Dear Millstone Editors
This submission is in reference to the current concern regarding the noise from the construction site at Enerdu and other commitments required of the proponent.
As outlined in PRATAC’s post , “the project is well underway and approved by the Province”, however, I believe it important for all to remember that this project was approved subject to various conditions (and evidence of meeting those conditions may make people more inclined to be understanding).
In particular, it seems very little evidence has been shared with respect to meeting the mitigation recommendations from the Heritage Impact Assessment (HIA) which formed part of the final approved Environmental Assessment.
In the fall I respectfully wrote to Enerdu to ask if they would share an update on the various heritage impact mitigation recommendations included in the final HIA (which I outlined in the letter) as even then, the project was well underway.
There are “pre”, “during” and “post-construction” mitigations outlined in the HIA. There was evidence of communication with the home owners in the area regarding pre blasting surveys, however, that was the only recommendation adhered to that was apparent.
On the Enerdu.ca site updates since the beginning of the project, reference to the mitigation requirements related to water quality has been frequently mentioned, but there was only one brief comment about built heritage mitigations in their August 8th update, reading: “This will include monitoring for vibration and overpressure of nearby structure” (I believe they intended it to read “structures” – plural).
Also last fall, the Ministry of Tourism, Culture and Sport also confirmed that the proponent “should” follow all of the mitigation recommendations outlined in the HIA (several of which were considered to be “key”).. Mr. Campbell responded to me and advised that the proponent would preparing a report for the Ministry and the town.
I am a “retired” member of the Heritage Committee (HC), and I followed up with the HC as a delegation on this matter. The HC made a motion for Council’s consideration requesting that a report be requested of Enerdu as to the status of the mitigation recommendations outlined in the HIA. The motion was discussed at the Committee of the Whole in the fall, and this task was delegated to the Mississippi Mills Facilities Manager, Robert Kennedy (I provided Robert with a copy of my letters outlining the mitigation recommendations to facilitate his task). To date, I do not believe the Heritage Committee (or Town), has received such a report.
There are several mitigation recommendations for pre and during (and post) construction phases of the project (see the Final Heritage Impact Assessment Executive Summary at the beginning of the document as well as detailed mitigations outlined on Pages 31 – 37).
There are a couple of recommendations that are of particular concern to me.
One was the commitment (as noted in various documents forming the final approved Environmental Assessment documents, as well as in a letter to the town from OEL-HydroSys in 2013) to report on any deeply buried or previously submerged cultural resources exposed during or following any construction work.
Specially, that the work should cease in the area until the find had been assessed by a licensed archaeologist and that they would also inform the Town’s Heritage Committee should such a discovery be made. It had been reported by one or more workers on the site during the excavation work in the late summer / fall, that many relics from the big train derailment of 1977 had been uncovered. Certainly, these relics would have been of significant interest to many people in town and likely to the museums as well. Certainly, the conditions outlined above were not met, but hopefully they had the presence of mind to at least document, photograph and retain these items.
The other concern was the deep gouge under the water line that became apparent after the excavation and removal of the existing weir to one of the pillars of the train bridge which was very evident when viewed from Ottawa street.
Although the bridge was inspected by Lanark County representatives, it is not clear if the inspection took place before or after the excavation and removal of the old weir (which is when the gouge became very noticeable). The key recommendations in the Executive Summary of the HIA state in part, “During construction, measures should be taken to address accidental damage to heritage resources, including the former railway bridge”.
Of course, the intent of these mitigations is that they be followed and not just agreed to in order to get an approval for a project. And perhaps several of these mitigation recommendations have indeed been met — they are all important, but without any transparency of their status to the town or the public it is difficult I think for many to be “understanding and accommodating” given the current issue with the project.