Underlying Assumptions are Flawed

The County Plan began its section on gravel policy by stating that natural resource extraction is “an important land use in the County that satisfies local, regional, and provincial resource needs.”  In contrast, the draft MDP’s comparable section opens with the statement that the “extraction and use of natural resources in Rocky View County is an important contributor to the local economy.”  That statement is of questionable validity. 

 

The aggregate industry’s contribution to the local economy is through job creation and/or tax and levy payments to the County.  Most gravel-related jobs are filled by people who live outside of Rocky View.  In terms of County revenue, the aggregate industry pays municipal property taxes and the Community Aggregate Payment Levy (CAP levy) – neither provide significant revenue for Rocky View. 

 

The industry’s property taxes are dramatically lower than other industrial operations since its property is taxed as farmland except for the portion that is being used as an active gravel pit.  Even then, property taxes are minimal since gravel operations have few, if any, permanent structures.  The CAP levy has recently been increased from $0.25 per tonne to $0.40 per tonne.  However, even at the higher rate, the industry only pays about $1.5 million in these levies each year.

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To put these payments into context, it costs the County about $1 million to repair one kilometre of road.  Given the wear and tear the gravel industry imposes on our road network, their payments pale in comparison.

 

No Policies to Protect Residents

While the draft MDP’s introductory paragraph recognizes that resource extraction requires “careful consideration for how extraction is planned and implemented”, it does not include any policies to address the acknowledged “community concerns” or reality that "resource extraction can significantly impact adjacent land users”.  The draft MDP provides virtually no guidance for future gravel applications.

 

Specific Problematic Policies

Policy 3.3.1(c) – “Discourage residential development that may be impacted by future aggregate extraction and related industrial uses.”

• The focus of this policy is backwards.  Given the plentiful nature of aggregate, the County should be directing gravel pits to locate where they will not negatively impact current or planned residential development – not the other way around.

  • In contrast, the County Plan’s policy had stated – “Discourage residential development that may limit future aggregate extraction when proposed outside of an adopted area structure plan.”

• There is no detail on how the County will determine where these “future aggregate” locations might be.  

 

Policy 3.3.1(g) – “Consider co-locating other complimentary industrial uses adjacent to aggregate extraction sites.”

• If the MDP directed all future aggregate operations to areas outside of residential ASPs and away from other existing residential developments, there might be some logic in this policy. 

  • Without those constraints, this policy facilitates the industrialization of random areas in the County simply because a gravel operation was approved there.

 

Policy 3.3.1.(h) – “Consider successional transitions of aggregate extraction sites to other industrial and complementary uses (e.g. waste transfer or processing facilities).”

• All past County policy and current provincial regulations require reclamation of gravel pits to their original use (usually agriculture), unless there is a higher value post-reclamation use.

• This policy opens the door to create isolated pockets of industrial development with no logic for their location other than being where an earlier gravel pit had been located.

  • Since many existing gravel pits are located near residential developments, encouraging those locations to become permanent industrial sites defies understanding.