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Category Archives: Fisheries

Follow up to Town of Erin & Solicitor: Damage to Tributary on Solmar Land, Joint

West Credit River Brook Trout. Photo by Steve Noakes.

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”. 

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Concerns over Brook Trout and Fish Habitat on the West Credit River

West Credit River. Photo by Steve Noakes.

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. 

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Invitation to Mayor Alls: Coalition online Zoom Meeting, Joint

West Credit River. Photo by Steve Noakes

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? 

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Request to appear before the Standing Committee on Environment & Sustainable Development – Joint

West Credit River, Photo by Steve Noakes

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. 

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Erin WWTP: Follow-up on 18 February 2021 questions to Town of Erin Mayor and Town Council, Joint

West Credit River Brook Trout. Photo by Steve Noakes.

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.” 

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Erin WWTP: Designation Request for a federal review under the Impact Assessment Act

West Credit River, by Steve Noakes.

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.

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Coalition concerns over Erin Wastewater Treatment Plant

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.

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Proposal to increase set fines for recreational and commercial fishery offences

The ORA favours conservation of Ontario’s natural resources, and most especially as it relates to fish and their habitat. ORA agrees that the Ministry should apply existing federal government guidance for fines and increase the use of contravention tickets for more types of offences. It makes sense to issue tickets rather than using the federal court process.

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Exempting dams from requiring a Permit to Take Water – ERO-019-2517

Melville Dam, Credit River, breached on 26 June 2017

ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations[i].  There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”.  It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations.  Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water.  It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.

[i] Statement of Environmental Values: Ministry of the Environment and Climate Change

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Proposed Comprehensive Project List under the EAA – ERO-019-2377

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.

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