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 20^th 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.

Conflicting OMNR Renewable Energy site information:

The established Conservation Reserves C1702 cuts the Third Falls location down the middle. The OMNR renewable energy potential list had declined this site because of its location with regards to the C1702 boundary.

A recent communication with Carrie Hoskins, Renewable Energy stated that “For the most part Provincial Parks and Conservation Reserves are not currently being considered”. The intent of the Lands for Life effort was to protect natural areas from these invasive man made projects of irreversible nature.

General Statement related to Notice of Commencement:

The Third Falls location is accessible from Timmins Ontario. The road access distance to the Third Falls is equal to or even less than the distance from Foleyet. The fact that the site is in the OMNR Chapleau District does not preclude the fact that Timmins should also have been considered for the second Xeneca Open House location.

The following comments and questions are addressed to Xeneca with various relevant Ontario Government controlling agency overlaps.

“The natural earthly design of these extremely valuable river ecosystems will never be matched or copied.” Hunters, fishermen, youth groups, outdoor enthusiasts and paddlers and tourists still enjoy the Ivanhoe River.

1. How will you be able to replace or mitigate the original earthly design of the Ivanhoe River features referred to as “The Chutes”, “Third Falls”?

2. There are new watercraft design advancements and increased navigation skills levels in place today. How can a white-water craft operator pass through the structures you plan on constructing other than having to portage a much longer distance than already in existence?

3. The specific aquatic species habitat usage near the proposed structures must be identified before developing conceptual structure designs and layout arrangements. Exact spawning locations of various species should be known. How will you approach this next phase of aquatic sampling?

4. Liability issues and public safety around your proposed sites need careful attention. “This is not a tourist attraction”. How do you propose restricting land access and limiting water access near the control and generating structures of your proposed project sites?
   

“Lake Sturgeon has been my species of concern in aquatic river habitats of our major tributaries in the Moose River Basin and across the province”. “This watershed’s extent of natural presence of the above specie has slowly been depleted for over a century result of our activities and historical usage of our river systems”. “Further disturbances to lake sturgeon existing habitat will likely have negative effects on its survival”.

1. I have experienced modified flow regimes during spring freshet. Sturgeon spawn progression was modified, stressing even more the ripe females trying to migrate under these abnormal man-made conditions. How will you operate during freshet and year round operation if you are allowed to operate with “modified peaking”? How is it even possible to mimic natural flow conditions if the proponent’s goal is to produce electricity?
   

1. Lake Sturgeon biology is not fully understood and must be studied further before modified peaking is permitted. Lake Sturgeon feeding and juvenile nursery habitat can be affected upstream and downstream of your proposed energy complex structures and controls. Who will gather the necessary science and technology to prevent further hardships to this prehistoric natured species?
   

1. The Ontario Ministry of Natural Resources has designated Lake Sturgeon as a species of “Special Concern” in North-eastern Ontario. Provincial efforts are in place to reduce the impact on existing populations with a no limit or possession regulation with recreational fisheries in Ontario. During this phase of environmental aquatic field work, will you stress the importance of identifying lake sturgeon presence and activity above and below your proposed sites?

1. Larvae drifts from hatched eggs will be affected by both flow regiment, silting and oxygen starvation due to possible flow modification following lake sturgeon spawn. “Modified Peaking” adds more stress to the survivability of this species. Are you prepared to deal with further studies beyond the established environmental assessment timelines?

1. Spillway entrainment issues comparable to the Adams Creek spillway on the Mattagami River Little Long Generating Complex will stress the fragile lake sturgeon population. Regulated minimum flow requirements will prevent potential watershed isolation leading to death of sturgeon specimen. How can you make this operation viable to investors when operating parameters prevent the operator from profitable energy production?
   

1. In the past 100 years we have come close to totally eradicating this species that had survived more than 130 million years without evolving from its original physiological earthly design. How will you and your project sponsors survive knowing you could possibly be part of the total demise of lake sturgeon?
   

This comment document was prepared for Xeneca from their Open Houses held in Foleyet.

Some comments and questions should also be covered by various Ontario Government Agencies.

I prepared this document for the Friends of the Ivanhoe River and have submitted it to the chair of our membership for routing to our mailing list.

Dated: April 5^th 2011

Laurent “Larry” Robichaud

Member

Friends of Ivanhoe River