The Marter Township GS ER continually minimizes, confuses, and glosses over the facts to provide the reader with the desired impression that amounts to more of a sales pitch than a relaying of the facts contained in the supporting documentation. The general public are not normally versed in the technical aspects of a waterpower project, and would heavily rely on what is said in the main document – the ER. To rely on the ER for the facts would provide an unrealistic impression of the proposal because it is riddled with inconsistencies and inaccuracies in its translation of the supporting documentation.
In many areas of the ER, the claims are glossed over and do not align with the documentation and studies contained within the ER. Such as in Table 25, where under the issue “Upstream inundation may alter water quality (methyl-mercury) and heavy metals in reservoir”, the resolutions indicate, “No impact anticipated….” Yet, the Hutchinson Report pointed out several reasons why it could be a problem – see comments in No.2.
As MOE staff, pointed out in a July 3, 2013 correspondence to Xeneca, section 4.2.2 of the Class EA for Waterpower projects deals with the identification of potential effects of a project. “An effect is any change to the environment, positive or negative, that could occur as a result of the project…. This Class EA requires the proponent to assess the potential effects as well as any net effects after mitigation and focuses on those effects common to waterpower projects.” The Notice of Completion states, “the ER concludes that there are no significant adverse effects after the application of mitigation and adaptive management measures. The Marter Twp. GS is categorized as a project on a managed waterway pursuant to the Class EA.”
It is ORA’s submission that Xeneca’s approach falls far short of their claims in many key aspects of this ER, and does its best to sell the reader on the project, with an approach of convincing the reader to just trust them, let them build it, and then through monitoring and adaptive management during pre and post construction the riverine ecosystem will be just fine. This approach is not acceptable.