August 11, 2011
Vanesa Enskaitis
Public Affairs Liaison
Xeneca Power Development Inc.
T: 416-590-9362 X 104
Dear Ms. Enskaitis:
Please find enclosed my response to the two volumes of the Environmental Assessment (EA) for the Chute generating plant.
RESPONSE TO EA REPORT
I have come to the conclusion after reviewing the EA report for the Chute GS Project that there are many unresolved issues. Some of these deficiencies are permits not acquired; field studies still on going, and information gathered that has not been completed.
This report seems to have been fast tracked for what reason, political or financial, definitely not for the social and environmental impact on the river.
Issues to be addressed
1. The inundation distance for the Chute and Third Falls are a moving target. The Chute has changed from 2.8 km to 6.4 km and the Third Falls proposal is up in the air from 14 km to 30 km which would flood to the base of the Chute. With an inundation distance now of a total of 36.4 km, should these tow dams that are operating in tandem be assessed under one EA.
2. With the 36.4 km of inundation all of the natural spawning zones that walleye use will be lost. Also, pike, speckled trout, perch, ling and whitefish spawning locations will be altered dramatically as these species all spawn at different times of the year. This has been stated many times in the EA. What compensation will be put in place to maintain the population of all species; restocking, fish ways, spawning beds if at all possible? Also let’s not forget Lake Sturgeon that has been angled at the base of the Chute on two different occasions, where will they spawn?
3. Is there an agreement between MNR and Xeneca regarding flows to ensure legislated obligations under the Lakes and Rivers Improvement Act 1990? This would apply to all portions of the river affected by the 2 dams. Lakes and Rivers Improvement Act. O.Reg. 454.96. 2D – the purpose of this act is to provide for the management perpetuation and use of fish and wildlife and other natural resources dependent on the lakes and rivers. Xeneca has not demonstrated that they have compiled adequate information for the Chute site to comply with the Act.
4. There are many paragraphs in the EA that state that there will be residual and negative effects. Why then would the construction be permitted to proceed if there are not guarantees that fish and wildlife habitat will not be destroyed. “No Net Loss”.
5. Note dated May 30, 2011 MNR Chapleau – Project description insufficient to conduct a through review. When will this project description be complete?
6. Volume 1 page 10-15 Environmental Characterization Report – has the report been completed for the Crown Reserve or Groundhog Park?
7. Volume 1 page 11-15 Social – have the social issues been addressed: page 12-15 Concerns – why were these not addressed before completing the EA report?
8. Volume 1 page 6-15.4 – Was the acid rock drainage study complete?
9. Permit to take water O.Reg 387.4 – has this permit been applied for?
10. Certificate of Approval for noise emissions. It is perceived that the nearest receptor would be the town of Foleyet 14 km away. This would be a false outlook, the campers, Eco tourists, anglers, hunters, trappers and canoeists are all the real receptors and are all within close proximity to the proposed Chute GS.
11. With 6.4 km of inundation, fluctuating daily during all seasons of the year, what will aquatic animals do for habitat dwellings during the winter, spring, summer, and fall seasons?
12. There are many cold water species that have been identified in the Ivanhoe River by NRSI – speckled trout, ling, and lake whitefish. Xeneca has stated in the EA that cold water species will not be at risk. If the head pond is depleted and water temperature (approximately 77 degrees Fahrenheit August 4, 2011) flows down stream and fills the reservoir what will be the average temperature of the water in the reservoir.
13. Why was the Archeology study not completed?
14. Ontario Resource Based Tourism Policy 1997. The wilderness used by this industry plays an important role in conserving the environment for future generations. Do stake holders still have a say in the decision making and considerations of the environment, social economic, and cultural effects; and if so why is the provincial government now trying to put these sensitive areas of the north on a path of destruction?
15. Who is going to monitor the Q80 during the low flow of the year and will the sum of the two Q80’s (Chute and Third Falls) have an effect on the requirement for the flows below the Third Falls for the Groundhog Park and Crown Reserve.
16. It is stated that all electronic monitoring will be done remotely by Xeneca. Who will be policing them? All critical data including flow reports should be forwarded to MNR Chapleau with soft ware that flags substandard operations.
17. It is written in the EA time lines are tight. Why then did it go to press with so many studies not completed. Two years of data is not enough time to thoroughly examine the river and the effects these two dams will have. A 7 year spawning cycle for Lake Sturgeon for example would have been missed.
