Summary of Recommendations:
It is ORA’s position that referring to this proposal as a “run-of-river” operation throughout the entire Environmental Report (ER), and not revealing or addressing the fact that this facility is actually a peaking operation that holds water back to produce power during peak demand hours, is a fatal flaw that places the integrity of the entire ER in question. We must then ask, what other important details have been left out.
After having carefully reviewed the ER and the Response from Enerdu, and for all the reasons set out in this letter, ORA is making a formal request to the Minister of the Environment to elevate this proposal to an Individual Environmental Assessment.
Failing the implementation of Recommendation 1, ORA requests that the Minister reject Enerdu’s ER, and the proponent be ordered to provide an ER that addresses all the recommendations and concerns set out in this letter.
The categorization of “Existing Infrastructure” does not define or differentiate the rigor or level of the environmental evaluation required, and therefore the full impacts of the existing and planned operations must all be fully considered and assessed – both upstream and downstream.
If Enerdu’s intent is to continue peaking this facility, then the proponent should be ordered to correct their ER by removing all reference to this project as a run-of-river and to instead make reference to it as a “modified peaking hydroelectric facility”.
That the Minister require Enerdu to reveal whether the new weir would be capable of being raised above 117.7 masl – regardless of compliance levels. The detail of the maximum height that the new weir is capable of being raised must be included in the ER.
That the Minister require Enerdu to include the details of the decision of the MRWMP Standing Committee in the ER. This is an important decision that has bearing on all aspects of the proposal.
That the Minister require Enerdu to redesign their project to comply with the MRWMP Standing Advisory Committee’s recommendations to restore water levels to those that existed prior to 2004.
That the Minister require Enerdu to provide a minimum compensation flow of 2.2 m3/s in order that their operation does not interfere with MRPC’s mandatory requirements, and so the scenic values of the Town of Enerdu are not impacted.
ORA strongly recommends that the Minister require Enerdu to complete an Economic Impact Study to determine the impact of this project on the tourism and recreation aspects of the Town of Almonte’s economy.
Enerdu be required to resolve the issue of Quit Claim eligibility before Statement of Completion.
That the Minister require Enerdu place funds up front for future dam decommissioning if for some reason in the future this facility is no longer economically, environmentally or socially sustainable and viable.
In order to meet the requirements set out in the Class EA for Waterpower, section 2.5.3, ORA strongly recommends that Enerdu be required to adjust their proposal to ensure their operation will not negatively impact on any other affected riparian landowners.
In any future opportunities to comment, and in order to assist the public in preparation, Enerdu be required to provide user friendly documents that can be highlighted, copied, cut and pasted, and the review period be a minimum of 60 days – preferably 90 days.
On 29 January 2013 Enerdu responded to ORA’s 18 January 2013 comment letter (enclosed), herein referred to as Response, and many of our final remarks will be based on this Response, as well as the Environmental Report (ER) for the Enerdu Generating Station Expansion and Redevelopment Project for the Mississippi River, in Almonte.
To read the full documents please click on correspondence in tray below:
Download Enerdu’s Response to ORA -29 January 2013.