To Whom It May Concern, I am…

ERO number

026-0411

Comment ID

184786

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

To Whom It May Concern,

I am submitting this formal objection regarding Environmental Registry of Ontario (ERO) Notice #026-0411, relating to the proposed renewal of a Permit to Take Water (No. 1036-C85QXZ) for Galibier Materials.

After reviewing the publicly available information, I do not believe there is sufficient transparency, technical detail, or comparative data provided to support informed public consultation or to justify approval of this application in its current form.

Accordingly, I am formally opposing this application and requesting full disclosure and clarification of the outstanding information outlined below.

Permit history and water-taking authorization

* What were the exact approved water-taking limits under Permit No. 1036-C85QXZ and previous approvals prior to this?
* Is the proposed maximum of 2,937,600 litres per day (2,040 L/min) identical to, lower than, or greater than the previously approved limits?
* Have any changes been made to seasonal restrictions, operating conditions, or pumping intensity?
* Why are full historical permit conditions not included in the public posting for comparison?

Renewal justification and changes

Although this application is described as a renewal, there is no clear explanation of:

* what conditions remain unchanged from the original approval
* what conditions have been modified, previous issued approvals all seem to be 5 years and do not include category 3 risk significance!

Without this comparison, meaningful public assessment is not possible.

Term length (10-year approval request)

I request a clear explanation for why a 10-year Permit to Take Water term is being requested at this time.

Further context is relevant. Under ERO #019-4309 (Ministry reference 3402-C6HHPZPG, September 2021), prior regulatory activity occurred at this site. I request clarification on:

* how previous approvals and durations were considered in establishing the current requested term
* whether prior permits were also issued for 10 years or shorter durations (they see to be 5 years)
* what specific environmental or hydrogeological rationale supports a full 10-year renewal period now?

Hydrogeological and environmental impacts

Please provide the full hydrogeological assessment supporting this application, including:

* baseline groundwater modelling data
* impact on surrounding private wells
* effects on surface water systems and recharge areas
* implications for the Minesing Wetlands and broader Nottawasaga Valley watershed
Galibier’s hydrological report shows underground stream direction NW towards the wetlands and this water I would
Assume would be part of that after use.

It is not clear from the public posting what updated data, if any, supports continued long-term water extraction at this scale.

Cumulative impacts

There is insufficient analysis provided regarding cumulative impacts, including:

* nearby aggregate operations and other water-taking permits
* long-term groundwater stress and seasonal drought conditions- Minesing was under a water ban in 2025 due to drought conditions how has this past and future concerns been evaluated ?
* climate change impacts on recharge and aquifer resilience

A stand-alone permit assessment is not sufficient without cumulative regional analysis.

Monitoring, enforcement, and compliance
Please clarify:

* how compliance with daily and annual limits will be monitored- who specifically is in card or monitoring and enforcement and how is usage tracked by someone other than the applicant ?
* whether real-time monitoring or independent verification is required
* what enforcement mechanisms are in place for exceedances
* whether public reporting of water-taking data will be made available

Transparency and supporting documentation

It is also noted that key supporting materials are not readily accessible through the public registry posting.

For proper public review, I respectfully request that the following be made fully available:

* hydrogeological and technical reports
* historical permit documentation (Permit No. 1036-C85QXZ) and all other previous issued approvals
* compliance and inspection history
* cumulative impact assessments
* any peer review or third-party evaluations that have been conducted or are pending

Conclusion

Due to the lack of clear comparative data, insufficient transparency regarding historical authorization conditions, and the absence of fully accessible technical justification, I am formally opposing this application in its current form.

I respectfully request that this application not proceed until:

* full disclosure of supporting documentation is provided
* historical and proposed permit conditions are clearly compared
* and cumulative environmental impacts are fully assessed and made publicly available

Regards,