Muter: There is a viable solution that will address all concerns

From Mary Muter: presentation to public meeting

International Joint Commission July 16 2012 

Chairs Comuzzi and Pollack, Commissioners Knott, Glance and Moy,

As you are aware, I am the Great Lakes Section Chair for Sierra Club Ontario and acting Co-chair of the Bi-national Great Lakes Coordinating Committee for all 9 Great Lakes Sierra Club Chapters. You have before you a very large group of concerned citizens who have returned for the fourth time to repeat to you that 13 years of sustained low water levels have had very serious ecological and economic impacts. Quite frankly they feel they have not been listened to. The time to act to restore our water levels is now before further ecological and economic harm takes place. For almost 13 years our water levels has met the terms of crisis conditions as identified in your 1993 Levels Reference Study. And as an Environment Canada  staff member working in the Study said to me in 2007 – the IJC is right now ignoring their own advice – the Levels Reference Study Crisis Conditions recommendations.

You and your predecessors have heard of the initial work in 2004 with W.F. Baird and Associates to determine if an increase in conveyance capacity in the St Clair River is a contributing factor to the sustained low water levels.  Baird found a significant increase and presented their findings to Environment Canada, USACE, USGS, GLERL , GLC and the IJC.  The then US Chair Schornack stated that the findings were sound and justified further investigation by the IJC.  Following that the Upper Lakes Study Board was established.  Originally the Commissioners requested our involvement in the Study in appropriate areas. But once underway the Study Board made it clear that our input was not welcome. So we have watched this entire saga unfold mainly from the sidelines. However our understanding and expertise have allowed us to review with integrity a significant portion of the Study’s work. Unfortunately for the general public, the science is so complex that their ability to understand it is extremely limited.  That has saved the Study Board from closer scrutiny and more overt public outrage. 

I am here today to tell you that Sierra Club Ontario’s Great Lakes Section does not accept the findings or the recommendations regarding St Clair River restoration.  We know the devastation that has happened to our wetlands, and diking a few of the thousands of dried up wetlands will do nothing for fish that need wetlands for spawning and/or nursery habitat.

In the past four years we have given you carefully documented verbal and written submissions, expecting that that well-founded proposals would be treated with respect and that changes would be made to address legitimate concerns. Sadly that has not happened. The Study is now completed and you are here to hear our comments on the Final Report from the IUGLSB. The bottom line is that some of the science has not been carried out at the level worthy of the IJC.  As for the truly good science, the list of misrepresentations in the reports and the failure at times to use accurate data have led to conclusions that, if followed, will lead to further ecological harm. The most egregious error is the conclusion that nothing can be done in a responsible manner to slow the flow through the St. Clair River.  Unless the mainly finite waters of the Great Lakes are managed responsibly by restoring Michigan/Huron/Georgian Bay to their pre-1962 levels, the decline will continue.  Eventually less and less water will flow down the St. Clair and Detroit Rivers.  What will happen to Lakes St Clair and Erie?  They will suffer the same consequences as our beloved Georgian Bay.

But let me speak of my own main concern about the Study – I believe it has been carried out to intentionally divide and conquer the concerned people of Lakes Michigan/Huron/Georgian Bay. Never at any time was there any realistic attempt to develop a consensus toward a solution to this longstanding problem. The concerns of the US group Save our Shorelines about potential high water levels received inordinate and inappropriate attention, given the highly unlikely probability of 1986 highs ever happening again. I note that the Final Report’s graph on page 167 tells us that according to the Regional Climate Change models we have an over 85% likelihood of even lower water levels in the future. By contrast the likelihood of higher water levels is about 5%. Yet the text related to this graph goes on at length about the potential damages of high water levels to the Muskegon Save Our Shorelines group.   The decision to appoint the attorney who established Save Our Shorelines to the position of US Public Interest Group Chair speaks volumes about the bias that existed within the Study. This slide, totally unrelated to this study, was used last year for the Webex and at all public meetings.  It clearly implies that a 25cm restoration of Michigan/ Huron/Georgian Bay water levels would lower Lake St. Clair levels by 1 meter.  But  the Study’s own models showed a temporary decline of 7cm. What was the point of this enormous misrepresentation? Fear-mongering! To drive the public to accept the do nothing to the St. Clair River conclusion.

Most recently I learned that at your latest meeting on Lake Erie shores the attendees were told that there would be significant ecological harm if Michigan/Huron/Georgian Bay water levels were restored.  Really?    When Lake Erie levels have been mostly well above average for the past 13 years and ours 38 to 50 cm (15 to 20 inches) below average?  Is it honest to state that a temporary decline of 7cm for Lake Erie would have significant ecological impacts? Where is the scientific evidence of that? Nowhere!  And why did the Study not determine the ecological and economic impact of the documented loss of 2,000 ha of the highest quality wetlands found anywhere in the Great Lakes – right here in Georgian Bay?  That ecological and economic loss must be tremendous!  It is only briefly touched on in the Final Report.  

You now have a huge challenge in front of you, Commissioners.  You need to reverse the fear mongering generated by the 2011 report and last summer’s IUGLSB public meetings.  You need to set about now to re-educate all interests, stating that there is a viable solution that will address all concerns and that any downstream impacts can be managed to make them minimal and temporary – a mere 5 to 7 cm. Compare that to the 25 cm of glacial deposit that we have lost since 1962 with no hope of recovery unless responsible action takes place in the St. Clair River.  Enabling our water levels to be restored by 25cm over 10 years is the only responsible option available to you. Your strong leadership will lead to an understanding that proper management of this valuable mainly finite resource demanded this restoration. Canada’s well-respected Great Lakes hydrology expert Ralph Pentland stated that effective management of this restoration would result in no downstream impacts whatever.  In his report to the Study he also said that if governments came together following a recommendation from you the Commissioners, restoration structures could be in place within 10 years. We do not have a moment to waste.

We have been working collegially with the other large Great Lakes engos to develop consensus on what should be done. It took months of work to help folks understand this complex science. Now all 9 Sierra Club Great Lakes Chapters have reached by consensus a policy that MH/GB water levels should be restored gradually by 25cm following a full EIS to determine the best method in consideration of both upstream and downstream conditions. Great Lakes United has passed a very similar resolution and now US NWF and the Alliance for Great Lakes are also supporting restoration. Here locally the Federation of Tiny Township Shorelines Associations has been very supportive as you can see, of restoring our water levels. Earlier today you heard from the distinguished flow-modeling engineer Bill Bialkowski that there is a viable solution that needs full 3D modeling and prototype assessment in the St. Clair River.

I will close by asking: How do you plan to reverse the fear mongering that resulted from last summer’s Restoration Report public meetings? And how can we help you to develop consensus and support for 25cm restoration of Michigan/Huron/Georgian Bay water levels and to then allow the levels to fluctuate within the range determined in your excellent 1993 Levels Reference Study?