Summary: Before this PTTW…

Summary: Before this PTTW proposal can be definitively evaluated, a comprehensive assessment of cumulative effects first needs to be done for the entire area. Such an assessment logically would be preceded by a rigorous assessment of the hydrostratigraphy, including surface-borne geophysical methods to provide insight beyond the usual methods of borehole-log correlations and hydraulic response observations.

Furthermore, the requested daily volume of 9,720 cubic metres (9,720,000 litres), for 230 days each year, simply strains the bounds of reasonable credibility (irrespective of the calculations presented in the Harden report of January 14, 2026), especially when onsite water-recycling can be easily be done with settling ponds and other technologies (as are widely practiced in European countries, and as the OSSGA lobby group itself also points to). The problem of unrealistically large aggregate water takings is endemic to aggregate PTTWs across Ontario.

Concerns

1. Lack of understanding of cumulative effects, including both the proposed Esbaugh PTTW as well as the implications stemming from the existing Region of Waterloo municipal wells PTTW.

It is important to remember that the proposed Esbaugh PTTW is not the first major water taking in the area. Most notably, the Region of Waterloo (ROW) has long been allowed to take 157.8 Litres per second (9,468 litres per minute, so 13.6 million litres per day) from its Wilmot Centre wellfield (municipal wells K50, K51, K52). These Regional wells (K50, K51, K52) are located 1700 metres from the Esbaugh Pit, and draw from the deep sandy aquifer system.

However, the Esbaugh PTTW, which is asking for 9.7 million litres per day, will definitely conflict with the Regional water wells, given that the Esbaugh water-taking will be from the same deep aquifer system as the Regional wells. The Region’s own hydrogeologists have clearly noted this conflict in public meetings at Regional Council.

What is needed here is a holistic assessment of cumulative impacts across the entire area (ideally all of the Waterloo Moraine). In any case, for a growing region that is facing a water shortage, the municipal takings need to be given precedence over aggregate takings, simply for reasons of the public good. (That being said, municipal takings should not be allowed to take precedence over local ecological integrity and local domestic residential wells.)

Concomitant with this problem is another issue: local provincially significant wetlands (PSWs) and shallow, private residential wells have been drying up (over a trend that has accelerated in the past six years), ostensibly due to the aforementioned municipal water takings. See, for example, Drying wells and dying wetlands , and Councillor wants halt on new water-taking permits in Waterloo Region , as well as Water-taking permits for gravel pits filed in midst of Waterloo Region’s water crisis .

In other words, the drying-out of local residential wells and the dessicated wetlands are not a coincidence. Both are logically tied to the high-volume Regional wells nearby. And, everything will be worsened by the proposed PTTW of the Esbaugh Pit.

2. Insufficient long-term monitoring and insufficient insight into detailed hydrostratigraphy.

The need for more rigorous long-term monitoring (with the implied need for more fulsome hydrostratigraphic understanding) was noted in the Burnside Report. For example, Section 5.1 refers to windowing in an aquitard layer. Given the presence of this mentioned window, and given the highly complex geomorphological nature of the quaternary (glaciofluvial) geomorphology of the Waterloo Moraine, additional windowing or thin areas in aquitards are to be expected. In simplest terms, this means that aquitard layers might not be as continuous as the neatly drawn stratigraphic correlations (as cited in hydrogeologic reports) between borehole logs imply. (I will return to this topic subsequently.)

Before this PTTW application can be properly evaluated, independent hydrogeologic monitoring (for example, by MOECP or by a third-party hydrogeologist hired by either the MOECP or the Region of Waterloo) should first be done for a minimum of two years. Monitoring should be done via dataloggers (pressure transducers) that record the water levels in each monitoring well every four hours, and that are read at minimum on a weekly basis in the warm-weather months (May, June, July, August, September), and quarterly otherwise. Datasets should also be compared to all prior datasets, extending back to when the Region first began monitoring the wells in this area. Also included should be piezometers (installed in stilling wells) in the Shingletown wetlands.

3. Need for metering of all actual PTTW water takings.

If this PTTW is granted, then metering of all PTTW-requiring water takings (including the existing well on the Esbaugh property itself) should be mandatory. This should include regular unannounced visits to verify the meter readings and that the meter remains functional. Without metering, there is no way of knowing the actual water takings, and this holds true for all PTTW sites. And, without field measurements of water takings, meaningful water-balance calculations are impossible.

