The ORA offers strong support for polluters being held accountable; however, that isn’t what’s happening here. Rather than strengthening enforcement tools that hold polluters accountable, this government is systematically and persistently dismantling, weakening or bypassing all environmental policy and legislation that was designed to protect the environment and deter those industries, corporations or individuals who would pollute and/or destroy the environment.
These ERO postings consistently mislead the public, especially in the top several paragraphs and titles, which contain misleading introductions to the proposed policy the government is proposing. In fact, you can always count on these “modernization” policy changes to be a further attack on environmental policy and legislation. It is even more despicable that these attacks have largely been carried out during the government’s declared COVID Emergency, where no public consultation is required, and what consultation that does take place is meaningless when the main objective is to cut red tape and remove any roadblocks to development and pollution, in spite of the public’s strong recommendations to protect the environment.
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.
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.
ORA supports objectives that involve clean, healthy, safe and sustainable freshwater management. Our lakes and rivers flow across many borders, including municipal, regional, provincial and country-wide borders. Therefore, it is necessary to consider a Canada Water Agency that uses an integrated watershed and basin approach in its core mission and mandate, acting as an oversight agency.
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.
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.
While the effects of large hydro projects (200 MW) have been well known and documented for over a century, small (up to 10 MW) and medium sized (10 MW to 200 MW) hydroelectric projects involve many of the same impacts per unit of power generated and, cumulatively, the environmental degradation can exceed that of large hydro projects. Small and medium sized hydro projects are situated on smaller and often more sensitive riverine ecosystems; however, like large hydro projects, will also alter the river’s flow regime and can have significant impacts on the aquatic environment, as flow is a major determinant of a river’s ecological characteristics and its aquatic biodiversity.
A recent study examined scaled hydropower impacts in the Nu River basin of southwestern China, where the researchers calculated impact per MW of capacity across 14 metrics between small and large hydropower projects (with small being below 50 MW as defined in Chinese policy). They found that small hydropower dams had greater impact per MW for 9 of the 14 metrics, including length of river channel affected and impact on habitat designated as conservation priorities.
Brook trout spawning in a coldwater stream. Film by Steve Noakes
Groups concerned about Erin’s proposed plant effect on coldwater fish, by Keegan Kozolanka
Ontario Rivers Alliance says town has ‘dismissed’ plans to protect Credit River brook trout from Erin wastewater plant, by Alexandra Heck
The Town of Erin (Erin) is in the design phase of a new sewage treatment plant, and the Ontario Rivers Alliance (ORA) is concerned that the sewage plant effluent will endanger some of the most productive and highly valued brook trout populations in the West Credit River. Continue reading
As a basic, the province must have a comprehensive approach to watershed management through flood mapping, mitigation and hazard planning and protection, including services such as wetland protection, climate change adaptation and resilience, biodiversity health and land use planning. In other words, we must be beefing up our public safety and environmental protection efforts, rather than gutting and streamlining key policy and legislation, as well as funding for our regulators.