TRENT RAPIDS POWER CORPORATION

DOMINION WATER-POWER APPLICATION AND COMMENCEMENT OF ENVIRONMENTAL SCREENING

Trent Rapids Power Corporation (737 Merton Street, Toronto, Ontario M4S 1B4), a joint venture of Peterborough Utilities Inc. (1867 Ashburnham Drive, Peterborough, Ontario K9J 6Z5) and Shaman Power Corporation (737 Merton Street, Toronto, Ontario M4S 1B4), hereby gives notice that on July 7, 2005, an application was filed with the Director of Waterpower, Parks Canada Agency, under the Dominion Water Power Act (DWPA) for a Priority Permit to develop a small hydroelectric generating facility on the Otonabee River at Peterborough, Ontario. The site of the proposed facility is the west bank of the Otonabee River adjacent to Locks 22 and 23, on private lands and lands leased from Trent University and the Federal Crown.

The project involves constructing an intake with control gate structure immediately upstream of the existing dam at Lock 23, a canal on the west bank of the Otonabee River leading to a powerhouse and dam structure and an outlet channel downstream of the dam at Lock 22. Using the Otonabee River as a water source, flows of water regulated by the Trent Severn Waterway would be bypassed around the existing dams at Locks 22 and 23 and returned to the river below the Lock 22 dam, to generate approximately 6 megawatts of electricity. The project is designed to operate on a run-of-the-river principle that does not require storage of water or water level manipulation. Electricity generated would be used locally and/or for general use in Ontario.

An environmental screening for the project will be conducted in accordance with provisions of the Canadian Environmental Assessment Act and the Ontario Ministry of the Environment's "Guideline to Environmental Assessment Requirements for Electricity Projects (2001)."

The intent of this notice is

• to determine, on behalf of the Minister of the Environment, Government of Canada, the level of public interest or objection to the project in consideration of issuance of a Priority Permit under the DWPA. A Priority Permit provides permission for project-related studies and does not constitute permission for construction;
• to provide the first of two mandatory public notices pursuant to the Ontario Ministry of the Environment Guidelines; and
• to request public input on the project.

In the event of protest or objection, the Minister may determine that a hearing may take place. Interested parties will have further opportunities to obtain information and provide comment during the permitting process that will be conducted under the Dominion Water Power Act regulations and other legislation subsequent to the issuance of a Priority Permit.

Under the Dominion Water Power Act, interested parties are encouraged to provide comments or objections in writing within 30 days of this notice to the Director of Waterpower, Parks Canada Agency, P.O. Box 567, 2155 Ashburnham Drive, Peterborough, Ontario K9J 6Z6.

Under the Ontario Environmental Screening process, comments and objections will be accepted at any time during the environmental screening process and should be submitted to the Director of Waterpower, Parks Canada Agency, at the above address. Comments and objections will be considered only if they are in writing.

A public open house will be held on Thursday, February 2, 2006, from 5 p.m. to 9 p.m. at the offices of Peterborough Utilities Services Inc., 1867 Ashburnham Drive, Peterborough, Ontario, to convey project information to interested members of the public.

December 20, 2005

TRENT RAPIDS POWER CORPORATION

A healthy mature hardwood forest is situated west of Lock 22. The woodland is dominated by beech and sugar maple trees. The trees are large with full healthy crowns and thick trunks. Sample beech trunk diameters are 63.5, 63.1, 53.5 cm. d.b.h. respectively. The average trunk diameters of the sugar maples is 48 cm. d.d.h. with some large maples having diameters of 83 cm d.b.h. Other species of mature trees present in low numbers include hemlock, white ash and basswood. The well-spaced trees are interspersed with an understory of small trees and saplings of beech, sugar maple, white ash, alternate-leafed dogwood and bitternut hickory. The dominant groundcovers of the area are blue cohosh, zigzag goldenrod, red baneberry, virginia waterleaf and leatherbush. Introduced plant species such as black currant and Japanese knotweed are also present.

A female Cooper's Hawk was observed in the woods on several occasions. The mature hardwood forest, located near a wetland, makes this an attractive area for this rare hawk species.

Criteria Satisfied

1 - Leatherbush and bitternut hickory rare/uncommon plant species in southern Peterborough County occur sparsely in the area.

2 - The large, beech and maple trees of this woods are species of the climax forest. The moist lowland topography and mature deciduous trees provide excellent habitat for the Cooper's Hawk, a bird species which is very uncommon throughout Ontario.

7 - This nature area offers opportunities for the study of plant ecology, bird habitat etc.

