Section 22.214.171.124 of the proponent’s 2009 Environmental Screening/Review report concerns “In-stream Construction” and states that: “MNR’s Parry Sound District timing restrictions for in-stream construction activities state that no in-water work shall be conducted from April 1 to July 15” and “Therefore, in-water works (e.g., installation and removal of cofferdam and working platform, removal of rock plugs, intake approach channel excavation) are scheduled between July 16 and March 31.”
Section 126.96.36.199 of the proponent’s 2012 Addendum confirmed this: “As per the ES/RR, MNR’s timing restrictions regarding in-water work will be followed during installation and removal of the cofferdam and the cofferdam will be completely removed from the water.”
However the proponent’s construction plans submitted to Transport Canada state: “Installation of the upstream cofferdam will commence on June 1, 2015”. The proponent does not have permission to begin in-water construction work on this date:
- Firstly, it just doesn’t make any sense that the proponent is trying to perform construction for which they do not have approval.
- The proponent cannot simply delay the proposed project by a one and a half months because they must entirely remove the upstream cofferdam before the end of next March to allow for the spring freshet. Given the difficulty and delays of working in the winter, it may not be possible to get all the work needed completed by the end of next March.
We brought this plan for unapproved work to the attention of the MNR, and we hope the MNR will consider this in their on-going review of the proponent’s Plans and Specifications, as is required under the Lakes and Rivers Improvement Act.
We also note that the proponent’s construction plans submitted to Transport Canada state they would begin installation of their downstream cofferdam in September 2014, which has not happened. Given it could not be installed before April 1 as too many issues are currently outstanding, the installation of the downstream cofferdam could also not begin until July 15. This would be almost a year delay to a project that hasn’t started yet.
Construction plans that do not make sense, and schedule problems and delays before a proposed project even gets started should all be of concern to potential investors.