January 29, 2013

Mayor John Levi

Town ofMississippiMills

3131 Old Perth Road

PO Box400

Almonte,ON  K0A 1A0

 DELIVERED BY HAND

Re: The Enerdu Project – Planner’s Comments, January 22, 2013 (The Comments)

Dear Mayor Levi,

We have lived at80 Clyde Street in Almonte since June 2010. Our property is on the north shore of the Mississippi River just east of St Paul’s Anglican Church. The house was constructed in 1867.

 

The Almonte waterfalls and the Enerdu Power Plant are not visible from our waterfront. However, as riverside residents who swim and boat on the river and as residents who value Almonte’s historic downtown, we must express our dismay at the incomplete and superficial manner in which Almonte’s Planner has responded to the Final EA Assessment (the EA Report) concerning the Enerdu Project (the Project) at the Wylie Flour Mill.

Our concerns are listed here and will be discussed below.

i)                The Comments do not include an opinion on the overall suitability of the Project. A separate planning report is needed to address this issue.

ii)              The Comments fail to take a realistic approach to the losses which will be suffered by the downtown businesses.

iii)            The Comments appear to suggest that Enerdu may conduct its hoe‑ramming and blasting work during the summer.

iv)             The Comments fail to note that the EA Report does not recommend that soil stability or riverbed toxins be studied.

v)               The Comments fail to address the scale of the new powerhouse.

vi)             The Comments fail to note that, contrary to the EA Report, the Project will not be a “run of the river” facility.

vii)           The Comments fail to note that the EA Report mischaracterizes the Project when it describes it as a “redevelopment” and an “expansion”.

viii)         The Comments suggest that the powerhouse will be cosmetically acceptable if it is “compatible” with the present Wylie Flour Mill. This suggests that Enerdu will be free to clad its powerhouse in shiny corrugated steel.

Discussion

 i)                The first paragraph of the Comments indicates that the Planners have not included an opinion on the Project. How can it be that Almonte’s planning experts have not provided an opinion about whether, from a planning perspective, the Project is suitable for Almonte’s downtown historic riverscape? We suggest that our planners should immediately be directed to issue a separate report which describes the positive and negative aspects of the Project and includes an unbiased, well reasoned and fully explained conclusion.

ii)              The Comments downplay reality when they say that the Project’s construction “may” disrupt Almonte’s summer festival and tourist business. The fact is that construction will inevitably be loud, dirty and lengthy and will drive the public away and harm already fragile downtown businesses.

iii)            The Comments are vague. They suggest that the Project be “completed” in September. This language can be read to allow Enerdu to construct during an entire summer period as long as the work is finished in September.  If the Planner meant to say that Enerdu should be limited to excavating and hoe-ramming only in September, the Comments should have clearly stated that fact. As presently written, the Comments do not clearly take issue with summertime construction.

iv)             The Comments are incomplete. It is inconceivable to us that the Planner would not comment on the EA Report’s failure to require a study to determine whether toxins are present in the riverbed which could pollute the river if dislodged by the excavation and hoe-ramming.  It is also inconceivable that the Planner failed to note that no studies were recommended to determine which buildings and properties on the river and elsewhere in town might be damaged by the proposed excavation and hoe-ramming.

v)               The Comments do not refer to the large scale of the new powerhouse and the extent to which it will dwarf the river, the falls and the Riverwalk.

vi)             The Comments seem to accept that the EA Report’s description of the Project as a “run of the river” facility is accurate when it is obvious that the present power station and the Project involve weirs that interrupt the waterflow. In our view, the term “run of the river” is employed to suggest that the Project is a natural and therefore a welcome undertaking.

vii)           The Comments fail to observe that the Project is almost entirely new construction. The powerhouse, the weir gate and its foundation are all new structures. In our view, the description of the Project as a “redevelopment” and an “expansion” is an effort to downplay the scale of the Project to make it appear less invasive.

viii)         Regarding cosmetics, the audio tape of the meeting held at the Townhall on April 11, 2012 discloses that, in response to a question we posed, Mr. Jeff Cavanagh’s representative (who made it clear that he spoke for Mr. Cavanagh) committed to cladding the new powerhouse in stone. However, the Comments show that the Planners were unaware of this commitment. The Comments say that an exterior that is “compatible” with the present Wylie Flour Mill will suffice. The problem is that, at the moment the Flour Mill on the riverside, is clad in shiny corrugated steel. Accordingly the Comments suggest that the Planners are prepared to accept a shiny steel building dominating the downtown riverscape. This is completely unacceptable. The Planner must be asked to consider whether the appearance of the powerhouse should be compatible with the Townhall and other historic buildings by being entirely clad in stone in accordance with the commitment Enerdu has already made.

These deficiencies taken together give us the impression that the Comments were prepared with a view to minimizing the impact of the Project.

  •  To conclude, we oppose any steps by Council to facilitate or approve the Project because:
  •  It is not supported by a comprehensive planning report;
  •  There is no evidence of any benefit to the town ofAlmonte– the only benefit is to one resident;
  •  The property and environmental damage it may cause have not been adequately studied;
  •  Damage to struggling businesses on Almonte’s main street has not been estimated and no provision has been made requiring Enerdu to compensate businesses for their losses;
  •  There is no requirement that Enerdu compensate Almonte and/or private property owners for physical damage to buildings or properties; and
  •  As riverside owners we have riparian rights which entitle us, among other things, to access to quality water. In our view, at present, there is no reason to believe that those rights are adequately protected.  This area was highly polluted in the era of the woolen mills and there should be positive evidence from an independent study showing that the area to be excavated and hoe‑rammed is free of toxins.

Respectfully submitted,

Sandra Simpson and Allan Mann

cc:       Mr. Bernard Cameron

Mr. Garry Dalgity

Mr. Alex Gillis

Mr. Rick Minnille

Mr. John Edwards

Mr. Shaun McLaughlin

Mr. Paul Watters

Mrs. Val Wilkinson

Mr. Duncan Abbott

Mr. Denzil Ferguson

MississippiMills Chamber of Commerce

MississippiMills Heritage Committee

Mississippi RiverWatchers

 

Muriel Kim

OEL – HydroSys Inc. a Blumetric Company

3108 Carp Road

P.O. Box430

Carp,ON  K0A 1L0

 

Sarah Nugent

Ministry of Natural Resources

10 Campus Drive, Post Bag 2002

Kemptville,ON K0G 1W0

 

The Hon. Michael Gravelle, Minister

Ministry of Natural Resources

Suite6630, 6th Floor,

Whitney Block

99 Wellesley Street West

Toronto,ON  M7A 1W3