Vermilion River Stewardship 379 Ronka Rd. Worthington, ON, P0M 3H0 (705) 866-1677 VermillionRiver@Rogers.com 7 February 2011
Nickel District Conservation Authority (NDCA) Drinking Water Source Protection Program (DWSPP) 200 Brady Street, 1st Floor, Tom Davies Square Sudbury, Ontario P3E 5K3 Attention:
Mr. Paul Sajatovic, General Manager
Dear Mr. Sajatovic: Re:
Vermilion River Proposed Hydroelectric Dams Xeneca Development Corporation Ltd.
Further to our recent conversation, I am writing on behalf of the Vermilion River Stewardship, Walden CAN & Copper Cliff CAN to relay our concerns regarding 3 of 4 run-of-river hydroelectric dams proposed for the Vermilion River, by Xeneca Power Development Inc. (Xeneca), at McPherson FaIls, Cascade Falls, Soo Crossing, and Wabagishik Rapids. As you know, the first three of these proposed dams in question, have no Project Descriptions, and are presently going through the Environmental Assessment (EA) approval process. Therefore, we can only refer you to what has been provided to us in the Project Overview (PO) issued by Xeneca, and enclosed for your information. Our concerns are as follows: 1.
The Inco Source Water Intake located relatively close to the bottom of Cascade Falls. We note that your GSSPA Draft Risk Assessment – May 2010, designates the area above the falls as Intake Protection Zone (IPZ) 2 with a Vulnerability Score of 7, and the area below the falls IPZ 1, with a Vulnerability Score of 10, and an Assessed Level of Uncertainty of “High”. McPherson Falls would have a head pond inundation of approximately 100 meters on Crown Land, Cascade Falls a 3.5 km head pond inundation proposed on Crown and private lands, and Soo Crossing a 4.5 km head pond inundation on Crown and private lands. Xeneca’s PO indicates these dams are all slated for “modified peaking”, which means water will be collected in these head ponds until peak demand hours, to be released through the turbines possibly several times each day to take advantage of those peak demand hours. We anticipate this will create several major threats to the Inco Source Water Intake as follows:
2.
Water rushing through the turbines would create a significant surge of water into the downstream flow, stirring up silt and sediment from the river bottom, creating turbidity, and a risk of releasing heavy metals, such as methyl mercury, and others, into the mix; Erosion of river banks caused by this additional turbidity is another very real possibility; In all 3 dams in question, water flow will be backed up and interrupted for long periods of time in order to fill these head ponds, and left standing until peak demand hours, so water will have an opportunity to increase in temperature. These last few summers we have had lower water levels, and algae has already been an issue on the River, and in wells located along the River, and cyanobacteria may be an additional risk;
Under “modified peaking” there will be an extreme and rapid increase in water levels and current when water is released through these dams, and this could present a major public safety hazard for people swimming at the Centennial Park public beach, located very close to the base of Soo Crossing.
The GSSPA Risk Assessment Report has already placed a high risk assessment to IPZ 1 of 10, and IPZ 2 of 7, so all 3 of these dams would seem to impose a very critical and significant threat to those 13,000 people in Lively, Walden, Whitefish & Copper Cliff receiving drinking water from this source. All three dams are relatively close to one another, and we are very concerned with how this will increase or decrease turbidity, sediment, water levels and water quality in and around this Intake.
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We urge NDCA/DWSPP to: 1.
Deny permission to Xeneca, under Section 28(1) of the Conservation Authorities Act, to restrict, regulate or interfere with the use of water from the Vermilion River at these 3 locations; and failing that Require Xeneca to treat McPherson Falls, Cascade Falls and Soo Crossing as one interconnected system within the EA process; and Require Xeneca to undertake an Individual Environmental Risk Assessment on all three of these dams.
2. 3.