8 - the large beech and maple trees of this woods provide a very attractive setting in context with the nearby river.

Recreational Use Walking, nature appreciation, skiing, T.U.N.G. cornroast

This wetland extends from the east side of highway 28 north of Woodland Drive to the Otonabee River near the west side of Lock 22.

The wetland is composed of open, shrubby and wooded areas. Waters from a stream flowing from Total Loss Farm and from springs originating amongst cattails and cedars north of Woodland Drive merge to form a watercourse which meanders through the area flooding a flat lowland. Near highway 28 an open wet meadow has been created which has been colonised by impressive stands of 1.4 m. tall ostrich ferns and large patches of rough horsetail, grasses and a few scattered apple trees. Bordering the meadow in the south is a wooded area containing white cedar, black ash and aspen trees. In the north is a thicket of low-growing willows which is studded with taller white elm and black willow tree.

Further east the stream flows through an area containing small trees of white cedar, black ash, white elm, aspen, basswood, balsam fir, and yellow birch. Beneath the trees is a dense tangle of wetland plants including hairy willow herb, jewelweed, boneset, joe-pye-weed, cattails, purple-stemmed aster and marsh marigolds. An elliptical basin located in the northeastern portion of the area is wooded with similar tree species, but the ground is covered by mosses, liverworts, sedge, bur reed, dwarf raspberry, marsh bedstraw, spikenard, virgin's bower, helleborine. The area contains six fern species: royal, sensitive, marsh, lady, cinnamon and bulblet fern.

The wetland and it's wooded border provide habitat for a variety of bird species including nesting red-tailed hawks, black-billed cuckoo, common yellowthroat, yellow warbler, chipping sparrow, song sparrow, swamp sparrow, gray catbird, hairy woodpecker, eastern kingbird and ruffed grouse. Sightings and evidence of mammal species of the area indicate the presence of: white tailed-deer, raccoon, porcupine and gray squirrel.

Criteria Satisfied

1 - royal fern is a rare/uncommon plant species south of the Canadian Shield, while spikenard is a species restricted mainly to moist, rich woods. Both species are found in this area.

6 - the wetland collects and stores water from a stream, springs and rain and meltwater run-off. Drainage from the area flows into the Otonabee River.

7 - the area is used to teach the identification and ecology of lowland vegetation

8 - the fern and horsetail meadow portion of this area are particularly attractive and can be viewed from highway 28.

Teaching Use Biology 100, 322

A proposal has been made by the Trent Rapids Corporation (a joint venture of PUS and Shaman Power Corp.,Toronto), to construct a canal on the west bank of the Otonabee River between locks 22 and 23 for the purpose of generating electricity. The intake for the canal will be above lock 23 on private land, the outlet and most of the canal will be on Trent University land. Some Parks Canada land is involved. The canal will be excavated through a deciduous forest and mixed woodland and part will be in a Nature Area on the Trent Property.

1. The loss of 150 year old sugar maple and beech trees from the remnant sugar maple/American beech forest, and the loss of 100 year old Eastern white cedar tree and large black cherry trees as a result of canal construction.
   
2. Disturbance to the hydrological regime of the forest and woodland caused by canal construction leading to the loss of trees remaining on the narrow island to be created between the canal and river edge.
   
3. Loss of trees growing on the narrow, artificially created island may lead to river bank instability and erosion.
   
4. Canal construction will open up the more or less closed canopy of the forest and woodlot leading to increased light penetration to the forest and woodland floor. This will favour the establishment and growth of thickets of the invasive alien species European buckthorn that is so common in the surrounding area.
   
5. Opening up the forest and woodlot by canal construction may cause wind throw and wind damage to tall trees.
   
6. The canal will cut off access along a 1.5 k stretch of river bank for wildlife seeking water.

1. The possible loss of aesthetic views, especially in the fall, from the river road, picnicking areas and parking lots along the east bank, and for boaters on the river, of the relatively pristine forest and woodland adorning the west bank of the River. This idyllic view-scape could be spoiled if a chainlink fence is constructed, for safety reasons, to keep people out of the 5 m deep canal, and if the trees remaining on the artificially created island die from lack of water in the thin soils. Even if native trees are re-planted they may not thrive and survive because of water shortage.
   
2. The loss of the view of a natural river bank to unsightly rock-filled gabions installed to arrest erosion along the narrow artificial island created between the canal and river bank edge.
   
3. The loss of a chance to view 150 year old sugar maples and American beech growing together in a natural setting.
   
4. The loss of views through the forest and woodland trees at ground level due to invasion by the noxious alien species European buckthorn.
   
