Comment
Objection to Category 3 Permit to Take Water
This submission formally opposes the issuance of the requested Category 3 Permit to Take Water for the Hallman Pit.
Category 3 permits represent the highest level of potential environmental risk under Ontario’s water-taking regulatory framework and require clear demonstration that no unacceptable environmental impact or interference will occur. The available information does not meet that threshold.
The permit should therefore be denied due to:
1. The Critical Issue: Former land use as an Industrial Feedlot
2. Record of Site Condition (RSC) Misclassification
3. Nitrate Monitoring Gaps
4. Salt Loading Risk
5. Wellhead Protection and Vulnerability Mapping
6. Private Wells and Capture Zone Expansion
7. Wetland–Aquifer Connectivity
8. Regulatory Consistency Problems
9. Policy Conflict: Ontario Water Quality Objectives 3.2.2
10. The Structural Reality
Supporting documents
Submitted March 6, 2026 11:22 PM
Comment on
ESBAUGH SAND & GRAVEL LTD. - Permit to take water
ERO number
026-0124
Comment ID
183058
Commenting on behalf of
Comment status