Required Cycling Operation Needs Scientific Study

Summary
We have sent this letter to the Ministry of the Environment detailing our concerns on the major development that the proponent would be required to operate their proposed generating station in a cycled operation during the peak in-water recreation time every summer.

Detail
On March 28, 2011 we were informed that the Director of the Environmental Assessment and Approvals Branch made a decision to deny all the requests that this proposed project be elevated to require an individual environmental assessment.

The process allows that the Minister of the Environment can be requested to review this decision, and many submitted such a request, including SaveTheBalaFalls and the Township of Muskoka Lakes (others are posted under Recent Articles). These requests detailed many concerns.

As a result, the Ministry of the Environment requested additional information from the proponent, for example about the cycling operation (despite the proponent claiming for years that the more benign run-of-river operation would be used, the MoE recently informed us that cycling operation would be used for at least 8 weeks every summer). As a result, the proponent provided this response to the MoE.

So we have now learned the following:

• That the proponent is just now, a year and a half after filing their “Notice of Completion”, considering to use something called infrasound generators to keep fish away from the proposed generating station’s water intake, even though there are many reasons why these can be expected to not be effective.
• The cycling would need to be at least for 8 weeks, from mid-July to mid-September, but depending on the rainfall, could be from mid-June to late November.
• We have no assurances from the proponent that the proposed cycling would be a maximum of once per day, as they have previously written that it would be every 4 to 8 hours. We don’t even know that they can commit to such an assurance, as they would be required to accomodate the needs of Ontario Power Generation.
• The public would need to be warned (industry practice is to use sirens and strobe lights) before the proposed generating station would be cycled on each day, and the proponent would attempt to do this when the public would not be present – so this siren could need to be run every day of the summer at 6:00 am.

This change that the proposed generating station use a cycled operation is so significant, the proponent should be required to re-issue their environmental screening report and provide a public comment period. Or, as the public has been requesting for over a year, this project should be elevated to require an individual environmental assessment.

As a result, we have sent this letter to the Ministry of the Environment detailing our concerns.