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

Jul 182016
 

In attempting to show they have addressed public safety, the proponent is making incorrect statements, such as these four, our responses follow each.

  1. The MNR’s Section 28 Notice means it is illegal for people to be in the water at the Bala falls.

    This is completely incorrect …

    • Firstly while the MNR did issue a notice under Section 28 of the Public Lands Act, this only applies to the land of the proposed construction site, it does not have any impact on the public’s rights to be in the water.
    • Secondly, as the Moon River is a navigable waterway, the public has a right to use the water, for boating or swimming as they wish.

       

  2. People should not be in the water anywhere near the Bala dams.

    People have a right to be in the water, as it is a navigable waterway. Just 100 m away are the only public docks on the Moon River, and even closer are are three private residences and their docks. The proponent has even proposed portage points between the Bala dams. This is an in-water recreational area.

    • The MNR stated this is an in-water recreational area in the 2005 Request for Proposals which started this entire process. The proponent acknowledged this in their 2005 proposal and again in their 2009 environmental assessment.
    • The proponent stated their proposed project would: “… not generally diminish the public’s enjoyment of the area for swimming, boating, fishing, picnicking and hiking”. It is the proponent’s responsibility to honour their commitments.
    • The MNR does have a red sign on each of the Bala dams, which reads: “Danger, Fast Water, Keep Away”, with four pictographs that are unreadable from any distance (at least one if which could not be interpreted by most everyone). But this sign refers to dangers caused by the dam, not the fast water that would exit the proposed generating station and extend hundreds of feet down the Moon River.
    • People can judge natural dangers such as from waterfalls. That is part of growing up and being Canadian. But this would be a remotely- and automatically-operated danger. How would people be informed of the extent of the fast water which would exit the proposed generating station, and would start without warning.

       

  3. The same amount water would be flowing into the Moon River even if the proposed generating station was built.

    The concern is where does this water enter the Moon River, and would there be warning before it starts.

    • In Bala, the MNR’s “primary water control structure” is the Bala south dam, so most water currently enters the Moon River through the Bala south channel. When stop-logs are removed from the Bala north dam to increase the flow through it, the MNR’s Public Safety Measures Plan for the Bala dams requires: “visual surveillance to ensure no persons are in the dangerous water area and to warn persons to stay clear while changes affecting water flow and level are made.”
       
    •  What the proponent has therefore not addressed is that:
      • Instead of flowing through the Bala south channel, most of the water entering the Moon River would instead be through their proposed generating station, so this fast water would be more than 200′ closer, and be directly adjacent to the very popular in-water recreational area at the base of the Bala north falls.
      • This fast water would start, without warning or local Operator, at about noon on summer days, even though the MNR’s Public Safety Measures Plan requires first warning those in the water.

         

  4. The remote Operator would have video cameras to see if there were people in the water, and the station would slowly ramp-up operation so people could get away.

    These would be nice extra features, but would be completely inadequate as the core of a Public Safety Plan, for example:

    • It would be unacceptably optimistic to trust people’s lives; that some busy and distracted multi-tasking remote Operator would be attentive every station start-up, for the duration of the proposed station’s ramp-up and afterwards, that the cameras would be aimed where people may be, and that the cameras would all be operational and unaffected by sunlight and dirt.
    • And what if people were in an area that would become dangerous, would the Operator wait hours for them to leave.
    • The proposed station’s mininum flow would be twice the flow that caused the 2008 drowning due to the tailrace flow of the nearby Wilson’s Falls generating station. If people who would be endangered by the tailrace flow of the proposed Bala generating station could even figure out what was happening, they would suddenly find themselves in grave danger, and could panic or be unable to escape. Starting the deadly machine in the hopes this would warn unsuspecting people to get away is a ridiculous idea.

       

  5. Transport Canada’s approval confirms the public safety issues have been addressed.
    While Transport Canda did provide approval under the Navigation Protection Act

    Transport Canada …

    • Has no mandate or expertise for in-water recreation such as swimming, wading, or Scuba diving. So there has been no assessment of the impact on these activities either upstream or downstream of the proposed project, so all in-water recreation public safety concerns remain unaddressed.
    • Has no responsibility for boating in the Moon River, so all boating concerns in the Moon River remain unaddressed.

     
     More detail is provided in this article.

Before any construction is allowed to begin, the proponent needs to provide a complete Public Safety Plan, including showing that areas outside of their proposed safety booms would be safe for in-water recreation – as is required by their environmental approvals.

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