Dylan & Katerina Goulding…

Dylan & Katerina Goulding and family -Formal Comment/Objection to Walker Aggregates Inc. Water-
Taking Application
ERO Number: 025-0587
Ministry Reference Number: 3171-DGHJX5
We respectfully submit this formal comment/objection to Walker Aggregates Inc.’s Category 3 Permit
to Take Water application for aggregate washing at the Redford Pit. We urge the Ministry to deny the
application due to its potential for significant and irreversible environmental harm, lack of
transparency, and inadequate technical justification.
1. Lack of Transparency and Public Notification
We are alarmed by the absence of proper public consultation. Despite the high-risk nature of this
Category 3 application, no direct notification was provided to residents or landowners within the
affected area. How will the applicant ensure our well water is not affected? We only became aware of
this application by checking the ERO registry while monitoring for a separate expansion. This process
lacks the transparency and diligence that Ontarians expect from applications with potentially significant
environmental consequences.
2. Category 3 Risk – Highest Level of Environmental Concern
The Ministry classifies this application under Category 3, acknowledging the highest potential for
unacceptable environmental impact or interference. This alone warrants exceptional scrutiny.
According to Canadian Mining Magazine, wash ponds present multiple risks, including:
• Water loss due to evaporation and seepage
• Contamination from poorly settled fines and sludge
• High maintenance demands and risk of liner failure
• Disruption of operations due to unreliable water recycling
• Long-term degradation of surrounding land
These risks are not hypothetical; they are inherent to the system proposed.
3. Insufficient Technical Detail and Questionable Data Sources
The hydrogeological report submitted in support of this application is insufficient, it lacks the
necessary specificity and transparency. Key concerns include:
• No indication that wash ponds will be lined. The applicant's report provides no evidence of
proposed liners or design specs.
• No defined location of the wash ponds on the property making it impossible to evaluate
proximity to sensitive features and receptors.
• Wash ponds will be below the water table which does not meet the requirement of the current
ARA licence.
• Monitoring wells used to justify the application are located on the planned expansion lands, not
the currently licensed site.
• No water balance study has been completed.
• Statements of “no impact” are presented without evidence or explanation of methodology.
This is wholly inadequate for a Category 3 application. SPSI has submitted a Hydrogeological Report
peer reviewed by Lloyd Lemon, M.Sc., P.Geo. From Lloyd Lemon Geoscience Consulting you can
find this review here:
https://acrobat.adobe.com/id/urn:aaid:sc:US:639d7f48-c08b-4e6a-a520-684…
4. Highly Vulnerable Aquifer and Karst Geology
The pit lies entirely within a Highly Vulnerable Aquifer (HVA) and within a sensitive karstic dolostone
area. The western region of Grey County, Ontario, is known for its karst geology, characterized by
soluble bedrock like limestone and dolostone that has been shaped by the dissolution of water. This
karst terrain includes features like sinkholes, caves, and fissures, which can create challenges for
groundwater protection due to the potential for contaminants to enter the underground water supply. As
shown in the Worthington-Ruland Karst Hydrogeological Study (Walkerton, 2001), this region is
uniquely prone to rapid and unpredictable groundwater movement, including transport of contaminants.
The consequences of even minor infiltration of wash pond effluent into the aquifer could be
catastrophic for drinking water sources and surface water ecosystems.
5. Proximity to Significant Watercourses
The pit and the unlicensed expansion area where well data was collected sits between the Saugeen
River and the Styx River, within 100 metres of the Saugeen at some points. The study claims “no
impact” yet provides no modelled evidence of how the ponds or water taking will affect:
• River flows or seasonal recharge
• Sediment transport or turbidity
• Aquatic habitat and water temperatures
• Floodplain functions or wetland dynamics
This is unacceptable given the proximity to regulated hazard lands under the jurisdiction of the
Saugeen Valley Conservation Authority (SVCA).
6. Cumulative Impacts Ignored
This application cannot be reviewed in isolation. Two adjacent properties have submitted new
aggregate license applications:
• JT Excavating (ERO 019-6532)
• J.R. McLaughlin (ERO 019-7255)
All three footprints are contiguous, forming a large-scale industrial extraction zone within a sensitive
riverine ecosystem. Approval of this water-taking sets a precedent for further applications, without any
cumulative impact analysis on:
• Surface and groundwater flows
• Aquatic ecosystems
• Air and dust emissions
• Land use compatibility and economic impacts
The failure to assess cumulative impacts is a significant omission.
7. Community Trust and Historical Deception
In 2023, Walker installed monitoring in drinking water wells on nearby private properties, assuring
residents that “we will never take water.” This application directly contradicts those assurances. Using
data from these wells, obtained under that premise, undermines trust and calls into question the
integrity of the engagement process.
8. Environmental, Economic, and Public Interest
The Saugeen River is a vital resource, a drinking water source, a recreational asset, a wildlife corridor,
and a driver of the local economy. Any degradation of its flow, quality, or ecology would have
devastating and long-lasting effects on our community.
Approving this application, based on vague assertions, limited data, and a process that excluded the
public, would set a dangerous precedent and risk long-term damage for short-term private gain.
9. Lack of information on impact to adjacent private wells.
Our property has (2) private wells which provide drinking water for our family as well as our two businesses on the property and may they be impacted by the proposed operation. We have received no notice of this application or discussion from the proponent on how the proposed operation will impact our drinking water quantity and quality. Prior to any consideration of water taking, there must first be consultation with adjacent land owners as to the impact of the operations on their drinking water source(s), with onsite investigations showing the extent of the impacts on neighbouring properties.
Conclusion
This application:
• Fails to provide adequate technical evidence;
• Relies on flawed or misleading data;
• Misrepresents intentions to the community;
• Ignores cumulative impacts with two adjacent applications;
• Places critical water resources at risk, including private wells used as drinking water sources.

For these reasons, we respectfully urge the Ministry to deny this Permit to Take Water under the current application.