The proposed project would make all this too dangerous to continue …

Jan 272012
 

Summary
Through many communication channels, the proponent continues to provide incorrect information to the public, to the media, and to the Ministry of the Environment.

Detail
The proponent continues to make statements such as:

  • “the flow during the tourist season, which is in the summer, will not change over those falls” (Toronto Star, January 26, 2012).
  • “The typical summer flow through Bala’s North Dam will be maintained” (FAQs, BalaFalls.ca, January 27, 2012).
  • “flows during the majority of the tourist/summer season (June to October) will not experience any change” (Environmental Screening Report, Section 6.3.5.1).

These statements are simply not true, which we show below in five different ways (and using the proponent’s own information).

1) The proponent’s Environmental Screening Report shows in Table 2.1 that the lowest mean monthly water flow through Bala (which is in August) is 23.1 m3/s. Allowing for the 4 m3/s allocated for the Burgess Creek power station, this shows there currently is a mean flow of over 19 m3/s for the Bala North and South Falls – even in August. Yet, the proponent offers only a total of 2 m3/s or 3 m3/s. Obviously the proponent is “mis-stating” something when they say the flow won’t change.

2) Table 5.2 of the Muskoka River Water Management Plan notes that for the Bala North and South Dams “Minimum outflow of 3.0 m3/s from each dam is to be maintained by leakage or log removal to maintain downstream water quality” and “Burgess Power Station provides an additional minimum flow of 4 cms” . Providing a minimum of 6 m3/s of water flow is not the same as the proponent’s proposal to provide only 2 m3/s or 3 m3/s, even though they are claiming there would be no change.

3) In fact, the proponent’s misinformation even has the Ministry of the Environment contradicting itself. In the MoE’s March 25, 2011 elevation decision letter to all requesters, the Director of the Environmental Assessment and Approvals Branch states “Any incoming flows of 20 m3/s or less (which may occur during the summer season) will be distributed entirely over the two Dams and the Project will shut down until the flow increases to operating conditions, i.e. water flows over 20 m3/s.”

However, on the same date, the same MoE Director sent the same requesters this letter which informed us of the cycling agreement the proponent had signed months earlier. And this agreement requires the proposed plant’s operation be cycled (that is, turned off and on, with no additional water over the falls) during these low-flow times, rather than shut down.

So the MoE is providing mis-information to the public, based on either a misunderstanding or mis-information from the proponent. You can be sure the public is equally flummoxed by this confusing information received.

4) The proposed flow can be examined in more detail. As shown in Figure 2.4 of the proponent’s Environmental Screening Report (below, and click for a larger view – and the information is in tabular form in the “Existing” columns here), even during the driest four weeks of the year (weeks 32 through 35 inclusive), the average flow through the Bala North and South Falls is a total of 10 m3/s. Yet the proponent is offering only a total of 3 m3/s (combined for both Falls). This would be a reduction of 70%.

Again, the water flow through Bala would not be maintained, in the summer or any other time of the year. The proponent is making completely incorrect statements about fundamental issues.

5) We can examine the proposed flow graphically by using the following information:

  • The existing weekly flows from the proponent’s Figure 2.4 above.
  • In Section 6.3.5.1 and 6.3.5.2 of the Environmental Screening Report the proponent states that the flow over the North and South Falls would usually be 1 m3/s each, with 2 m3/s over the South Falls from the May 24 long weekend to the weekend after Thanksgiving.
  • In their Letter of Intent, November 30, 2010, the proponent states that the flow over the North Falls would be increased to 9.5 m3/s for two weeks in the spring for Walleye spawning, and to 2 m3/s for two weeks following this for the Walleye incubation period. Further, their letter states that the maximum capacity of the proposed powerhouse is 96 m3/s, so any flows in excess would be over the Falls.
  • Finally, in a letter from the proponent to the Township of Muskoka Lakes, March 18, 2010, the capacity of the south channel is given as 252 m3/s. Adding this to the 96 m3/s capacity of the proposed powerhouse shows the combined flow capacity of the proposed powerhouse and the South Falls to be (96 + 252 =) 348 m3/s. So given the maximum monthly flow of 317 m3/s (April, Table 2.1, Environmental Screening Report), even during the spring freshet, it would not be expected that the North Falls would have any more than leakage flow.

The above information is entered in the “Proposed” columns here, and the resulting proposed weekly flows, are shown below (click for a larger view).

As is clearly shown in the above graph, despite what the proponent says, the flows would be substantially reduced, even in the summer – to a trickle in most all months that people typically visit Bala:

  • From mid-December through January, when snowmobiling is common
  • From May through October, when most tourists typically visit.

Conclusion
So again we say, the proponent continues to make statements – such as “the flow during the tourist season, which is in the summer, will not change over those falls” – these statements about the most fundamentally important issues of their proposed project, which are simply not true.

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