Submitted via the…

Submitted via the Environmental Registry of Ontario

Re: ESBAUGH SAND & GRAVEL LTD. – Proposed Permit to Take Water, Hallman Pit, Wilmot Township (ERO 026-0124)

On behalf of the Grand River Environmental Network (GREN), we are writing to express our serious concerns and strong opposition to the proposed Permit to Take Water for Esbaugh Sand & Gravel Ltd. at the Hallman Pit in Wilmot Township (ERO 026-0124).

According to the Environmental Registry posting, the applicant is seeking a new Category 3 Permit to Take Water to withdraw up to 13,500 litres per minute, for up to 12 hours per day, to a maximum of 9,720,000 litres per day, on as many as 230 days per year, for a period of ten years, from a pond on the Hallman Pit property for aggregate washing and dust suppression. This represents an extraordinarily high volume of groundwater extraction from a stressed watershed and a community that already faces documented drinking water capacity constraints.

1. Unsustainable, high‑risk water‑taking in a stressed system

A daily maximum of 9.72 million litres, repeated up to 230 days per year, is not a minor or routine industrial use: it is a massive, ongoing removal of groundwater that is functionally equivalent to several Olympic‑sized swimming pools of water per day. Over a ten‑year term, the cumulative volume is staggering. Granting a long‑term, high‑volume, Category 3 permit in this context is incompatible with the precautionary principle and with the province’s stated commitments to protect source water.

Category 3 status acknowledges that this proposal has the highest potential to cause unacceptable environmental impact and/or interference with other users. That alone should trigger the most stringent scrutiny, conservative assumptions, and a clear onus on the proponent and the Ministry to demonstrate that there will be no significant impacts on groundwater levels, nearby private wells, dependent ecosystems, or municipal drinking water sources. Based on the information available through the Registry, that standard has not been met.

2. Conflict with regional water‑supply constraints and planning

Waterloo Region has already had to impose significant limitations on new development because existing infrastructure and water supplies cannot safely and sustainably meet projected demand. The Region has explicitly paused new servicing agreements in parts of the Mannheim service area because of water capacity concerns and the risks to long‑term drinking water security.

In this context, it is indefensible for the province to consider approving large new industrial water‑taking permits that will further draw down the same groundwater system residents and municipalities rely on for drinking water. Industrial water‑taking must not be prioritized over secure, long‑term drinking water supply for current and future residents.

Approving this permit would directly undermine regional water‑supply planning and send a troubling signal that the province is willing to approve new, high‑volume, discretionary industrial uses of groundwater in the very same area where local governments are being forced to curtail growth because of limited water.

3. Cumulative and long‑term impacts have not been adequately addressed

The Grand River watershed already hosts numerous aggregate operations and other industrial and commercial water‑takers. Any assessment of this application must address not only site‑specific impacts, but also cumulative impacts on:

Regional groundwater levels and recharge over the ten‑year term and beyond

Flows, temperatures, and ecological health of connected surface water systems

Wetlands, cold‑water streams, and other sensitive features

Existing and future private wells, farm operations, and municipal production wells

Best‑practice guidance for cumulative effects assessment in the Grand River watershed emphasizes the need to consider existing and approved operations together, and to evaluate additional stress against already degraded subwatersheds and stressed groundwater systems. A single‑project lens is not acceptable for a Category 3, decade‑long, multi‑million‑litre‑per‑day water taking.

If the Ministry cannot clearly demonstrate, using current data, transparent modelling, and conservative assumptions, that cumulative effects will remain within sustainable limits under a changing climate, then this permit should not be approved.

4. Climate change and drought risk are being ignored

Climate change is already altering precipitation patterns, recharge rates, and the frequency and severity of droughts in Southern Ontario. Long‑term permits that lock in very high levels of groundwater extraction for a decade must be evaluated against scenarios that include:

More frequent and prolonged low‑water conditions

Increased competition among users during droughts

Reduced resilience of aquatic and terrestrial ecosystems

Any approval that does not fully integrate climate projections and conservative low‑water scenarios into its analysis is out of step with modern water‑resource management. At minimum, the Ministry should not grant long‑term, maximum‑volume approvals in the absence of robust climate‑informed stress testing and clear adaptive management tools (including enforceable reductions in permitted takings during low‑water periods).

5. Public interest, equity, and trust

Nearby residents, including many households on private wells, will bear the risks if groundwater levels drop, wells are impacted, or ecosystems are degraded. Many of these residents have already raised concerns about the gravel pit’s operations, about enforcement, and about the potential impacts on their wells and local streams.

Water‑taking decisions affect not only the proponent and the Ministry, but also current and future residents throughout the Grand River watershed. Approving a massive Category 3 water‑taking permit at this time, in this location, would further erode public trust in the province’s willingness to safeguard shared water resources in the public interest.

6. Requests and recommendations

Given the serious risks and uncertainties outlined above, GREN respectfully asks the Ministry to:

Deny the proposed Permit to Take Water for Esbaugh Sand & Gravel Ltd. (ERO 026‑0124).

At minimum, if the permit is not outright denied, significantly reduce the allowable daily and annual volumes, shorten the permit term, and impose stringent monitoring, public reporting, and adaptive‑management conditions, including mandatory reductions or suspensions of water‑taking during low‑water conditions.

Undertake and make public a comprehensive, up‑to‑date cumulative effects and water‑budget analysis for groundwater and surface water in the Mannheim/Grand River subwatersheds before considering any additional industrial or commercial water‑taking permits.

Establish an immediate moratorium on new and expanded industrial and commercial water‑taking permits in Waterloo Region until a credible, climate‑informed plan is in place to secure the Region’s long‑term drinking water supply and protect ecologically significant features.

Meaningfully consult with affected residents, Indigenous communities, municipalities, watershed organizations, and local environmental groups on any future water‑taking policy and permitting decisions in the Grand River watershed.

7. Conclusion

The volumes requested in ERO 026‑0124 are not compatible with the current and future realities of groundwater stress, climate change, and drinking water constraints in Waterloo Region. The Ministry has a clear responsibility to safeguard source water and apply the precautionary principle. In our view, the only responsible decision is to refuse this application and to re‑orient water‑taking decisions toward long‑term watershed health and drinking water security.

Thank you for considering these comments. We would welcome the opportunity to discuss these concerns further or to participate in any broader review of water‑taking policy and practice in the Grand River watershed.