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Category Archives: Joint

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

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

“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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ERO-019-4867 – EA Requirements for Advanced Recycling Facilities – Joint

“Advanced recycling” is an umbrella term, sometimes also called “chemical” or “molecular recycling” that encompasses an ever-growing list of technologies that are speculative when it comes to recycling plastic. The reality is that there is no known commercial example of an “advanced recycling” facility anywhere in the world that turns plastic waste back into plastic products or packaging.

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Ending Plastic Pollution – A Call to Action – Joint

Canada has committed to ending plastic waste by 2030.i Reaching this goal will require ambitious actions that address the full life cycle of plastic.

Canada is a major—and growing—producer of plastics and the world’s second highest user of plastic on a per person basis.ii Production, use and disposal of plastics is an increasing contributor to climate change and habitat degradation. It also imposes disproportionate harm on those living next to production and disposal facilities, often low-income and Black, Indigenous and People of Colour communities.

We, the undersigned, therefore call on the Government of Canada to commit immediately to implement the following actions on an urgent basis:

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DRAFT PROJECT LIST REGULATION UNDER THE ENVIRONMENTAL ASSESSMENT ACT (ERO 019-4219) – Joint

West Credit River. Photo by Steve Noakes.

 Accordingly, we request that the Ministry revise and re-post the draft regulation for further public review/comment to ensure that it fully implements the stated purpose of the EAA, namely, the betterment of the people of Ontario by providing for the protection, conservation, and wise management of the environment. 

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Bradford Bypass – Designation Request for a federal Impact Assessment – 63 groups

We are 63 environmental, farm and community organizations, many of which supported the February 3, 2021 designation request for a federal impact assessment of the Bradford Bypass highway (400-404 extension link) under the Impact Assessment Act. We are writing to indicate our support for the November 9, 2021 designation request made by three local community groups: Forbid Roads Over Green Spaces, Stop the Bradford Bypass and Concerned Citizens of King Township. Like them, we believe the proposed highway will result in adverse social and environmental impacts within federal jurisdiction. 

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EBR Application for Investigation of Town of Erin – Proposed Erin Wastewater Treatment Plant – Joint

West Credit River Brook Trout. Photo by Steve Noakes.

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. 

Please click on this Google Drive link to view or download the Application for Investigation and Appendix A.  Continue reading


Per- and polyfluoroalkyl substances under Annex 3 of the Great Lakes Water Quality Agreement – Joint

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).

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Inground Infiltration of Wastewater

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.

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Media Release: Erin Wastewater Treatment Plant – Federal Review Denied

West Credit River. Photo by Steve Noakes.

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.”

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