On May 31, 2012 the proponent released an Addendum to their 2009 Environmental Screening Report in an attempt to fulfil their environmental assessment requirements for their New Proposal which could apparently be built solely on Crown land.
According to the regulations, an Addendum is allowed for “minor modifications to projects, and to require consultation on changes that are environmentally significant.” For the following reasons, we believe this is not a “minor modification”, and in fact this is a New Proposal which has never been presented to the public before, as it would have a:
- New site – as it would no longer use municipal land (it is important to note the proponent’s original 2005 proposal and the information presented at their 2007 public meeting required municipal land for Option 1).
- New location and orientation (the dangerously turbulent water exiting the tailrace would be more than 60′ closer to the base of the north falls and would be angled substantially more towards the shore and the base of the north falls, as compared to the Option 1 as previously presented to the public).
- Different technology (possibly using two vertical turbines rather than a single horizontal turbine, this would kill more fish).
- Different operating regime (the cycling operation now proposed was not discussed in their Environmental Screening Report).
All of these changes have significant negative impacts on; public safety, appearance, traffic delays, risks to the north dam and highway bridge, risk of flooding Lake Muskoka, use of areas such as Margaret Burgess Park and the Precambrian Shield parking lot for storage of construction materials, and so on.
As noted above, there should have been public consultation for such changes, but the proponent has not offered this.
So that we all can fully evaluate these major changes, we requested an extension to the deadline of June 29, 2012 for public comments on this New Proposal, but the proponent has refused. We look forward to responses from the Ministry of the Environment concerning the public’s comments on the proponent’s New Proposal.