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379 Ronka Road Worthington, ON P0M 3H0 (705) 866-1677 LindaH@OntarioRiversAlliance.ca OntarioRiversAlliance.ca

14 May 2012

Noel Boucher Environmental Coordinator Hatch Ltd. 4342 Queen Street, Suite 500 Niagara Falls, ON L2E 7J7 Email: NBoucher@Hatch.ca Dear Noel: Re:

Kabinakagami River Proposal Neeskah, Peeshoo, Wahpeestan, and Wapoose GS Notice of Inspection and 30-Day Review of Draft Environmental Report

Ontario Rivers Alliance (ORA) is a Not-for-Profit grassroots organization with a focus on healthy river ecosystems all across Ontario. ORA members represent numerous organizations such as the French River Delta Association, Vermilion River Stewardship, CPAWS-Ottawa Valley, Friends of Temagami, Paddle Canada, Whitewater Ontario, along with many other stewardships, associations, and private and First Nations citizens, who have come together to support healthy river ecosystems in Ontario and to ensure that the waterpower proposals currently going through the approvals process are environmentally, economically and socially sustainable. ORA has the following comments and questions: 1.

Climate Change – Section 7.2.2 Scientists are predicting an increase in extreme rain and drought events, and a general increase in temperatures. The “Working Group I of the IPCC reports in its Third Assessment Report on Climate Change (IPCC, 2001) that the globally averaged temperature is projected to increase by 1.4°C to 5.8°C over the period 1990–2100.”1 a. What are the projected changes to river flow rates due to drought and evaporation as temperatures continue to warm and ice cover is reduced? b. The ER states, “Decreases in flow in the river, particularly when coupled with hotter summer months, could result in an increase in the warming effect of the head pond, due

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Canada’s Fourth National Report on Climate Change: Actions to Meet Commitments under the United Nations Framework Commission on Climate Change- 1.1 Climate Change, P5.

"A World of Healthy River Ecosystems."

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Ontario Rivers Alliance

May 14, 2012

to less flow and corresponding increase in residence time” – this is a major concern and deserves more consideration and detail in the ER. c. What is the expected rate of increase in methylmercury production from increasing water temperatures due to climate change? 2.

Flow Rates Appendix C-11, P15 – Operational/Biological Meeting – 12 January 2012, P2: Your flow data is based on 1951 to 1986 Water Survey Canada records. CLFN and local trappers both reported that water flows in the Kabinakagami River seem/appear lower over the last 10 years, and this is backed up by the World Meteorological Organization reporting that 2000-2009 was the hottest decade on record, with eight of the hottest 10 years having occurred since 2000. Northland Power has not collected any recent data - “TR indicated that the hydrology analysis with data from the Kabinakagami supplemented by adjacent river systems has been used in the analysis of Project economics and Northland is comfortable with this approach.” ORA submits that Current and accurate flow data collection is key to determining the feasibility of the project, methylmercury production, water quality effects, and ultimately the risk to public health and safety, and the riverine ecosystem. a. What is your rationale for opting not to record current flow data since your field studies began back in 2010? b. The foundation of this proposal, with all your predictions of impacts and energy production, are based on old flow data, when the climate has already warmed considerably since 1986 – this is not acceptable. c. Reduced flows mean a longer residency time, lower to no energy production, and increased methylmercury production, so current flow figures are essential to assess these proposals. d. Have any flows been documented since you began your field studies to compare historical flow with actual current flow? e. Have general flow trends for Ontario rivers since 1987 been studied? This data must be present in your ER? f. If so, are those flow rates, comparisons and calculations available for review? g. In the summer low flow season you indicate a total residency time of 42.6 hrs at 30 cm/s, however, i. what is your residency time when flows go below 30 cm/s, ii. what is your residency time when flows go below 8 cm/s and turbines are shut down, iii. what will the maximum residency time be? h. Historically, how many days in a year has flow been lower than 8 cm/s? i. When turbines are shut down will flow then be allowed to freely escape through the dam – or will flow be held back to fill the headpond? j. During the low flow seasons, will the head ponds be filled, then water released to produce power, then filled again to produce power – in a cycling or peaking strategy?

