July 25th, 2011
Multi-lake regulation results show very large improvements across the board for all scenarios and lakes.
As you are aware, the public information meetings being hosted by the Upper Great Lakes Study Board to discuss Phase 2 of the Upper Great Lakes Study are happening next week (see schedule below).
“The contrast between economic growth and environmental damage, so prevalent during the region’s previous era of economic prosperity, is a relic of the past. A healthy ecosystem is increasingly understood to be crucial to the region’s future economic success” (June 2011) – Vital Commons, An Agenda for the Great Lake St. Lawrence Region. Mowat Centre / Brookings Institution.
Attached is our review of the Study Board’s recent Restoration Report. We would appreciate your help in circulating this to anyone you think would be interested.
Based on our review of the materials provided by the Study Board and their preliminary report of benefits, we would like to encourage a single themed response from the public recommending multi-lake regulation be implemented to protect the waters of Lake Michigan-Huron. This is currently being debated by the Study Board. As recognized by the Study Board, this would necessitate regulatory structures and possible remedial work in the St. Clair River which is a theme we have been promoting for the past decade. I hope this is a strategy that you will support.
At the Phase 2 meetings we will focus on addressing lower water levels by introducing a plan for multi-lake regulation. This is supported in the IUGLS report - “results show very large improvements across the board for all scenarios and lakes.” Lakes Michigan and Huron are the only unregulated lakes in the system and they are running into trouble due to an accumulation of impacts from a century of human interference in the natural water level regimes.
The Study Board will propose the creation of a Water Quantity Advisory Board (see slide). As proposed, this board would have no regulatory capabilities, oversight or structures with which to ameliorate any undesirable water level conditions. It is our opinion that this function would be best addressed by a Multi-Lake Regulatory Authority overseeing the entire connected system to ensure ecological and economic integrity is maintained throughout – from Lake Superior to the St. Lawrence River. This is in harmony with the positions of other stakeholders not the least of which is the Shipping Industry.
In a separate report on the Great Lakes Navigation System undertaken by the US Army Corps of Engineers, they conclude that a transportation rate savings of approximately $3.6 billion per year “justifies the costs of maintaining its infrastructure. Moreover, future operation and maintenance of the system can likely be performed in a manner that minimizes environmental impacts.” It is possible that Phase 2 reported costs of multi-lake regulation could be folded into this process to drastically reduce costs associated and to provide the economic justification the Study Board will suggest is lacking.
It is our opinion that the Study Board has provided the IJC (Commissioners) with ample justification to advance the process of addressing the water levels issue despite its recommendations to do nothing. And we saw that the IJC did just that in tasking the Study Board to undertake the preliminary study on the restoration of water levels. Due to the timelines they have followed, the Study Board did not include the impacts of climate change nor of regulation especially multi-lake regulation in the Restoration Study. Both of these additional factors will be discussed in the Phase 2 report and will lend even more importance to the approach we are recommending. As noted in the review, the Study Board does have a resistance to acting in this regard.
Phase 1 of the Upper Great Lakes Study is closed. This was the phase dealing with changes to the flow in the St. Clair River. It is important that the upcoming meetings stay focused on Phase 2 issues and not get derailed into a rehash of old news about a difference in flow rates between 6% and 9% that is within experimental error of the models in question. There is a difference between “riverine conveyance increases” and “flow rate increases” that the Study Board previously pointed out in its Phase 1 rebuttal of this work. This argument over minutia is a red herring and we already know that it is not sufficient to motivate action by the Study Board and will fall on deaf ears and waste important time in these Phase 2 meetings.
- Aug. 2, from 7-9 p.m. at Lambton College (www.lambton.on.ca), Room A223, 1457 London Road, in Sarnia;
- Aug. 3, from 7-9 p.m. at the Royal Canadian Legion (legion.ca), Normandy Room, 490 Ontario St., in Collingwood;
- Aug. 4, from 7-9 p.m. at the Royal Canadian Legion, 196 Queen St., in Midland;
- Aug. 5, from 12-1:30 p.m. is a special GBA/GBF meeting (UGLSB panel to attend) – at the Parry Sound Legion Hall, 30 Mary Street, Parry Sound, ON, P2A 1E4
- Aug. 6, from 10 a.m. to noon at the Park Center, Main Hall, 39 Henry Drive, in Kagawong (Manitoulin Island);
- Aug. 10, from 7-9 p.m. at Lakehead University (www.lakeheadu.ca), ATAC Room, 955 Oliver Road, in Thunder Bay; and,
- Aug. 11, from 7-9 p.m. at Algoma University (www.algomau.ca), Great West Life Theatre, 1520 Queen Street East, in Sault Ste. Marie.
In this overview presentation regarding Phase 2 of the Study, topics covered will include:
- The potential to improve the regulation plan for Lake Superior outflows at Sault Ste. Marie as well as the need for ongoing monitoring to allow for adaptive management;
- Restoration scenarios for Lake Michigan-Huron water levels including an exploratory analysis of potential lake restoration options. The methods, construction impacts and long-term lake level impacts will be presented; and,
- Multi-lake regulation options.
