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Photo by Linda HeronPhoto Credit

Erin WWTP – Environmental Compliance Approval – Joint

By Linda Heron on Wednesday, August 24th, 2022
Posted in Environmental Compliance Approval, Erin WWTP, Joint, ORA Submissions, Regulatory, Rivers at Risk, Urban Development, Waste Water Treatment Facilities, West Credit River

Photo by Steven Noakes – West Credit River Brook Trout

The Coalition for the West Credit River (Coalition) remains very concerned with the potential environmental impact of the Erin Water Resource Recovery Facility (WRRF) and, in particular, the temperature of its treated effluent harming the sensitive coldwater Brook Trout habitat of the West Credit River. 

As your Ministry is aware, the approved sewage treatment plant proposes to discharge large flows of sewage effluent into the relatively small flow of the West Credit River. The lack of significant dilution will greatly magnify the thermal impact of warm effluent on this coldwater stream. 

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Put nature at the centre of Canada’s Adaptation Strategy – Joint

By Linda Heron on Wednesday, July 13th, 2022
Posted in Climate Change, Joint, River Concerns

Photo by Steven Noakes – West Credit River

As representatives of more than 90 organizations from across Canada, we are writing to urge you to put nature at the centre of Canada’s forthcoming National Adaptation Strategy.

The impacts of climate change are already being felt across the country, and we must all work together to both reduce greenhouse gas emissions and build resilient communities and ecosystems.

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Environmental Compliance Approval Number 7877-CALRZU – Erin Water Resource Recovery Facility – Joint

By Linda Heron on Friday, June 3rd, 2022
Posted in Aquatic Life, Brook Trout, Erin WWTP, Fisheries, Joint, Regulatory, River Concerns, Rivers at Risk, Sewage, Urban Development, Waste Water Treatment Facilities, Water Quality, West Credit River

Photo by Steven Noakes

First, the Coalition for the West Credit River (Coalition) would like to express our deepest appreciation that you and your staff worked with our Technical Team over the last several months to incorporate some of our recommendations into the Environmental Compliance Approval (ECA). However, we are concerned that our key recommendations for improvements to the draft ECA, received by you on 2 May, were not reflected in the ECA approved on 3 May 2022. 

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Delegation Request – Erin Water Resource Recovery Facility – Joint

By Linda Heron on Friday, June 3rd, 2022
Posted in Aquatic Life, Brook Trout, Environmental Compliance Approval, Erin WWTP, Fisheries, Joint, Regulatory, River Concerns, Rivers at Risk, Sewage, Sewage, Urban Development, Waste Water Treatment Facilities, West Credit River

Photo by Steven Noakes

The Coalition is very appreciative of your strong support in recommending to the Honourable David Piccini, Minister of Environment, Conservation Parks (MECP) and Mayor Allan Alls, Town of Erin, that our draft Monitoring and Adaptive Management Plan be integrated into the Environmental Compliance Approval (ECA). As you are likely aware, the ECA for the Erin Water Resource Recovery Facility was approved on 3 May 2022 by Aziz Ahmed, P.Eng., MECP Manager of Municipal Water & Wastewater Permissions, appointed for the purposes of Part II.1 of the Environmental Protection Act. 

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Renomination of Radionuclides as Chemicals of Mutual Concern Under the Great Lakes Water Quality Agreement

By Linda Heron on Monday, May 16th, 2022
Posted in Great Lakes Protection Act, Great Lakes Water Quality Agreement, Joint, Radionuclides, Regulatory, Regulatory Submissions

Five years ago, in March 2016, 110 groups submitted an application under the Great Lakes Water Quality Agreement (GLWQA) to designate radionuclides as Chemicals of Mutual Concern (CMCs) under Annex 3 of that Agreement. We submitted our nomination in reply to Environment and Climate Change Canada’s (ECCC) and the U.S. Environmental Protection Agency’s (EPA) call for nominations from the public. 