3.

Head Ponds Preparation and Filling – Section 3.3.9-P3-23 to 26 a. “The expected average flow rate during this time period would be around 30.6 m3/s. At this flow rate, the overall duration to fill all four head ponds would be 5.8 days” 2

"A World of Healthy River Ecosystems."


Ontario Rivers Alliance

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b. Unfortunately there is no current flow data, and with climate change upon us many rivers have experienced increasingly lower flows over the last 10 years – so there is a very good possibility these averages and assumptions are incorrect. c. Water sitting in a head pond for 5.8 days, exposed to solar warming, has potential for numerous negative effects – this must be addressed. d. Is this “infilling” a one-time only deal – on initial start-up? e. If not, then how often will this infilling happen during the low flow seasons? f. You indicate you will pass a minimum of 3 cm/s (after ceasing generation operations due to low flow) – how often will this minimum flow occur? g. How long will it take to fill the head pond back up when flows go below 8 cm/s and the turbines are shut down? 4.

Methylmercury – Fish Mercury Concentrations – Appendix G In your Notice of Inspection you indicate “that the Project will not result in significant negative environmental effects”, and yet “Negative impacts may include increases in fish mercury concentration”, and in your own estimates the increase will be from 1.7 to 2.0 times above baseline for the Kabinakagami River Project – and has been up to 7 times in other projects – 100 kms or more downstream. ORA would suggest that this increase is very significant and, 15 to 35 years duration would have a serious health and safety impact on those downstream First Nations relying on fish as a main staple in their diet. a. ORA is requesting a bar graph that compares the baseline mercury levels in fish tissue, by species, to the predicted levels. b. Tables 8-2 and 8-3 must show not only existing fish consumption advisories, but also the predicted fish consumption advisories – to indicate the increased risk to public health and safety. c. The relative increase and absolute concentration in mercury are both vital in this study – ORA would like to see graphs for both. d. P 23 - Comparing these proposals to other reservoirs is important but ORA is more interested in how these increases will affect stakeholders. e. Have the affected First Nations communities been notified that predicted elevated mercury levels will lead to fish consumption restrictions, and perhaps even bans? f. Will Northland post fish consumption warnings and restriction notices at each launch site to protect public health? g. How would Northland mitigate and/or compensate the downstream First Nations communities for the loss of fish as one of the main staples in their diet? h. It was indicated many times that due to the uncertainty of formula tools, there is no real predictable certainty, so increases could be even higher. i. Accurate flow readings are essential to accurately predict effects on total mercury concentrations in fish tissue. j. Section 5.10.2.2.3 “Net Effects and Significance of Net Negative Effects - The net effects on surface water quality will be an increase in nutrients, organic carbon and methyl and total mercury concentration. It is predicted that these changes in water chemistry will be relatively short-term in duration until the decomposition process is largely complete; a process that may take between 3 and 10 years, as evidenced by water chemistry changes in other hydroelectric facilities in Canada that have experienced similar changes.” This statement is contradictory to the information in Appendix G above – which is it?

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"A World of Healthy River Ecosystems."


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5.

Fisheries There is no provision for fish passage in this ER. Table 5.2 - Page 5-10: “Installation of cofferdams will block the movement of fish throughout this section of the river. This will be permanently blocked following construction of the dams.” The implication here is that the species of fish in this river don’t migrate – this is not acceptable. a. ORA requests that turbines which are the least dangerous for fish be used in plant design and operation. b. Upstream and downstream fish passage must be incorporated at all 4 dams – there is now a promising design for Lake Sturgeon2. c. What is the expected downstream impact on fisheries for the downstream First Nation communities?

6.

