ERIN – A lot of water has flowed through the septic tanks of Erin since September 1995, when a standing-room-only public meeting was held on a proposed $25-million sewage treatment plant for the Village of Erin.
The plan was prompted by a public health report citing pollution of the West Credit River by failing septic systems – but the residents weren’t buying it.
Not enough information. Who’s going to pay? Flawed planning process. Is it really needed? No community consensus.
Fast forward to May 2009, the first public meeting to develop Erin’s Wastewater Environmental Assessment (EA), a completed copy of which today sits on the desk of the environment minister awaiting possible approval.
The EA started with a “visioning” process, and most residents said they wanted Erin to stay more or less the way it is.
A few more stores would be good, a Tim Hortons for sure, a few more employers, better recreation services, some seniors housing – but preferably without the hassle and expense of building the town’s first sewer system, people said.
A local columnist at the time predicted the community could still be searching for a consensus in 10 years.
Now, in 2019 – 10 years and $2 million later – Erin has a town council elected on a platform of moderate growth and a completed EA for a $118-million wastewater system, but there is still no consensus on the plan among local residents, downstream neighbours or even provincial government ministries.
The EA has been stalled since June 2018, with three appeals and a batch of critical comments from the Ministry of Natural Resources and Forestry (MNRF). The Ministry of the Environment, Conservation and Parks (MOECP) has authority to approve the EA or demand changes, but doesn’t expect resolution until late spring or early summer.
Ministry of Natural Resources
The EA was conducted under the supervision of the MOECP and Credit Valley Conservation (CVC), with effluent levels below regulated limits for various contaminants.
Concerns were raised by the MNRF during the study process, and addressed by Ainley Group on behalf of the town.
During the commenting period after the EA was complete, MNRF district planner Tara McKenna sent a letter to Ainley, the MOECC and CVC summarizing objections that remained unresolved.
Mayor Allan Alls said Ainley “answered all of [MNRF’s] questions” but the MOECP has not responded. The MNRF letter was not distributed to council members.
MNRF spokesperson Jamie Prentice said they are still reviewing the Ainley response. Once finalized, ministry comments will be provided to both Ainley and the MOECP.
The proposed location of a treatment plant at 10th Line and Wellington Road 52, with entry to the river at Winston Churchill Boulevard, has been identified in the EA as having the best water flow to dilute the treated effluent.
However, the MNRF wants other sites in Erin to be considered.
The MNRF says the Assimilative Capacity Study of the river, which has already had several revisions and periods of extra data collection, still does not have enough information, and it recommends different computerized modelling.
“It is not clear how the effluent targets for water quality parameters will be achieved and ensured,” the MNRF letter says. The effluent outfall point has already been moved to avoid a spawning area for brook trout, which are sensitive to elevated water temperatures.
“No mitigation for potential thermal impacts appears to have been identified. Is there an option to cool the effluent before discharging into the river?” the MNRF letter asks.
“Placing the outfall at Winston Churchill Blvd. could prevent safe passage to known spawning sites immediately upstream.”
Ainley said any temperature difference would be insignificant and have no effect.
The MNRF is also concerned about possible overflows in the sewer system during storms, which in older systems result in untreated sewage being discharged to the river. The Erin system is to be designed with no overflow tanks to handle storm surges, but MNRF recommends them “to prevent spills which would likely impact sensitive brook trout habitat.”
Ainley says modern sanitary sewers do not need these precautions since they are “closed” systems, meaning rain water goes only into storm sewers, and does not normally infiltrate the wastewater sewers.
Ainley acknowledges possible future damage to sewer pipe joints could cause a minor amount of fresh water leakage into the pipes.
“While the capacity during Phase 1 may not be an issue, there is likely a much greater risk of overflows or spills at full build out,” states the MNRF letter. “The infrastructure at this point will be older (possibly more susceptible to leaks/breaks).”
The MNRF is asking how beaver dams in the area would affect effluent mixing, though Ainley dismissed this issue when raised by local residents.
The final concern of the MNRF is the feminization of male fish by endocrine-disrupting compounds that are “routinely measurable” in municipal wastewater but not regulated by MOECP. Exposure to this estrogenic contamination leads to “reduced reproductive success,” the letter states.
MNRF recommends the use of treatment technology used elsewhere to significantly reduce this contamination.
The MOECP is also considering three part II order appeals of the EA made last June, which is expected to delay the process by about one year.
One is from Liz Armstrong, a resident of rural Erin known for environmental activism with the Climate Change Action Group of Erin. She says that with a proposed flow of 380 litres per capita per day (LPCD), the system will be far overbuilt, even for the proposed maximum of 14,600 urban residents.
“Given current water use of 160 LPCD in urban centres, this is an extraordinarily high design flow rate,” said Armstrong.
“Water-conscious municipalities everywhere are aiming to reduce per capital consumption, and apply conservation restraints that will in turn reduce infrastructure costs.”
Ainley says the extra capacity is an industry standard, intended to offset loss of efficiency as the system ages over an 80-year lifecycle, and provide for extra growth if the town chooses to allow it.
Armstrong also objects to the cost of including a fresh water infiltration rate of 90 LPCD in the design, which is required by MOECP, despite the expectation there will be virtually no infiltration.
She also contends the $118 million full build-out cost of the system is excessive, and that there should be a competitive design-build process.
Beyond the initial cost, she says operating costs and asset management costs (preparing to eventually replace the system) should be fully estimated.
While the EA included a $30,000 sub-study that effectively ruled out the option of discharging treated effluent to subsurface soil instead of the river, Armstrong argues there should have been study of a broader range of options, including clusters of smaller processing systems that could discharge to either soil or surface water.
Since Erin’s wastewater is to be discharged at the Erin-Caledon border, there is concern in the downstream community of Belfountain, just 2.2km from Winston Churchill Boulevard.
Two part II order appeals of the Erin EA have been made from this area, one from the Belfountain Community Organization (BCO) and the other from Ann Seymour, who has the river running through her property.
While there was some discussion between the mayors of Erin and Caledon, there was no consultation with downstream residents.
“Belfountain was really blindsided by this,” said Seymour. “The wastewater treatment plant is the wrong thing to do. It’s the wrong location. I am convinced that the plant will damage the West Credit River and cause the collapse of one of the most pristine cold-water fisheries in Ontario.”
She is disappointed Credit Valley Conservation has supported the plan to treat Erin’s wastewater, and predicts that efforts to educate the Erin population about what not to put in the sewers will be not be sufficient.
“An education program is not a substitution for removal of toxins,” Seymour said.
Over the long term, she believes the plant will not remove, and the fish will not tolerate, a flow of salt, ammonia, endocrine disrupters, estrogen-based compounds, medications and micro-fibres.
“There is a solution and a compromise for Erin and the West Credit River in Caledon,” Seymour said in a letter to the MOECP. “Erin can still grow by putting households on individual septic sewage systems and cancel the proposed wastewater treatment plant.”
Judy Mabee, president of the BCO, said the MOECP has been communicating to try to come to an agreement, but, “We are not anywhere near that yet.”
She said filters don’t exist to eliminate hormones and organic compounds, and there will be chronic low-dose exposure for any creatures that rely on the river.
“With the chloride levels that would be there for, technically, full build-out, there’s not much hope for that river,” Mabee said.
While she is worried the ability of fish to survive the effluent, she’s also concerned about human health.
“We do have people who drink directly from the river, who use that water for household usage,” Mabee said, noting they have purification processes in their homes.
For the Wastewater Environmental Assessment documentation visit the wastewater page, under the town hall menu, at erin.ca.