Save the Bala Falls

The following e-mail was sent to the Ministry of the Environment on July 6, 2011.

Hello Mr. Sanzo,

As described in the attached letter, we are concerned that the proponent has not addressed the significant environmental issue of the change in direction of the water entering the Moon River.

As a result, there are unaddressed public safety and marine navigation issues.

Thank you for your attention to this.

Mitchell Shnier, on behalf of SaveTheBalaFalls.com

The proponent has made statements which are misleading and which are “less-than-truthful” (much less). We have therefore sent this letter to the Ministry of the Environment and the Ministers of the Environment, Tourism and Culture, Natural Resources, and Energy and Infrastructure, and also to our MP.

Summary
Some of the many unaddressed concerns about the proposed hydro-electric generating station at the Bala Falls are here.

Some History
To summarize what has happened so far:

• October 2009 the proponent issued their environmental screening report.
• November 2009 we detailed many unaddressed issues (as did many members of the public).
• March 2011, the Director of the Environmental Assessment and Approvals Branch of the Ministry of the Environment denied all the requests that this project be elevated. The MoE also sent a letter to the proponent which included the agreement which would require the proposed station to use a cycled operation.
• March 2011 we sent our concerns about cycling operation to Fisheries and Oceans Canada. We received a response that they are working on a response.
• April 2011, we requested that the Minister of the Environment review the Director’s decision. The Township of Muskoka Lakes also sent in a request (as did many members of the public). The Moon River Property Owners’ Association also sent in a request, this included the 156 questions gathered by the Township in response to the proponent’s statement that they would only accept written questions (the proponent has not yet responded).
• June 2011, due to additional information received, we detailed some of our unaddressed concerns about the cycling operation.

Summary
We have sent this letter to the Ministry of the Environment detailing our concerns on the major development that the proponent would be required to operate their proposed generating station in a cycled operation during the peak in-water recreation time every summer.

Detail
On March 28, 2011 we were informed that the Director of the Environmental Assessment and Approvals Branch made a decision to deny all the requests that this proposed project be elevated to require an individual environmental assessment.

The process allows that the Minister of the Environment can be requested to review this decision, and many submitted such a request, including SaveTheBalaFalls and the Township of Muskoka Lakes (others are posted under Recent Articles). These requests detailed many concerns.

As a result, the Ministry of the Environment requested additional information from the proponent, for example about the cycling operation (despite the proponent claiming for years that the more benign run-of-river operation would be used, the MoE recently informed us that cycling operation would be used for at least 8 weeks every summer). As a result, the proponent provided this response to the MoE.

So we have now learned the following:

• That the proponent is just now, a year and a half after filing their “Notice of Completion”, considering to use something called infrasound generators to keep fish away from the proposed generating station’s water intake, even though there are many reasons why these can be expected to not be effective.
• The cycling would need to be at least for 8 weeks, from mid-July to mid-September, but depending on the rainfall, could be from mid-June to late November.
• We have no assurances from the proponent that the proposed cycling would be a maximum of once per day, as they have previously written that it would be every 4 to 8 hours. We don’t even know that they can commit to such an assurance, as they would be required to accomodate the needs of Ontario Power Generation.
• The public would need to be warned (industry practice is to use sirens and strobe lights) before the proposed generating station would be cycled on each day, and the proponent would attempt to do this when the public would not be present – so this siren could need to be run every day of the summer at 6:00 am.

This change that the proposed generating station use a cycled operation is so significant, the proponent should be required to re-issue their environmental screening report and provide a public comment period. Or, as the public has been requesting for over a year, this project should be elevated to require an individual environmental assessment.

As a result, we have sent this letter to the Ministry of the Environment detailing our concerns.

When I was growing up our family pet was a West Highland Terrier (this is the white dog of Black & White Scotch – my father would always note he was the “pee-anist” in the family). Mozart was adorable, but dumb and could not be trained, find his way home, or remember the limits of his rope when there was a squirrel to be chased.

When offered cheese to do a trick, he would get so excited that his little brain would overload and he would ignore all prompts and do everything he knew at the same time; he would beg, roll-over, sit, and shake-a-paw simultaneously (comical to watch, but there was never any progress on this reward-for-learning effort).

The proponent is doing the same thing, they’re saying anything and everything, without thinking it all through and without ensuring it all makes sense. They just want their approval to proceed because then they expect we would have to accept whatever bad news turned out to be required – maybe barbed-wire fencing, strobe lights and sirens, too much noise and vibration, a look-out that isn’t at the water’s edge, blasted rocks piled up the side of a concrete cube as the best they can do to disguise this 120′-long poured-concrete ugliness, a 75′-long and 15′-high driveway retaining wall, a town’s economy ruined because people won’t come to see where the falls used to be, a dangerous water intake scaring people from using the town docks, and on and on.