WO Position Statement

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To: DFO - CEA Registry Office -Central & Arctic Region - Ontario Area

To: Mark Holmes / Uwe Roeper, Xeneca Power Development Inc.

To: Kelly Thompson, A/Manager, Navigable Waters Protection, Transport Canada

To: Joanna Samson, Water Resources Coordinator, Ministry of Natural Resources – Pembroke

 

Cc: Vanessa Enskaitis, Petawawa River Rats, Mayor of Petawawa Bob Sweet, Community Alliance to Save the Petawawa, Whitewater Ontario Members

 

May 20, 2011

Re: CEAA Registry Number: 11-01-61006

Big Eddy Hydro Project on the Petawawa River.

Whitewater Ontario (WO) is a volunteer-driven organization uniting, supporting, and sustaining the inclusive development of the whitewater paddling community and resources. Our diverse membership of over 400 includes recreational paddlers, high performance slalom athletes, open boaters, and freestyle competitors.  While our membership is diverse and representative of many whitewater disciplines, members of Whitewater Ontario share a common belief about river access and the preservation of existing waterways for current and future generations.  Our membership encompasses both current and future users of the Petawawa River for recreational purposes, including but not limited to navigation.

USAGE

The Petawawa River, as it flows through the Town of Petawawa is a well-known, world-class destination for whitewater boating enthusiasts.  It provides a training facility for our Olympic athletes, as well as many members of the Canadian kayak and canoeing teams.  Informal data gathering has been able to identify approximately 5000 person trips per year; by recreational boaters, for commercial rafting, by competitive athletes and by community groups such as the Boy Scouts of Canada, the YMCA Canoe Camping Club and the Alpine Club of Canada. The river also provides a training ground for members of the Canadian Forces.

Our membership currently uses the river for recreation at any point between ice out (March) to ice-in (December) at a wide range of water flows between 470 CMS and 10 CMS.   This section of river is safely navigated at a broad range of flows, with each flow level offering a unique experience. This variability of flows is valued. It is also worth noting that while the river may remain navigable at very low flow rates, flows below 25 cms considerably increase the risk of injury and damage to equipment, and negatively impacts the quality of the recreational experience.

Whitewater Ontario is adamant that the safe navigation of the river must be maintained, and that the quality of the recreational experience and usage be maintained. The construction of a portage trail, or a “play wave” style feature in or around the affected reach is not a suitable compensatory measure.

The proponent of the Big Eddy Project (CEAA 11-01-61006), Xeneca, appears to be presenting, and basing decisions on arbitrary and unrealistic assumptions about the conditions required for recreational boating on the Petawawa River and to our knowledge, has not made any legitimate attempts at collecting actual baseline data.  The intent of this letter is to communicate our concerns about these inaccuracies, and to ensure that the regulatory agencies involved have the position of Whitewater Ontario, as a representative of Ontario’s whitewater community.  Whitewater Ontario therefore asks that proper baseline data be required to be collected via participatory water monitoring over a suitable timeframe of no less than two boating seasons (March – December). In addition, in the interest of transparency and reasonable disclosure, we request that public consultation is completed once the project environmental assessment is completed and disclosed (with suitable disclosure of data and the data collection process). In addition, proper public disclosure and consultation is required once proposed flows and project specifications have been identified.

CONCERNS

Whitewater Ontario has the following concerns with the “Big Eddy” hydroelectric generating scheme on the Petawawa River, currently being proposed by Xeneca Power Development Inc.

These concerns are based on information provided by Xeneca directly to Whitewater Ontario members; by information being provided by Xeneca to the general public at Public Information Centre; and on information included in the draft document entitled PROPOSED OPERATING FLOWS AND LEVELS, Big Eddy Hydro Project (April 2011) prepared by ORTECH Consulting for Xeneca Power Development Incorporated as well as the posted Project Description available on www.Xeneca.com.

 

1. Protection of the Rights of Navigability:  The Petawawa River “Town Section” currently sees approximately 5000 paddler trips per year.  For the majority of the year, the proposed project will render large sections of that river unnavigable through the significant reduction of flows and the construction of a river-wide weir. The Project Description, the draft and the information being provided to the public provides no assurance that navigability will be maintained.

