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

Dec 212014

The proponent was selected through a competitive process, based on statements which they appear to be intending on not honouring. For example, in 2005 the proponent stated that their proposed generating station would:

  • Rise only 5' above the ground.
  • Not be above the road (so the view down the Moon River would be preserved).
  • Not affect the swimming and boating in the area.

These were important commitments, which the proponent should be obligated to honour. But the most recent information from the proponent is that the proposed generating station would be 30' above the water, and 21' above the road. And would be so dangerous that Margaret Burgess Park would need to be fenced-off because they would make swimming too dangerous.

In 2004, the Ministry of Natural Resources began a process to enable construction of  a hydro-electric generating station at the Bala falls by making available a small parcel of Crown land directly south of the Bala north falls. The basic arrangement (as specified in this MNR Policy and Procedure) was that due to the expected desirability of the site, a competitive process would be used to select an Applicant of Record (that is, a proponent).

The evaluation of the proposals would use a point system that considered several factors including the types and magnitude of potential impacts of the proposed project and the mitigation strategies for these potential impacts.

The selected proponent would then be eligible to receive the “Feed In Tariff” subsidized rate for power generated and be obligated to operate and perform minor maintenance on the Bala north and south dams.

Based on their proposal (dated July 5, 2005), the proponent, Swift River Energy Limited, was selected by the MNR. You can read the part of their proposal which they made public here (it will take minute or so to download).

Of interest is that the proponent states that the Crown land site made available by the MNR in 2004 is the same as that for the proponent’s current proposal (which they refer to as Alternative 1A). For example, the proponent’s 2012 Addendum to their 2009 Environmental Screening / Review Report (ES/RR) states:

  • In Section 2.1, Project Location: “The ES/RR investigated several alternative locations for the Project, including, but not limited to … the original Alternative 1 location that would be located entirely on Crown lands. Note that this was the original project layout provided to MNR in 2005 for its Waterpower Site Release Program and presented at the first Public Information Centre in August 2007.”
  • In Section 3: “The Alternative 1A project location was included in the ES/RR under a similar layout named Alternative 1. This was the project location that was used in the initial MNR Waterpower Crown Land Site Release process in 2005 and was presented to the public at the first Public Information Centre in August 2007”.

That is, the proponent confirms the site location for their original 2005 proposal is the same as that for their current Alternative 1A proposal. Despite this, the proponent appears to have forgotten about the commitments they made. Below we have highlighted in bold some quotes from the proponent’s original 2005 proposal:

  1. Cover letter: Swift River is aware that the Bala site has substantial beauty for the local population, both permanent and summer residents, and is a tourist gem for the people of Ontario. This is clearly recognized in our proposal.”
    • It was recognized that the Bala site had important tourism and aesthetic requirements, and the proponent committed to addressing these.
  2. Cover letter: Our proposal incorporates the safe public use and enjoyment of the site, attractive landscaping, a public educational component, and the funding of local school scholarships in the environmental sciences.”
    • In fact, the proponent’s current Alternative 1A proposal is not safe, and as a result the proponent has determined they would need to fence off Margaret Burgess Park. This completely contradicts their claims on which they were awarded Applicant of Record status.
  3. Figure 2.2.1: “The power facility would be operated as a ‘run-of-river’ power plant …”:
    • It would not. The treacherously turbulent water from the proposed generating station would begin at about noon on more than of all summer days, just when people would be in the water just a few feet away.
  4. Figure 2.3: A large fold-out page with photographs of people and nature, and captions such as:
    • “Preserving our scenic legacy”; If the “legacy” is the Bala #2 generating station that used to be on the site from 1924 to 1972, this was 16' x 16', but the proposed station would be more than 50' wide x 100' long, there’s nothing even close to scenic or legacy about that.
    • “Creating opportunities for recreation …”; The proposed generating station would have more than 10 times the flow of the previous station. The only thing that would be created are new dangers.
    • “Green power, green space, in harmony”; This would be a poured-concrete bunker, there would be nothing harmonious about it.
    • “Community sensitive green space planning”; The proponent plans on taking 94% of the flow over the Bala falls, they have not shown any sensitivity to the community.
    • “Respecting our cultural heritage”; The proponent was the only objector to the Township of Muskoka Lakes notice to designate the adjacent Portage Landing site under the Ontario Heritage Act, that isn’t respecting anything.
  5. Section 2.2.4: “Our intention is to harmonize the architecture of the new facility with the natural environment of the site by installing a low-profile power house built mostly underground (bunker-type). Its roof will be below road level and only some 5 ft above ground level, creating an excellent vantage point for visitors to view the surrounding …”.
    • The most recent drawings from the proponent show the proposed generating station would be 30' above the water and 21' above the road. This would obstruct the view down the Moon River, which would eliminate a main reason those passing through stop and stay a while.
  6. Section 2.2.4: “Obviously for reasons of public safety, there will be some safety restrictions placed on public access near specific areas at the intake, powerhouse and dam. However, these restrictions will not generally diminish the public’s enjoyment of the area for swimming, boating, fishing, picnicking and hiking.”
    • In fact, in-water recreation would no longer be safe either at the base of the north falls, or for Scuba diving from Diver’s Point.
  7. Section 2.2.4: “One part of our community relations program will be the sponsorship of local sports teams and other community service projects. Another is the establishment of an annual scholarship program that through the auspices of the local Board of Education, will enable deserving college or university students to pursue their studies.”.
    • We’ve never heard the proponent offer this in the nine years since they submitted this proposal.
  8. Section 2.2.4: “In summary, new technology, sensitive development of the site, proper and full consultation in the community will contribute …”.
    • In the nine years the proponent has been pursuing this opportunity, they have held only two public meetings, both for proposals which they have now abandoned. This is not “full consultation”.

The proponent was selected based on the statements in their 2005 proposal. They should not be permitted to substantially change their proposal without additional study and public consultations.

The proponent was allowed to submit their 2005 proposal as a result of their submitting a Statement of Qualifications in 2004, the cover letter for this states: “We have a vision by which the sites can, in a manner compatible with sustainable environmental and aesthetic interests, produce electricity through nonpolluting waterpower in clean, nonoffensive plants in park-like settings.” The proponent’s current plans are that their poured-concrete building would be within a foot of the property line on all sides, rising 20' above the road. This would be offensive, not “park-like”.

In addition, Section 2.1 of the proponent’s 2012 Addendum states: “The footprint and elevation of the Alternative 1A plan presented in this Addendum illustrates the largest building size required for both configurations. Therefore, this size may indeed be reduced following detailed design prior to construction”. However, as noted here, the proponent’s current drawings show their Alternative 1A proposed generating station has a footprint 48% larger than what their 2012 Addendum said was already the “largest building size”.

  • This was a commitment the proponent made as part of their 2012 environmental approval, and they should not be allowed to unilaterally decide they no longer will be bound by their commitment.

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