Wednesday, August 24, 2011

August 19, 2011

Re: Comments on IUGLS report “Options for Restoring Lake Michigan-Huron Water Levels: An Exploratory Analysis”

The Great Lakes Section of Sierra Club Canada wishes to submit the following comments on the May 26, 2011 document of the International Upper Great Lakes Study entitled “Options for Restoring Lake Michigan-Huron Water Levels: An Exploratory Analysis”, and on the ensuing Public Meetings that occurred in Canada.

Impact of Another Scenario: Zero Restoration of Lake Michigan-Huron (MH)
Although Zero Restoration of MH was part of the study proposed by the IJC Commissioners, details of the impact of such an approach were not given in this report or in any detail at the public meetings.  The implications of this oversight are discussed later in this submission; however it should be pointed out at once that this oversight is representative of the general lack of balance in the report and in the presentations at the public meetings, which is a major issue. By not evaluating the “do nothing” scenario it is implied that there are no negative impacts to the status quo or that they are considered acceptable.  Existing and possibly worsening negative impacts to the environment and economy around Lakes Huron & Michigan should be included in this report for the IJC’s consideration.

Use of IUGLSB Great Lakes levels and connecting channels flow data
In a previously submitted Sierra Club report on restoration simulation modeling  by Bill Bialkowski, (one of the engineers in our Great Lakes Section), by using three different approaches found the outflow of Lake Huron to be missing 200 cu.M./second flow. Was the correction of the connecting channel flows made prior to running the restoration simulation models for this Restoration Report? If not, why not? An explanation is needed, for this significant missing 4% amount of the flow could influence the results.

Error Found in Presentation of Downstream Impacts
Sierra Club has confirmed with IUGLSB Co-Chair Dr. Eugene Stakhiv that there are errors in the presentation of restoration’s downstream impacts.  There is a contradiction between the report’s graphs and the “Table 3.3 Downstream impact of restoration, comparing staged and instantaneous scenarios”.  The numbers on Table 3.3 and in the text are consistently higher than the values portrayed in accompanying graphs.  Though this error was confirmed, we have not yet received the clarification.  Is one of the portrayals correct, or are they both wrong? On the one hand, the model shows that the impact on the Port of Montreal would be almost zero.  On the other hand, the result looks as if the Port of Montreal would be unusable for a period of time – a possibility that would quickly and categorically turn some stakeholders against the restoration option.   We recommend that all possible efforts be made to correct the report and to clarify to stakeholders the best prediction of conditions.

Lake St. Clair Fishery
In Section 6.8 (page 138), the following statement appears: “A lowering of Lake St. Clair water levels by a metre or more could eliminate more than 40% of the available fish spawning habitat in shallow near-shore areas of Lake St. Clair.”  At the public meeting a colourful map was shown on the screen to illustrate the dire habitat and sport fishing loss if this 1-metre lowering occurred.  However none of the St. Clair River restoration scenarios show a lowering of Lake St. Clair by more than 7.5 cm.  At the same time, what was flashed on the screen and discussed was an old map created for a different project to outline the problems that would ensue if Lake St. Clair were hypothetically lowered by one metre.   The use of that map in the report and at the public meetings could have misled the public into thinking that Lake St. Clair was going to be lowered by 1 metre.  

Water Levels Imbalance
The current situation of 13 years of low water levels on Lake Michigan-Huron (MH) and several years of higher than long-term average water levels on Lake Erie is presented in the report as the normal base from which to describe the impact of any possible efforts to raise MH.  It is, however, not the historical normal base, for Erie and MH were usually in harmony regarding higher and lower water levels.  At the public meetings Study Board representatives justified their interpretation of the current relationship as normal by citing changing weather patterns that have been leading to greater precipitation south of MH and directly on Erie and its basin.   Though what the Study Board states may be partly true, it is not credible that the weather pattern has changed so much over 13 years to lead to the current imbalance, for 79% of the total water supply to Lake Erie flows from MH through the connecting channel, and only 21% of the water in Lake Erie comes from its own receipt of precipitation and runoff from its basin.  Where are the data to support the claim that the main factor in the creation of the imbalance in the current water levels there is precipitation?  The changing weather patterns explanation was also used at several public meetings to refute statements that the increased flow through the St. Clair River has been an important cause of the imbalance in those lakes’ water levels

