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”. Continue reading