On behalf of the 23 undersigned organizations, we are writing concerning work on per- and polyfluoroalkyl substances (PFAS) under Annex 3 of the Great Lakes Water Quality Agreement. We urge the U.S. and Canadian Governments to work together in developing a joint binational strategy to address these chemicals in the Great Lakes region.
As you know, under Annex 3 of the Great Lakes Water Quality Agreement (GLWQA), the Canadian and U.S. Governments (the Parties) have designated two individual PFAS and their isomers (perfluorooctanoic acid, or PFOA, and perfluorooctane sulfonic acid, or PFOS) and one category (long-chain perfluoroalkyl carboxylic acids, or LC-PFCAs) as chemicals of mutual concern (CMCs).
In consideration of the ecosystem benefits of a healthy West Credit River and its sensitive Brook Trout and Redside Dace population, we are recommending that inground infiltration of the final wastewater effluent be seriously considered, as a viable alternative to discharging warm sewage effluent directly into the West Credit River. Discharge of treated effluent by way of passive infiltration into the ground with slow percolation into this relatively small stream is the best way to ensure that the final effluent reaches the stream as natural and cold groundwater.
Judy Mabee, Chair of the Coalition and President of the Belfountain Community Organization stated that, “The Coalition is not deterred by the Minister’s Decision. We will continue on with our work to protect this highly valued coldwater Brook Trout population in the West Credit River. We are more than willing to work with the Department of Fisheries and Oceans and other federal and provincial regulators, including the Town of Erin and its consultants, to advocate for a wastewater plant that sets a new best in class industry standard for the protection of sensitive coldwater receiving streams.”
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 draft Strategy should include stricter fish consumption advisory that will protect the health of people in the Great Lakes basin to reflect stringent levels of PFOS concentration in fish adopted by the Great Lakes Consortium for Fish Consumption Advisories Best Practice for PFOS Guidelines.
The Coalition has carefully reviewed the ESR to see what habitat related to endangered or threatened species, Schedule 1 SARA species, migratory birds or rare and uncommon plants may have been impacted by significant damage that was done on the Solmar property in late December 2020 and into the first quarter of 2021. In particular, the damage related to the premature removal of brush and trees in and around the Project site, as well as significant damage to a first order tributary to the West Credit River in a Provincially Significant Wetland and Greenlands Natural Heritage designated area (Addendum 2). The Coalition has ascertained that there were no permits or authorizations for any of this work to take place. It is very difficult to do additional bird and tree studies when a great number of the trees and habitat were removed and burned.
The proposed Erin Wastewater Treatment Plant (Project) would release over 7 million liters of sewage effluent daily into the West Credit River, which is a relatively tiny receiver stream. This large volume of sewage effluent would be released downstream at the Wellington County Line into one of the last remaining native Brook Trout Populations in southern Ontario. This self-sustaining Brook Trout population is thriving because of the West Credit River’s unique and pristine coldwater habitat.
The purpose of Aaron Detlor’s communication was to “advise that the Haudenosaunee hold treaty rights over the area contemplated by this Project, and that the Project will interfere with those rights and interests… At the same time we are hereby asking Minister Wilkinson and the Crown generally to withhold any pending approvals subject to the commencement of a good faith process to uphold the honour of the Crown”.
Protected areas are a proven means of conserving biological diversity and mitigating the impacts of climate change, two of the greatest challenges we face as a society. They also enjoy broad public support. For example, a 2018 national survey conducted by IPSOS found that 93 percent of Canadians believe that protected areas are necessary. Similarly, a 2019 national survey conducted by Abacus Data found that 88 percent of Ontarians support protecting or conserving more natural spaces and 91 percent supported Canada’s 2020 protected areas commitment. There is no doubt where the public interest lies on this issue.
Jack Imhof, an Aquatic Ecologist/Watershed Scientist, says “It is essential an independent federal assessment of the Erin Wastewater Treatment Plant be conducted in order to ensure the health of downstream communities and survival of the last healthy Brook Trout and Redside dace populations left in the Credit River watershed. This is NOT a “Fish or People” issue.” Jack Imhof has been involved in the study, assessment and management of the West Credit River since 1979, as well as the data collection and writing of the West Credit Subwatershed Study.