18. In the EA, Xeneca is constantly pressing the MNR for permits but Xeneca has not been provided all pertinent information required to receive these permits.
19. Volume 2 page 2-2 Six years of data is not sufficient to generate a reliable flow series so other flow records in the region have also been accessed to synthesize at the project site. How can this be quantified as OPG has control of other dams in the region and water flows are not consistent for example, OPG lowered Horwood Lake 8 feet during the 2010 spring run off which took almost one year to regain its level.
20. Will a canoe portage be installed with danger signs upstream to facilitate the safe passage around the site?
21. Safety – during the low flows when Q80 is in effect and the dams are not generating power after 7 PM there is a potential that the river will not be navigable by anglers as they try to come upstream at 10 PM when prime time fishing is complete. Is this not covered under the Navigable Water Protection Act? Winter anglers will be at risk as ice conditions will be unsafe due to fluctuating water levels. During the summer, how much of the river will be inaccessible for those who wish to fish from shore and in the rapids? A statement by Mark Holmes “We are not OPG and we will not be fencing the river.” Is this a safe practice?
22. The MNR has stated their concerns many times in the EA that loss of fast water habitat, wildlife, and other natural resources dependant on the Ivanhoe River are not impacted due to the alteration and negative impact on user groups and the overall economy of the north.
23. Biodiversity Strategy (2005) – This policy has a number of goals that it addresses; the protection of genetic species and eco system use and to develop the biological assets of Ontario sustainability. The Lake Sturgeon are part of this strategy. Why is this not the case for a SAR at the Chute? With the low count of sturgeon, can we afford more loss due to the run of the river system?
24. What will be the mortality rate of fish and wildlife in the trash racks and turbines as the run of the river elevations are constantly changing. Has this been added into the equation? What happened to “no net loss”?
25. LRIA – Purpose of the Act. 2-E the protection of the natural amenities of the lakes and rivers and their shores and banks. This is not the case in Xeneca’s history, for example the Misema River near Englehart.
26. Volume 1 Page 4-5 Sediment trapping/starvation issues mobility of fine silts. Action may be required in 6 years. This statement is in contradiction to other statements in the EA stating that silt will have no effect. Six years will be too late to adjust flows.
27. There is a proposed fill embankment up stream of the Chute. Will it and the fill embankment proposed by the First Nations as part of the main structure of the dam be susceptible to floods and erosion?
28. Who is going to pay for year round road maintenance to the dam – Xeneca or the Provincial Government?
29. Transmission line corridors are also a moving target and an issue with MNR Chapleau. Has Xeneca come up with a plan and why was this not complete before the EA was published?
30. Volume 1 page 5-15 – Are all the permits in place for construction, sediment control, erosion control, and access roads?
31. Who will benefit from the assessment of the buildings, dam, and road ways? Will the Town of Foleyet see any of this revenue?
32. Notes 3rd page – Richard added that the head ponds were generally small and that little or no alteration would occur as the plants would adjust to compensate and generally maintain head pond levels. If head pond levels are not rising or falling then inflow = outflow. Volume 1 Forward/Operational Strategy – when natural flows are below the maximum capacity of the turbines but above the required ecological flow, water will be stored during the off peak hours for use during the peak hours, affecting water levels upstream and flows downstream. The 2 statements are in the EA and contradict one another. Bottom line – water in = power out no matter what the cost to the river.
33. I have not found in Volumes 1 & 2 where Xeneca has demonstrated financial security. We are in a fast moving world and new technology is upon us daily. Should an alternative to generating stations be developed and dams are no longer useful, funds or securities should be in place to rehabilitate the structure to its natural original state at the site for example as in the Mining Act which states that companies are responsible for having monies available to reclaim mining sites before construction starts.
34. Who in the past has paid for decommissioning power generating sites, the owner or the provincial government?
35. Public Consultation – no meetings were held in Timmins but 2 copies of the EA were on display there. Local stake holders not invited to a meeting in November 2010. Foleyet Chamber of Commerce was not notified of any meeting. Bait fish harvester for Oats Township not notified of meetings. Local Citizens Committee not notified of meetings.
36. Why is there not an agreement between the Ivanhoe Lake Camper’s Association, Xeneca, and MNR Chapleau that water in the Ivanhoe Lake will never be lowered to generate power?
Conclusion
There will be significant negative impact which can not be mitigated or compensated for and this is stated quite regularly in the EA. All the stake holders will be affected if this project moves forward. No dams = “no net loss”.
Yours truly,
Hugh Currie
White Pine Lodge