We understand the NDCA’s commitment to protecting and working with the public, and in this regard look forward to your response. Representatives from our Stewardship, the Walden-CAN, and Copper Cliff-CAN would be happy to meet with you to discuss this matter further. Sincerely,
Linda Heron, Chair Vermilion River Stewardship
Neeltje Van-Roon, Chair Walden-CAN
Joanne Renzoni, Chair Copper Cliff-CAN Enclosure Cc:
The Honourable John Wilkinson, Minister of the Environment 77 Wellesley Street West 11th Floor, Ferguson Block Toronto ON M7A 2T5
Mark Holmes, VP, Corporate Affairs Xeneca Power Development Inc. 5160 Yonge Street, Suite 520 Toronto, ON M2N 6L9
France Gelinas, Nickel District MPP Hanmer Valley Shopping Plaza Suite 15, 5085 Highway 69 North Sudbury, ON P3E 5K3
Rick Bartolucci, MPP Sudbury 93 Cedar Street, Unit 302 Sudbury, ON P3E 1A7
Mayor Marianne Matichuk City of Greater Sudbury mayor@greatersudbury.ca
Carolyn Hunt Inco Environmental Group 18 Rink St. Copper Cliff, ON P0M1N0
Jacques Barbeau, Councillor, Ward 2 jacques.barbeau@greatersudbury.ca
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Proposed Vermillion River Waterpower Development Sites – Project Overviews At Soo Crossing - FIT Contract # F-000639-WAT-130-301 – MNR Site #2CF11 Cascade Falls - FIT Contract # F-000640-WAT-130-301 – MNR Site #2CF09 McPherson Falls - FIT Contract #F-000642-WAT-130-301 – MNR Site #2CF46, 2CF47 Wabageshik Rapids - FIT Contract # F-000645-WAT-130-301 – MNR Site #2CF12 Xeneca Power Development Inc. (Xeneca) has received 19 Feed-In Tariff (FIT) contracts from the Ontario Power Authority (OPA) representing a potential waterpower development of 72.5 MW of clean, renewable power for the province of Ontario. Four (4) FIT contracts have been awarded for potential development on the Vermillion River. The four proposed generating stations are McPherson Falls, Cascade Falls, At Soo Crossing and Wabageshik Rapids, located on the Vermillion River, west of the City of Greater Sudbury (see key maps).
Project Overviews The proposed waterpower generating stations will generate clean, green, renewable energy at a total installed capacity of approximately 11.8 MW. The Soo Crossing station will have water control structures (spillway and earthfill dams) and powerhouse with penstock. The Cascade Falls and McPherson Falls stations will have a water control structure (spillway dam) and powerhouse with an open approach channel. The Wabageshik station will have a water control structure (control dam) and powerhouse with a discharge channel. New roads and upgrades of existing roads will be required to access the sites. Transmission lines connecting at Larchwood and/or Espanola TS will be installed in order to connect the stations to the provincial power grid. The projects are subject to the provisions of the Ontario Waterpower Association’s “Class Environmental Assessment (Class EA) for Waterpower Projects“(2008). Pursuant to the Class EA, these projects are considered to be associated with a managed waterway. The Class EA process requires Xeneca to undertake an evaluation of the proposed waterpower projects to determine potential effects to the environment (positive and negative) during construction and operation and prepare an Environmental Report. The projects may also require review and approval under the Canadian Environmental Assessment Act and post-EA approvals are also needed from regulatory agencies. To date, Xeneca has prepared detailed topographic mapping for the Vermillion River at the proposed sites and initiated a variety of environmental field studies to collect existing baseline data on the aquatic and terrestrial features in the area. Preliminary site development concepts of the proposed generating stations are being prepared and will be refined following the collection of additional environmental and engineering field data this summer. The following provides a summary of the key aspects of each of the proposed waterpower generating stations based on the planning and conceptual design work completed to date. This information is subject to change pending the results of further on-site data collection, environmental reviews, and preliminary design.