4. Serious Credibility Concerns with Aggregate Industry and also MOECP’s PTTW Program

Additionally, the aggregate industry and the MOECP need to bear a joint responsibility for the PTTW-credibility issue in the aggregate context. This was most dramatically illustrated by a recent Region of Waterloo Council Meeting wherein an executive from the Ontario Sand, Stone, and Aggregate Association (OSSGA) lobby group was quoted as saying “What is unfortunate is the wording on the permits—they leave the impression there is a large volume of water being taken out of the watershed every day. The water is not leaving the site, and it is the exact same water that is moving back and forth from the pond to the wash plant, over and over again.”

Although onsite recycling of aggregate-wash water via settling ponds is not a new idea, the reassuring-sounding OSSGA statements on recycling run directly counter to the detailed calculations supporting the very large water takings (as cited in the Harden January 2026 report supporting the Esbaugh PTTW application ). In simplest terms, if 9.7 million litres per day is not really 9.7 million litres of water per day, then this begs the question of why Esbaugh has requested 9.7 million litres per day.

Another question that really needs to be asked is simply: how many other PTTW permits has the MOECP issued over the years that have been deliberately oversized? Also, could the oversizing (over “overrequesting”) of PTTWs have been done in order to block potential competitors?

5. Need for more sophisticated field investigations, using modern geophysical methods, in order to further investigate the local hydrostratigraphy in detail

The hydrogeology of the Waterloo Moraine is complex, and has been studied over many years. At the same time, I note that all of the past hydrogeologic studies germane to the Shingletown area are based on hydrostratigraphic interpolations between existing boreholes. The interpolations are based on the assumption of continuity between the borehole drilling logs.

Because these interpolations are affected by geologic uncertainty, and because the strata can vary significantly over short distances , different aquifer layers can potentially be interacting in complex ways. Such studies should be done by third-party hydrogeologists and geomorphologists who are familiar with the Waterloo Moraine’s hydrostratigraphic complexities, including directional variations (anisotropy) and locational variations (heterogeneity) that are known to interact in complex ways. Geological uncertainty appears to be a major factor at play here, and the only way to gain meaningful insight is via rigorous, in-depth field studies. Again, these need to be done before a PTTW for the Esbaugh Pit is contemplated.

For example, seismic geophysical methods (such as Vibroseis), as were employed experimentally by the Ontario Geological Survey on Wilmot Line in Waterloo in 2001, yielded valuable insight into the local-scale hydrogeologic complexities that had been missed at the scale of the Waterloo Moraine Model. Such geophysical methods are one example (but not the only example) of the type of insight that would be enormously helpful at the Wilmot Centre and Shingletown areas. In any case, geophysical methods such as Vibroseis would be highly insightful if used in the Shingletown area.

The old argument that “the private residential wells are drawing from a shallower aquifer than the deep municipal wells” is not being disputed here. However, the simple “shallow-versus-deep-aquifer” classification rests on the hydrostratigraphic interpolations and pumping-test response observations that have been done as part of the previous groundwater modelling work that the Region and its consultants have done in the past.

What is needed here is a more rigorous form of investigative work, in order to reduce the geologic uncertainty in the modelling. This would require more actual fieldwork, not simply depending on stratigraphic interpolations between existing boreholes, and not merely correlating the responses observed at the existing monitoring wells (at their depths and locations) with respect to the various pumping rates from the municipal wells at their various depths.

Ultimately, and in the longer term, the traditional-style groundwater models that have been done to date should be expanded into groundwater-surface-water-interaction models. The numerical complexity (and also cost) of this kind of work is hereby acknowledged, given that groundwater and surface water conceptually work on different time scales. However, the state of these modelling tools has advanced tremendously over the years, given the growth of computational power, accompanied also by the advent of improved numerical methods, faster calibration routines (if detailed field datasets are obtained beforehand), and sophisticated mathematical solvers capable of converging to solutions more efficiently than ever before.

The Region’s own datasets and numerical modelling also point to a need for further investigation into the geomorphology of the aquifers (hence the hydrostratigraphy). See, for example, Region Staff Report EES-WAS-26-001, which notes that the observed decline in water levels in private wells and the simultaneous drying-out of the Shingletown wetland (both of which were not predicted by the modelling) point to deep-seated problems with the modelling. Clearly, the Region’s predictive numerical modeling requires better hydrostratigraphic information.

It is important to remember that fundamental physical principles that govern the interactions between groundwater and surface water do not obey political or jurisdictional boundaries. Once again, the cumulative impacts are of key importance. For example, given that an aggregate operator (the Esbaugh Pit) has applied for a PTTW, it is clear that cumulative effects will need to be ascertained in a coordinated fashion. The cumulative complexity of groundwater-surface-water interactions inherently calls for both agencies (i.e. the Region and the MOECP) to work together on such topics, even if no formal working arrangement has yet been made.