| The Independent Expert Review of the Lake Ontario - St. Lawrence River Study (LOSLR)The International Water Levels Coalition (IWLC) was very pleased with the foresight shown by the International Joint Commission (IJC) in commissioning an expert third party review of the recently completed 5-year study. With over $20 million spent, it is essential that we now have confidence that the information generated by the study is reliable enough to be used in the decision-making processes integral to the adaptation of a new regulatory plan.In establishing an expert scientific review committee, the IJC very wisely chose two bodies with impeccable and unimpeachable credentials: the National Research Council (NRC) of the U.S. National Academy of Sciences in collaboration with the Royal Society of Canada (RSC). Their recently published report “Review of the Lake Ontario-St. Lawrence River Studies” was, quite naturally, in-depth, insightful and informative.
While praising the scope of the studies as well as the depth of much of the environmental work, the NRC/RSC described a number of shortcomings with the studies. They felt the intervals used in measuring water level changes (quarter-months) were not fine enough to capture significant short-term level changes. They felt a dynamic model should be adapted for an updated plan. They found there to be a general lack of supportive documentation including clearly validated sampling plans, methodologies and data aggregation techniques. The NRC/RSC also criticized the lack of detailed descriptions of the uncertainties in the data.
On the positive side of their report, the NRC/RSC made many recommendations, both short-term and long-term. Much of the lacking documentation and a more detailed description of the data uncertainties can still be provided in the short-term. A commitment to a defined ongoing program could incorporate many of the NRC/RSC long-term recommendations.
The IWLC has advocated the use of a dynamic regulation plan (such as nature provided prior to the Seaway/Power Project) since the inception of our organization. This will take some time and effort to fully develop and implement, but it is something that desperately needs to be accomplished.
The IWLC’s current position remains consistent with our declaration at the Water Levels Summit III in Clayton, NY in August of 2005. We believe that the adoption of Plan B+ is a great place to begin the evolutionary process of going from a mid-twentieth century linear regulation plan to a more natural twenty-first century, environmentally sensitive, dynamic regulation plan that takes advantage of the advances in technology.
Possibly one of the most clarifying developments in the entire study was the review and resultant recommendations provided by the NRC/RSC. The questions raised by the NRC/RSC review need to be answered and the recommendations offered need to be implemented. To have spent over $20 million thus far and not make any meaningful significant changes would be highly irresponsible. We need to begin the adaptive management phase of the study and continue to pursue the more “ideal” natural plan.
Has the NRC/RSC Review Changed the IWLC Position on Plan B+ ?With the number of problems already identified in the overall study, is the IWLC still supporting Plan B+?First, our decision to support Plan B+ was not based upon the final study report’s economic numbers since we believed them to be seriously flawed. The problems that we found in the recreational boating study were very similar to those uncovered by the NRC/RSC in the three other parts of the study that they reviewed.
Instead, our decision was based upon only the calculated water levels during the boating season. Water levels under Plan B+ clearly remain higher from mid-August through October. The great majority of recreational boaters have indicated that the present regulation plan’s curtailment of the late-summer-fall boating season is a major concern for them. The low fall water levels created by the current plan also presents serious problems for marinas during haul-out time.
Secondly, the choice of Plan B+ from an environmental viewpoint is apparent. Plan B+ maintains water levels much closer to the natural variation and is the closest to the design of Mother Nature. It shouldn’t take a blooming genius to figure out that Mother Nature had designed the best plan for the environment in the first place!
Let’s take a look at the way that Plan B+ works and why it differs from the various other man-made plans. Plan B+ starts with the premise that Mother Nature’s pre-project plan was a very sound plan. The calculated weekly outflows basically start out with what would have flowed out of Lake Ontario and down through the International Rapids prior to the building of the Seaway/Power Project (Mother Nature’s dynamic plan). Minor adjustments are then made to lessen abrupt changes and to reduce the chance for flooding or prolonged dry spells. The “natural rhythm” of the seasonal rise and fall of the water levels is restored. It is critical to fish and wildlife that levels are rising and falling at the correct time of the year.
A lingering flaw in Plan B+ is the quarter-month intervals. Mother Nature’s dynamic regulation plan made second-to-second adjustments to the outflow rates. She didn’t wait a week or a quarter of a month to make her decisions between adjustments. To truly understand the dynamics of the lake and river we need to use at least daily and hourly intervals. We are in 100% agreement with the NRC/RSC on this matter.
It is certainly understandable why we didn’t use daily and hourly intervals back in the 1950’s. We didn’t have high-speed computers to handle such a volume of information in a timely manner. That is not the case today. Water level data is now available on a second-to-second basis, the same as it used to be to Mother Nature. The information is available; we choose not to use it.
While changing this time interval should have been done during the study, it is not too late to begin the process now. We can begin by implementing Plan B+ with quarter-month intervals, continue to develop the finer interval models, and incorporate them into the plan over time as part of the adaptive management process.
The very worst-case scenario would be to remain with a plan based on out-dated technology, e.g., the current plan - Plan 1958 DD. We have experienced and documented its failings. We have spent over $20 million and know there are better ways to manage the lake and river. We desperately need to begin the process of bringing the regulation plan into the twenty-first century. We cannot accept yet another failure.
We need to attend the IJC’s public hearings on the study results to be held this summer (we’ll keep you informed on the where and when). We each need to also contact our elected government officials and express our opinions and let them know that we expect at least some positive results from our $20 million in taxes.
