The proponent claims their 2012 Addendum was “factual”, but it was not:
- The proponent’s 2009 Environmental Screening Review Report clearly showed that their Option 2 proposal would not have obstructed the Bala Portage (which has always been south of the Bala north falls).
- But their 2012 Addendum shows that their current Alternative 1A proposal would obstruct the Bala Portage; however this Addendum stated this change would be a “postive impact to portage”.
We see from this letter from the proponent and the excellent coverage by MooseFM of this issue that the proponent has responded to the Wahta Mohawks’ concern about the lack of First Nations consultation for the planned obstruction of the Bala Portage and the Wahta’s subsequent notification that even after the proponent’s claimed consultation, the proponent further negatively impacted the Bala Portage by increasing the size of their proposed generating station by 48%.
Firstly, the proponent stated to Wahta Chief Philip Franks:
The 2009 ESRR design blocked the Moon and Lake Muskoka ends of the purported portage trail. The 2012 Addendum design was a ‘positive impact to the portage’ because only the Moon River end of the trail would be blocked. In other words, the Lake Muskoka end of the trail is not blocked (the ‘positive impact’) by the revised Project design.
As shown by the red line in the graphic below, the proponent’s Option 2 design, which they presented in their 2009 Environmental Screening Review Report would not have obstructed the Bala Portage (click on the graphic for a larger view, and more detail is here):
- The Bala Portage would not have been obstructed at the Moon River (as this area is outside of the restricted downstream safety boom area as shown in their Figure 6.5 – and the proponent would even have provided stairs to facilitate this access as noted in their Section 18.104.22.168).
- And the Bala Portage would not have been obstructed at Lake Muskoka (in fact, in their Section 22.214.171.124, the proponent recommended Diver’s Point as an alternate location, just as is shown in the graphic below).
In fact, the information presented by the proponent in 2009 would have allowed the Bala Portage to continue to be used as it was by David Thompson in 1837 and by the First Nations even before that, from what is now called Portage Landing on the Moon River to Diver’s Point on Lake Muskoka, details here.
Clearly, the proponent’s 2009 Environmental Screening Review Report showed that the Bala Portage – south of the Bala north falls – could continue to be used.
However, as shown below, the proponent’s 2012 Addendum shows that for their current Alternative 1A plan, they relocated the planned site for their proposed generating station with the result that it would obstruct the Bala Portage at the Moon River. This is due to; the province’s actions in building the Muskoka Road 169 highway bypass in 1965, the location of the opening in the highway guardrail, and the slope of the land at Portage Landing. The result is that all of the routes which may have been used by the Bala Portage over the years, for which the proponent’s own study attempts to speculate, would be obstructed.
In summary, the Bala Portage has always been south of the Bala north falls. The proponent’s 2009 Environmental Screening Review Report showed that for their proposed Option 2 design, the Bala Portage would not have been obstructed. But the proponent’s 2012 Addendum showed that for their currently-proposed Alternative 1A design, the Bala Portage would be obstructed. This change is definitely not a “postive impact”.
Secondly, as is further detailed here, in the proponent’s 2012 Addendum they provided a drawing of their proposed Alternative 1A generating station, the outline of which is highlighted in blue below (the red line is the Crown land property boundary).
However, 18 months later – over a year after all claimed consultation was completed – the proponent provided a new drawing of their proposed Alternative 1A generating station as part of their Driveway Entrance permit applications. The blue line below highlights the new outline.
Carefully measuring the areas of both of these Alternative 1A outlines shows that after the proponent finished consultation and after they received environmental approval for their 2012 design, the proponent increased the footprint of their design by 48%. The Bala Portage lands are culturally significant to the Wahta and other First Nations of the area, and there should have been consultation on this further negative impact on these lands.