Environmental Registry of…

Environmental Registry of Ontario
Ministry of the Environment, Conservation and Parks

Re: Serious concerns regarding water-taking from the Waterloo Moraine for the Hallman Gravel Pit ERO 026-0124

To whom it may concern,

I am writing to express my serious concerns about the proposed water-taking associated with the Hallman Gravel Pit on the Waterloo Moraine. This proposal poses unacceptable risks to drinking water security, groundwater-dependent ecosystems, and the long-term resilience of our regional water supply.

The Waterloo Moraine is a critical recharge area that supplies municipal wells and private wells for communities across the Region of Waterloo. Removing large volumes of water for aggregate washing and related industrial uses in such a highly sensitive recharge and wellhead protection area is fundamentally at odds with the precautionary approach embedded in Ontario’s source protection framework and with the stated intent of the Clean Water Act. Once groundwater quantity or quality is degraded, it is extremely difficult and costly—if not impossible—to restore.

My specific concerns include:

Risk to municipal and private drinking water

The Hallman Pit is located in a key recharge area that contributes to municipal wells which collectively supply a significant portion of the Region’s drinking water. Any interference with groundwater levels or quality could directly compromise municipal supplies and private wells in nearby communities.

If wells are impacted, residents and municipalities would bear the financial and logistical burden of mitigation, replacement, or new infrastructure, while the benefits of the proposed water-taking accrue to a single industrial operation.

Cumulative impacts and existing water stress in the Region of Waterloo

The Region is already facing documented constraints on its water system, and has had to limit or delay new development in certain service areas because safe and sustainable water capacity cannot be guaranteed under current conditions.

In this context, authorizing a new or expanded industrial water-taking on the Waterloo Moraine, for non-essential purposes like aggregate washing, is inappropriate and inconsistent with a precautionary and climate-resilient approach to water management. Cumulative effects from multiple permits and other land uses must be assessed, not considered in isolation.

Threats to groundwater quality and the loss of natural filtration

Gravel extraction removes and disturbs the natural filtration media above the aquifer. This can increase the vulnerability of the underlying groundwater to contamination from spills, fuel handling, recycled asphalt and concrete, wash ponds, and other industrial activities associated with pit operations.

Any contamination event in this location could have far-reaching consequences because of the hydraulic connection between the pit property and wells that serve a large number of residents. The contingency measures typically proposed for spills do not adequately address the long time scales and high costs associated with remediating a contaminated aquifer.

Climate change and long-term water security

Climate change is expected to alter recharge patterns and increase the frequency and severity of droughts and extreme weather. In a changing climate, it is imperative that Ontario prioritize the protection of groundwater recharge areas and avoid new, discretionary water-taking that increases vulnerability.

Approving water-taking for aggregate processing above a critical aquifer undermines local climate adaptation efforts and contradicts the goal of building long-term water resilience for current and future residents.

Public interest and equity

Groundwater is a public resource on which households, farms, and ecosystems depend. Allowing intensive industrial water-taking in a sensitive recharge area effectively privatizes a shared, finite resource for the benefit of one operator, while distributing the risks and potential costs across the wider community.

Many local residents and community organizations have clearly and consistently opposed this pit and associated water-taking because of the serious implications for water security, farmland, and the environment. Their concerns should carry significant weight in the Ministry’s decision-making.

Given these concerns, I respectfully request that the Ministry of the Environment, Conservation and Parks:

Deny the proposed water-taking associated with the Hallman Gravel Pit on the Waterloo Moraine.

Apply a precautionary approach by refusing new or expanded industrial water-taking permits in the Waterloo Moraine and other critical recharge and wellhead protection areas until robust, independent, cumulative impact assessments demonstrate that such takings will not compromise drinking water security or ecosystem health.

Strengthen transparency and public reporting on groundwater conditions, water-taking permits, and enforcement actions in the Region of Waterloo, so communities can meaningfully understand and participate in decisions that affect their water supply.

Protecting the Waterloo Moraine is essential to safeguarding safe, clean drinking water and a healthy environment for present and future generations. I urge the Ministry to put the public interest and long-term water security ahead of short-term industrial demands and to reject this water-taking proposal.

Thank you.