planned to be brought back to farmland, we will have manure on fields less that 1 metre from our water table and within 200 yards of our wellheads.
There are also other studies, one done in Finland, that show that there are in fact changes to the water chemistry during and after aggregate has been mined. The data exists and should be monitored and the exact changes in water should be public knowledge. As far as we citizens are concerned, there has been no proof supplied that they will not negatively affect our municipal water supply. We get a sales pitch with their opinion. No data, no facts. We do it all the time is not proof of any kind. Unless we are shown proof, we intend to fight this pit with whatever means necessary. It would be a whole lot easier to supply us with the proof.
Aggregate is not identified as a threat under the Source Water Protection
The committee that identifies threats have attempted to list aggregates as a threat however the director in charge will not allow it. Why is this? What does the director know that the experts don’t? It would seem that the aggregates takes priority and what we don’t know won’t hurt us. That is simply not true. We call for research to be completed which proves exactly what affects there are on our water supplies. If it is proven beyond doubt that it is safe, then we have a hundred years of aggregates sitting right here. If not, we consider our water essential to life and will protect it.
If you would like access to the reports and research that we have done, it is online at
If you would like more input from someone who thinks outside the box, feel free to contact me.
Thank you for your time.

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