Labelling Almonte an industrial town in the Enerdu Heritage Impact Assessment is twisting the truth

Figure 1: Current powerhouse
Figure 1: Current powerhouse

Ms. Muriel Kim Ms. Julie Harris

BluMetric Environmental Inc. Contentworks Inc.
3108 Carp Road, P.O. Box 430 120 Sunnyside Avenue
Carp, ON, K0A 1L0 Ottawa, ON, K1S 0R1
mkim@blumetric.ca jharris@contentworks.ca

 June 18, 2014

Dear Ms. Harris, and Attention Ms. Kim

The following are my heritage related concerns regarding the proposed Enerdu Project.

The destruction of the present Almonte riverscape, as proposed by Enerdu, by turning a scenic draw for tourists, in a residential area, into an industrial complex in the middle of the Mississippi River, is not the way to go.

As someone who lives in the study area I applaud the ongoing restoration of buildings and the town’s efforts to further beautify Mississippi Mills, actions which benefit tourism and have a cumulative positive effect on Mississippi Mills and Ontario as a whole. The Enerdu proposal, will lead to lower property values, less aesthetic appeal, less retail and lower rental rates. In other words, a potential loss in Town revenues. Mayor and Councillors take note.

Unresolved health, environmental and riparian rights issues aside, you, Ms. Harris, at the May 27th 2014, meeting of the Mississippi Mills’ Heritage Committee attempted to justify the Enerdu project by suggesting Almonte is an industrial town. In its textile heyday (early 1900s) upwards of eight mills were operational, including the Wylie Mill. However, the landscape has changed since then. The mills have been converted to condominiums, the riverfront is residential and projects suited to tourism, such as Riverwalk, and gardens have been installed and more are planned. The town now relies heavily on tourism. The town has moved on. Labeling Almonte as a landscape “ strongly industrial” is twisting the truth. I beg to differ. Couples have their wedding pictures taken on Riverwalk with the falls or mill as background. They will not flock here to be photographed in front of a dam and/or an industrial building.

You suggested that further justification for constructing an industrial complex in the middle of the scenic Mississippi River was based on the premise that “landscape is never static “and change is “a continuing pattern”. You suggested change is inevitable. I don’t accept change as a rationale for re-introducing industrialization to Almonte. I have already stated that Almonte has changed. For the better. The River is cleaner, less cluttered and still spectacular. We already have two run-of-the river generating stations and don’t need a third one in the downtown corridor within the same kilometre reach. Especially one that is not run-of-the river and which has the potential to degrade the cultural landscape, especially upstream, where I live.

I noted that you were unable to respond to many of the questions by the Heritage committee other than with “I don’t know” or “it’s complicated”. It’s not that complicated, please don’t treat us as fools. I can handle a technical explanation or two.

Communication does not appear to be one of your strong points. And yet it is my belief that good communication is the essence conducting an assessment, any assessment. The Mississippi Mills’ Heritage Committee asked, “Have you talked to the people along the river that are affected (by the project)”. According to my notes you replied something to the effect that it was not your job to talk to the affected people, but that you had used your “judgement” to “look at values” instead. How can you assess values without gaining some insight through dialogue?

And that is one of the many problems regarding this project proposal. Enerdu, and its consultants who should be impartial, in my view, seldom provide accurate information or sometimes none at all (the public asked for perspective drawings on the project but were told this was too expensive to provide; public volunteers had to create their own) How can the public be expected to understand the project when they have to do the work of the province and the proponent? When information is shared it is often reluctantly shared by Enerdu. When councillor Val Wilkinson asked about flows, Ms. Sugarman volunteered the information that they (Enerdu) had proposed a flow to the Ministry of Natural Resources.. When she was asked what that was, the response given as “we didn’t decide on a figure”. Are we to believe that no figures were mentioned? When asked how much the river width will be reduced by a new power facility the answer was “slightly”, yet in reality a good one third of the river would be obstructed. On being asked how Enerdu will comply with Mississippi Mills’ lighting by law, the answer was, “as much as possible”. My interpretation of that last statement is: we won’t be complying, and you’ll just have to live with it. It seems obfuscation is the watchword for Enerdu.

Confronted with the question of major impacts due to the removal of river bed (major protected fish habitat) through hoe ramming or blasting (Enerdu is unclear what they are doing), your response Ms. Harris was, Oh, boy, “not sure”, it’s a “small project”. I beg to differ. The destruction of a river, an environmental corridor and fish habitat, a visual heritage treasure and the livelihood of a town, is not small change.