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Hydroelectric Program Development and Assessment – IESO Small Hydro Program

By Linda Heron on Friday, May 13th, 2022
Posted in Class EA for Waterpower, Energy, Heavy Metal Contamination, Hydroelectric, Industry, Ontario Water Resources Act, ORA Submissions, Pollution, Regulatory Submissions, River Concerns, Rivers at Risk, Species at Risk, Water Quality

First, it was enlightening to be provided with a clear definition of small and large hydro facilities in the Hydroelectric Program Development and Assessment webinar, as well as a total amount of power generated by these categories. You informed that the definition of small hydro would have a scope of installed capacity of 10 MW and under, with 30 companies representing 50 facilities generating a total of 120 to 150 MW, and large hydro having a scope of installed capacity of over 10 MW, with 3 companies representing 22 facilities producing a total of 1,000 MW. 

The increased number of small hydro facilities making such a small contribution to our electricity grid impacts on multiple Ontario riverine ecosystems, whereas the 22 facilities producing 1,000 MW of power on presumably fewer rivers has a much lower trade-off value. Additionally, larger rivers have a greater capacity to buffer some of the worse effects of hydroelectric. 

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ERO 019-4971 – Draft Low Impact Development Stormwater Management Manual

By Linda Heron on Wednesday, April 27th, 2022
Posted in Climate Change, Environmental Protection Act, Environmental Registry, Ontario Water Resources Act, ORA Submissions, Planning Act, River Concerns, Rivers at Risk, Sewage, Stormwater, Urban Development, Waste Water Treatment Facilities, Water Quality, Watershed Planning

Blue Heron in Waterloo, Ontario, by Leslie Bamford

The ORA is in full agreement that Low Impact Development (LID) must be a priority in development planning guidance for stormwater management practices and should include innovative green infrastructure such as rain harvesting, rain gardens, green roofs, urban trees and forests, permeable surfaces, ditches, swales, stormwater catchments, and must emphasize the protection of wetlands.

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Bill C-28, An Act to amend the Canadian Environmental Protection Act, 1999 – Joint Support

By Linda Heron on Friday, April 22nd, 2022
Posted in Bill C-28, Bills, CEPA, Joint, Regulatory Submissions, Urban Development

“Banksy Toxic Waste” by Noodlefish is marked with CC BY-NC-SA 2.0.

The undersigned organizations and experts support the following Submission to the Ministers of Environment and Climate Change and Health on Bill C-28, An Act to Amend the Canadian Environmental Protection Act, 1999, etc. submitted by the Canadian Environmental Law Association in February 2022. This submission is relevant for Bill S-5 (An Act to amend the Canadian Environmental Protection Act, 1999, to make related amendments to the Food and Drugs Act and to repeal the Perfluorooctane Sulfonate Virtual Elimination Act) released on February 9, 2022. 

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A Clean Electricity Standard in support of a net-zero electricity sector – Discussion Paper

By Linda Heron on Friday, April 15th, 2022
Posted in Climate Change, Dams, Energy, Government, Hydroelectric, Impacts, ORA Submissions, Policy & Process, Regulatory, Regulatory Submissions, Removal, River Concerns, Rivers at Risk, Urban Development, Water Quality

Abitibi River – Twin Falls GS

When people refer to hydroelectric as clean, it’s usually in the context of GHG emissions; however, governments and utilities often use the term categorically and without caveat or qualification. Using the word “clean” in this context is misleading. Just because hydroelectric facilities are not spewing out smoke does not mean they are clean or renewable.  In fact, waterpower has resulted in significant and ongoing impacts on water quality, water quantity, ecological processes, fish and wildlife populations and habitat, and to aboriginal communities. Hydroelectric also makes a significant daily contribution to the earth’s accumulation of greenhouse gases (GHG) in our atmosphere.

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ERO-019-4967 – Municipal Wastewater and Stormwater Management in Ontario – Discussion Paper

By Linda Heron on Monday, March 28th, 2022
Posted in Environmental Registry, ORA Submissions, River Concerns, Rivers at Risk, Sewage, Stormwater, Waste Water Treatment Facilities, Watershed Planning

The province should not be streamlining reporting requirements. Wastewater and stormwater management are vitally important to the health and resilience of our freshwater resources and to the people of Ontario. There are numerous complex and site specific considerations for each and every outfall of sewage effluent that is unique to the area and the water body. We cannot continue to release partially treated or untreated sewage into our lakes and rivers. We must stop thinking about how we can make it easier and start thinking about how we can make wastewater treatment more efficient and effective so we can build resilience into our lakes and rivers to help prepare for a warming climate. 

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