Bill 111 amends the Greenbelt Act, 2005 to stop expansion of aggregate extraction inside Ontario’s Greenbelt by changing the legal status of the Greenbelt Plan and adding cross-references to the Aggregate Resources Act. The measure inserts statutory definitions for “pit” and “quarry,” and alters a statutory reference in section 9 so the Greenbelt Area becomes the controlling territorial term.
The change matters because it converts the Greenbelt Plan into an instrument that is deemed to bar new aggregate-permit applications and permit applications to expand existing operations inside the Greenbelt Area. For companies in the aggregates sector, builders and provincial planners, this changes where future supply can be approved and shifts regulatory decisions from project-level permitting to plan-level designations that will guide provincial permitting outcomes.
At a Glance
What It Does
The bill amends the Greenbelt Act so the Greenbelt Plan is 'deemed' to prohibit anyone from applying for an aggregate permit to open a new pit or quarry in the Greenbelt Area or to expand an existing one. It also aligns the Act’s terminology with the Aggregate Resources Act by adding definitions for “pit” and “quarry.”
Who It Affects
Aggregate operators regulated under the Aggregate Resources Act, construction and infrastructure sectors that rely on locally sourced aggregate, provincial ministries that process permits, and municipalities hosting Greenbelt lands are directly affected.
Why It Matters
By using a deeming provision at the plan level rather than creating a standalone prohibition in the aggregate statute, the bill places the Greenbelt Plan at the center of permitting outcomes, narrowing the geographic options for future aggregate approvals and potentially redirecting demand to non-Greenbelt sources.
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What This Bill Actually Does
The bill adds two simple but consequential pieces to the Greenbelt Act: first, statutory definitions that tie the terms “pit” and “quarry” to the Aggregate Resources Act; second, a new subsection that treats the Greenbelt Plan as if it expressly forbids certain aggregate-permit activity in the Greenbelt Area. Technically the bill does not create a new offence; instead it changes the legal landscape that permit authorities must apply when deciding whether to accept or grant an application.
Because the bill says the Greenbelt Plan is 'deemed to prohibit' applications to operate new pits or quarries or to expand existing ones, the practical effect is that permit applications for those activities located in the Greenbelt Area should be denied or considered contrary to the Plan. The operative language targets applications (the procedural step) rather than declaring existing lawful operations illegal; it therefore resolves future permit eligibility more than it alters the legal status of already-authorized extraction sites.The bill also modifies an earlier cross-reference in section 9(1) of the Act by replacing a reference to the Plan’s 'Protected Countryside' with 'the Greenbelt Area.' That substitution matters because it centralizes the Greenbelt Area as the statutory geographic unit for related decisions and consistency obligations.
The change streamlines language, but it also raises implementation questions about mapping, pending applications, and how provincial permit authorities will treat applications made before or after Royal Assent.Finally, the bill takes effect on the day it receives Royal Assent. There are no transitional provisions in the text that explicitly grandfather pending applications or address how existing permits will be treated; those gaps leave administrative discretion and potential legal challenges as the likely paths for resolving edge cases.
The Five Things You Need to Know
Section 1 adds definitions: ‘pit’ and ‘quarry’ now have the same meanings as under the Aggregate Resources Act, directly linking the two statutes’ terminology.
Section 6 inserts subsection 1.1 that deems the Greenbelt Plan to prohibit any person from applying for an aggregate permit to start a new pit or quarry in the Greenbelt Area or to expand an existing one.
The amendment to subsection 9(1) replaces the phrase 'Protected Countryside' with 'the Greenbelt Area,' making the Greenbelt Area the statutory territorial reference for related consistency rules.
The bill contains no new offence, penalty, or express grandfathering clause; it operates by altering plan status and comes into force upon Royal Assent.
Because the prohibition is framed as a ban on applying for permits rather than an explicit statutory repeal of existing permits, the text leaves unresolved how pending or already-issued permits will be administratively or judicially treated.
