Save the Bala Falls

We delegated at the Township of Muskoka Lakes Council meeting on January 18, 2011, our presentation is here.

We delegated at the District Municipality of Muskoka Council meeting on January 10, 2011, our presentation is here.

On November 22, 2010 the Ministry of the Environment started their 30-calendar-day decision period on our requests to have the proposed project elevated to require an individual environmental assessment.

This means that the MoE expects to decide within the next two weeks whether the proponent can build their proposed hydro-electric power station at the Bala Falls (the six possible MoE decisions are described beginning at the bottom of this page).

It was a more than year ago that the proponent released their environmental screening report. Due to the public safety issues, loss of hundreds of feet of the only public shoreline in the area, many major problems, unaddressed issues, wishful thinking, and important details ignored, the community response was massive.

Despite this strong public response, the proponent has since only repeated what they have already stated, with no new information.

Despite being requested by the MoE to study the economic impacts, the proponent’s economic impact study neglected to look at any of the negative impacts, did not interview any business owners or tourists, did not even visit Bala during the summer or even on a weekend to understand how important tourism and the Bala falls are to the area, did not provide any justification for the claims made, and ignored the fact that most of the income to the project would be government subsidies.

The proponent initiated a scenic flow committee, but there has not been any information made available or publicized about this.

If you feel that your concerns have not been addressed, then within the next week:

1. Write a brief letter to Mr. Adam Sanzo, the project evaluator at the Ministry of the Environment, and briefly summarize; your previous concerns, what information you have subsequently received or been able to determine, and what you still need to know. (It would be best not to just re-send your letter from a year ago, the MoE still has these on file.) Let him know that because the proponent has so actively avoided responding to our requests for information and clarification, an individual environmental assessment is required, as only this requires that the public have input into the Terms of Reference of what is to be studied, so we can finally be sure of having our many concerns addressed.
2. Send a copy of this letter to your Member of Provincial Parliament (the MPP for Parry Sound-Muskoka is Norm Miller, and the Minister of Tourism and Culture is Michael Chan) and Member of Parliament (MP) so they know your concerns as well. Let them know most of our previous municipal Councillors were not re-elected, largely due to this issue – this will be of interest to our provincial politicians as the provincial elections are mere months away (on October 6, 2011). Remind them that the top reason tourists come to Canada is to enjoy the natural scenery. Let them know that even though it has been a full year since an unprecedented number of requests for more information were submitted by the public in response to the proponent’s environmental screening report, the proponent has still not provided any new information.
3. Send a copy of this letter to the Township of Muskoka Lakes (it would be best to only send this to Chief Administrative Officer Walt Schmid, due to the current change of Councillors), so that he knows that our concerns are widespread.

   (Contact information for all of the above is here.)

4. Send a copy of this letter to your local newspapers. Let them know that this was a major election issue and most of the previous Councillors did not get re-elected. Let them know that the Architectural Conservancy of Ontario awarded us the prestigious Margaret and Nicholas Hill Cultural Heritage Landscape Award which “recognizes individuals or groups and their projects that have led to a heightened level of awareness and appreciation of Ontario’s significant landscapes.” Let them know claiming to be green doesn’t justify enriching a private developer and bankrupting the local area’s economy. Let them know the previous municipal government had no public consultation on giving away public lands and the use of our water – our primary assets.

In their October 2009 environmental screening report, the proponent offered these proposals to compensate for the fish habitat which would be lost due to the construction and operation of the proposed hydro-electric power station at the Bala falls.

One significant issue is that the proposed power station would virtually eliminate the flow of water over the north dam and this flow is needed for walleye (also known as pickerel) spawning (the spawning areas are shown here and a description is here).

As described at the end of Section 6.2.5.2 of Section 6 of their environmental screening report, the proponent originally offered that since they would take most all of the available water through their proposed power station and not leave at least the 9.5 m³/s of flow over the north dam required for walleye spawning between April 15 and June 1, they would instead provide an additional 200 m² spawning habitat enhancement area adjacent to the exit of the south channel as compensation.

Somehow, the walleye were expected to figure out that if there wasn’t enough flow at the base of the north falls to do their thing, they were to mosey over to a pile of rocks at the south falls to spawn.

Anyways, the proponent subsequently modified the above according to this proposal, dated November 30, 2010. Here they offer that instead of the offered 200 m² compensation area, the proponent would ensure that at least 9.5 m³/s of water would go over the north dam, and they would reduce the amount of water going through the proposed power station if necessary.

Two likely issues are:

1. They would only ensure this 9.5 m³/s of flow over the north dam for a two-week period. If the little fishies don’t spawn during the two-week period, well, they’ll just have to wait until the next year. Talk about pressure to perform.
2. You can be sure there would be disagreement about whether the 9.5 m³/s is in fact adequate for spawning, and whether the proponent was in fact providing 9.5 m³/s of flow. After all, this would just be someone’s estimation of flow by looking at it. And when the people paying your salary and deciding whether you get to keep your job want to make more money by putting more water through the power station, the fish would lose that unfair battle.

