The proposal uses the words …

The proposal uses the words "discharging via a municipal ditch within the Lake Saint Clair Watershed."

This wording is specifcally vague, and hides the fact that the stormwater run-off discharges into the Sydenham River, one of the important habitats of the Spiny Softshell Turtle (endangered).

Under the Recovery Strategy developed by the Ontario Ministry of the Environment for the Spiny Softshell Turtle, "The main threats to the Canadian population of the Spiny Softshell are: shoreline and riverine habitat development/alteration; water level management; collisions with boats; illegal collection; human-subsidized predatorsfootnote 5[5]; exotic and invasive species; livestock farming and ranching; fishing by-catch; and disturbance from human activities. Other threats identified include contamination and nutrient loading and climate change. The Spiny Softshell is highly vulnerable to any increases in rates of mortality of adults or older juveniles since the species has delayed sexual maturity and a low reproductive rate."

The Recovery Strategy continues by noting "Aquatic habitat of the Spiny Softshell can be impacted by the degradation of water quality caused by the runoff of contaminated water from agriculture (e.g., nutrients and pesticides), industry (e.g., industrial waste), roads (e.g., de-icing salt), and urban areas (e.g., heavy metals) (Mitchell and Klemens 2000; Bishop et al. 2010)."

Allowing the construction of this facility with it's current intent to discharge stormwater run-off rich in fertilizer into what is classified as Critical Habitat for the Spiny Softshell Turtle is an act which borders on intentional extirpation of an endangered species within an area of the Sydenham River.