A consultant working for Enerdu recently completed a Heritage Impact Assessment (HIA) to be sent to the Ministry of Tourism, Culture and Sport. Enerdu was ordered to prepare the HIA by environment minister Jim Bradley last year, in order to “help guide the conservation of identified built heritage resources and cultural heritage landscapes.”
At tomorrow’s Committee of the Whole meeting the Town’s Heritage Committee, chaired by Jason Gilmore, will recommend that Council approve its report describing “inconsistencies, errors or unclear aspects” of Enerdu’s HIA. The report makes for interesting reading:
The Mississippi Mills Heritage Committee has prepared a response to the Enerdu Heritage Impact Assessment. This response is on the agenda of the Committee of the Whole for Tuesday August 12.
THE CORPORATION OF THE TOWN OF MISSISSIPPI MILLS
DATE: August 12, 2014
TO: Committee of the Whole
FROM: Jason Gilmore, Chair, Mississippi Mills Heritage Committee
SUBJECT: APPROVAL OF HERITAGE COMMITTEE COMMENTS ON THE ENERDU
HERITAGE IMPACT ASSESSMENT
THAT Committee of the Whole recommends that Council approve the comments prepared by the Mississippi Mills Heritage Committee on the Enerdu Heritage Impact Assessment;
AND FURTHERMORE THAT the comments be forwarded to the Ministry of Tourism, Culture and Sport (Heritage unit) on behalf of the Town.
The final Enerdu Heritage Impact Assessment (HIA) was released by the proponent’s consultant Content Works Inc. in July 2014.
The Mississippi Mills Heritage Committee has reviewed the final HIA report and has prepared its comments in order to clarify or point out a few inconsistencies, errors or unclear aspects of the final report. The Heritage Committee believes that doing so will help the Ministry reviewer.
As the Heritage Committee is an advisory committee to Council, it is seeking Council’s authority to submit the cover letter and comments on the final Enerdu HIA.
There are no financial implications associated with this recommendation.
The Heritage Committee has prepared its comments on the final HIA and is seeking Council’s authority to submit the comments on behalf of the Town.
Respectfully submitted, Reviewed by:
Jason Gilmore, Diane Smithson,
Heritage Committee Chairperson Chief Administrative Officer
Cover letter and comments on final Enerdu HIA
August 13, 2014
To whom it may concern:
In relation to the Mississippi Mills Enerdu project for which you are currently reviewing the Heritage Impact Assessment (HIA) as requested by the Minister of Environment, the Mississippi Mills Heritage Committee would like to provide you with some additional comments after our review of our copy of this final HIA. We believe there are some errors, omissions or lack of clarity on a few issues mentioned in the HIA, and we wanted to bring some clarity for you on these points. You will find them all described below.
Chair, Town of Mississippi Mills Heritage Committee
cc. Diane Smithson, Town of Mississippi Mills CAO
Julie Harris, ContentWorks Inc. (consultant/author of Enerdu HIA)
Muriel Kim, BluMetric Environmental (Consultant for Enerdu)
1. Widest crossing error – Page 19, Last sentence
This sentence reads: “The widest crossing of the Mississippi River at Almonte begins next to the Almonte Flour Mill….” (Bold added)
This is not the case, as a Google map of the Mississippi River in Almonte can confirm; the widest crossing of the Mississippi River at Almonte is located about 1/2 km east, near the Almonte Fairgrounds. In particular, this error could be quite misleading for the MTCS Heritage Planner reviewing the Final HIA, given that many residents are very concerned about the reduced width of the river at precisely the area where the new powerhouse is intended to be located (i.e. next to the Almonte Flour Mill) which is one of the most narrow areas of the river. The proposed powerhouse would reduce the width of the river to only 39 meters between the outer wall of the proposed powerhouse and the wall of the Barley Mow restaurant located in a designated heritage building.
2. Riverchannel – perceived vs. actual, Page 25, last sentence
This reads: “The construction of the power house will also change the perceived width of the river channel”.
However, the change is to the actual (not perceived) width of the river channel. Currently about 54.5 meters from designated heritage building and will be reduced to 39 meters. Page 34, “The powerhouse will obscure view of the bridge (Figure 36), and change the appearance of the river’s width”. (All bold added) It would be more accurate to simply say, “…. and reduces the river’s width”.
3. Historical Development and Site Analysis, Page 9 – 2nd paragraph
It reads: “The neighbourhood near the property includes residential, manufacturing and commercial uses”. (Bold added) The reference to manufacturing is the Hydro Components building across from the Flour Mill (Fig. 13), but that building is not included in the study boundary (Figs. 8 and 11), so is somewhat misleading. The neighbourhood within the study area includes only residential and commercial uses.
