by Al Seaman
The EMC of July 31, 2014 contains an article headlined “Enerdu releases final heritage report”. In that article, Ron Campbell, the project manager at Enerdu, is reported as saying the following:
“Enerdu has now met all of the conditions from the Environmental Assessment including completing the Heritage Assessment and the Flood Control Assessment.
“The Mississippi Valley Conservation and the Ministry of Natural Resources are both satisfied with the additional planning that we have done,” said Campbell. They have also submitted the planning and construction report to the Ministry of Natural Resources for review. Campbell says they hope construction will start this fall because they have made a commitment to the town to avoid the busy season.
The Flood Control issue has roots that go back over two years, and contrary to what is stated above, the issue has not yet been “satisfied”. A review of the facts is needed.
In the early stages of looking at the preliminary information from Enerdu it was evident that there was a potential problem at the narrowest point in the river, the section between the Barley Mow and the Enerdu plant. In the record 1998 spring flood there would have been an overflow at that point except for quick deployment of sandbags. With the addition of the new power house that narrow channel would be reduced by 30%, and clearly that would increase water levels and flood risk. When the Enerdu Environmental Report was released in December 2012, there was no reference to this issue. On January 16, 2013, Mississippi RiverWatchers responded to Enerdu about many points in the ER, including the lack of flooding analysis at the power house.
The Enerdu response to that, dated January 30, 2013, was to simply dismiss the problem with the statement “Flooding conditions downstream of the weir would be influenced primarily by the two dams/spillways downstream of the Enerdu GS, which are under the ownership and management of other parties. Given that the Enerdu GS would not influence flooding conditions downstream of the weir, HEC-RAS modelling was not conducted for the downstream reaches.” This, of course, is false and is a blind denial of reality.
In the meantime, RiverWatchers submitted their request to the Ministry of the Environment for a Part II order dated January 28, 2013, with our January 16 response to Enerdu attached. The granting of a Part II order would have required a more complete environmental assessment.
A response from the Minister of the Environment on November 18, 2013 rejected the request for a Part II Order, and summarized the Ministry’s position on the many issues raised previously. On the flooding risk it set an additional requirement for Enerdu:
“To provide further oversight, a condition has been developed by the Ministry of the Environment, in conjunction with the Ministry of Natural Resources and the Mississippi Valley Conservation Authority, to ensure additional modeling is completed. The purpose of the condition is not to change the design of the Project but to ensure that any potential mitigation measures that may be required are considered early in the planning process.”
The same response from the Minister of the Environment also established a further condition on impacts to cultural heritage:
“The Ministry of the Environment, in conjunction with the Ministry of Tourism, Culture and Sport, has developed a condition to require Enerdu to complete a Heritage Impact Assessment which is to be provided to the Ministry of Tourism, Culture and Sport for its review and comment.”
As noted in the EMC article, the required Heritage Impact Assessment (HIA) has been completed, but to my knowledge its review and comment by the Ministry of Tourism, Culture and Sport has not been completed.
Until recently, nothing has been released as to the results of the required flooding analysis by the Enerdu consultants. The final HIA opened the door a bit on that issue with the following statement buried in its Appendices:
“To mitigate against potential flooding impacts, a flow bypass will be constructed through the existing powerhouse to:
- Reduce the flooding hazard in the bypass reach, by reducing the total discharge flowing through that reach in regional flood conditions (342 m3/s);
- Reduce the flooding hazard upstream of the Enerdu GS, by providing a greater discharge capacity compared to the existing facility.
“The results of hydraulic modelling, conducted for the regional flood scenario of 342 m3/s, have demonstrated that the proposed powerhouse will not have any adverse impact on flooding hazard to heritage and non-heritage structure in the bypassed reach, provided that the proposed flow bypass in the existing powerhouse is constructed.
“These results were presented to the Ministry of Natural Resources (MNR) and the Mississippi Valley Conservation Authority (MVCA) in a preliminary Technical Note issued on March 14, 2014, which was followed by a meeting between MNR, MVCA, the proponent and the consulting team on March 25, 2014. During the meeting, the agencies accepted the preliminary conclusions with minor revisions to the Technical Note. The revisions were reflected in a revised Technical Note issued on April 16, 2014. The final Technical Note was included as part of a larger application package submitted to the MNR in June 2014, for approval under the Lakes and Rivers Improvement Act.”
