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.
If the SEV is not being taken seriously now, why would we believe it will be taken seriously when this new SEV is adopted? The MECP should respect and fulfill its SEV in all areas of its purpose, which is its promise to Ontario taxpayers. Rather than focusing so heavily on the economy the MECP must apply its SEV in the protection and conservation of the environment.
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:
Immediate action on plastics is necessary. The government’s Science Assessment on Plastic Pollution, referenced in the Regulatory Impact Assessment Statement, confirmed that plastic pollution is widespread in Canada, causing a range of adverse effects on wildlife and ecosystems. Furthermore, there is strong public support for federal action. Recent polling found that 95 per cent of Canadians are concerned about plastic pollution and 86 per cent support a federal ban on single-use plastics. Every day Canada fails to act, another 7,900 tonnes of plastic waste end up in our landfills and environment.
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.
We, the 70 undersigned organizations, are deeply concerned about both the “sharp increase” in the use of Minister’s Zoning Orders (MZOs) over the past year and the enhanced powers granted to the Minister of Municipal Affairs and Housing through amendments to the Planning Act, without public consultation, through Schedule 17 of Bill 197.
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.
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.
Overall, the material presented makes clear that the Fund mechanism will make it easier for habitat destruction to occur at the hands of industry and developers. Indeed, according to the proposal the main purpose of the Fund is to give operators a quicker and less cumbersome alternative to completing actions to provide an overall benefit for the species negatively impacted by their activities. The Fund is a part of a package of damaging amendments to the Endangered Species Act, 2007 (ESA), passed in June 2019 that, taken together, represent a gross weakening of the ability of the Act to fulfill its purpose to recover Ontario’s at-risk species. Our primary concerns with the Fund are outlined below.
The Trout Lake River has since time before memory been out travel route to and from Lac Seul and other places south. That river system is still a travel route. The river is full of wild rice fields, medicines, and other relations who thrive in the interdependence of this water system. The Trout Lake River meets with the Chukuni River and both then flow into the English River. Downstream of the English River are two communities, Grassy Narrows First Nation and Wabaseemoong First Nation. These two communities have already been devastated by the presence of methyl-mercury in the water and in their local food sources. I am sure that you are aware of their ongoing efforts to have the river cleaned up and for their people to be given proper medical care for having been poisoned by this polluted river.
You will find all the submissions made by ORA and our members here.