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.
A Coalition member has reached out to your staff Planner to determine whether permits and authorizations were in place before this work was undertaken; however, this information has not been forthcoming.
Therefore, the Coalition is inviting you to attend our online Zoom meeting scheduled for Thursday, 25 March 2021, at 7:00 pm, to answer the following questions:
1. Which permits and/or authorizations did the Town of Erin and/or Solmar obtain before carrying out this work on the proposed Erin Wastewater Treatment Plant Project lands;
2. Who is the registered owner of the subject Project lands;
3. Who directed this work to be done; and
4. Who performed the work?
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.
The Coalition for the West Credit River is following up on our previous correspondence dated 18 February 2021 as we have not yet received a response to our questions that were laid out as a precursor to a meeting with Council. Please let us know when we can expect answers to our questions so we can move forward with scheduling a meeting.
Also, on 25 February 2021, the Coalition filed a Designation Request with The Honourable Jonathan Wilkinson, Minister of Environment and Climate Change, under Subsection 9(1) of the Impact Assessment Act. We have since received acknowledgement that the Impact Assessment Agency of Canada has commenced the review of our request, and that “If designated, to proceed with the Project, the Town of Erin would be required to submit an Initial Project Description, thereby commencing the planning phase of the IAA. In that case, the planning phase would include the Agency determining whether a federal impact assessment is required.”
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.
The West Credit River subwatershed supports headwater tributaries of the Credit River and is considered the crown jewel of coldwater Brook Trout fisheries in southern Ontario. The entire footprint of the Project, including the network of underground sewers, will result in numerous crossings of first, second and third order streams. Additionally, the West Credit River feeds into the main Credit River at the Forks of the Credit Provincial Park. This area is part of the UNESCO Niagara Escarpment World Biosphere Reserve (Reserve), home to several sensitive fish species, including the endangered Redside Dace and Atlantic Salmon. Atlantic Salmon, historically extirpated, are being reintroduced as part of the broader Lake Ontario Atlantic Salmon Recovery Program. This Reserve is within 1 km downstream of the Project’s effluent discharge, and Redside Dace (Schedule 1, Species at Risk Act, 2002), are known to occupy the West Credit River within 4 km downstream of the effluent diffuser.
A highly controversial environmental assessment study under the Ontario Environmental Assessment Act was completed 23 years ago. It concluded that the project would cause adverse effects to fish habitat including severe stormwater and groundwater impacts. The environmental assessment did not evaluate the impacts on species at risk, migratory birds or climate change. This study has not been updated.
The provincial regulatory process is grossly inadequate.
Overall, the material presented makes clear that the Fund mechanism will make it easier for habitat destruction to occur at the hands of industry and developers. Indeed, according to the proposal the main purpose of the Fund is to give operators a quicker and less cumbersome alternative to completing actions to provide an overall benefit for the species negatively impacted by their activities. The Fund is a part of a package of damaging amendments to the Endangered Species Act, 2007 (ESA), passed in June 2019 that, taken together, represent a gross weakening of the ability of the Act to fulfill its purpose to recover Ontario’s at-risk species. Our primary concerns with the Fund are outlined below.
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.