Recommendation: In order to protect navigability, the compensatory flow (flow in the affected reach) must be kept at a minimum of 25 cubic metres per second unless the natural river flow itself falls below this level.

2. Loss of a Recreational Resource: The Project Description, and previous correspondence with the proponent has made it clear that the Big Eddy hydroelectric project will drastically reduce flows through the affected reach ( aka Railroad Rapid) rendering it unnavigable and severely hampering its recreational use for paddlers, as well as countless others for swimming, fishing and other recreational uses.  This project will gravely affect the quality of the experience, the safety of the users and the natural environment.

Recommendation: To permit the continued safe recreational uses for which this section of river is known, and in keeping with the guidance provided by the Province of Ontario’s Lakes and River Improvement Act, Whitewater Ontario recommends that compensatory flows in the affected reach be kept at a minimum of 66% of the incoming flow.  And, in addition, that flows in the affected reach are increased to match the natural flow rates a minimum of 1000 hours per year, with no qualifying limits on minimum or maximum flow.

Note:  There cannot be a minimum flow requirement to justify the releases as this makes schedules largely impossible, and the river is enjoyed at the entire range of natural flows, offering a unique experience and challenge at each of the different flow rates.

3. Public Safety: The Petawawa River Town Section is located in a populated area, and in addition to use by whitewater paddlers it is common to find both children and adults swimming, fishing in and around the river.  The Project Description provides no detail on how the safety of those in the affected reach between the weir and the powerhouse will be assured.  This is particularly relevant due to possibility of severe fluctuations in water levels and flows due to scheduled operation, and even more concerning should the turbine shut down due to electrical supply chain issues or turbine operation failure. The increase in flow will be immediately redirected into a previously “dry” section of riverbed. This will present a valid safety issue.

Recommendation: It is the position of Whitewater Ontario that the inherent risks of whitewater are best conveyed to the public by maintaining a whitewater environment in the affected reach.  This will be far more effective than signage or fencing. By maintaining a whitewater environment in the affected reach, it will help to ensure that those in the affected reach are aware that (1) it is in fact a river bed; (2) that whitewater can and does run through that section on a regular basis.

The greatest safety advantage of maintaining that section as a whitewater river is that it will prevent or greatly reduce the presence of non-boaters/non-swimmers from the affected reach (such as sunbathers, picnickers, etc.)and in turn the likelihood that an ill-equipped person could be caught by changing flows in the affected reach.

To achieve this, a minimum of 25 cms must be kept in the affected reach as long as the incoming flow is over 25 cms.  Should river flows drop below 25 cms all incoming water must be diverted to the affected reach.

4. River Access: The Project Description provides no assurance that public access to ‘affected reach’ of the Petawawa River nor the immediate vicinity of the powerhouse outflow will be provided for.  This is relevant to access via watercraft, swimmers or pedestrian traffic. Navigable waterways are public resources and access should not be restricted.

Recommendation: It is the position of WO that the proposed weir or any other installed, floating or anchored materials not present an additional obstacle or barrier for boat or other river-based access to the affected reach.  In addition, the use of fencing to prevent pedestrian access to the affected reach should not be permitted.  Any changes in river flow or hydrology must not prevent the use of any section of the current existing river bed by the recreational community. For example, significant staging and access eddies, areas of slack water or eddies used for ensuring the safety of swimmers and boaters can be identified and must remain unaffected by the project. These factors must be taken into account when designing the facility and determining the operational schedules.

 

I extend an offer to assist in any way that I can in providing further information or comment on any aspect of the proposed project, or the subsequent analyses that must be undertaken before final decisions are made.  If you, or the proponent, wish to engage with the members of Whitewater Ontario, I will be glad to assist in this.

This river is dearly loved by the local paddling community and known the world over for its whitewater; I would ask that you take every step possible to ensure that this resource is protected for current and future generations of river users.

 

 

 

 

Warmest regards,

Jim Tayler

President, Whitewater Ontario

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