Jul 302011
 

It really is quite simple

This is a page from our presentation to the Township of Muskoka Lakes Council, May 16, 2011, the entire presentation is here.

We just want to know whether the project would be safe for the visiting public, whether the structure would be beautiful, and whether there would be enough scenic flow so the Bala Falls could still be called the Bala Falls.

Jul 292011
 

People of all ages are drawn to the waterfalls and the natural beauty. And both would be no more if this proposed generating station was approved.

Jul 272011
 

Summary
Transport Canada has not responded to questions concerning public safety. 
 

Detail
Transport Canada is the responsible authority for many of the public’s concerns for the proposed hydro-electric generating station at the Bala Falls.

We have found that the proponent will not provide responses that answer our questions, so we have posed these directly to Transport Canada, with no response, as summarized below.

  1. On May 5, 2010 we sent this e-mail to Transport Canada. We were requesting information for some of the concerns we detailed in our response to the proponent’s environmental screening report, including:
    • Why the proposed upstream safety booms use a design which does not facilitate self-rescue.
    • The rescue procedures and responsibilities required for people hanging onto each of the upstream safety booms, and for boats held against these safety booms.
    • Explain how water speeds comparable to those during spring runoff would be safe during the main summer recreation period, directly adjacent to the town docks. 
       
  2. We promptly (on May 7, 2010) received this reply from Transport Canada in which they state they “will work on getting a full reply to you”, and that “a direct reply will be provided to you”
     
  3. After not receiving a reply for 4 months, on September 21, 2010 we sent this follow-up e-mail asking when Transport Canada would be able to respond to our May 5, 2010 e-mail, and also whether Transport Canada has authority for the safety aspects of the proposed project for in-water recreational activities, such as swimming. 
     
  4. After another 4 months of waiting, on January 19, 2011 we sent this follow-up e-mail (along with the original attachments) noting we were still awaiting a response to our May 5, 2010 e-mail and also that we continue to have many public safety concerns, such as:
    • How the upstream safety boom can be considered safe given that its concave design works against self-rescue.
    • That children are being encouraged to swim upstream of the water intake, as part of the Bala Regatta. 
       
  5. There has been no further communication from Transport Canada.

It is now over a year since asking these questions, and all we have received from Transport Canada is the one response that they would respond.

Given that the proponent hasn’t replied to these public safety concerns either, what is the public to do. The environmental assessment process includes public consultation requirements, but the proponent, Transport Canada, and the Ministry of the Environment will not respond to the public’s concerns.

Jul 272011
 

Summary
Transport Canada appears to be providing approvals for which they are not qualified.

Marine navigation approval from Transport Canada is being erroneously accepted as confirmation that in-water recreational activities, such as swimming, can continue upstream of the proposed hydro-electric generating station at the Bala Falls. 
 

Detail
For this proposed project, we understand Transport Canada’s mandate is marine navigation. For example, approving the design and location of the safety booms.

However, we understand that Transport Canada has no expertise or mandate for in-water recreational safety. This is confirmed in the second page of this e-mail from Transport Canada, where they state “Transport Canada does not have authority over swimming safety”.

Yet, we see in the second page of this letter concerning the Bala Regatta, Transport Canada states: “I have corresponded directly with the Bala Aquatic Association concerning their historic regatta and you have addressed their concerns in the ESR (2.2.5.7) and with the surface water velocity and plant flow figures (6.1, 6.2c). Their activities should be able to continue as they have planned.”

Concerning this remarkable statement from Transport Canada we note the following:

  1. First, Section 2.2.5.7 of the proponent’s environmental screening report simply notes what the Regatta is, that some activities take place from the town dock, and that it includes swimming activities. Figures 6.1 and 6.2c show the flows throughout the year and at different locations, but have no information on whether swimming and other recreational activities would be safe. And certainly, there is no mention of the currently-required cycling operation which would periodically increase the flow above historical the historical values, further increasing the danger to in-water recreational activities both upstream and downstream of the proposed generating station. We therefore do not understand what information or justification Transport Canada has to state of the Bala Regatta that “Their activities should be able to continue as planned”
     
  2. Second, both the proponent’s environmental screening report and our response to the proponent’s environmental screening report noted that the Bala Regatta includes swimming activities (as well as fun boating activities where participants often end up in the water). We do not understand how Transport Canada can be providing any advice on the safety of in-water recreational activities given that they do not have, and have confirmed they do not have any “authority over swimming safety”
     
