Restore Our Water International Says IJC Fails to Implement It’s Own Emergency Measures to Mitigate High Water Levels on Upper Great Lakes

November 15, 2018 2:02 pm Published by

Open Letter from Restore Our Water International requests that the IJC and its operational Boards commit to impartial implementation of ALL of the 1993 crisis response measures to make our communities more resilient to a changing climate. The Governments of the United States and Canada have done a major disservice to its constituents by ignoring the IJC’s long valid recommendations.

Restore Our Water International
7749 Cordwood Shores Drive

Mr. Jean-Francois Cantin, Canadian Member, ILSBC National Hydrological Service
Environment and Climate Change Canada
801-1550 avenue D’Estimauville, 8th Floor, Office 8103 Québec, Quebec CANADA G1J 0C3

Major General Mark Toy, U.S. Member, ILSBC Commander, Great Lakes and Ohio River Division U.S. Army Corps of Engineers
550 Main Street RM 10524

Cincinnati, Ohio 45202-3222 Dear Mr. Cantin and MG Toy:

I am writing to you as the Chair of Restore Our Water International (ROWI) to express our concerns about the International Joint Commission’s (IJC) failure to implement emergency response measures to mitigate high water levels on the upper Great Lakes over the last four years. ROWI is an alliance of American and Canadian organizations concerned about the dire environmental and economic impacts of severe high and low water levels on the upper Great Lakes, including Georgian Bay. ROWI represents over 15,000 shoreline owners and commercial interests. The mission of ROWI is to advocate for restoration of natural water level ranges and flows in their interconnecting waterways altered by man-made changes.

The IJC has failed to implement its own recommendations outlined in its 1993 Report to Governments from the International Levels Reference Study dealing with crisis response measures for mitigating extreme water levels throughout the Great Lakes. Our membership believes that the IJC has worked against implementing solutions to reduce excessive outflows through the St. Clair River during the 14-year low water epoch from 2000-2014 and ignored the necessity to reduce inflows from the Long Lac and Ogoki (LLO) diversions over the last two years. Both of these measures were outlined in the 1993 IJC Levels Reference Study as key approaches to reduce damages caused by extreme water levels. The inaction by the IJC and the ILSBC in particular over the last four to five years has caused substantial damage to the ecosystem and economy of the upper Great Lakes in favor of hydropower production in Ontario. The IJC’s Advice to Governments dealing with the International Upper Great Lakes Study in 2013 recognized that flexible structures in the St. Clair River warranted further study. However, the IJC failed to promote further investigations on this concept thereafter. Generally, consistent public concerns for structural and operational adaptive measures have been ignored by both Governments.

Following the disastrous and protractive 14-year long extreme low water period of the early 21st century, lake levels shot up starting in mid-2014 on Lake Superior and quickly followed on Lakes Michigan-Huron as well as the other lakes downstream. The 1993 Reference Study identified two significant levels of note, being referred to as “initial action levels” for each Great Lake when adaptive operational measures should be undertaken. The high water initial action levels for lakes Superior and Michigan-Huron are 183.58 meters (602.30 feet) and 176.98 meters (580.64 feet), respectively. The major action to be undertaken at those levels was to coordinate hydropower cutbacks of the LLO diversions into Lake Superior.

Cheboygan, MI 49721

Starting in January 2014, Lake Superior’s mean water levels have exceeded the initial action level in 33 of the 57 full months until now, nearly 58% of the time. Over the same period, the increased inflows from LLO and operational deviations from Plan 2012 have caused Lakes Michigan-Huron levels to exceed the initial action levels for a total of 4 months. Higher water levels on lakes St. Clair and Erie throughout the same 57-month period are also exacerbated by this inaction.

The LLO diversions are man-made and controllable benefitting only hydropower interests. Meanwhile the unnatural additional supplies have exacerbated beach erosion and bluff retreat on the upper Great Lakes, along with adversely affecting littoral transport, ecological processes and shore protection structures throughout the system.

It is long overdue for the ILSBC to petition the IJC to negotiate a reduction in LLO diversion inflows to not exceed 30 cubic meters per second (cms) (or 1,060 cubic feet/second) until water levels on the upper Great Lakes return to ranges below the initial action levels. In particular, this measure needs to be implemented before the Spring 2019 freshet north of Lake Superior causes another season of abnormally high water levels downstream. Our analysis indicates that if the 30 cms maximum LLO outflow restriction had been applied beginning when Lake Superior exceeded the initial action trigger of 183.58 meters in June 2014 and carried out every month thereafter when levels were above that target, water levels throughout the system would be dramatically lower. In fact, Lake Superior levels would now be at least 10-15 centimeters (4 to 6 inches) lower, with similar lowering of lake levels for each lake downstream. Diverting water into the Great Lakes when we have abnormally high water supplies can no longer be justified, regardless of the impacts on hydropower production.

We ask you to utilize the authorities that you possess under the Boundary Waters Treaty as amended to ensure that benefits and disbenefits are shared equally between user groups and geographies. Furthermore, we request that the IJC and its operational Boards commit to impartial implementation of ALL of the 1993 crisis response measures to make our communities more resilient to a changing climate. The Governments of the United States and Canada have done a major disservice to its constituents by ignoring the IJC’s long valid recommendations.

Respectfully,

Roger L. Gauthier, Chair
Restore Our Water International, Inc.

 

 

Copies furnished:
Mr. Rod Caldwell, Secretary, ILSBC
Mr. Arun Heer, Secretary, ILSBC
Mr. Jacob Bruxer, Regulation Representative, ILSBC Lt. Col. Greg Turner, Regulation Representative, ILSBC

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