This was news indeed, and since it seemed inconsistent with a recent article in Millstone News by Councillor Alex Gillis, who is also a Board Member of MVCA, I asked him by email on July 21, 2014 for an update. He was very prompt with an initial telephone update, and subsequently by email with the following direct quotation from Paul Lehman, the General Manager of MVCA, on July 23, 2014:
“Hello Alex, the HIA is referring to a technical note which provided some preliminary hydraulic analysis to demonstrate that the potential increase in flood risk could be mitigated. This did not include any hydraulic modelling nor details on how Enerdu would provide a bypass. These details will need to be included in their submission to MNR for approval under the L&RIA and toMVCA for a permit under Ont. Reg. 153/06. To date MVCA has not received this submission although I do expect to receive it shortly.”
Clearly, something is afoot, but it has not moved forward to the extent that is implied in the statements of Ron Campbell in the EMC. I also note a recent comment from Mayor Levi in the Millstone: “The engineering study on flooding has been completed and agreed upon by MNR in conjunction with MVCA. The MVCA is only an advisory group to MNR thus not approval agency.” It is clear that MVCA has neither received the required hydraulic analysis, nor have they approved it. It is also clear that MVCA is not just “an advisory group to MNR” but does have a legislated responsibility for approval of any construction that may affect flooding on the Mississippi.
In the meantime it seemed appropriate to ask Enerdu’s consultant for a clarification, and on July 22, 2014 I sent an email to Muriel Kim of BluMetric Environmental Inc. requesting more information on the Enerdu Project and Hydraulic Modelling. The response the next day was:
“The Lakes and Rivers Improvement Act application package and the Technical Note contained therein are currently undergoing review by MNR. The information is not solely Enerdu’s to release as it is part of a government regulatory process; only the regulator can make the decision to release it.”
This appears to be yet one more smoke screen that is typical of the responses that we have been getting from Enerdu’s consultants over the past two years. In reality, this information for the most part is Enerdu’s and they can decide to release that part of it on their own if they are so inclined.
On July 25, 2014 I followed up this issue by sending an email to the Kemptville office of MNR requesting more details on the hydraulic modelling issue. At the moment, one week later, I have still not received a response.
So, the bottom line is that Enerdu has not progressed with their plans as completely as Ron Campbell implies. It seems to me that his comments are more of a smoke screen to make Enerdu opponents feel that it is now a done deal, and to give up. It is not done yet, so don’t give up, but continue the pressure on Enerdu.
To our Town Council I offer my thanks for the first step this week in the implementation of a one year delay on the Enerdu development. The above story is about the flood modelling issue only, but there are a great many more where the known information is very tenuous. There are also a number of other permits and approvals needed before any construction can start and little is known about their true status. It appears that much still remains to be done. After over two years of the Enerdu dance of seven veils, in which we get to see brief and partial glimpses of what is behind the veils, it is time to stop the dance and for Enerdu to get down to some full and open discussion of what is really being planned. A one year time out will give an opportunity to reach an understanding of the benefits of this project to Almonte and what are acceptable costs in terms of community, cultural and environmental damage resulting from the development. Hopefully some common ground can be found that will lead to an acceptable plan.
It is worth noting that throughout this multiyear battle, we have neither seen nor heard from Jeff Cavanagh. He clearly is the person behind Enerdu Power Systems Inc, and is listed as President, Secretary, Treasurer and sole Director on the current Corporation Document List from the Ministry of Government Services. He has remained invisible and silent behind his phalanx of consultants under various names – OEL, WESA, BluMetric, and Contentworks. Their collective attitude is withhold as much information as possible from the public, and if something must be released, to put the best possible spin on a part of the facts. It is time for Jeff Cavanagh to come forward and engage in some meaningful discussion. RiverWatchers have made it clear on a couple of occasions that we are available for some direct discussion. So far there has been no response.