Fixed Structures vs. Other Measures
In Section 8 (pages 154 and 155) of the report, the IJC directive to the Study Board is outlined.  Part of it follows: “The analysis will include an investigation of structural and non-structural measures at an exploratory level of detail.  The Commission is aware that as part of the first phase of the study, you have already undertaken a preliminary reconnaissance of structural measures to remediate the impacts of past dredging for the St. Clair River.  The public has also suggested a range of approaches, including inflatable weirs and power generating turbines.”

What is in the report are dozens of pages on fixed structures in the St. Clair River presented in great detail.  Even peer-reviewer Loucks criticized the excessive detail of the description of the fixed structures.  Inflatable weirs are dismissed in a couple of paragraphs in the report and received similar treatment at the public meetings.  Power-generating turbines are presented briefly and at first positively in the report, followed by a report on modeling in the St. Lawrence River that “.showed less than a 3 cm (1.2 inch) increase in water levels immediately upstream of six turbines”. The report authors should be aware that a proposed project with up to 396 turbines in the St. Clair River is under investigation.  The National Research Council is conducting a study of the ability of submerged turbines to hold back water.  Unfortunately, that study will be published after the deadline for public comment on this report.  Before that study and the environmental impact studies of the turbine proposal for St. Clair River are published, the U.S Co-chair Dr. Eugene Stakhiv is known to have circulated an email stating that the turbines will turn local fish into “chum”.  This is not a foregone conclusion: the evaluation of the submerged turbines in the Bay of Fundy states that there is neither an increase in the mortality rate of fish nor damage to the very productive marine life.  In short, a more thorough and balanced study is needed of both the submerged turbines and inflatable weirs concepts.

In addition, it has been well known for some time that the environmental community is not promoting fixed structures but rather flexible ones. The elaborate printed details of the nature and cost of fixed structures are a further example of the lack of balance in the May 26 report. 

Worst Case Scenarios
The following appears in Section 3.5 (page 36) of the May 26 report: “Results of a worst-case, poorly-timed restoration show that instantaneous 10 cm (3.9 inch) restoration might drop record low Lake Erie surface elevations by an additional 7 cm (2.8 inches) for almost one year. Also, a worst-case poorly-timed instantaneous 25 cm (9.8 inch) restoration might drop record low Lake Erie surface elevations by an additional 12 cm (4.7 inches) for almost 1 year. These outcomes require terrible timing of an instantaneous restoration during a period of already record low water levels.”  In a balanced report this devastating statement would be followed by the description of a “Best Case Scenario”.  That would be accomplished by excellent timing of a gradual raising of MH levels during a period of high water levels on Lakes Erie and Ontario and low water levels on MH.  Such conditions exist today, and it is quite possible that gradual remediation measures would result in only a very small, temporary lowering of the high levels of Lake Erie.  The May 26 report has many worst case scenarios presented in detail, as summarized in Section 3.3.3 (page 22). The lack of a balanced approach to this study is exemplified by this stress on worst-case scenarios.

Justifying the Cost
Section 7.5.4 (page 150) of the May 26 report reveals what is possibly the true agenda of the Study Board.  It begins with the following: “The proposed works, while potentially benefitting some select area-specific riparian, recreational boating, and environmental interests, likely will not provide the broader scale of economic benefits that has traditionally been demonstrated to support funding of major lake regulation initiatives.”  Economic benefits are, then, the key issue.  Thankfully the study does show in detail the future economic benefits to the shipping industry of raising MH levels in order for commercial ships to carry full loads as opposed to the loss of income that industry is currently suffering because of low water levels on MH.

