The following letter was sent to the Ministers of Natural Resources, Energy, and the Environment.
March 9, 2011
Linda Jeffrey
Minister of Natural Resources
Whitney Block, 6th Floor, Room 6630
99 Wellesley Street West
Toronto, ON M7A 1W3
416 314-2301
LJeffrey.mpp.co@liberal.ola.org
Brad Duguid
Minister of Energy and Infrastructure
Hearst Block, 4th Floor
900 Bay Street
Toronto, ON M7A 2E1
416 327-6758
BDuguid.mpp.co@liberal.ola.org
The Honourable John Wilkinson
Minister of the Environment
77 Wellesley Street West
11th Floor, Ferguson Block
Toronto, ON M7A 2T5
416 314-6790
minister.moe@ontario.ca
Dear Ministers,
Summary
The proposed Bala Falls hydro-electric generating station has significant outstanding water flow and water level issues which have not been addressed by the proponent. Furthermore, the proponent’s recent agreement with Ontario Power Generation requiring the proposed station not use the previously stated “run-of-river” operation has not been communicated to the public, and this is especially a concern due to the resulting public safety issues.
We applaud the Ministry of the Environment’s science-based decision and policy-making procedures, but in this case, the proponent has not addressed the science, as described below.
Detail
As you may know, there is currently a proposal to build a hydro-electric generating station at the Bala Falls, in Bala, Ontario.
For over five years, the proponent has stated this proposed station would implement a “run-of-river” operation, as this:
- Would be more acceptable to land owners on Lake Muskoka and the Moon River.
- May be required by the Muskoka River Water Management Plan (MRWMP).
- Is better for shoreline animal habitats and vegetative buffers.
However, we recently learned that the proponent would be required by Ontario Power Generation (OPG) to operate this proposed station in a peaking mode (also called a cycling, ponding, or storage mode) to accommodate the interaction with a downstream OPG facility and their other requirements.
This highlights several concerns we have, including the following:
- Why has the public not been consulted, nor even informed of this significant change. Changes to the Muskoka River Water Management plan require such public involvement.
- The control of the water level of Lake Muskoka, which has many, many shoreline structures which are very sensitive to water levels, would be by a private company that would not be subject to any penalties for unacceptable water levels even if due to their own negligence or for-profit motivations. The proponent has stated the only recourse would be for private individuals to each initiate legal action for each occurrence of damages.
- This is a concern, as the proponent would have significant financial motiviation to operate the Lake Muskoka water levels at the high end of the allowed range – or even to regularly exceed the allowed range – as this would maximize their revenue from the proposed power station (this is because for a given flow of water, a greater “head” results in more power produced). However this would leave less margin of safety before flooding would occur due to an unexpected significant storm.
- The proponent has requested that the MRWMP be modified to allow a “Best Management Zone”. However, rather than explaining the rationale for this major amendment (as defined and required according to Section 17.2 of the MRWMP), the proponent only explains this was requested by the Ministry of Natural Resources, and no rationale has been forthcoming from either party.
- This peaking/cycling mode of operation would be mainly required during the low-flow summer months, exactly when there is the most in-water recreation at this very popular tourist destination. This unannounced and remotely-controlled change in water flow is exactly the concern of the OPG/OPP “Stay Clear, Stay Safe” campaign as this would be a major public safety issue, and was not addressed by the proponent’s environmental screening report. Transport Canada apparently only has jurisdiction for marine navigation, so there is no stakeholder agency taking responsibility for this public safety issue (other than informal comments by the OPP that this project should not proceed).
In conclusion, there are significant and unaddressed water-related issues for this proposed project.
We therefore request that this project be elevated to require an individual environmental assessment, so that the public can have input to the information which needs to be provided by the proponent.
—————————————————————————————-
Mitchell Shnier, on behalf of SaveTheBalaFalls.com
25 Lower Links Road
Toronto, ON M2P 1H5
Telephone: 416 222-1430
E-mail: Mitchell@Shnier.com
cc: Mr. Adam Sanzo, Project Evaluator, Environmental Assessment and Approvals Branch