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.
When these unregulated projects come home to roost, and the environmental impacts begin to damage or destroy highly valued public interests, such as our lakes and rivers, endangered species, our drinking water, and the economy, the government will pay a very high price. Unfortunately, the damage that will result from these irresponsible and negligent actions will not easily be undone, and in many cases will not be resolved in our lifetimes.
If the government wants to incorporate “one-project, one review”, then it must be a robust EA process with fulsome public and Indigenous consultation, or it may find the process much longer than it might have intended.
We were very disappointed in Ms. Paul’s decision to deny our Application for Investigation; however, we were also not surprised. This provincial government has systematically dismantled much of Ontario’s environmental policy and legislation with an ambitious goal of “cutting red tape”, and “modernizing”. They have successfully carried out their mission through specious explanations that mislead the public and deflect concern over important Environmental Registry postings and massive omnibus Bills. This method has allowed them to proceed with sweeping cuts to numerous pieces of important legislation without much public fuss – all during their declared COVID Emergency. The decision on our Application for Investigation is simply another example of bypassing key legislation to facilitate a Project that has strong community opposition.
The ORA offers strong support for polluters being held accountable; however, that isn’t what’s happening here. Rather than strengthening enforcement tools that hold polluters accountable, this government is systematically and persistently dismantling, weakening or bypassing all environmental policy and legislation that was designed to protect the environment and deter those industries, corporations or individuals who would pollute and/or destroy the environment.
These ERO postings consistently mislead the public, especially in the top several paragraphs and titles, which contain misleading introductions to the proposed policy the government is proposing. In fact, you can always count on these “modernization” policy changes to be a further attack on environmental policy and legislation. It is even more despicable that these attacks have largely been carried out during the government’s declared COVID Emergency, where no public consultation is required, and what consultation that does take place is meaningless when the main objective is to cut red tape and remove any roadblocks to development and pollution, in spite of the public’s strong recommendations to protect the environment.
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 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”.
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 Coalition for the West Credit River is calling on Johnathan Wilkinson, (Minister of Environment and Climate Change Canada) for a federal review of the Environmental Study Report (ESR) for the Erin Wastewater Treatment Plant (Erin WWTP), under the Impact Assessment Act.
The Erin Wastewater Treatment Plant (Erin WWTP) will discharge over 7 million litres of effluent daily, releasing a toxic plume of chloride, ammonia and decreased oxygen into the West Credit River, directly upstream of native Brook Trout spawning nursery and habitat, and endangered Redside Dace.
Please sign the Cut the Crap, Keep the Credit petition.
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:
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.