Gravel Watch letter highlights environmental divide on Cornerstone certification

AWARE News Network

AWARE Simcoe note: there’s disagreement among environmentalists over the Cornerstone Standards Council, which claims to be an “independent, impartial, transparent, consistent and rigorous process” to confirm whether aggregate sites meet its standards.To date, four sites, including the Miller Paving Ltd. quarry in Carden, have been certified.

Industry and environmentalists are represented on the Cornerstone board. Supporters include Environmental Defence, which is offering a workshop next week in Oro Station, and Ontario Nature, which features Cornerstone in the current issue of ON Magazine.

Gravel Watch Ontario, a coalition formed in 2003 that represents and advocates on behalf of Ontarians in matters related to aggregate resources, withdrew from the Cornerstone Standards Council in 2013 over concerns that it may claim to be delivering outcomes that its standards cannot ensure.

Gravel Watch sent the following letter this month to mayors and councils across Ontario:

Subject: Concerns regarding Cornerstone Standards Council (CSC) Responsible Aggregate Standard and Certification System

Background

Gravel Watch Ontario acts in the interests of residents and communities to protect the natural environment, health, safety and quality of life for Ontarians in matters relating to aggregate resources. We are a province-wide coalition of citizens’ groups and individuals.

Aggregate (sand, stone & gravel) production has a long history of being controversial and challenging for municipalities. Ontario requires aggregate materials to support our built communities. Unfortunately, the process of extracting aggregate resources comes with inherent social and environmental impacts.

Many stakeholders, including the aggregate industry, governments, community and environmental groups have been seeking a way to deal with this challenge. The development of a voluntary enhanced aggregate standard was proposed. The envisioned standard would outline a set of requirements that aggregate producers could adopt and then be recognized for. After several years of work, the Cornerstone Standards Council Responsible Aggregate Standard and Certification System, the CSC program, was drafted.

Members of Gravel Watch Ontario served on the Cornerstone Standards Council Board and the founding Standard Development Panel for over two years. We have substantial knowledge of the Standard as written as well as the original intent. Gravel Watch Ontario is contacting municipal leaders across Ontario to ensure they are informed regarding serious concerns with claims made by the CSC program which are not supported by the Standard requirements. Indeed, the claims made in relation to the program outcomes appear at times to grossly misrepresent what the Standard requires.

CSC Does Not “Raise the Bar”

For example, the program claims that it “recognizes and rewards both public and privately owned aggregate operations that go beyond regulatory compliance and adopt industry best practices” and that it “ensures high levels of operational practice are met and monitored”. Unfortunately, the Standard does not contain specific targets or requirements on some of the most relevant operational issues for aggregate production sites. For example, there are no operational targets set for noise, dust, vibration, ambient light, and water consumption, among other areas.

The Standard when addressing noise, dust, light and water has the following requirements:

“When addressing adverse environmental impacts … the applicant implements (consistent with the scale and intensity of the operation) an Environmental Management System or a series of Standard Operating Procedures that are consistent with or exceed existing regulatory requirement”. The Standard has no mandate to exceed regulatory requirements; being consistent is sufficient.

There is no reference in the Standard to adopting industry best practices and no reference to current industry norms. Certified sites may actually be performing below established industry benchmarks. Without explicit requirements on the most relevant social and environmental aspects of aggregate production, the program cannot be delivering on the claims made above.

Further, a review of the audit reports relating to the four program certificates granted thus far, reveals that one or two CSC auditors spend a very limited time on an aggregate site; typically, only a day or two. The reports provide no indications that the auditors have taken any independent measurements of the environmental factors that the Standard claims to assure.

The environmental audit process seems to have become a paper exercise of reviewing reports, some of which appear to have been prepared during the application and licencing process as predictors of future outcomes and commitments for future actions. The degree to which these predictions actually became reality is unknown. Without actual measurements being taken or observations beyond a brief 48-hour interval, there can be no claims made as to how these sites generally operate. The current auditing process in no way supports the claims by CSC regarding full regulatory compliance, industry best practices and the monitoring of high levels of operational practice.

CSC “Lowers the Bar”

For any certification program to be legitimate, the requirements of the program must be met before certification is awarded. A review of the audit reports relating to the certificates already granted shows that none of the four sites certified have met all the requirements of the Standard. Even when non- conformances were in areas that CSC claims as a focus (e.g., addressing adverse environmental impacts), those sites were still granted a certificate based on a requirement for future corrective action.

More concerning though were sites that had non-conformances relating to compliance with existing regulatory requirements. Of the four sites certified by CSC thus far, two were found to have non- conformances with site plan requirements. Further, one site was reported to be in non-compliance with Ontario Regulation 127 which deals with Airborne Contaminant Discharge Monitoring and Reporting. If CSC certified sites are in violation of regulatory requirements, how can the program claim that CSC “recognizes and rewards… aggregate operations that go beyond regulatory compliance”?

Summary

Gravel Watch Ontario continues to believe there is value in a robust voluntary aggregates standard which recognizes performance that goes beyond existing regulation. That is why we dedicated over two years to the development of what we had hoped would be such a standard. To deliver on that promise, though, the standard must set a high bar and enforcement must be rigorous, thorough, and absolute. The current CSC Responsible Aggregate Standard and Certification System fails to deliver on those requirements and as a result fails to justify the outcomes that are being claimed.

Gravel Watch Ontario is committed to ensuring that municipalities across Ontario, as consumers and/or producers of aggregate resources, are informed regarding the Cornerstone Standards Council aggregate program. We ask that you add your voice to calls to improve the program and make it what it was originally intended to be. In its current form, it is a disservice to all those in Ontario who are working hard to address the inherent challenges for those communities where aggregate extraction activities occur.

If you have any questions or would like to discuss our comments further, please feel free to contact us.
Sincerely,
Graham Flint
President, Gravel Watch Ontario 

Cornerstone response