4. Powerhouse – design (various references)
Several areas in the Final HIA including the proposed process in Appendix 5 indicate “the proponent will choose the final design”. However, in a letter to the Town from the proponent on March 11, 2013, the proponent agreed that the MMHC and Town would be consulted during the detail design phase and “the goal of these proposed discussions is to arrive at a mutually agreed-upon design for the proposed powerhouse that will satisfy the needs and concerns of all parties involved.” It would then follow from this written agreement, that both parties would mutually choose the final design.
5. Lack of Assessment of Net Effects as per the OWA Class EA, and no discussion regarding “how effectively the mitigation will address potential impacts” as per the MTCS letter.
As per MTCS letter, “when impacts are identified, a report needs to provide mitigation options consistent with best practices in cultural heritage resource conservation, and to include a discussion on how effectively the mitigation will address potential impacts” (bold added)…. and as per the OWA Class EA — “The assessment of the significance of net effects after impact management and mitigation should consider the value of the resource affected, geographic extent of the effect, duration and frequency of the effect, irreversibility of the effect….” . “The proponent may also determine that the importance of net effects, the costs of mitigation or the significance of unresolved issues makes the project unfeasible.”
In the Final HIA, Page 31 it states: “Some potential adverse impacts from the Enerdu Project cannot be fully mitigated.” Furthermore, with respect to mitigation recommendations that were suggested in the Final HIA, there was no discussion that actually describes “how effectively the mitigation will address potential impacts” nor is there an assessment after mitigation of net effects in accordance with the OWA Class EA.
Powerhouse –The HIA acknowledges “the project is located in a sensitive location in the Mississippi River Cultural Landscape, and it will insert a relatively large 21st century work (the powerhouse) into the landscape”. It provides some mitigation suggestions “to lessen the negative impacts”, but does not indicate how effective the mitigation efforts will be. For example, the stone cladding as suggested by the proponent may look nice, but at the end of the day, the Enerdu powerhouse will still be a large building inserted into the river landscape and out of scale with its surroundings. Case in point, the new powerhouse will be only 39 meters from a designated heritage building adapted a few years ago as a restaurant with a riverside patio.
Furthermore, the powerhouse and intake weir will extend out to the 3rd of 7 heritage railroad bridge piers and will mostly or totally obscure the 3 piers depending on the vantage point. The Ontario Waterpower Association Class EA provides guidelines under Section 4.3.1 Assessment of Effects, Page 38 which could have aided the consultant in assessing the net effects after mitigation, or in some cases, assessing the effects where no mitigation is possible.
Obermeyer weir / gate – As a follow up to a public comment, the HIA reads: “The final HIA includes revised mitigation measures, but no mitigation is proposed for the Obermeyer gate.” However, even with the reduced footprint for some of the weir sections, again there is no discussion on the effectiveness of the mitigation or of net effects (with respect to the new weir, at the widest part the footprint will still be about 6 times that of the current weir, in the middle about 4 times that of the current weir, and at the weir closest to the Riverwalk, about 2.5 times wider than the existing weir in that area.) There is still a significant negative effect.
The HIA states that the project will now allow for an aesthetic flow which will pass over all weir sections during the daytime in the summer to reduce visual impact. However, on Page 26 it reads, “In low water periods, the new weir will be almost completely exposed…..; the Obermeyer gates will also be visible.” It also says that the new weir will be almost completely exposed as the weir is today, however, as indicated above, the footprint of the new weir is significantly bigger than that of the existing weir. See Figure 32 which is a picture of the current weir at a low water period and which clearly shows the much smaller footprint as compared to what the proposed new weir would look like in low water periods (see Figure 10, bottom left in which the concrete base and rubber bladder illustrate a much more significant intervention than that of the current weir).
6. Figure 7, Conceptual Drawing provided by Enerdu.
When the draft HIA was presented to the Heritage Committee, the HIA heritage consultant had agreed to include a revised rendition of the Enerdu drawing which shows the piers as being spaced more appropriately so that the viewers have a more realistic impression that the 7th and final pier ends in line with the Barley Mow Restaurant. However, the final HIA notes that the revised drawing is not included for reference. The Enerdu rendition gives the impression that the proposed new powerhouse and intake canal are much farther away from the Barley Mow than they would be in relation to how the piers are portrayed.
7. Parks Canada Guidelines references, page 34
In the HIA page 34, the consultant referred to the “Parks Canada, Standards and
Guidelines for the Conservation of Historic Places in Canada: A Federal, Provincial and Territorial Collaboration” document, in relation to the design of the powerhouse: “The design should address, to the greatest extent possible, the building’s orientation, scale, massing, composition, proportions, colour and texture.” (Footnote 52; this footnote refers to the Parks Canada document).
The consultant then goes on to say: “Further guidance on addressing these elements is found in the Standards and Guidelines”, and lists a few examples about proportions, massing, etc… However, the guidelines in the Parks Canada document are also very helpful with respect to Spatial Organization in cultural heritage landscapes.
