People would drown

Our main concern about the proposed hydro-electric generating station at the Bala falls is public safety, which the Ministry of Natural Resources and Forestry has stated they will consider as part of their upcoming assessment of the proponent’s application for Plans and Specifications approval for permanent works under the Lakes and Rivers Improvement Act. We look forward to continued dialogue on how this would be addressed.

That is a polite way of saying we are baffled why too many people don’t care that this proposed generating station would drown people.

Here are eight particular concerns:

1. The situation at the Bracebridge Falls would not apply
    The MNR assumes that because Bracebridge Generation Ltd. operates the Bracebridge Falls generating station that the proponent using Bracebridge Generation could operate the proposed Bala station safely. However, in Bracebridge:
   • There is a 110′-long concrete breakwater directing the flow away from the municipal docks. Bala would have no such protection.
   • The Bracebridge swimming area is 800′ away. But in Bala people would be swimming just a few feet away from the treacherously turbulent water exiting the proposed station.
   • The flow from the Bracebridge station is less than ⅓ of what it would be in Bala.
      
2. The MNR incorrectly believes Bala’s in-water recreation could be stopped
   • The fast and extremely dangerous water exiting the proposed Bala station would continue at least 300′ downstream of the proposed station. The MNR’s warning sign on the Bala north dam would not apply that far and people couldn’t even see it at that distance.
   • There are nearby public and private docks from which people have the right to enter the water and would expect that a “neighbour” has not made the adjacent water deadly.
   • Due to the private shoreline ownership downstream, fencing and “no swimming” signs could not be posted in the required locations to indicate areas of danger.
      
3. Transport Canada’s approval is inadequate
    The MNR is depending on Transport Canada’s approval issued under the Navigation Protection Act, however:
   • This did not consider swimming, scuba diving and wading, as these are not within Transport Canada’s mandate or expertise.
   • This did not assess impacts to boating downstream, as the Navigation Protection Act excludes the Moon River from Transport Canada’s consideration.
   • Transport Canada assumed summer flows would be only 21 m³/s, as this is the average flow in July and August. However, the proposed Bala station would operate at full capacity about 21 days every summer – resulting in flows more than four times this.
     • Considering only the average flows from the proposed Bala station would be like building your house without a roof because it usually doesn’t rain.
        
4. The Wilson’s Falls drowning
    In 2008 a 16-year-old boy drowned as a result of attempting to swim past the fast and turbulent flow from the Wilson’s Falls generating station (this is a few km north of Bracebridge):
   • While it is rare for people to be swimming at, or even visiting, Wilson’s Falls, Bala is an extremely popular in-water recreational area.
   • The flow from the proposed Bala station would be more than ten times that from the Wilson’s Falls generating station.
      
5. The required cycling operation would make this even more dangerous
   Due to the required cycling operation, the proposed Bala station would start, automatically and without warning, at about noon on about ⅓ of summer days – just when people would be in the water only a few feet away.
    
6. It would be unprecedented to build a hydro-electric generating station in the middle of an extremely popular in-water recreational area
    Visiting 32 hydro-electric generating stations in southern Ontario shows that:
   • None are located in the middle of an in-water recreational area, with directly adjacent boating, swimming, and scuba diving.
   • None have public and private docks as close.

   That is, it would be unprecedented to locate a hydro-electric generating station in the middle of a recreational area, yet the proponent has not shown how they would, or even if it would be possible to, operate the proposed Bala station safely.

7. The Royal Lifesaving Society says a safety plan is needed now
    Despite these many in-water dangers, the proponent has not had a competent authority assist with required measures. So we commissioned the Royal Lifesaving Society, who are Canada’s lifeguarding experts, to assess the situation, and they found: “… this development would create an unusually and extremely dangerous situation, and therefore requires a commensurate level of planning … [which] should be started and completed before any construction proceeds, to both ensure it would be practical to implement, and so that any required changes could be incorporated into the design of the proposed station.”
    
8. It would bankrupt Purk’s Place
    As shown by their Public Safety Measures Plan, the Ministry of Natural Resources uses a calculation from Transport Canada to determine the location required for the upstream safety boom. The location and dangers of the intake for the proposed Bala station would require the upstream safety boom to be relocated farther upstream. As a result, boats could not reach Purk’s Place docks, and this would shut down a key part of this important local business.