The Coalition for the West Credit River (Coalition) remains very concerned with the potential environmental impact of the Erin Water Resource Recovery Facility (WRRF) and, in particular, the temperature of its treated effluent harming the sensitive coldwater Brook Trout habitat of the West Credit River.
As your Ministry is aware, the approved sewage treatment plant proposes to discharge large flows of sewage effluent into the relatively small flow of the West Credit River. The lack of significant dilution will greatly magnify the thermal impact of warm effluent on this coldwater stream.
First, the Coalition for the West Credit River (Coalition) would like to express our deepest appreciation that you and your staff worked with our Technical Team over the last several months to incorporate some of our recommendations into the Environmental Compliance Approval (ECA). However, we are concerned that our key recommendations for improvements to the draft ECA, received by you on 2 May, were not reflected in the ECA approved on 3 May 2022.
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.
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.
A presentation made by the Chair at ORA’s 16 October 2021 Annual General Meeting:
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.
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 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.