The Coalition for the West Credit River, of which the Belfountain Community Organization is a member, wish to inform Mayor Alan Alls and Council (the “Town”) that the questions asked in our 18 February 2021 correspondence were either not addressed at all or not satisfactorily addressed in the final Environmental Study Report (ESR) for the proposed Erin Wastewater Treatment Plant (Erin WWTP).
The Coalition reached out in good faith to the Mayor, in the hopes that he would answer our questions, and perhaps resolve some of our concerns and make it unnecessary to take this matter to the federal level for a review under the IAA. However, it has become crystal clear that the Mayor was not acting in good faith when we were informed by the Town’s lawyer, Quinto Annibale, in his 10 March 2021 email to me, that “all of the questions and issues which were raised and answered during the Part 2 Order request made to the Minister of the Environment Conservation and Parks pursuant to the Environmental Assessment Act. As you know the Minister considered each of these issues and refused to grant the Order. Since you participated in the Part 2 order request, my client sees very little useful purpose in answering the same questions again and therefore will not be responding to the detailed questions contained in your February 18, 2021 correspondence”.
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 writing to you today to share our urgent concerns about an impending and grave threat to the ongoing health of the West Credit River and the sensitive coldwater environment and ecosystem that it sustains. The West Credit River flows through the Towns of Erin and Belfountain, a premium get-away for fly fishers and GTA urban dwellers seeking near-wilderness respite just a short drive northwest of Toronto.
The West Credit River is acknowledged as one of the last remaining wild and self-sustaining native Brook Trout fisheries in southern Ontario and is recognized for its environmentally significant ecosystem as part of a UNESCO World Biosphere protected area, well before it exits at the Forks of the Credit River.
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.
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:
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.
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.
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.
As we all work to emerge from this unprecedented disruption, our 235 organizations and millions of supporters want to emphasize that investments in nature and biodiversity on our lands and in our ocean can create jobs and be an essential part of an economic recovery and a sustainable future. Canada is in a particularly strong position to lead global efforts in this regard. We support your commitments to increase protection of lands, freshwater, and ocean, embrace nature-based climate solutions, and urge you to invest in achieving these outcomes.