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.
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.
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 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.
Thank you again for your invitation to meet. We very much welcome the opportunity to discuss our concerns with you and your representatives. Prior to scheduling our meeting, it would be more productive if you could address the questions below in writing. Our expectation is that your answers to the questions below will provide a framework for our meeting. Details of our concerns are outlined in the updated “Briefing Notes”- attached.
The questions that follow do not represent all our questions and concerns; however, we would appreciate detailed answers to the following:
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.
Wetlands are among the most productive and diverse habitats on Earth. They provide incalculable benefits for communities, including flood mitigation, water filtration, carbon sequestration, wildlife habitat, wild foods and medicines, recreational opportunities and more. They are also of immense economic value. For example, wetlands can reduce the financial costs of floods by up to 38 percent; in the Great Lakes region the benefits provided by wetlands are worth 13 to 35 times more than the cost of protecting or restoring them; and in southern Ontario alone wetlands provide over $14 billion dollars in benefits every year.
Ontarians may have invented the Blue Box, but our current linear, make-use-dispose economy makes it impossible for recycling alone to solve our growing waste problem. Currently, less than seven per cent of Ontario’s waste is recycled through the Blue Box, and 1 the province sends over 8 million tonnes (70 per cent)2 of trash to landfills and incinerators every year.
The focus of the Strategy’s five goals should not just be on “Natural Resources”, but rather on the resilience of the province’s natural heritage landscape, using a watershed approach, in consideration of the cumulative effects of all past, present and future development on our air, land and water. Additionally, the scope of the Strategy must be broadened to encompass a review of all policies, guidelines and legislation that do not support the resiliency, conservation and protection of our streams, rivers, lakes and wetlands in this warming climate. Continue reading