In consideration of the ecosystem benefits of a healthy West Credit River and its sensitive Brook Trout and Redside Dace population, we are recommending that inground infiltration of the final wastewater effluent be seriously considered, as a viable alternative to discharging warm sewage effluent directly into the West Credit River. Discharge of treated effluent by way of passive infiltration into the ground with slow percolation into this relatively small stream is the best way to ensure that the final effluent reaches the stream as natural and cold groundwater.
Judy Mabee, Chair of the Coalition and President of the Belfountain Community Organization stated that, “The Coalition is not deterred by the Minister’s Decision. We will continue on with our work to protect this highly valued coldwater Brook Trout population in the West Credit River. We are more than willing to work with the Department of Fisheries and Oceans and other federal and provincial regulators, including the Town of Erin and its consultants, to advocate for a wastewater plant that sets a new best in class industry standard for the protection of sensitive coldwater receiving streams.”
After careful consideration of the information provided by the Town of Erin, federal authorities, provincial ministries, the local conservation authority, the concerns expressed in your letter, other known public concerns, and advice from the Impact Assessment Agency of Canada (the Agency), I decided that the Project does not warrant designation pursuant to Subsection 9(1) of the IAA.
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.
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.
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.
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.
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.
The Coalition for the West Credit River is following up on our previous correspondence dated 18 February 2021 as we have not yet received a response to our questions that were laid out as a precursor to a meeting with Council. Please let us know when we can expect answers to our questions so we can move forward with scheduling a meeting.
Also, on 25 February 2021, the Coalition filed a Designation Request with The Honourable Jonathan Wilkinson, Minister of Environment and Climate Change, under Subsection 9(1) of the Impact Assessment Act. We have since received acknowledgement that the Impact Assessment Agency of Canada has commenced the review of our request, and that “If designated, to proceed with the Project, the Town of Erin would be required to submit an Initial Project Description, thereby commencing the planning phase of the IAA. In that case, the planning phase would include the Agency determining whether a federal impact assessment is required.”
Our concerns are well documented in the attached Briefing Notes report, which has been prepared by our Coalition in the process of requesting a federal review under the Impact Assessment Act.