Over the past two years, your office has received many letters from people in Mississippi Mills regarding expansion of the Enerdu hydro-generating facility in the middle of Almonte’s downtown heritage district. To that chorus of concerned citizens and community groups, I am adding a plea from their Mayor.
I will state up-front that I am not expecting your government to stop the project—I understand the legal problems that action would cause. Premier, I am asking that your office:
1) Provide a fair hearing for local environmental concerns about the health of the Appleton Wetlands.
2) Review shortcomings in the Class EA for Waterpower that leave local councils and citizens out of the decision-making process.
Since December of 2014, I have had the pleasure to consult in person with ministers in three departments involved in the development of the Enerdu facility: the Honourable Bill Mauro, the Honourable Glen Murray and the Bob Delany. They all understood our frustrations, but they cannot or will not help us resolve either problem.
On behalf of the Council and residents we represent, I am appealing directly to you and your office knowing that the solution to these matters crosses ministerial responsibilities and may prove challenging for any single provincial ministry or agency.
Environmental Concerns for Appleton Wetlands
First, I ask that the Province re-evaluate the operating water levels set in the Mississippi River Water Management Plan (MRWMP), which your government can do without legal penalty. And I ask that the Province recognize and accept the science presented by the Mississippi Valley Field Naturalists (MVFN), in the absence of any science to the contrary from provincial ministries.
On November 22, 2012, the Standing Advisory Committee of the MRWMP recommended that the Ministry of Natural Resources and Forestry (MNRF) review the water management plan for Reach 18 of the Mississippi River to alleviate the wetland die-off upstream from Almonte. MNRF refused. Since then, scientists from MVFN completed a detail study of the die-off and concluded the cause is an overly high water level. The high level is set by flashboards at the Enerdu dam in Almonte. In April 2015, MNRF refused to accept the MVFN’s findings. That ministry rejected science in favour of vague hypotheses.
A second study from MVFN released this month proved that the high-water level created by Enerdu causes a loss of power production at the dam owned upstream by TransAlta Corp. The net result is less hydropower for Ontario. Given that TransAlta loses in this equation, the company may seek some form of compensation or consider a lawsuit for damages.
Therefore, there are the science and environmental concerns, and there is the argument that the new facility in Almonte will not add to Ontario’s energy grid. These are valid reasons for the Province to review the MRWMP.
Shortcomings in the Class EA
Second, I ask that the Province close a loophole in the Class EA for Waterpower legislation that lets the proponent build a generating station of any size inside an urban area without any oversight mechanism that would include municipal elected representatives and/or officials.
In November, the Council of Mississippi Mills passed the following resolution: “The Town of Mississippi Mills requests that the Province of Ontario grant Ontario municipalities the authority to control the design, placement, and scale of any structure related to hydro generation in its urban heritage core.”
Subsequently, at least ten municipalities, the County of Lanark, and the Eastern Ontario Wardens Caucus endorsed our resolution. The reason is simple. The Class EA for Waterpower seems designed for hydro generation on rural waterways. It does not acknowledge a case like ours, where the facility is proposed for the centre of our heritage downtown.
The most glaring omission in that EA is the lack of any method of oversight over the placement and scale of the facility. In Almonte, the proponent wants to erect a two-story powerhouse jutting out into the river, instead of refurbishing the current shore-side facility. I have conferred with all three ministries on this issue and they all confirm they do not regulate the placement and scale. One manager within MOECC told me the facility could have been six-stories high and no ministry would have challenged that. If no ministry is responsible for placement and scale, who is? Is it fair to municipalities to leave those decisions entirely in the hands of the proponent?
I know that the previous Minister of the Environment approved the Enerdu EA, so I am not asking that the Province risk a legal challenge by opening that application. However, I am asking you, Premier, to provide a mechanism whereby our town can require the proponent to justify the need for a new, two-story building instead of refurbishing the existing powerhouse.
This plea is not a cry for special treatment. We are one of many municipalities that insist on a measure of control over all industrial installations within our boundaries. In our circumstance, the new facility will be built in the heart of our community’s heritage downtown. It will forever change the face of our Town.
To be clear, our community is not “anti-green” and this is not a case of NIMBY. In fact, Mississippi Mills is a proud supporter of green energy. Our two solar and three hydro installations generate more renewable energy than the power our town consumes. And we have more solar projects on the way.
To conclude, it would seem at present that all provincial ministries’ review processes and decisions on the Enerdu facility expansion benefit the proponent exclusively. We are hoping that it is possible for Mississippi Mills – both its residents and its natural resources – to get balanced treatment in this matter.
Premier, you are our last resort, and we appeal to you to consult with the three Ministers concerned and for your office to work towards a solution that will duly consider the points of concern with Mississippi Mills residents – and their Mayor.
Premier, if you or your staff have questions about the MVFN study or the negative impact of the Enerdu project on the community of Mississippi Mills, please contact me directly. I would also be pleased to meet with you at your earliest convenience should you wish to discuss this situation in greater detail.
Mayor, Mississippi Mills, Ontario