Even as a primarily economic evaluation this report has gaps:
·         Where are the data on economic consequences to the sport and commercial fishery of this ongoing loss of fish habitat on Georgian Bay and the North Channel  (already 30-40%) if MH water levels are not raised and do not fluctuate normally? 
·         Where are the data on the cost to marinas of dredging and the closure of docking spaces in the past 13 years and in the foreseeable future if water levels on MH continue to remain this low or go even lower? 
·         Where are the data on the economic consequences to riparian interests of the invasion of Phragmites australis due to the continuous exposure of new shore where they thrive? 
·         Where are the data on the cost to water-access property owners of current and very likely future lower water in MH that leads to inaccessibility?
·         Where are the data on the future cost to municipalities on MH, particularly Canadian ones, of the likely adaptive management measures that the Study Board has already discussed, if nothing is done to raise the water level of MH?  
These essential data to decision-making on economic grounds are nowhere to be found in this report. These are just some of the costs of the “do nothing” alternative that has been left out of this report’s evaluation of alternatives.

Paragraph 3 in Section 7.5.4 (page 150) provides a troubling rationale for not restoring water levels: it may be ‘politically’ difficult.  It begins with: “The problem is that many changes have occurred since the completion of the 8.2m (27-foot) project in 1962.  First, many riparians have adapted to the present water level regime and would experience significant additional losses from flooding and erosion if average Lake Michigan-Huron levels were to be permanently increased”, and the paragraph ends with: “This would suggest that such prospective restoration would be politically infeasible.”   The riparians who have “adapted” are almost exclusively U.S. citizens in western Michigan who obtained the right to own the newly exposed land down to the water’s edge and created splendid beaches and, in many cases, some structures on that land which, if traditional fluctuations in a normal, balanced water level situation occurred, would be threatened at the higher levels of the usual range.  Their claims and, at the Parry Sound-Muskegon public meeting on Phase I, the  public threat of court action “if  anything placed in the St. Clair River raises our water level one inch” explain the ‘politically infeasible’ statement.

Although at every recent public meeting in Canada, Dr. Ted Yuzyk repeated that his team were exclusively scientists and part of an independent agency with no political aspect to it, it is clear that the politics of dealing with a powerful U.S. group that has already won one court action against the U.S. Army Corps of Engineers has steered the agenda of this study towards rejecting, for both unsubstantiated economic and clearly political reasons, any logical correction of the current low water levels in MH. Further evidence of that is the $8 Billion price tag that was quoted at the recent public meetings  for 5-lake regulation and the new structures and studies necessary for it.  No figures were given to show that this price tag is accurate. Nor was there any mention that future shipping industry and other financial benefits would make such an investment very sound economically.  Once again, where is the balance?

Government’s commitment to compensate
Thanks are extended to the Study Board for acknowledging on in Section 7.6 (page 151) under “Findings” that: “There exists an existing government commitment to compensate for the lowering effect of the 7.6 m (25-foot) and 8.2 m (27-foot) navigation channel deepening projects” and “There is no record, however, of a government decision not to complete compensation in the St Clair River.”  That should speed up the process of decision-making.

It is important to note that Ralph Pentland, in his report to Phase I of the study, stated that, if both federal governments declared the situation an emergency, the work could be completed in eight to ten years.  That official report makes it all the stranger that the current report’s proposal for restoration as it would impact Georgian Bay is to raise its water level by only 10 cm over 40 years.  The report points out that 40 years of GIA in, say, the Parry Sound area, would render that rise negligible, while the corresponding rise in water level caused by a combination of the restoration and GIA would be unpopular to some shoreline property owners in western Lake Michigan.  If, however, the restoration raised MH water levels by 25 cm in 10 years, the net impact of that rise along with 10 years of GIA would be +22.6 cm at Parry Sound and +26.4 cm in south-western Lake Michigan. Surely that modest difference in impact would not be rejected by reasonable people in Michigan

