Oh, Now Cycling is Not Cycling

In a remarkable development, the proponent has redefined the english word “cycling” to mean “not cycling“.

• Exhibit 1: In the April 22, 2011 edition of the Muskoka Weekender (the article is here), we learn that “The definition of run-of-river can include minor cycling …”. So that rather than a constant output of water from the proposed hydro-electric generating station, it would be turned off and on daily, and this can still be called run-of-river.
• Exhibit 2: Months ago, and without telling the public, the proponent signed an agreement with Ontario Power Generation requiring the proposed station to be cycled when the flow available is less than 26 m³/s. Read it for yourself in point 3 here. This is fully 1/3 of the proposed station’s capacity:
  • Firstly, this is hardly “minor”.
  • This flow is typical for eight weeks during the summer tourist season. So the plant would be turned off and on at least once every day during the core in-water recreation period.
  • So scuba divers upstream, and children portaging their canoes directly adjacent to the station’s tailrace downstream would have no way of knowing whether the station is operating or not. And 26 m³/s of water is 26 tons of water per second, that’s the weight of more than 26 small cars per second, this is major turbulence, and a serious unaddressed public safety issue.
• Exhibit 3: The proponent’s Letter of Intent for Works or Undertakings Affecting Fish Habitat (provided to Fisheries and Oceans Canada in November 2010) notes on page 6 that the fish habitat would be “subject to relatively constant hydraulic conditions”. This would certainly not be the case. Similarly, the analysis in Section 6.2.5.6 (entitled “Fish Impingement, Entrainment and Turbine Mortality“) of the proponent’s environmental screening report for fish entrainment (that is the term used for fish getting sucked into the proposed plant’s turbines, killing a percentage of them) does not consider this operation and does not cite any studies with this operation. And the environmental screening report has no information on how this unnatural and daily cycling operation would affect the shoreline habitat of nesting birds and other wildlife.
• Exhibit 4: The proponent would be paid 50% more – yes that is correct 50% more – for power produced during the daily periods of peak electrical demand. You can bet this for-profit developer would do almost anything for this bonus (heck, who wouldn’t want this). And in fact, even though they’ve been telling us for years that the proposed station would be run-of-river, the agreement with OPG shows they intend to operate the plant in a cycled mode during other times of the year as well. You do need to read between the lines, in point 1 it is called “optimized”. Sometimes it is called modified peaking, or load cycling, or storage, or peaking. Lately, even the Ministry of Natural Resources has been playing with words and calling this “essentially run-of-river”, or “intermediate”. Apparently the secret phrase to really mean run-of-river is “run flat”. Silly naïve us, we didn’t know that when the proponent says “run-of-river”, we need to also ask if it would be “run flat”. I guess you need to be a hydraulic engineer to be that smart.

The point is, the required operation of the proposed hydro-electric generating station would not be run-of-river (during at least the peak summer in-water recreation times), the public has not been informed, and the proponent’s environmental screening report and information provided to Fisheries and Oceans Canada is incomplete.

This is yet another shameful instance of the proponent trying to withhold information the environmental assessment process requires to be disclosed. This is not a partner to the community, this is a private developer abusing the process.