And on the topic of unfair, in justifying the lost fish habitat due to the 45′-deep and 36′-wide water intake for the proposed power station which would be where Purk’s Place is currently, the proponent considers this same water intake to be a fish habitat, even though they confirm there would be “entrainment mortality” – this is the technical term for what happens to fish that get sucked into the power station.

Fish and turbines do not a good combination make and (warning, this part is for mature audiences only, may contain coarse language), the fish may encounter:

• “rupture of the swim bladder” due to the rapid pressure change,
• “grinding (when a fish is drawn into an area with small clearance between turbine parts),” and
• “sudden acceleration or deceleration resulting in turbulence and shear forces that could literally tear fish to pieces“ (this text is all directly from the proponent’s environmental screening report).

That is, the proponent is suggesting that fish should raise their young’uns at the intake to their proposed 4,300,000-watt bass-o-matic.

Some have suggested that the hydro-electric power station at Fenelon Falls (this was built about 13 years ago) shows that such a project would be good for Bala (see related article here).

The situation is completely different, for example:

1. There never was, and there isn’t now any in-water recreation directly upstream or downstream of the Fenelon Falls:
   • Here is a photograph looking upstream from the Colborne Street bridge (which runs along the top of Fenelon Falls). Behind the flowers is the water intake channel bringing water into the power station. Note to the right is a concrete retaining wall, and a chain-link fence to ensure people stay away from the dangerous water intake.
   • Here is a photograph looking at the north shore of the river (the ledge of the falls and downstream is to the right). The power station’s tailrace is just to the left of the long concrete retaining wall (which extends a few feet above the ground to form a fence) along the north side of the river.


2. So public safety was not an issue for Fenelon Falls because people couldn’t get near the water anyways. The concrete retaining walls, and the speed and the depth of the water never did permit in-water recreation. There are no docks directly upstream or downstream of the falls.


3. There is a huge amount of concrete all around the Fenelon Falls:
   • Here is lock 34 of the Trent-Severn Waterway, which is just to the north of the power station (which is just to the left). Functional, but not a lot of natural beauty here either.
   • Here is a view upstream, showing the exit from lock 34 on the right, and the power station just to the right of Fenelon Falls.
   • The large concrete structure on the south side of the river is a restaurant (it was initially a saw mill, and later a hydro-electric generating station).


4. So the construction of the Fenelon Falls power station didn’t affect the natural beauty of the area, so would not affect the tourist draw of the area.

In fact, because of lock 34 on one side and the restaurant/mill on the other side, there never were very good places to view the Fenelon Falls, so the additional vantage point from the power station was a fine idea.

But this is not the situation at Bala:

• Bala has natural and publically-accessible shoreline, with Muskoka rock, not the concrete which had already surrounded Fenelon Falls all the way to the waterline and below (and the other shoreline is lined with “No Trespassing” signs).
• Bala has important and constantly-used boat docks both directly upstream and downstream of the falls, Fenelon Falls does not.
• Bala has in-water recreation both directly upstream and downstream of the falls, Fenelon Falls does not, and never did.
• The construction of the Fenelon power station did not displace any businesses, eliminate any portages, or eliminate any of the town’s uniqueness, but at Bala all of these would occur.
• The Fenelon Falls power station is in the middle of a large commercial and industrial area, but in Bala, the proposed power station would be within a few hundred feet of many private residences.
• There are no safety booms upstream or downstream of Fenelon Falls, but the proponent’s drawings show there would need to be two upstream safety booms, and one downstream safety boom at the Bala Falls.
• Apparently there is always enough water to run at least one of the two turbines at the Fenelon Falls power station. However the proponent has stated that during the summer the proposed power station at Bala would need to be cycled on and off every four to eight hours – and we know it is likely that a siren and strobe lights would need to be used to warn the public of this, as this is currently industry practice in Ontario.
• Bala already has many great vantage points to view the falls (and these would be ruined by the proposed power station), whereas much-needed vantage points were provided by the Fenelon Falls power station.
• While the power station in Fenelon Falls is somewhat hidden (and the Falls are many times wider than the the power station), the proposed power station for Bala would be very prominent – rising 20′-high above the Moon River, be a simlar width as the Falls, and would be directly in view of the main vantage points.

Therefore, there are no lessons from Fenelon Falls. It is a different situation. Because of the geography and prior construction of the locks, the construction of the Fenelon Falls power station did not affect public safety. And because of the way the public views and uses the area, Fenelon Falls’ tourism was not negatively affected. But this is not the situation for Bala.