Dear Premier-designate Doug Ford …

Summary
While we look forward to your keeping your commitment that your new government will stop construction of the proposed hydro-electric generating station at the Bala falls, all Ontarians will be comforted to know this can be done by simply requiring the proponent to fulfill the commitments they made for their FIT contract and environmental approval.

Please reply, do you need more reasons than this to stop the proposed project until the proponent shows they would fulfill all of the contractual and environmental commitments below.
 

Detail
When you visited Bala on February 27, 2018 (Facebook video here, copy here) you committed that if the Progressive Conservative Party of Ontario forms the next provincial government, you would stop the proposed project to build a hydro-electric generating station at the Bala falls.

We are well aware that Ontarians are rightfully outraged that the Liberal’s poor planning of stopping the proposed Oakville and Mississauga generating stations resulted in Ontario paying cancellation costs of more than a billion dollars.

For the proposed Bala project, there need not be any cancellation costs as all the provincial government has to do is require the proponent to abide by the commitments made for the approvals they have received. For example:

1. The proponent’s Feed-In Tariff contract requires:
   1. The proposed project be in commercial operation by May 11, 2019.
      • The proponent’s own internal report (North Bala G.S. Project Outline and Update, March 13, 2014) by the design consultant WSP shows they would not be in commercial operation until many months after the deadline.
         
   2. The generating capacity of the proposed project must be at least 4.5 MW.
      • The proponent’s own internal report (North Bala G.S. Project Outline and Update, March 13, 2014) states the generating capacity would be less than this, and since then there have been at least three design changes which would further reduce the generating capacity.
         
2. For their environmental approval, the proponent stated:
   1. Their proposed project would make the water in the Moon River dangerous for less than 34′ downstream from their proposed generating station. 
      • They have since shown their proposed project would make the water downstream of their proposed project treacherously-fast and -turbulent more than double this distance, and extending outside of their proposed downstream safety boom.
         
   2. Their proposed project would make the water in the Bala north channel dangerous only up to the current upstream safety boom.
      • But the Point of No Return calculation used by Transport Canada and the Ontario Ministry of Natural Resources and Forestry shows the operation of the proposed Bala project requires that this upstream safety boom be relocated farther upstream. This would prevent the only boat rental in the area from renting boats, which would have a significant negative impact on the boat rental and the area’s economy.
         
   3. The minimum flow through their proposed project would be between 14 and 20 m³/s.
      • But the proponent has since stated the minimum flow would be between 26 and 30 m³/s, which is three times the flow which caused the 2008 drowning of a 16-year-old boy at the nearby Wilson’s Falls hydro-electric generating station.
         
   4. The height of the generating station would not be above road level (so the view down the Moon River would not be obstructed by this concrete industrial facility).
      • The proponent has since shown their proposed generating station would rise three storeys above road level.
         
   5. The width of the generating station would be 33′ to 40′ wide, and the footprint would be 400 m².
      • The proponent has since shown their proposed generating station would be more than 60′ wide, and the footprint would be more than 600 m².
         
   6. They would not dump sediment into the Moon River, would treat all water pumped from the proposed construction site, and there were no hazardous materials in the excavated material.
      • The proponent did directly dump blasted rock into the Moon River, their water treatment system did not have the capacity or components required, and they did not adequately test for hazardous materials.
         
3. The Environmental Assessment Act states that the Ministry of the Environment and Climate Change has responsibility for human life, and the 2017 decision by the Environmental Review Tribunal cancelling the proposed Fairview wind turbine project near Collingwood, ON confirms both this.
   1. The MOECC must therefore seek expert input when they do not have expertise required.
      • The MOECC does not have expertise, and did not seek the expert input required to assess public safety (Transport Canada’s mandate and expertise only concerns boating, not public safety for in-water recreation). The MOECC has therefore not fulfilled its obligation to protect human life.
         
   2. The MNRF’s Public Safety Measures Plan for the Bala Dams requires that those recreating in the Moon River be warned before flow is increased.
      • However the proposed generating station would not have a local Operator and it would be remotely- and automatically-operated. It would therefore not be possible to adequately warn those that could be drowned of the start-up of the proposed generating station.