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Category Archives: Regulatory Submissions

EBR Application for Investigation of Town of Erin – Proposed Erin Wastewater Treatment Plant – Joint

West Credit River Brook Trout. Photo by Steve Noakes.

The Belfountain Community and Planning Organization and Linda Heron are filing an Application for Investigation of the Corporation of the Town of Erin, under Part V, of the Environmental Bill of Rights, 1993. We are very concerned that the Town is moving forward to the construction phase of the Project when it has not yet fulfilled key commitments it made in its Town of Erin Urban Centre Wastewater Servicing Class Environmental Study Report.  The Ministry will investigate whether the Town contravened or violated Section 38 of the Environmental Assessment Act. 

Please click on this Google Drive link to view or download the Application for Investigation and Appendix A.  Continue reading


Comments on the draft of Canada’s Great Lakes Strategy for PFOS, PFOA and LC-PFCAs Risk Management (April 26, 2021) – Joint

The draft Strategy should include stricter fish consumption advisory that will protect the health of people in the Great Lakes basin to reflect stringent levels of PFOS concentration in fish adopted by the Great Lakes Consortium for Fish Consumption Advisories Best Practice for PFOS Guidelines.

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Proposed Erin Wastewater Treatment Plant – Follow-up Commitments to the Environmental Study Report

The Coalition has carefully reviewed the ESR to see what habitat related to endangered or threatened species, Schedule 1 SARA species, migratory birds or rare and uncommon plants may have been impacted by significant damage that was done on the Solmar property in late December 2020 and into the first quarter of 2021. In particular, the damage related to the premature removal of brush and trees in and around the Project site, as well as significant damage to a first order tributary to the West Credit River in a Provincially Significant Wetland and Greenlands Natural Heritage designated area (Addendum 2). The Coalition has ascertained that there were no permits or authorizations for any of this work to take place. It is very difficult to do additional bird and tree studies when a great number of the trees and habitat were removed and burned.

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ERO-019-3007 – Reviewing Ontario’s long-term energy planning framework

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.

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Request to remove Schedule 3 from Bill 257 – Joint

Update:  Ontario Government Passes Bill 257: Planning Act Amendments That Unleash Sprawl MZOs from Basic Planning Rules, Ontario Nature, 13 April 2021

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.

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Request to appear before the Standing Committee on Environment & Sustainable Development – Joint

West Credit River, Photo by Steve Noakes

The Coalition for the West Credit River is writing to you today to share our urgent concerns about an impending and grave threat to the ongoing health of the West Credit River and the sensitive coldwater environment and ecosystem that it sustains. The West Credit River flows through the Towns of Erin and Belfountain, a premium get-away for fly fishers and GTA urban dwellers seeking near-wilderness respite just a short drive northwest of Toronto. 

The West Credit River is acknowledged as one of the last remaining wild and self-sustaining native Brook Trout fisheries in southern Ontario and is recognized for its environmentally significant ecosystem as part of a UNESCO World Biosphere protected area, well before it exits at the Forks of the Credit River. 

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Erin WWTP: Designation Request for a federal review under the Impact Assessment Act

West Credit River, by Steve Noakes.

The West Credit River subwatershed supports headwater tributaries of the Credit River and is considered the crown jewel of coldwater Brook Trout fisheries in southern Ontario. The entire footprint of the Project, including the network of underground sewers, will result in numerous crossings of first, second and third order streams. Additionally, the West Credit River feeds into the main Credit River at the Forks of the Credit Provincial Park. This area is part of the UNESCO Niagara Escarpment World Biosphere Reserve (Reserve), home to several sensitive fish species, including the endangered Redside Dace and Atlantic Salmon. Atlantic Salmon, historically extirpated, are being reintroduced as part of the broader Lake Ontario Atlantic Salmon Recovery Program. This Reserve is within 1 km downstream of the Project’s effluent discharge, and Redside Dace (Schedule 1, Species at Risk Act, 2002), are known to occupy the West Credit River within 4 km downstream of the effluent diffuser.

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Bradford Bypass – Request for designation under s.9 of the Impact Assessment Act – Support

A highly controversial environmental assessment study under the Ontario Environmental Assessment Act was completed 23 years ago. It concluded that the project would cause adverse effects to fish habitat including severe stormwater and groundwater impacts. The environmental assessment did not evaluate the impacts on species at risk, migratory birds or climate change. This study has not been updated. 

The provincial regulatory process is grossly inadequate.

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Proposal to increase set fines for recreational and commercial fishery offences

The ORA favours conservation of Ontario’s natural resources, and most especially as it relates to fish and their habitat. ORA agrees that the Ministry should apply existing federal government guidance for fines and increase the use of contravention tickets for more types of offences. It makes sense to issue tickets rather than using the federal court process.

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Reject Schedules 6 and 8 of Bill 229 to Protect Conservation Authorities and Species at Risk

Bill 229 is just the most recent in a long list of omnibus bills containing devastating amendments, exemptions and streamlining of key environmental policy and legislation designed to protect our environment and communities and provide the public and stakeholders with meaningful input.  These government actions have created a deep erosion of public trust and confidence.  It is unacceptable that it would mislead its citizens and bypass the norms by taking advantage of a world-wide health emergency to aggressively push their destructive agenda through.

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