In the Standards and Guidelines document, Section 4.1.4 with respect to Spatial Organization for Additions or Alterations to a Cultural Landscape, it states that what is not recommended, and that is “introducing a new feature that alters or obscures the visual relationships in the cultural landscape, such as constructing a new building as a focal point, when a character-defining vista was traditionally terminated by the sky.” The proposed powerhouse would be a new feature, a constructed new building which would be a focal point in the cultural heritage landscape. The character-defining vista is currently not terminated by the sky, but certainly it is in part defined by the natural shoreline in front of the existing power plant, the natural step falls and the bridge with its 7 piers (the natural shoreline and step falls would be totally eliminated and 3 of the 7 railroad bridge piers would be mostly or totally obscured.
8. Public Comments – Appendix 1
a) Page 2, last comment:
Public Comment: “Draft HIA does not reference the Official Plan.”
Response: “The final HIA includes a reference to the Official Plan.”
However, the comment was included in Mr. Chris Grosset’s letter (you should have a verbatim copy, provided by the consultant) on Page 2, 4th paragraph which reads:
“The Draft HIA does not reference the Official Plan and the way in which the land use has changed over time to result in the current zoning used by the municipality for the area within the study boundary.”
He goes on to say in the paragraph on the following page of his letter: “The omission of contemporary land use zoning (which according to the official plan of the municipality are Commercial, Residential, and Open Space within the boundary used for the study) is not reflected as part of the evolution of the landscape.”
Thus, while the Official Plan is indeed referenced in the HIA, it is not referenced in the context in which this comment was written.
b) Another comment which surrounds the powerhouse which was posed by several people is that the proposed powerhouse would be “out of scale with its surroundings”, as it would jut significantly into the river channel. The HIA uses language that indicates the powerhouse will be “relatively large”, but this descriptor does not address the concern that it would also be out of scale in relation to its position in the river (and would be a mere 39 meters between its outer wall and the wall and riverside patio of the Barley Mow, a designated heritage building now adapted for use as a restaurant).
c) Additionally, the first comment on Page 1 of Appendix A regarding mitigation measures and monitoring was asked in a different and broader context (i.e. that any mitigation measures be monitored and not just those for the powerhouse, in order to “verify the extent of effects [and compare actual with predicted effects], effectiveness of impact management strategies and whether additional measures are warranted” in accordance with Provision 4.5. Effects Monitoring, Ontario Waterpower Association Class EA, Page 43). Furthermore, the response would lead one to believe that there is a sub-section in the HIA labelled “monitoring”, which there is not.
d) Page 5 of Appendix 1
Public Comment: The consultant should be following an officially sanctioned methodology, as required by the Government of Ontario in the letter presented in Appendix 1, otherwise how is the community to feel confident that the HIA has been completed with full consideration of all relevant information, and that the findings are free of bias.
Response: “….. The Final HIA generally follows the guidelines of the MTCS in letters and documents, but no guides have contemplated the complexity of the heritage conditions in Almonte in the context of this type of proposed intervention.
However, as this project is guided by the OWA Class EA which provides is own very clear guidelines and processes (and frequently references the Ontario Heritage Act), it is confusing as to why the guides would not be applicable in this case.
OWA Class EA, Page 57, Section 5.3.8 states that “The EA Act defines environment broadly to include cultural conditions that influence the life of humans or a community.
Cultural heritage resources are important components of those cultural conditions. Therefore, a standard aspect of EA processes in Ontario involves assessing the effects an undertaking may have on known or suspected cultural heritage resources and assessing those effects.” The document is very clear that if cultural heritage resources are located within 300 meters of the proposed site, that further technical heritage studies be undertaken by the proponent before the EA is finalized to allow for public input and impact assessment prior to any approvals. Furthermore, the framework in the OWA Class EA provides the direction that if significant net effects remain after mitigation, the proponent should either revisit the impact / issue management strategies, or ultimately defer or cancel the project. Also, as noted above, Section 4.3.1 Assessment of Effects, Page 38 provides guidance in assessing the net effects after mitigation, or in some cases, assessing the effects where no mitigation is possible.
On page 31 of the Final HIA, there is a Mitigation Listing from the OWA Class EA. In the
OWA Class EA, this information is included under Appendix B, “Examples of Mitigation Measures for Potential Environmental Effects”, Section 2.3. However, at the beginning of Appendix B, it is stated that “The following are examples of the types of mitigation measures generally considered for waterpower projects. This is not an all-inclusive list. Alternatives to the measures listed below may be considered and/or implemented as circumstances dictate.” Therefore, as this list is not exhaustive, and although in terms of the powerhouse, it may be designed so that its design is sympathetic to the existing built heritage attributes, the mitigation recommendations do not take into account any consideration of the proposed large and out of scale structure in relation to its intended insertion in the river landscape.