Response to SREL February 10, 2009 Letter to District

In response to our Option 3 suggestion of locating the power station (as shown here) SREL provided this February 10, 2009 letter to the District Municipality of Muskoka.

Summary

What is missing from this response letter is; information showing that a serious evaluation of the alternatives has been done, comparisons of costs between the Options including any off-setting factor, and an opportunity to interactively work with the proponent to refine the alternatives given feedback and further information.

Detail

We have the following comments on this letter:

1. Page 1: SREL refers to their Option 2 as a “buried option”. While their Option 2 power station is shown to be below highway 169, given that it would rise 18′ above the Moon River (plus the height of any railing / safety fencing), we feel it should not be described as “buried”.
2. Page 2, point 1a: The letter notes that the capacity of the south dam may need to be reduced during construction of a South Channel option and this capacity may be needed during flood flow conditions. We note that the construction plans for SREL’s Option 2 requires a coffer dam to be built in the North Channel while the rock plug is removed, and this coffer dam would also reduce the flood handling capacity. We understand the restrictions needed during construction in the South Channel may be lengthier and would welcome information how many months this would be, and whether this work could be done over two low-flow periods.
3. Page 2, point 1b: We agree that a South Channel option may require it to be deepened, and this would involve significant work. We note that for Option 2, excavation/blasting is required 50′ below the highway and this too would involve significant work. We would welcome receiving detail of why SREL feels these two situations are different.
4. Page 2, point 1c: It may well be necessary to upgrade or modify the south dam as part of a South Channel solution – offsetting this may be that the costs for the temporary bridge required for Option 2 could be avoided for a South Channel option. We understand the construction costs for SREL’s Option 2 may be $24M, and would welcome receiving detail of expected costs for a South Channel option.
5. Page 3, points 2a-c: We would propose fully investigating locating the intake integrated with, or slightly downstream of, the south dam so that it remains somewhat hidden from Bala Bay, has less impact on Diver’s Point, and would require a smaller safety boom.
6. Page 3, point 2d: Constructing the power station on the south side of the South Channel, at the north end of the Canadian Shield parking lot (shown here as Option 4) could keep it hidden from the Moon River, especially if the plant could rise no higher than the existing parking lot and use a method such as stop-logs for dewatering, rather than a solid steel gate.
7. Page 3, point 2e: I agree that construction near/under a railway line will require coordination with the railway, but this is required for SREL’s Option 2, as well as for a South Channel Option. Also, Option 3 would only require closing Bala Falls Road, which wouldn’t be a problem since the highway would remain unaffected, so this would have significantly less traffic impact. For Option 4 it may be possible to re-route traffic highway through the Canadian Shield parking lot and also leave Bala Falls Road open, so again, there could be less traffic disruption and expense than for Option 2. All this would need to be further discussed, but the point is the proposed Options could be less traffic disruption.
8. Page 4, point 3: We agree that the Option 3 we suggested could have substantially lower power output depending on how the discharge is handled, however, the Option 4 we have suggested would have a comparable power output as Option 2. We look forward to the opportunity to discuss this further.
9. Page 4: We note that SREL continues to state that many questions will be answered by the Environmental Screening Report, and also that the Ministry of the Environment’s Guide to Environmental Assessment Requirementsor Electricity Projects (page 33) states “Proponents are encouraged to circulate a draft of the Screening Report, or relevant sections of the report, to the appropriate agencies and key stakeholders for comment prior to the formal review periods.” Yet, SREL has refused to provide any such information both the the District Municipality of Muskoka (certainly a key stakeholder) and to us.