Why the IWLC Supports Plan B+In late 2000 the United States and Canada decided to support a 5-year study to be conducted under the supervision of the International Joint Commission (IJC). The study was to determine if the current 1950’s water levels regulation plan should be replaced with an updated plan that would additionally take into account environmental concerns and the much expanded recreational boating industry. The study cost of $20 million (US) was shared equally by both countries and concluded in 2005. Herein we describe our rationale for supporting one of the plans proposed - Plan B+.Sometime this year the IJC will reach a decision concerning the possibility of choosing a new regulation plan for the Lake Ontario - St. Lawrence River system. The IWLC believes this will be an extremely important decision, impacting the Great Lakes system for years to come. We wish to express our recommendation for Plan B+, and the rationale for our decision.
The IWLC was founded on the basis of looking for a regulation plan equitable for all, not just for one interest or one single area. We felt that both recreational boating and the environment should be added considerations in any new plan. We also thought that regulation should try to return the system closer to its natural order - more out of just common sense than any specific environmental studies. These were our stated aims well before any of the plans came forth.
Many of our originating members were from the boating industry, owners and operators of marinas. They, along with many of our members, stated that the most important issue with water levels was the rapid “draw-down” of levels from the late summer to autumn. A common comment was “they just pull the plug in August and put an end to our boating season”. Marina owners stated that they needed higher autumn levels for “haul-outs” in October. A first year boating survey by the Public Interest Advisory Group (PIAG) reinforced this when 96% of those identifying water level problems associated with a time of the year, cited low levels in the late summer to autumn as their greatest concern.
In the end, we examined five plans. Two of these were reference plans: 1) Plan 1958DD, currently in use, and 2) Plan E, a plan that very closely mimics the natural outflows prior to the St. Lawrence Seaway Power Project. There were three new proposed regulatory plans: Plan A+, Plan B+, and Plan D+. So why did we finally choose to support Plan B+?
Using the latest data models, Plan A+ would produce very few cases of low boating water levels from May through August (for Lake Ontario and the 1000 Islands - almost zero). However, both Plan A+ and Plan D+ require rapid “draw-downs” beginning in late August - similar to the current plan. The “draw-down” for Plan A+ is essentially the same as the current plan and the “draw-down” for Plan D+ is more severe. Plan A+ is definitely the best plan for May - August boating levels only in Lake Ontario and the St. Lawrence River down to the Cornwall-Massena dam.
What Plan A+ doesn’t do is add any length to the boating season, provide marina owners with levels for October “haul-outs”, or alleviate the “they pulled the plug in August” syndrome. It also does nothing to restore the natural order to the system or to restore the environmental damage we’ve done to the system over the past forty-six years. Using the latest models, both Plan A+ and Plan D+ perform poorly environmentally. As an example, on page 84 of the Study Board’s Final Report it states “Plan A+ is not allowing the needed lows for the regeneration of the wetlands. These results are consistent with the 50,000 year stochastic run of the Lake Ontario wetlands model which shows Plan A+ to be the worst plan (including Plan 1958DD) for both the meadow marsh and emergent marsh”.
However, if there is an interest in a longer boating season without the rapid “draw-downs” in the late summer and autumn and in the environmental health of the lake and river, Plan B+ is preferable. Marina owners have indicated to us that the longer season is very important to them. Because Plan B+ follows the more natural outflow patterns, the water levels are spread out more evenly over the year, with less variation within a year. However there are greater year-to-year variations as did occur in the natural system. Providing for “the needed lows for the regeneration of the wetlands” would cause occasional boating problems with Plan B+. During these times it would be difficult to boat, even during the summer months.
So, as expected, it all came down to a series of compromises. None of the plans are ideal for all interests and all areas. How well does each of the plans meet our stated concerns and objectives? What do we give up with each of the plans? In the end we looked for the best fit. In keeping with our original aims, we chose not to exclusively consider only one interest or one exclusive area.
We felt that Plan B+ best met the original concerns and aims of the IWLC and represented the best compromise. It addressed the most repeated concern of our recreational boaters and marina owners in that it would alleviate the rapid decline in water levels in the late summer and autumn and extend the boating season. It is the only plan that begins to return the lake and river to their natural patterns of level changes. It is the only plan that helps to restore our environment and fisheries. Many of our members have stated that the occasional very low water years (about 3 out of 101) is a reasonable price to pay for the other clear advantages. Most all would like the availability of a longer boating season combined with environmental improvements. We also believe that the “do-nothing” option (i.e., staying with Plan 1958 DD) would be highly irresponsible. After $20 million and a great deal of work and effort from those involved in the Study, we certainly all know better than to accept the past status quo.
In the end, we felt we should act responsibly and “do the right thing” for this incredible resource (the Lake Ontario - St. Lawrence River system) that we have the very good fortune of sharing and enjoying. We believe that means recommending Plan B+.
We believe the adoption of Plan B+ would be a very positive first step in an ongoing process of constant review, updates and improvements to water level regulation through adaptive management. We likewise support changes to the Advisory Group and the St. Lawrence Board of Control to make them more inclusive of, and more responsive to, a broader array of interests.
The IWLC pledges continued support for a regulation plan that attempts to achieve water level control that is equitable for all interests as well as sustaining the ecology of the Great Lakes-St. Lawrence River system
Click here to view IWLC on the Road in Support of LOSL Plan B+. |
Twist in the tail: Size is no obstacle for the cormorant, which simply unhinges its jawbone and lets the pike slide out of sight down its elastic throat