I am writing to submit…

I am writing to submit questions and comments regarding the proposed renewal of Permit to Take Water No. 2768-A48JN9 for GolfNorth Properties Inc. in Thedford, Ontario.

In January 2026, the United Nations University Institute for Water, Environment and Health formally declared that the world has entered an era of “Global Water Bankruptcy”. This report concluded that long-term water use in many regions has exceeded renewable inflows and safe depletion limits, and that the resulting damage to rivers, lakes, aquifers, wetlands, and glaciers is effectively irreversible. The report explicitly called on governments to transition from crisis management to “bankruptcy management”, meaning transparent water accounting, enforceable limits, and protection of remaining natural water capital.

Given this context, I respectfully ask the Ministry to address the following questions before granting this renewal:

On cumulative water demand and competing pressures: GolfNorth Properties Inc. operates multiple golf courses across Ontario and holds several permits to take water simultaneously (including ERO 026-0275 in Thamesford).

What is the total cumulative volume of water that GolfNorth is permitted to withdraw across all of its Ontario operations?
Has the Ministry assessed the aggregate impact of these combined takings on regional water systems, particularly in the context of what the UN has described as irreversible losses to natural water capital?

At the same time, Ontario is aggressively pursuing AI data centre development, with nearly one hundred data centres already clustered around the northern shores of Lake Ontario and Microsoft alone cleared to consume vast quantities of municipal drinking water at multiple Ontario facilities.

How does the Ministry reconcile issuing 10-year water permits for recreational purposes when this new and rapidly expanding industrial demand for water has not yet been fully accounted for in provincial water budgets?

On the adequacy of the Category 1 classification: This permit is classified as Category 1, which assumes a lower risk of unacceptable environmental impact. However, this classification appears to have been made without reference to the broader hydrological context, including the UN’s finding that approximately 75% of the global population now lives in water-insecure or critically water-insecure countries, and that more than half the world’s large lakes have declined since the early 1990s.

What specific local hydrological assessments were conducted to support this Category 1 designation?
Were groundwater levels, local aquifer health, and downstream ecosystem needs evaluated?
Was any consideration given to the cumulative effects of climate change on water availability in the Lambton Shores area over the proposed 10-year permit duration?

On the appropriateness of the 10-year term: A 10-year permit extends through 2036. In that timeframe, Ontario’s water landscape is expected to change dramatically due to growing data centre demand, population growth, agricultural needs, and climate variability.

Should the Ministry not consider shorter permit durations, perhaps 3 to 5 years, with mandatory review periods that require updated hydrological assessments? This would align with the UN report’s recommendation for adaptive governance that matches hydrological reality rather than past norms.

On transparency and public participation: The notice provides only basic volumetric data and no supporting technical documents online.

What hydrogeological studies, environmental impact assessments, or water balance analyses were prepared to support this application?
Can these be made available to the public before the comment period closes?

Thank you for considering these comments. I urge the Ministry to approach all water-taking permits with the seriousness that our current hydrological reality demands