I am writing to submit…

I am writing to submit detailed comments and questions regarding the proposed amendment to Permit to Take Water No. P-300-6338405899 for R.W. Tomlinson Limited in Loyalist, Ontario. This is a Category 3 permit, the highest-risk classification under Ontario’s permitting framework, indicating that this water taking is anticipated to have the highest potential of causing unacceptable environmental impact or interference. The scale of this proposed taking demands the most rigorous scrutiny.

The proposed permit would allow R.W. Tomlinson to pump up to 3.4 million litres of water per day, every single day of the year, for ten years. That is approximately 1.24 billion litres per year, or over 12 billion litres over the life of the permit. To put this in perspective, a medium-sized AI data centre in Canada consumes roughly 1.13 million litres of water per day. This single quarry dewatering permit would authorize water extraction at roughly three times the daily rate of a data centre, yet it is being processed as a routine permit amendment with minimal public-facing documentation.

This permit is being considered at a moment of unprecedented strain on the world’s freshwater systems. In January 2026, the United Nations University formally declared that the planet has entered a state of “Global Water Bankruptcy.” The accompanying report found that 75% of the global population lives in water-insecure countries, that more than half the world’s large lakes have declined since the early 1990s, and that approximately 35% of natural wetlands have been lost since 1970. The report’s lead author, Kaveh Madani, stated plainly that for much of the world, the old “normal” for water availability is gone and cannot be recovered.

Simultaneously, Ontario is positioning itself as a hub for AI data centre development. The province’s Independent Electricity System Operator has flagged data centres as a major new source of demand through the 2030s, and nearly a hundred data centres are already clustered around Lake Ontario’s northern shores. The federal government has allocated $700 million to support data centre projects. These facilities consume enormous quantities of water for cooling and a recent CBC investigation found that Canada has almost no regulatory framework for monitoring or limiting their water use.

Questions for the Ministry
1. What is the purpose and destination of the dewatered water?

The permit states that water will be taken for “aggregate extraction dewatering”, meaning that groundwater must be continuously pumped out to keep the quarry dry enough for aggregate mining operations. Where does this extracted water go? Is it discharged into local surface waterways? If so, what are the quality standards for that discharge, and has the receiving waterbody been assessed for its capacity to absorb 3.4 million litres per day of potentially altered water (changed temperature, sediment load, chemical composition)? If the water is not returned to the local watershed, this represents a net loss to the hydrological system, which is precisely the kind of irreversible drawdown that the UN report identifies as driving water bankruptcy.

2. What are the impacts on the local groundwater table?

Continuous dewatering at 5,400 litres per minute, 24 hours a day, 365 days a year, will necessarily create a significant cone of depression around the quarry sump. This drawdown can lower water tables across a wide area, affecting residential wells, agricultural water supplies, and the baseflow of nearby streams and wetlands. What hydrogeological modelling has been done to determine the radius and depth of the cone of depression? How many residential wells, farms, and ecologically sensitive areas fall within the affected zone? The UN report warns that aquifer compaction caused by excessive pumping can be irreversible. Once the physical structure of an aquifer collapses, its storage capacity is permanently reduced even if pumping stops. Has this risk been evaluated for the Loyalist area?

3. Why is this an amendment rather than a new application?

The notice describes this as an amendment to an existing permit. What specifically is being amended? Is R.W. Tomlinson seeking to increase the rate or volume of extraction, extend the duration, or change the source? If this amendment represents an escalation of water taking beyond what was originally permitted, the public deserves a clear explanation of what has changed and why. An amendment to a Category 3 permit should face at least as much scrutiny as a new application.

4. What cumulative impact assessment has been conducted?

Loyalist is located in the County of Lennox and Addington, near the Bay of Quinte and Lake Ontario. The Great Lakes system is already under pressure from multiple directions, like agricultural runoff, municipal growth, invasive species, and now the rapid expansion of AI data centres along its northern shores. Has the Ministry conducted a cumulative impact assessment that considers this quarry dewatering alongside other permitted water takings in the region? Has the assessment accounted for projected data centre water demand in eastern Ontario over the next decade? The UN report is explicit: water governance must shift from evaluating individual permits in isolation to assessing cumulative, system-wide pressures.

5. How does this permit align with Ontario’s obligations to protect the Great Lakes?

Ontario is a signatory to the Great Lakes Water Quality Agreement and participates in various frameworks aimed at protecting the Great Lakes basin. Continuous groundwater dewatering in a region hydrologically connected to Lake Ontario has the potential to affect baseflow to tributaries that feed the lake. Has the Ministry evaluated this permit in the context of Ontario’s Great Lakes protection commitments? How does authorizing the extraction of over a billion litres of groundwater per year align with the principle of protecting remaining natural water capital?

6. What conditions and monitoring will be imposed?

Given the Category 3 classification, what specific conditions will be attached to this permit to protect the surrounding environment and community? Will R.W. Tomlinson be required to conduct continuous groundwater level monitoring in the surrounding area? Will there be trigger levels at which pumping must be reduced or halted? Will the company be required to report actual extraction volumes publicly? Will there be a requirement for periodic third-party review of the permit’s environmental impacts? Given that AI data centres in Canada currently face almost no reporting requirements for their water use, it is essential that extractive industries like aggregate mining at least be held to a transparent standard.

7. Has the Ministry considered the 10-year duration in light of accelerating water pressures?

A 10-year permit extending to approximately 2036 would lock in this massive water extraction through a period of unprecedented uncertainty about water availability. Climate change is altering precipitation patterns, reducing snowpack, and increasing evapotranspiration across Ontario. Data centre demand for water is projected to grow exponentially. The UN report calls on governments to adapt their governance frameworks to match new hydrological realities rather than assuming conditions will remain stable. Should this permit not include a mandatory mid-term review - for example, at the 5-year mark - with the power to modify or revoke the permit if conditions have materially changed?

8. What reclamation and restoration plan exists?

After aggregate extraction is complete, what plan is in place to restore the hydrological function of this site? Quarry dewatering can permanently alter local groundwater flow paths and reduce aquifer storage capacity. The UN report stresses the need to protect and restore natural water capital. What bonding or financial assurance has R.W. Tomlinson provided to guarantee that the site will be rehabilitated in a manner that restores, as much as possible, its pre-extraction hydrological function?

This is a Category 3 permit, the most consequential classification Ontario has. It authorizes the extraction of over a billion litres of groundwater per year from a single site, continuously, for a decade. It is being considered at a moment when the United Nations has formally declared global water bankruptcy, when Ontario is simultaneously inviting massive new industrial water demand from AI data centres, and when communities across Canada are beginning to grapple with the reality that their water supplies are not infinite.

I respectfully urge the Ministry to ensure that this permit receives the deepest possible scrutiny, that all supporting technical documents are made available to the public, that robust monitoring and enforcement conditions are attached, and that the permit duration includes mandatory review points. Ontario’s water governance must rise to meet the reality of our hydrological situation. We cannot continue to process permits as though the old normal still applies.

Thank you for your careful consideration of these comments.