  3. This letter from Transport Canada was written to Hatch Ltd., the environmental consultant used by the proponent, and as a result the proponent’s response to our swimming safety concerns (as e-mailed to SaveTheBalaFalls.com, and dated April 1, 2010 – no joke!) stated “Transport Canada has reviewed completed study reports and noted that the upstream Town Docks will be able to be used during the project operation in the same way as it presently is. Transport Canada has also noted that the Regatta activities may be conducted in their present form following the building of the project. Transport Canada has communicated this directly to the regatta organizers.” That is, the proponent believes they now have confirmation that swimming in the area would be safe. 
     
  4. And the Ministry of the Environment has also accepted this misinterpreted and erroneous information, as they have replied to us (in their March 25, 2011 letter denying the elevation request) “The Town Docks located upstream of the Project, will be unaffected by construction and operation with regards to access or navigation and will have no impact to the annual boat regatta …”. The boat regatta includes swimming activities, there is no such confirmation that there will be no impact.

We have detailed this concern in our request to the Minister of the Environment to review the Director of the Environmental Assessment and Approvals Branch’s decision to deny the requests that this project be elevated to require an individual environmental assessment (see pages 2, 5, and 15 to 18).

Jul 242011
 

People are drawn to water

The proponent would use a 10-ton jacking device to compress the dam’s stop-logs to allow only 1 m3/s of leakage flow over Bala’s north falls. Such a trickle would not draw people to Bala. The proponent would take 94% of the water through their proposed generating station, leaving only 6% for the falls.

Note that by international agreement, during days from April through October, 50% of the flow of the Niagara River must go over the falls, and the rest of the time (summer evenings and all winter), 25% of the flow must go over the falls. The rest of the flow is diverted and is shared equally between Canada and the US for power generation.

Why should scenic flow in Bala be any less important than scenic flow at Niagara Falls.

Jul 242011
 

The environmental assessment process has no obligation to find the best solution for all stakeholders

The environmental assessment process is a “greedy grab” where the proponent throws consultants and paid experts into the process to see how much they can get away with.

The public is left to be on stand-by for years to respond within days when a document or report (which has been in development for months or years) is released.

There is no requirement for the process to find the best solution for a community, or even to look for some measure of balance between the needs of the community versus the developer doing as they please (that is, spending the least while taking the most).

The water and the land are public resources, yet the public has no say in how they are used. The proponent’s “public consultation” has only been them telling us what they are planning on doing.

Jul 232011
 

In April 2011 the world-reknown National Geographic has published their list of the 10 Best Trips of Summer 2011 and Muskoka is number 1.

This is world-wide – Muskoka rates better than Patagonia (that would be in Argentina), Glacier Bay National Park in Alaska, and the Azores (Portugal). See the Toronto Star article.

But once people get to Muskoka, they’ll only come to Bala if there’s something to see. Muskoka is big, and there’s lots to do.

People won’t come to Bala to see dry rocks where the falls used to be. People won’t come to Bala to stand on a concrete building, feeling the vibration and listening to the drone of the 4 million watts of machinery below. They don’t want to look at a river (they can do that on the Internet), they want to touch the river.

What it unique about Bala is the falls and the natural shorelines and the water. People come to Bala to access the water, to stand on the shore, to fish, and to swim.

The proposed generating station would ruin all this. The world knows this is special, we need to protect it.

Jul 222011
 

Even though it is required by the environmental assessment process, there has been
NO meaningful public consultation.

For all the years of this process, the proponent has frustrated the public and the process as they only repeat their evasive responses rather than answering the questions asked. We have noted this abuse of process here and here.

The proponent has not accepted any public input, the only changes have been to increase the proponent’s revenue.

We still don’t even know what the appearance of the proposed structure would be, we’re not even allowed to post our concerns (see the proponent’s “…cannot be copied…” restriction above), such as noting that the provided rendering is impossible, as it has no provision for cooling the machinery (the louvres on the front are fake as there would be the 30′-wide steel tailrace gate directly behind them).

Jul 222011
 

People come to Bala to be near nature, not huge concrete generating stations.The proposed project would make most of the publically-accessible shoreline too dangerous for the public.People won