Water Management Plan – Section 9 a. Statements such as the one on P9-6, “relatively small facilities and associated head pond areas minimizes potential for temperature increases in head ponds” is not useful information. Actual data indicating expected increases and impacts is relevant and essential. This type of language designed to minimize can be misleading, and has no place in the environmental report – data should be provided for the reader to make their own evaluation and judgement. b. There is uncertainty when flow levels go below 20 cm/s. ORA requests more clarity on this Low Water Zone – you will “attempt” to regulate the head ponds isn’t reassuring – what might this mean for the upstream and downstream impacts? c. You state on P9-11, “Each facility will be operated under a ‘water level control’ strategy whereby, during periods of normal inflow (up to the rated flow of the turbines (82 m3/s), which occurs approximately 89% of the time in an average flow year). Can you please clarify this statement and give the data and formula for how the 89% figure was arrived at? d. When flows are between 8 cm/s and 20 cm/s will water be held back for a period of time to bring head pond up to normal levels to produce power at 20 cm/s for a period of time, then flow shut off to build head pond up again to produce power again at 20 cm/s for a period of time? e. When bringing head ponds up to normal levels, will all water be held back or will there be an environmental flow at all times passing through the dam? f. Will 3 cm/s environmental flow be the amount passed through the dam at these times?

7.

Accidents and Malfunctions – Section 6, P5-10 Dam failure when the turbine is at very low flow or shut down creates potential for downstream flow to change rapidly. This accident is not even considered in this Section. Unlike a dam failure which would most likely occur during periods of flood when downstream recreational use of the river is “not likely”, this accident can occur at any time. If this type of failure is not possible or credible then this position needs to be addressed and justified. Otherwise, Northland needs to show that the effects are acceptable.

8.

First Nations Consultation – Appendix C-P71

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Behaviour and passage success of upriver-migrating lake sturgeon Acipenser fulvescens in a vertical slot fishway on the Richelieu River, Quebec, Canada

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"A World of Healthy River Ecosystems."


Ontario Rivers Alliance

May 14, 2012

a. As stated in an email from Daniel McCarthy, on 6 December 2011, “Chief Andrew Solomon, on behalf of his community, Fort Albany would like to formally express his deep concern regarding the Kabinakagami River Project and the lack of consultation afforded to the downstream communities – especially Fort Albany and Kashechewan.” b. Could the problem here lie in the difference between being told something is going to happen, as opposed to being consulted as to how and if it should happen? The definition of consultation - “the act of discussing something with somebody or with a group of people before making a decision about it”. Was the decision already made before “consulting” with the downstream First Nations? 9.

Constance Lake First Nation (CLFN) Referendum The CLFN referendum clearly resulted in the majority voting against the project (105 against and 97 for the project). a. Why were the results of the referendum not respected by Northland Power and Chief Wesley? b. Would Northland Power have legally been able to develop these sites if it didn’t have a First Nations partner?

Thank you for this opportunity to comment on the Notice of Inspection for the Kabinakagami River Draft Environmental Report. Respectfully,

Linda Heron Chair, Ontario Rivers Alliance Cc:

Chief Andrew Solomon, Fort Albany FN – Andrew@fortalbanyfn.com Chief Jonathan Solomon, Kashechewan First Nation – ChiefJSolomon@knet.ca Grand Chief Stan Louttit - Mushkegowuk Council - StanLouttit@mushkegowuk.ca Karen Metatawabin, Fort Albany FN - KarenMetatawabin@hotmail.com Nicole Woolnough, MNR – Nicole.woolnough@ontario.ca Kelly Withers, DFO - Kelly.Withers@dfo-mpo.gc.ca Connie Smith, DFO - Connie.Smith@dfo-mpo.gc.ca

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"A World of Healthy River Ecosystems."

2012 05 11 ora comments kabinakagamidrafter  

ORA Comments on Draft ER, Re: Kabinakagami Hydroelectric Project - Draft ER

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