North Glengarry BESS ECA…

North Glengarry BESS ECA Application (ERO 025-089, Ministry Ref: 3623-
DJLLE2) for the approval of stormwater management works to serve a lithium-ion battery storage project site located at 1454 Skye Road, North Glengarry.

I have been involved with the project for a period of time. I attended the second public consultation meeting with the original public meeting poorly advertised and the public apparently unaware of the time or place.

The second meeting entailed a much larger public attendance and included some Township of North Glengarry council members. The public asked pertinent questions and were given limited, I would suggest, vague responses to their concerns such as fire response, environmental impacts, cyber security. When asked where the stored power would go when needed, the Compass representative, without hesitation, stated, “Ottawa”. However, the North Glengarry BESS Project website, under “Benefits to the Community, states, “The North Glengarry Bess Project will provide power to meet growing regional demand in the area”

A certified Ontario Civil Engineer with expertise in stormwater management and the environmental approval process, was asked to provide a professional evaluation of the proposed plan based on the publicly available information.
The concerns were:

Firewater Management Plan (The Critical Flaw): This is the single greatest environmental risk of a BESS facility. The proposal mentions containment but fails to specify the design
capacity of that containment. To be compliant with standard engineering practice and Ontario regulations, the containment system must be sized to hold:
1. 110% of the volume of the largest liquid-containing unit (e.g., transformer coolant).

2. Plus the total volume of water from the fire suppression system for a worst-case fire
duration (which can be thousands of gallons for many hours).

3. Plus precipitation from the 25-year, 24-hour storm event. The absence of this critical detail in the public summary is a major red flag.

Insufficient Detail on Toxic Runoff Treatment: The plan must detail the specific strategy for containing, testing, and disposing of severely contaminated firewater, which will contain toxic chemicals like Hydrofluoric Acid (HF) and dissolved metals. Standard stormwater ponds are not suitable. The public documents do not demonstrate how this will be addressed.

Hydrogeological Impact Assessment: A critical component for any project of this nature is a detailed assessment of the subsurface conditions (soil permeability, depth to groundwater). This is essential for modeling contaminant migration and protecting local groundwater. The adequacy of this assessment cannot be determined from the public summary.

Lack of a Public Decommissioning Plan: A responsible proposal would include a plan for the end-of-life recycling/disposal of the batteries, demonstrating life-cycle environmental
responsibility. This is not mentioned. ______________________________________

Meanwhile throughout the summer the company, began construction of the project without, I believe, all of the required documents submitted. For example, there is no dedicated "Indigenous Consultation Report" or "Aboriginal Engagement Summary"
This is made apparent by the Ministry of the Environment, Conservation and Park’s own comment on the ERO posting, dated April 11, 2024:

"The Ministry is in the process of consulting with Indigenous communities and will consider any comments received through that process in its decision-making."

It appears that there is no public record of any consultation process with the Mohawk Council of Akwesasne prior to Compass/North Glengarry BESS Inc. submitting the application for an ECA, as required by the Ministry of the Environment, Conservation and Parks.

For these reasons I request that North Glengarry BESS ECA Application (ERO 025-089, Ministry Ref: 3623-DJLLE2) for the approval of stormwater management works to serve a lithium-ion battery storage project site located at 1454 Skye Road, North Glengarry not be approved.