Site Name:
At Soo Crossing Generating Station
Location: Lat/Long Watercourse Identification: Proposed Generating Station Facilities:
Lat: N 46°23'41.78" / Long W 81°16'50.60"W Existing rapids/falls on Vermillion River ±70 m upstream of existing railway bridge, ±2.6 km downstream of Highway 17 Concrete and earthen spillway dam Penstock and powerhouse Transformer station 700m of new access road to existing Hwy 55 4.4 km 44 kV Transmission Line from 46.39598, -81.28248 to 46.546839, 81.265803 Head pond inundation extending ±4.5 km along the Vermillion River upstream of the proposed dam (1:100-yr flood levels to be determined) Inundated lands are Crown land and Private land. No major river tributaries affected by inundation. Run-of-River with modified peaking Fish species, habitat and migration Terrestrial vegetation and habitat Riparian rights (Crown and Private Land) First Nations/Aboriginal traditional land/resource use Recreational use and navigation Environment Assessment and Approvals: 2010 – 2011 Detailed Design: 2011 – 2012 Construction: 2013 – 2014 In-service Date: 2015
Proposed Transmission Facilities: Anticipated Zone of Influence: Operating Regime: Potential Environmental Considerations:
Proposed Project Phasing:
Site Name:
Cascade Falls Generating Station
Location: Lat/Long Watercourse Identification: Proposed Generating Station Facilities:
Lat: N 46°26'8.80" / Long W 81°17'10.02" Existing rapids/falls on Vermillion River ±400 m downstream of hydro corridor, ±4.4 km upstream of Highway 17 Concrete spillway dam Intake channel and Powerhouse Transformer station 500m of new road and upgrade of 4km of existing roads 4.4 km 44 kV Transmission Line from 46.43637, -81.28755 to 46.546839, 81.265803 Head pond inundation extending along the Vermillion River ±3.5 km upstream of the proposed dam (1:100-yr flood levels to be determined) Inundated lands are Crown land and Private land. No major river tributaries affected by inundation. Run-of-River with modified peaking Fish species, habitat and migration Terrestrial vegetation and habitat Riparian rights (Crown Land and Private Land) First Nations/Aboriginal traditional land/resource use Recreational use and navigation Commercial operations and tourism Environment Assessment and Approvals: 2010 – 2011 Detailed Design: 2011 – 2012 Construction: 2013 – 2014 In-service Date: 2015
Proposed Transmission Facilities: Anticipated Zone of Influence: Operating Regime: Potential Environmental Considerations:
Proposed Project Phasing:
Site Name:
McPherson Falls Generating Station
Location: Lat/Long Watercourse Identification: Proposed Generating Station Facilities:
Lat: N 46°28'15.79"/ Long W 81°17'40.98" Existing rapids/falls on Vermillion River ±8 km upstream of Highway 17
Proposed Transmission Facilities: Anticipated Zone of Influence: Operating Regime: Potential Environmental Considerations:
Proposed Project Phasing:
Concrete spillway dam Intake channel and Powerhouse Transformer station ±4 km of new access road to existing local road 4.4 km 44 kV Transmission Line from 46.47102, -81.2946 to 46.546839, -81.265803 Head pond inundation extending along the Vermillion River ±100 m upstream of the proposed dam (1:100-yr flood levels to be determined) Inundated lands are Crown land. No major river tributaries affected by inundation. Run-of-River with modified peaking Fish species, habitat and migration Terrestrial vegetation and habitat Riparian rights (Crown Land) First Nations/Aboriginal traditional land/resource use Recreational use and navigation Commercial operations and tourism Environment Assessment and Approvals: 2010 – 2011 Detailed Design: 2011 – 2012 Construction: 2013 – 2014 In-service Date: 2015
Site Name:
Wabageshik Rapids Generating Station
Location: Lat/Long Watercourse Identification: Proposed Generating Station Facilities:
Lat: N 46°16'8.94" / Long W 81°37'27.19" Existing rapids/falls on Vermillion River approximately ±400 m downstream of existing local road, approximately ±600 m downstream of Wabageshik Lake Concrete spillway and control dams Powerhouse and open discharge channel Transformer station ±400m of new access road and upgrade of 800m to existing road 16 km 44 kV Transmission Line from 46.26925, -81.627228 to 46.263321, -81.773308 Head pond inundation extending along the Vermillion River ±600 m upstream of proposed dam to Wabageshik Lake (1:100-yr flood levels to be determined) Inundated lands along Vermillion River are Crown land. No major river tributaries affected by inundation. Extent of inundation (if any) to Wabageshik Lake to be determined Run-of-River with possible modified peaking subject to confirmation Fish species, habitat and migration Terrestrial vegetation and habitat Riparian rights (Crown Land) First Nations/Aboriginal traditional land/resource use Recreational use and navigation Commercial operations and tourism Environment Assessment and Approvals: 2010 – 2011 Detailed Design: 2011 – 2012 Construction: 2013 – 2014 In-service Date: 2015
Proposed Transmission Facilities: Anticipated Zone of Influence:
Operating Regime: Potential Environmental Considerations:
Proposed Project Phasing: