Photo by Linda HeronPhoto Credit

William A. Allen – Comments to Xeneca – Ivanhoe River, The Chute

September 4, 2011

William A. Allen
9 First Ave., Box 85
Burk’s Falls, ON P0A 1C0

Vanesa Enskaitis
Public Affairs and Stakeholder Relations
Xeneca Power Development
5160 Yonge Street, Suite 520
North York, ON M2N 6L9

Ref: (416) 590-9362 X104; E-mail

Dear Ms. Enskaitis,

Re: Ivanhoe River – The Chute

Further to my letter of August 12, 2011 to you please note that I write as a private citizen of Ontario, one of the citizens with whom Xeneca has made a “binding commitment” through the Class Environmental Assessment process. (Ref: The Chute Environmental Report [ER] Foreword, unnumbered page F4). I write in open format to share with others who may be interested.
Thanks for your communication of August 15, 2011:

  • acknowledging Xeneca’s receipt of mine of August 12,
  • your notice that you have added my contact details to the Stakeholder Contact List for the Ivanhoe River projects
  • your further notice that you have sent my questions to the appropriate staff and consultants and
  • your notice that Xeneca will get back to me in a timely fashion.

Since Aug. 15 I have received no further communication from Xeneca or representatives of Xeneca. As a result Xeneca has not followed through in a timely fashion with me as promised. Nor does your website provide answers to my questions. I continue to not be satisfied with The Chute proposal or the evaluation process and now am not satisfied with Xeneca’s lack of communication with me.

Since Aug. 12 I have made a personal visit to various parts of the Ivanhoe River Watershed including The Chute and Third Falls (as well as Second and First Falls) and their respective proposed inundation zones. I found information that is not available in any of the documentation that Xeneca has shared with the public. Nothing during those visits reduces the concerns that I raised in my August 12 letter to you. In addition to the points which I raised on August 12 please note the following points. Continue reading

ORA Elevation Request – The Honourable John Wilkinson, MOE – Bala Falls

May 6, 2011:


In light of the numerous concerns, which ORA feels have not been adequately addressed, and out of respect for the mass public disapproval of this proposal, we request that an Individual Environmental Assessment be required for this proposed project, so that the public can be assured that the negative environmental impacts have been adequately mitigated.

However, we are alarmed to have learned that all such elevation requests in the last ten years have been denied. This is totally unacceptable, and indicates that the EA process is broken and is not adequately serving the public’s interest. We therefore request that you intervene as is your power and authority, and vary the Director’s decision.

Continue reading

ORA Comments to Township of Muskoka Lakes – Bala Falls

August 31, 2011:


ORA has reviewed the responses sent by Swift River Energy Limited (SREL) to the 156 questions provided to them. Far too many of the important questions are simply not answered by SREL. For example,

1. Proposed Project Design – is vitally important, and these questions were either completely ignored, or incorrect. The final project design is incomplete and inconsistent, so how can any responsible and ethical decision be made in favor of SREL.
2. Economic Impact Study – The proponent again conveniently disregards questions regarding the Economic Impact Study, or answers, but does not address the intent of the question. The integrity and intent of this Study is left in serious question with the lack of timing, sampling and application, so it has no meaning or usefulness.
3. Aesthetics – Questions regarding noise levels, business and tourist impacts, final appearance and landscaping have not been answered. Also, the public asks the important question about how much scenic flow there would be over the north and south falls. SREL’s response refers to other letters they have written that do not answer this question. As scenic flow is important – and is a negotiated amount, and more scenic flow means less revenue for SREL – this needs to be agreed upon as part of the approval process while the public has a strong negotiating position. If SREL gets permission to proceed, they would have no motivation to provide any increased scenic flow from the inadequate amount already offered.
4. Fish Habitat – These questions were ignored. SREL expects stakeholders to have blind faith that they will carry out their operations in a responsible way, and with integrity, when they have not shown these vitally important qualities in their environmental assessment or in their dealings with Stakeholders?  Continue reading

Ivanhoe River – First, Second and Third Falls – William A. Allen

Third Falls Pan – Video Clip 288:


Comments by William A. Allen:  This is Third Falls as viewed from a very unstable boat.


Second Falls Back Eddy – Video Clip 314:

Comments by William A. Allen:  I took this video as the radio was warning about an impending tornado. A short time later we got stuck in the wildest storm I have been in this year – high winds and driving rain, but thankfully no tornado. Second Falls has a magnificent big back eddy at this late summer water level.


Second Falls Up Close Eddy – Video Clip 321:

Comments by William A. Allen:  The very end of this video clip shows the top of Third Falls a couple of hundred metres downstream.

One of Several Branches of First Falls – Video Clip 369:

Comments by William A. Allen:  At low water in summer First Falls has several channels. Shown here is the top of the most westerly one.

Base of One Branch of First Falls – Video Clip 377:



Comments by William A. Allen:  If you look at the cover of the Third Falls Project Description you will see all 3 falls.

  • Third Falls is all the white water in the foreground
  • Second Falls is the modest white water with big rock in the middle and appears at the bottom of the top quarter of the cover photo.
  • First Falls is at the very top edge of the photo and has several channels.

With this photo for reference look agin at the series of Third Falls videos, all shot from the west side of the river (right side of the cover photo).

This video clip  shows the bottom end of the west channel of First Falls.

Briefing Notes – Allen-Struthers Hydroelectric Dam Proposal – by FRDA

French River Delta Association

Briefing Notes re apprehension about the hydro electric dam in Allen-Struthers

We are a group of local cottage and resort/marina operators and other members at large whose major focus is the environment. Our association is very worried about the impact of the green Energy Act (2009) implications for Northern Ontario as well as our local habitat and environment.

This Act which was passed into law has some laudable objectives:

  • to encourage the growth in clean and renewable energy sources
  • to achieve major savings in energy use
  • to create 50,000 new jobs in Ontario

To bring about these changes, the government is offering very generous incentives with the program called the Feed In Tariff program. Of major concern to the Delta association is the use of new small hydro electric installations to generate electric power. Of particular concern is, the environmental and monetary exemptions in the act for projects that may make a major economic contribution to the province. Although public consultation must take place, no rules have been set out on how this must be done. (very little public information has been put forth by the project proponents) While the Act does recognize the need for proper decommissioning plans it does not require decommissioning bonds. Local Municipalities have been removed from the decision making process. Local MNR and MOE branches are being told that the decisions are being made in Toronto. Local stakeholders have not been properly consulted during the development stage of this act. The Act in its present form, and the way that it is currently being interpreted and implemented, in our opinion, leaves Northern Ontario’s environment and economy to be raped and pillaged for the benefit of few. We have concerns that by circumventing the environmental aspects (the endangered species list and species at risk) in depth environmental assessments will not be required on a broad scale. 46 Water Power Feed in Tariff contracts have been offered in Northern Ontario, 32 of which are in the North East region. Continue reading

Ivanhoe River, The Chute & Third Falls – Robichaud

Proposed Hydro Energy Project Comments and Questions

Proponent: XENECA

Project: Ivanhoe River “The Chutes”, “Third Falls”

Ontario Ministry of Natural Resources Site Designation:

  1. 4LC18 The Chutes
  2. 4LC17 Third Falls

Project Time Frame Primary Target: April 2015 Turn Key Operation

Relevant OMNR Conservation Reserve: C1702

Document Purpose:

The following statements, comments and questions were prepared to establish issues that should be dealt with prior to moving forward on project development and environmental assessment directions and procedures.

Position Statement:

I am against all new hydro energy projects below 20 megawatt because these projects will modify and disturb the existing health of our rivers ecosystems that were already heavily damaged and modified by man’s drive for energy beyond basic human needs.

Supporting Position Statements:

The Moose River Basin major tributaries have already been tapped for hydro energy. Ontario Power Generation North-eastern Group is in the process of upgrading all the hydro generating sites that OPG operates. The increased energy potential was estimated at 400 megawatts.

Most of the major MRB tributaries natural river features of rapids and falls have been wiped out and access locked down at historical features dammed during the first half of the 20th century. Leaving the less important features has kept some natural earthly designs for both human and aquatic inhabitant usage and appreciation.

Ontario energy rates are reaching levels that are not even affordable to industry. Timmins has just lost its biggest operation that was consuming 122 megawatts. This region’s new hydro projects would create an excess of useless energy production not necessary for decades and beyond.

OPG still owns major reservoir dam structures that could be either sold or upgraded to produce energy from the already existing and somewhat environmentally healed head ponds. Continue reading

Currie – Ivanhoe River – Natural Waterfalls – Third Falls and the Chutes

Proposed Hydro Energy Projects

Location: Ivanhoe River – natural waterfalls Third Falls and the Chutes – near the town of Foleyet, Ontario

 Proponent:  Xeneca

Statement:  The following information from here on in is not new.  It has all been put forward during both Open House, but there are still some questions that have to be addressed before judgments are passed.  I feel that the natural resources will be greatly affected by these two dams.  I am opposed to any construction of any hydro energy projects on the Ivanhoe River.

At this time, there are 45 dams proposed to be built on Ontario Rivers.  All are a major concern to outdoor enthusiasts.   It appears that over time, within the next decade or two, there will NOT be a natural water falls left in our province to view and enjoy, and there is no doubt this will fully impact our ecosystem and destroy some of our environment.  The values of natural waterfalls have a different aspect to Northerners than Corporate Ontario.  Tourist outfitters are dependant on natural resources as they are and not in the modified state to suite urbanites. Continue reading

2009 EcoJustice Report – Flushing Out Truth: Sewage Dumping in Ontario

Author:  June 2009 (revised July 2009) Researched and written by Ecojustice Senior Scientist Dr. Elaine MacDonald and Staff Scientist Liat Podolsky with assistance from Communications Director Jode Roberts and Acting Communications Director Kori Brus.

Page 7:

Findings of Investigation

According to information obtained from the province of Ontario there are 107 combined sewer systems in eighty-nine different Ontario communities. In 2006 and 2007 there were 1,544 and 1,243 releases of raw or partially treated sewage reported to the provincial government respectively, although this information does not include all of the sewage treatment plants in Ontario.3
Of the incidents reported (see Table 1 below), we broke the data down according to ones reported to be caused by wet weather as well as incidents that included CSOs and bypasses.

