I am writing regarding the…

I am writing regarding the proposed renewal of Permit to Take Water No. 6253-A9ER9L for GolfNorth Properties Inc. in Thamesford, Ontario. My comments on ERO 026-0276 (the companion GolfNorth permit in Thedford) also apply here, and I incorporate them by reference. I wish to raise several additional concerns specific to this permit.

On groundwater withdrawal from the drilled well: Unlike the Thedford permit, this application includes water taking from a drilled well, a direct extraction from groundwater. The January 2026 UN Global Water Bankruptcy report specifically identified groundwater depletion as one of the primary drivers of water insolvency, noting that aquifers represent long-term “savings accounts” that, once depleted or compacted, cannot be realistically restored. At the same time, a recent investigation by CBC News found that at least two Microsoft data centres in Ontario have been authorized to consume vast quantities of municipal drinking water, with a growing number of AI facilities planned across the province. Municipal water systems ultimately draw from the same aquifers and surface water bodies.

Has the Ministry assessed whether the aquifer supplying this well can sustain both the proposed 10-year withdrawal for golf course irrigation and the escalating demands of data centre cooling, municipal growth, and agricultural use in the area?

On the lack of monitoring and reporting requirements: The permit details do not mention any requirements for ongoing monitoring of water levels, aquifer recharge rates, or ecological indicators in the surrounding area.

Given that the UN report urges “transparent water accounting” as a cornerstone of responsible water management, what monitoring conditions will be attached to this permit?
Will GolfNorth be required to report actual volumes withdrawn, and will that data be made publicly accessible?

On the Category 1 designation for groundwater taking: It is concerning that a permit involving direct groundwater extraction is classified as Category 1 (lowest risk). The UN report emphasizes that many aquifer systems globally are already in a state of persistent over-withdrawal.

What criteria were used to determine that this groundwater taking carries a lower risk of unacceptable environmental impact?
Were long-term aquifer sustainability projections considered alongside the growing pressures from other water users, including data centres?

On the principle of “highest and best use”: The UN report calls on governments to make difficult choices about how remaining water capital is allocated. Golf course irrigation, while economically significant to the operator, represents a recreational and commercial use of water.

In a context where AI data centres are consuming millions of litres of potable water daily, where agricultural water needs are intensifying, and where the global freshwater supply is in structural decline, should the Ministry not be applying a “highest and best use” framework when evaluating permit renewals?
How does the Ministry prioritize between recreational, industrial, agricultural, and municipal water needs?

Thank you for your attention to these concerns.