Section-by-Section Breakdown
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Definitions aligned to the Aggregate Resources Act
This section inserts statutory definitions for “pit” and “quarry” and ties their meanings to the Aggregate Resources Act. That alignment removes ambiguity about which land-extraction activities fall under the Greenbelt Act’s new measures and ensures that terms used in planning and permitting decisions are consistent across statutes. For operators and regulators, it means disputes over semantic scope are less likely to hinge on competing statutory definitions.
Deemed prohibition on permit applications
Section 6 gains subsection 1.1 that does not itself order closures or revoke licences but declares that the Greenbelt Plan is 'deemed to prohibit' applications to operate new pits or quarries or to expand existing ones in the Greenbelt Area. Legally, a deeming clause changes how the Plan must be read by decision-makers: when deciding permit applications, officials must treat the Plan as if it contains an explicit prohibition. Practically, this channels permit outcomes: applications located inside the Greenbelt Area should be rejected on plan-consistency grounds unless other statutory pathways supersede the Plan.
Territorial reference swapped to 'Greenbelt Area'
This amendment replaces the older phrase referring to 'Protected Countryside' with the broader statutory term 'the Greenbelt Area.' The swap clarifies that the Act’s consistency and protection rules operate across the Greenbelt Area as defined in the Plan, rather than a potentially narrower sub-designation. For planners and lawyers, that reduces uncertainty about which parcels fall under the new permitting limitation, but it also requires administrative guidance or mapping work to ensure permit reviewers and applicants apply the same geographic baseline.
Immediate commencement on Royal Assent
The bill takes effect the day it receives Royal Assent. There are no transitional provisions, which places emphasis on how ministries and operators handle applications that are outstanding at the moment of commencement. The immediate start date simplifies the statute but shifts complexity into administrative practice and case-by-case decisions about whether applications submitted before assent may be processed.
Short title
Establishes the short title, 'No More Pits or Quarries in the Greenbelt Act, 2023.' Short titles are procedural, but they signal legislative intent and focus — here, a clear policy priority on preventing new or expanded aggregate extraction within the Greenbelt Area.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Residents and landowners adjacent to Greenbelt lands — they gain stronger statutory backing for preventing new extraction proposals and for opposing expansions that could affect local land values, traffic, noise and water impacts.
- Environmental and conservation organizations — the bill locks in a planning-level prohibition that supports long-term conservation goals and narrows the avenues for future permitting inside the Greenbelt Area.
- Municipalities containing Greenbelt lands — municipalities gain clearer provincial policy support when resisting aggregate proposals and can plan land uses without the prospect of new nearby pits or quarries being permitted.
Who Bears the Cost
- Aggregate operators and landowners with extraction interests in the Greenbelt — they lose the ability to seek new permits or expansions within the Greenbelt Area, constraining business opportunities and the value of mineral rights on affected parcels.
- Construction, road-building and development sectors reliant on local aggregate supply — reduced local permitting options may raise procurement costs or increase haul distances if demand shifts to more distant sources.
- Provincial permitting authorities (ministries) and staff — agencies must implement the deeming provision, resolve questions about pending applications, update guidance and maps, and potentially defend decisions that follow the new plan status.
Key Issues
The Core Tension
The central dilemma is between protecting Greenbelt lands from new extraction and maintaining accessible, affordable sources of construction aggregate for infrastructure and housing: the bill favors permanent environmental protection via planning rules, but it does so without statutory mechanisms to manage aggregate supply implications or to resolve how pending and existing permits will be handled.
The bill uses a plan-level 'deeming' device rather than creating a stand-alone prohibition in the Aggregate Resources Act. That decision simplifies the statute but raises implementation questions.
First, the text does not state how to treat permit applications submitted before Royal Assent: are they grandfathered, frozen, or to be refused because of changed plan status? The absence of transitional language pushes this question into administrative discretion and, potentially, litigation.
Second, the statute deliberately targets permit applications rather than explicitly revoking existing licences. That leaves open how expansions authorized under existing permits will proceed and whether administrative approvals that were previously possible under the Aggregate Resources Act become legally vulnerable.
Third, the bill contains no explicit economic mitigation or supply-planning measures: it does not identify alternative aggregate sources, nor does it require a provincial strategy to offset supply constraints. That gap risks shifting costs to non-Greenbelt suppliers and to downstream construction projects without a coordinated resource plan.
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