A review of the reports indicates that if a sewage collection system is overflowing at several locations, each location may be counted as a separate incident. In most cases the duration of the bypass or overflow was unknown, but for the incidents in which the duration was provided, they varied from less than one hour to several days. The average length of incidents that were recorded was seven hours in 2007.

Sewage releases 2006 – 2007
Total reported sewage releases 1,544 1,243
Total releases reported to be due to wet weather 1,256 849
Releases reported to include combined sewer overflows 376 701
Releases that included bypasses 1,061 1,089 Continue reading

A Review of Lake Sturgeon Habitat Requirements and Strategies to Protect and Enhance Sturgeon Habitat

Kerr, S. J., M. J. Davison and E. Funnell. 2010. A review of lake sturgeon habitat requirements and strategies to protect and enhance sturgeon habitat. Fisheries Policy Section, Biodiversity Branch. Ontario Ministry of Natural Resources.  Peterborough, Ontario. 58 p. + appendices.

Pages 4 to 8:

The decline in lake sturgeon across much of North America has been attributed initially to unregulated fisheries and, more recently, to habitat alteration and destruction notably by pollution, dredging and channelization, and the construction of dams and hydroelectric facilities. Dredging and channelization can alter lake sturgeon spawning grounds. Sturgeon have been impacted by many forms of pollution which can disrupt olfactory feeding behaviour. Dams and hydroelectric stations can have a negative impact on lake sturgeon by fragmenting their habitat, impeding migrations to spawning grounds and, depending on the type of operation, having a negative impact on egg survival and recruitment. Downstream migrants may also be impinged or entrained at hydroelectric plants.

Attempts to resolve some of these habitat impacts have included construction of fish passes at dams, establishing base flows or “run-or-river” regimes at hydroelectric facilities, creation or enhancement of spawning areas, use of downstream guidance and diversion structures, and improvements to water quality. There has been some success with constructing artificial spawning grounds for lake sturgeon. Sturgeon have also been shown to display a positive response to improvements in water quality and “run-of-river” hydrologic regimes at dams and power stations. The ability to design a fish pass suitable for fish with the body size/shape and swimming capabilities of lake sturgeon has proven difficult, however, and further research is required in this area. Many sturgeon populations are also impacted by “peaking” operations at hydroelectric facilities and the issue of facilitating downstream passage over artificial barriers also needs to be resolved. Continue reading

Draft – American Eel (Anguilla rostrata) in Ontario Ontario Recovery Strategy Series

Author:  MacGregor, R., J. Casselman, L. Greig, W. A. Allen, L. McDermott, and T. Haxton.   2010. DRAFT Recovery Strategy for the American Eel (Anguilla rostrata) in Ontario.  Ontario Recovery Strategy Series. Prepared for Ontario Ministry of Natural Resources, Peterborough, Ontario. vii+ 78 pp.

Pages 23 to 24:

Barriers to Migration

Dams can severely impede upstream dispersal of juvenile eels in freshwater if no passage way is provided (Haro et al. 2000). It has been estimated that 85 percent of freshwater habitat for migratory fish in the United States has been lost due to barriers (Lary et al. 1998). In a 1998 study, the U.S. Fish and Wildlife Service determined that eels may have been eliminated from 81 percent of their historic habitat between Connecticut and Maine due to the construction of a large number of dams (ASMFC 2000). Barriers reduced eel densities by at least a factor of 10 on the Hudson River, and eel condition was significantly poorer above barriers (Machut et al. 2007). The situation appears similar in Ontario where at least 953 dams exist within the eel’s historic range (Figure 7). Hydroelectric dams generally pose the most significant barrier to upstream migration due their height. However, with the exception of one eel ladder at the Moses-Saunders facility on the St. Lawrence River, as of 2008 no provisions for upstream fish passage for any species have been made at any of the approximately 200 hydroelectric stations in Ontario.  Negotiations with a few facilities are now underway to correct this situation for upstream eel passage.

Turbines at Hydroelectric Facilities

Hydroelectric facilities in Ontario pose significant challenges to eels (Larinier and Dartiguelongue 1989; Mitchell and Boubée 1992; Desroches 1995; Normandeau Associates Inc. and Skalski 1998; Haro et al. 2000; Dönni et al. 2001, in ICES 2003; McCleave 2001; Allen 2008 b, c, d), as they impart serious individual and cumulative mortalities at the watershed level to downstream migrants en route to spawn (McCleave 2001; MacGregor et al. 2009). There are 87 hydroelectric facilities within the historic range of eels in Ontario, and 30 within the post-2000 range (Figure 8). As of 2009, many of these facilities continue to cause annual eel mortalities (Community Stewardship Council of Lanark County 2010; A. Bendig, pers. comm. 2009; K. Punt, pers. comm. 2009). With the exception of recent trap and transport efforts at Moses-Saunders, mortalities due to turbines at all hydroelectric facilities in Ontario continue unmitigated on most watersheds. Continue reading