Published on February 4th 2013
At its special meeting on January 31st, Council authorized the submission of the following response on behalf of the Town to Enerdu’s environmental assessment of the proposed project:
January 31, 2013
Ms. Muriel Kim
OEL-HydroSys P.O. Box 430 3108 Carp Road Ottawa, Ontario KOA 1L0
Mr. Ron Campbell
Enerdu Power Systems inc. 9094 Cavanagh Road Ashton ON KOA1BO
Ms. Kim and Mr. Campbell:
RE: Mississippi Mills Report on Proposed ENERDU Expansion Environmental Report
The Town of Mississippi Mills has prepared a comprehensive report in response to the Environmental Report which was prepared as required under the Class Environmental Assessment (Class EA) for Waterpower Projects with regards to the proposed expansion of the Enerdu Generating Station. The report has been available for a 47-calendar day review period, from December 17, 2012, to February 1, 2013. In the preparation of its response, the Town gathered feedback during this period from various community stakeholders including Council, sub-committees of Council, public groups and municipal staff. in doing so, the Town was able to capture the concerns of the community and are submitting the following comments:
Enerdu Power Systems is proposing an expansion and redevelopment of its existing hydro electric facility located in the old Flour Mill in the Town of Mississippi Mills, formerly Town of Almonte. The property subject to the application is located at 11 Main Street, along the north shore of the Mississippi River in the north-eastern part of the Mississippi River.
The Wylie Flour Mill was built in 1842 and the basement of the building was subsequently developed into a power generation plant. The timing of the conversion has not been confirmed, but historical records discuss an operational power plant in 1905. Recently, the flour mill portion of the building (above the working power plant) was converted into upscale condominiums. The Environmental Assessment has identified the existing generating station as a “run-of-river” facility, which consists of a powerhouse and an overflow weir. The Environmental Assessment (EA) for the proposed project has been completed to assess the potential impact of the development on the natural and physical environment and to provide information to the applicant regarding development planning of the site, assess potential impacts and propose mitigation measures.
The EA was finalized by OEL-Hydrosys on behalf of the applicant in December 2012 and was provided to the Town at the end of December. The Town is requested to provide comments to the Applicant by February 1, 2013. Continue reading
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