On the questions of signage,fencing and riparian rights asked by an Heritage Committee member the response lacked merit. These questions have been posed to Enerdu and its spokespersons before. The resolution of these issues is important to Almontians because the issues will affect their lives and the lives of their children. Ms. Sugarman quoted chapter and verse of Transport Canada policy, shifting the focus away from Enerdu. You, Ms. Harris “assumed” there would be signage and fencing and that the project would be “dangerous”, to which Ms. Sugarman added that “any power plant will have fencing”. In effect no substantive answers were forthcoming. Nothing has changed. No wonder the general public gets upset when the information they keep asking for is expressed in terms of “I don’t know, I assume, It’s complicated”.

Ms. Harris, you related a story during your presentation about two individuals approaching you and suggesting that they were pleased that Almonte produced electric power. Did you ever think that they

may have been talking about the two major hydro plants we already have? Did it not make you want to survey what the rest of the public in Almonte thought and how they felt about their lives and cultural landscape being negatively impacted, rather than you arbitrarily deciding on your “values” and then in retrospect asking for comments?

Monitoring is a cornerstone in assessing change and helping predict or model risk when conducting environmental or social assessments. This is one of the first things taught to aspiring biologists or sociologists. The concept of monitoring seems to have escaped your attention. Your response, according to my notes was again “I assume ………some trust is needed.” Why should we, the public, go on trust? Reports should provide unbiased facts. Proposals need facts in order to be evaluated. Perhaps the Minister of Environment is willing to go it on faith, that Enerdu (without explaining what they are doing) will do the right thing, given the lack of information, in the environmental assessment report, but the public shouldn’t have to?

However you did make it clear that the heritage assessment was not conducted under the Ontario Heritage Act. The Planning Act appears to have eluded the assessment as well. This I find very unfortunate. The environmental river corridor through Almonte, with its falls, flora and fauna, should be considered a heritage landscape. Ontario’s Ministry of Municipal Affairs and Housing (MMAH) policy statement 2005 (issued under Section 3 of the (Sections 2.1 Natural Heritage and 2.6 Cultural Heritage and Archaeology) provides direction on provincial matters of interest. This provincial policy is addressed explicitly and implicitly, to Ontario’s municipalities. One fundamental, often repeated principle is the protection of natural resources. The MMAH policy statement (2005) provides for the application of mitigative measures when heritage landscapes are affected by adjacent development. If one views the Mississippi River as a continuum, then Enerdu’s proposed Almonte site can be considered adjacent to all riverine cultural landscape upstream (Appleton Wetland) and downstream . Enerdu’s present operations have already been shown to significantly affect the wetland’s water levels. Did this factor into your cultural “values” ? Enerdu has arbitrarily chosen to ignore all existing or potential upstream and downstream) effects. Mitigative or alternative management practices do not appear to be on the table for Enerdu either.

Almonte has always maintained an unofficial significant heritage status with its diverse and rich community and tourist appeal. It has always been known for its scenic beauty and as the best kept secret in the Ottawa Valley. Its river beauty was often depicted and expressed on early 1900s postcards. We need to preserve the physical nature of Almonte as well as its community fabric and cultural ambiance. Enerdu’s proposal does not fit in with the above image; it will only serve to detract from Almonte’s historic small town charm.

Ms. Harris, you clearly indicated a biased preference for creating engineered landscapes and a concrete riverview in Almonte. Instead, what we need is the preservation of our existing cultural landscapes. The blasting of protected river beds, flooding caused by restricting flows through the replacement of scenic falls with a concrete weir and mid-river power facility is not the future I want. I don’t believe it is the planning that Mississippi Mills wants for Almonte. The Almonte scenic riverscape is an heirloom

bequeathed to Ottawa Valley residents by their forbearers. It is not Enerdu’s to destroy. It should be passed on, intact, to our children. It is not a concrete landscape as you, Ms. Harris depict it.

The Enerdu proposal should be placed in abeyance at the very least, until, Mississippi Mills Council has been able to pursue the possibility an Almonte Heritage Conservation District and completed their overall municipal planning.

Now Ms. Harris, having worked for federal and provincial governments for over thirty years writing and reviewing environmental assessments I recognize government rhetoric and jargon when I hear it. When I am confronted at meetings with responses to legitimate questions with such replies as, “ I assume, It’s organic, its complicated”, I cringe. No wonder the public gets irate. I am not attacking your credentials. I’m sure they’re just fine. But I question the applicability of your experiences in a unique situation such as Almonte.

With sincere thanks for the opportunity to comment,

Joachim Moenig, BSc. MSc.
Almonte, Ontario
The Millstone millstoneeditor@bell.net The Honourable Shelly Glover Min.Glover@pch.gc.ca
The Honourable Michael Chan, MPP mchan.mpp@liberal.ola.org