The proposed Erin Wastewater Treatment Plant (Project) would release over 7 million liters of sewage effluent daily into the West Credit River, which is a relatively tiny receiver stream. This large volume of sewage effluent would be released downstream at the Wellington County Line into one of the last remaining native Brook Trout Populations in southern Ontario. This self-sustaining Brook Trout population is thriving because of the West Credit River’s unique and pristine coldwater habitat.
To confirm our position that the habitat within the culvert is not degraded and supports Brook Trout throughout the year, we draw your attention to a video by Steven Noakes, a local videographer, entitled, Brook Trout fry at proposed outfall location Erin WWTP, taken on the 30th of April 2021 in and around the culvert at the proposed effluent discharge site. The video confirms that Brook Trout fry are abundant in and around the culvert and demonstrates that the culvert habitat is not degraded, removing any question that it supports Brook Trout. In addition, Brook Trout spawning activity occurs a short distance above and below the culvert, where redds are abundant within 75 to 100m of it. There is no question that this area supports Brook Trout in various life stages.
The purpose of Aaron Detlor’s communication was to “advise that the Haudenosaunee hold treaty rights over the area contemplated by this Project, and that the Project will interfere with those rights and interests… At the same time we are hereby asking Minister Wilkinson and the Crown generally to withhold any pending approvals subject to the commencement of a good faith process to uphold the honour of the Crown”.
No new hydroelectric projects should be included in the short or long-term energy plan. Hydroelectric power generation is dirty energy resulting in significant ongoing negative impacts to riverine ecosystems, including, but not limited to GHG emissions (methane and Co2), degraded water quality, declining fish populations, methyl mercury contamination of fish, and ongoing harm to Indigenous communities.
Protected areas are a proven means of conserving biological diversity and mitigating the impacts of climate change, two of the greatest challenges we face as a society. They also enjoy broad public support. For example, a 2018 national survey conducted by IPSOS found that 93 percent of Canadians believe that protected areas are necessary. Similarly, a 2019 national survey conducted by Abacus Data found that 88 percent of Ontarians support protecting or conserving more natural spaces and 91 percent supported Canada’s 2020 protected areas commitment. There is no doubt where the public interest lies on this issue.
Jack Imhof, an Aquatic Ecologist/Watershed Scientist, says “It is essential an independent federal assessment of the Erin Wastewater Treatment Plant be conducted in order to ensure the health of downstream communities and survival of the last healthy Brook Trout and Redside dace populations left in the Credit River watershed. This is NOT a “Fish or People” issue.” Jack Imhof has been involved in the study, assessment and management of the West Credit River since 1979, as well as the data collection and writing of the West Credit Subwatershed Study.
The Coalition for the West Credit River, of which the Belfountain Community Organization is a member, wish to inform Mayor Alan Alls and Council (the “Town”) that the questions asked in our 18 February 2021 correspondence were either not addressed at all or not satisfactorily addressed in the final Environmental Study Report (ESR) for the proposed Erin Wastewater Treatment Plant (Erin WWTP).
The Coalition reached out in good faith to the Mayor, in the hopes that he would answer our questions, and perhaps resolve some of our concerns and make it unnecessary to take this matter to the federal level for a review under the IAA. However, it has become crystal clear that the Mayor was not acting in good faith when we were informed by the Town’s lawyer, Quinto Annibale, in his 10 March 2021 email to me, that “all of the questions and issues which were raised and answered during the Part 2 Order request made to the Minister of the Environment Conservation and Parks pursuant to the Environmental Assessment Act. As you know the Minister considered each of these issues and refused to grant the Order. Since you participated in the Part 2 order request, my client sees very little useful purpose in answering the same questions again and therefore will not be responding to the detailed questions contained in your February 18, 2021 correspondence”.
ERIN: Mayor Alls of Erin boasted, “I can reach in my pocket and pay for it” when the Town of Erin announced the purchase of 5 Hectares of land for $2 – land with an estimated value of $210,000 in the Environmental Study Report (ESR).
Environmental lawyer David Donnelly spoke to the more than 300 people attending the March 25th virtual meeting to discuss the impact of the proposed Erin Wastewater Treatment Plant on dumping 7.2 million liters of sewage effluent daily into West Credit River Brook Trout habitat.
We, the 120 undersigned organizations, strongly oppose Schedule 3 of Bill 257, Supporting Broadband and Infrastructure Expansion Act, 2021, which proposes to amend the Planning Act so that both existing and future Minister’s Zoning Orders (MZOs) would no longer have to be consistent with the Provincial Policy Statement (PPS). We request that you remove this schedule from Bill 257.
The PPS sets the policy foundation for comprehensive, integrated, long-term land use planning in Ontario. It “provides for appropriate development while protecting resources of provincial interest, public health and safety, and the quality of the natural and built environment” (PPS Preamble). Regularly revised and updated though extensive public consultations with experts, stakeholders and Indigenous rights-holders, the PPS is meant to provide balanced, relevant and widely supported policy direction on planning matters. The Planning Act requirement (section 3) that all decisions affecting planning matters “shall be consistent with” the PPS ensures certainty, fairness, consistency and substantive merit in planning decisions across the province. A development that can only be authorized by exempting it from the PPS is a development that ought not to be authorized at all.
The Ontario Rivers Alliance (ORA) strongly disagrees with your response to our numerous concerns and recommendations when you assert that you “have concluded that temperature effects have been adequately assessed using field data, a nearby wastewater treatment plant’s effluent temperature data, and CORMIX – a state-of-the-art mixing model”. Your response totally ignored a key issue we raised that will impact on every aspect of stream health and Brook Trout survival, both over the short term and into the future.