It is clear that the exaggerated time requirement in the May 26 report caused a feeling of futility among some Georgian Bay residents. In addition, it is disturbing that, when in preparation for a local newspaper article, an Owen Sound Ontario reporter had a lengthy discussion with Chuck Southam at Environment Canada, the futility of any action to help Georgian Bay was stressed by Mr. Southam, citing GIA.  It is most unfortunate that Environment Canada is reinforcing the presentation of  as negative a view as possible of the restoration of MH water levels.

In Section 4.4.1 (pages 49 to 53) of the May 26 report, there are many statements about the negative impact of MH restoration on hydro-electric generation.  All of them are based on the assumption that the current level of MH is normal, which it is not; it is at a record-long period of sustained low water.  Returning MH to its normal range, that is, in equilibrium with Lake St. Clair, Lake Erie, and Lake Ontario, would in all probability result in the same levels of hydroelectric generation as those achieved before the 13 years of sustained low water levels on MH. This is a non-issue except for those who believe that MH should remain in this state of non-equilibrium with the downstream lakes.

1986 Revisited
In every description of restoration of water levels to MH by installing either permanent or the preferred flexible structures in the St. Clair River, there is the caveat that raising MH could, in various scenarios of frequency, lead to the high water level of 1986, or even higher.  At the same time, though in different parts of the report and in all the presentations at the public meetings, it is pointed out that the precipitation-carrying wind currents have altered their course such that there continues to be less precipitation on the MH and Superior basins and considerably more on the Erie and Ontario basins. These two statements – a possible repeat of shore-and property-damaging record high levels on MH, and ongoing low levels on MH induced climatically by lower precipitation on the MH basin, contradict each other. Yet those citizens at the public meetings seemed to accept them as plausible because they were presented in isolation.  These two future possibilities should be presented in juxtaposition to enable the public to weigh the balance between them.

It is also important to determine scientifically whether the flow of extra water through the St. Clair River caused by the increase in its carrying capacity has, by the present time, removed a significant amount of the base, glacier-deposited 99% of the water in MH.  That is a critical issue, especially as it concerns the inevitable future lows in the MH water-level range.  Those future lows received scarcely any mention in the May 26 report, as compared with the extensive coverage of the possibility of future highs.

Helpful Soft Measures
It is unfortunate that the May 26 report made no mention of some helpful soft measures such as the following: 
·         Re-naturalizing the extensive hardened shorelines on both sides of Lake Huron leading to the St. Clair River, in order to restore the previously natural flow of sand in the water entering the river;
·         Replacing the natural sand and gravel  bar at the outflow of Lake Huron removed in 1962;
·         Studying the feasibility of floating wetlands that would be moved in and out of the St. Clair River channel as needed.
These types of measures would improve fish habitat and would be looked on favourably by the environmental community and the general public.

Some Kudos
While this submission of comments is of necessity critical, we wish to compliment the Study Board for its coverage of Section 4.4.4 “Ecosystem” from pages 68 to 74 of the May 26 report.  Although we do not agree with the form of the restoration plans presented, restoration is important, and so it is encouraging that under “Evaluation Results” the following statement is made: “The restoration plans generally reduce the frequency of [extremely and permanently harmful] Zone Cs for three performance indicators (SMH-04, LMH-07, and LMH-08) while not increasing the frequency of occurrence of Zone Cs for any of the other 31 performance indicators.  Hence it improves the overall ecological performance of Lake Michigan-Huron somewhat, with the greatest positive effect being on the wetlands of Georgian Bay.” 

Ecosystem health is very important to the Sierra Club and to many of the stakeholders around the Great Lakes, and it is well known that a primary indicator of the health of a system is the health of its wetlands.  Let us share this strong concern for their care!


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