Sep 162013
 

On September 13, 2013, SaveTheBalaFalls.com had the opportunity to present an update to the Township of Muskoka Lakes Council.

The presentation is here.

Additional information provided subsequently follows:

Summary

  • The insurance cost cited is from this MNR report.
  • The proponent’s dangerous flow simulation shown would occur throughout the year, including many times each summer.
  • The required cycling operation would both amplify the lower flows of the summer, and would result in the proposed station’s operation beginning – silently and without warning – just when people would already be in the water. The result would be extreme danger and drownings.
  • Despite repeated requests, the proponent has not had an organization competent in swimming safety provide comments or suggestions on their current proposal.

 Detail

1) Concerning the insurance cost cited in this article:

  • This information is from this Ministry of Natural Resources’ recent study entitled “Economic Impact of Waterpower Projects on Crown Lands in Ontario”. Section 3.11 Costs, Table 2 (page 5) provides annual operating costs per MW of station capacity, where of the Total Operating Expenditures of $134,000, the Insurance Premium is $75,000.
  • I might add that this report carefully tallies economic benefits, but does not present any negative economic impacts, and therefore provides an incomplete and deceptive conclusion. Last year, I therefore sent this letter to the MNR, and received this response. Remarkably, the MNR simply replies that providing a balanced view of the economic impact was “beyond the scope of this project”.

 

2) Concerning how often the high flow used in the proponent’s flow simulation presented here would actually occur:

Firstly, this flow simulation is from the proponent’s Environmental Screening Report Addendum, released July 20, 2012, and this last page is entitled “Flow Velocity Field, Downstream Channel, Post Development, Q=98 cms”. This flow therefore represents the proposed generating station operating at full capacity, as confirmed by Section 2.1.2 of this Addendum.

Since February 2013, SaveTheBalaFalls.com has had an analysis of the Moon River water flow posted here, some conclusions from this and the proponent’s information provided are as follows:

a) While the average flow through the generating station in the summer months is typically low, it would be amplified by the required cycling operation:

  • For example, Section 2.1.6.1 (page 2-5) and Figure 2.4 of the proponent’s 2009 Environmental Screening Report shows that the flow through the Bala North Falls is typically less than 10 m³/s during the summer months (as any excess water now flows through the Bala South channel). However, the proponent would be required to operate the proposed generating station in a cycling mode operation during low flow periods “such that its operating discharge is 26 cms or more” (according to the December 15, 2010 signed agreement with Ontario Power Generation). Therefore, the flow at the base of the Bala North Falls would be increased during plant operation from less than 10 m³/s to more than 25 m³/s – an increase by a factor of more than 2½.
  • And shown in “Detail – Cycling Operation” here, this cycling operation would occur for about ⅓ of summer days, with operation beginning soon after 11:00 am on those days (which would be the most likely time for people to be in the water near the tailrace of the proposed station).

Therefore, this substantial increase in flow would occur often enough to be significantly dangerous.

b) Operation at the station’s full capacity is shown in “Detail – Running at Full Capacity” here:

  • It shows that during the 44 years of historical water flow data available, the station would have run at full capacity at least ten times during most every week of the year – even the summer weeks.
  • Specific analysis is provided for the most recent years the data was available, including that the station would have run at full capacity in 2009 both until May 25 and from July 31 to August 3. In 2008 the station would have run at full capacity; to May 26, from June 10 to June 25, from July 4 to 6, from August 12 to 20, and from September 16 to 22. And in 2007 the station would have run at full capacity to May 6, and from July 21 to 22.

That is, the station would operate at full capacity, as shown in the proponent’s flow simulation, many times each summer. So the drowning danger would be present often enough to be significant.

As noted, this information has been posted on the SaveTheBalaFalls.com website for over six months and we have not received any concerns about its accuracy. As always, contact us at info@SaveTheBalaFalls.com to discuss this data, the calculations, or anything else on the website.

 

3) Concerning our claim that drowning would result from the proposed station’s tailrace being so close to the in-water recreational area at the base of the Bala North Falls:

To begin with an example, I don’t think one needs any particular qualification other than some common sense to say that children should not play on the shoulder beside a busy highway.

  1. Further, when the proposed station is operating at full capacity (often enough, as noted above) the speed of the water from the tailrace would be faster than an Olympic swimmer can swim – as is noted here. Given the water exiting the station’s tailrace would be churning and turbulent due to the station’s turbine rotation, I think it is common sense that even when operating at less than full capacity, for example at the 26% for the required cycling operation, people would still drown in this fast water which would be just feet from where people would be swimming.
  2. I should note that despite repeated requests, the proponent has never had an organization competent in swimming safety provide any suggestions, concerns or advice about their proposals. I would be happy to defer to such input.
  3. Given the proponent’s extremely biased view, unsubstantiated assurances of safety from them should be ignored.
  4. I should also note that as provided by the example of the Moon River Property Owners Association’s concerns that known rocks and shoals in the Moon River are not marked, there is no organization responsible for public safety. As the Township of Muskoka Lakes would be the most affected by drownings due to the proposed station, it would be in the Township’s interest to pursue their own confirmation of public safety independent of the proponent.

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