The following letter was sent to the Ministry of the Environment on March 14, 2011.
Hello Mr. Sanzo,
Dam Failure
It has come to our attention that the work required to construct the proposed hydro-electric power station at the Bala falls should trigger a public safety assessment. Such requirements are in draft documents from the Canadian Dam Association and the Ministry of Natural Resources.
This would be prudent, given that the proposed project would involve rock blasting down 60′ within 65′ of the north dam – which is over 50 years old.
Given that the water level of Lake Muskoka is 20′ higher than the Moon River, and given the huge 120 km2 area of Lake Muskoka, a Bala dam failure would be catastrophic; to people and structures downstream, to boats and marine life upstream, and to the proponent’s finances.
According to the draft “Technical Guidelines and Requirements for Approval Under The Lakes & Rivers Improvement Act, Volume Three – Life Cycle Management of Dams“, Chapter 2, Section 2.2.3, this situation would be classified as “High Hazard Potential”.
Therefore, information is required from the proponent concerning:
- A risk assessment of what could happen, what areas would be affected, how these risks would be controlled, and what level of risk is acceptable.
- What steps would or could be taken to ensure the dam structure is not damaged.
- How the dam’s integrity would be monitored during and after blasting.
- The roles and responsibilities of each involved party, in the event of an emergency. This would be especially important, given the complex arrangement of the dam owner, the developer, the contractor, the dam operator, and the various levels of government.
- Insurance requirements and liability of each involved party.
Control System Failure
Furthermore, given the large flow capacity of the proposed power station (of perhaps 79 m3/s), as the plant’s control system could fail, the following should be documented:
- How the operator would be alerted of a failure (what failures would be automatically alterted, how would the public be able to contract the operator).
- The capability, steps, and time required to manually shut down the flow given a failure of one or more of each component (such as the control electronics, the control valves, or their actuators).
Conclusion
While Section 2.1.6.1 of the proponent’s environmental screening report notes that a Dam Safety Assessment was performed in 2000, this only considered flooding due to high flow events, not dam failure – and this Assessment certainly did not consider the possiblity of failure due to the proposed nearby rock blasting.
These are fundamental science-based, technical, public property, and public safety issues which need to be considered as part of evaluating this proposed project.
As this information has not been provided by the proponent, we therefore request that this project be elevated to an individual environmental assessment so that these serious issues can be properly addressed.
Thank you.
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Mitchell Shnier, on behalf of SaveTheBalaFalls.com
25 Lower Links Road
Toronto, ON M2P 1H5
Telephone: 416 222-1430
E-mail: Mitchell@Shnier.com