5. Thickets of European buckthorn will prevent access into the forest and woodlot by walkers.
   

1. The original proposal that was previously made for a similar hydroelectric project on the east side of the Otonabee River where most of the University development is occurring and where development is proposed in the Master Plan for the University Endowment Lands should be re-evaluated.
   
2. The west bank of the Otonabee River north beyond the main Campus should be left in its relatively pristine condition of hardwood forest and mixed woodland for future generations of the public and students to explore, marvel nature and enjoy.

Dr. Watson to Sherlock Holmes: “What on earth do you mean, Holmes, a Trent University Nature Area is going to disappear? Which one? How could that be? Why?”

“Well, Watson,” Holmes replies, “the Lock 22 Maple-Beech Woodlot Nature Area on the west bank of the Otonabee River, just north of the North parking lot, is likely to fall victim to a BOG.”

A surprised Watson exclaims: “But Holmes, the trees in this nature area are growing on limestone bedrock; there is no bog for them to disappear into.”

“No, not that kind of bog, my dear Watson, a man-made BOG; a Board of Governors is going to sink this Nature Area.”

“No, not that kind of bog, my dear Watson, a man-made BOG; a Board of Governors is going to sink this Nature Area.”

“But didn’t the BOG in 1990 resolve that this Nature Area, along with 15 others, were ‘special areas’ because they were environmentally significant?” queries Watson. “And, furthermore, Holmes, didn’t the BOG resolve that in University nature areas, building and incompatible use will be prohibited?”

“Yes, yes, my dear Watson, it did, but times change. Some Nature Areas on the Symons Campus are no longer considered environmentally significant and so are disposable.”

“Hmm, how can that happen, Holmes?” Watson muses.

Holmes replies: “Why, it’s easy, Watson; just press the delete button.”

Holmes goes on to explain: “A Toronto consulting company, ‘Office for Urbanism,’ has produced a Master Plan to suggest ways that the Symons Campus endowment lands might be used to generate revenue. Also the BOG in April, 2005 made it explicitly clear that building and incompatible use can occur in Nature Areas, if the Board so decides. Thus working with the BOG Property and Finance Committee, the consultants decided that the Lock 22 Maple-Beech Woodlot Nature Area and adjacent land should be classified as a ‘Green Buffers & Corridors (Special Area)’ in which development can occur.”

“Development such as what, Holmes?”

“Well, two of the nine potential uses listed by the consultants are for athletic fields and playgrounds.”

“Why, Holmes, can’t you just see kids swinging from large branches in the woods or sprinters burning up a 100m running track - that is, if the low branches and underbrush are cleared?”

“The real development involves clear-cuting a strip of land through the Nature Areas.”

“Actually, Watson, the real development involves clear-cutting a strip of land through the Nature Area and other woodland to dig a canal.”

“A canal for canoeing or kayaking, Holmes?” asks Watson, hopefully.

“No, no, Watson, the canal through this ‘predominantly green in nature’ area, as it is described by the consultants, is for a ‘green power hydroelectric facility.’ And, that, my dear Watson, is the beauty of designating this river-bank strip of land as a ‘Green Buffers and Corridors (Special Area).’ Maps in the Master Plan for the Endowment Lands (see the website: www.trentu.ca/endowmentlands) do not show a Nature Area in the ‘Green Corridors & Buffers (Special Area)’; it has, well, disappeared! Furthermore, Watson, then it can be claimed that the “green power facility construction” will not involve clear cutting trees in a University Nature Area but only will occur on so-called ‘vacant’ land.”

“Remarkable, my dear Holmes, truly remarkable,” exclaims Watson.

“No, no Watson, get with it, this is the 21st century, the term is spin, Doctor, spin.”

So what is all this about a disappearing nature area? In the mid-1990’s, a proposal was discussed for construction of a canal on the east bank of the Otonabee, between locks 22 and 23, to be used for hydroelectric power generation to provide revenue for the University. The University had been awarded the rights to hydropower generation from these two locks that are just north of the main campus. At the time, hydro costs for consumers were too low for the project to be deemed economical. Today, with electricity generation shortages in Ontario, the economics of hydroelectric power generation have changed and this project has resurfaced, but this time the proposal is to dig a canal through the hardwood forest and woodland on the west bank of the Otonabee River. However, in an article in the Peterborough Examiner on October 25th, 2005, about the hydroelectric project, Vice President O’Leary stressed that the land identified for the proposed canal and generating station was endowment property and was “vacant.” It was not mentioned that the project would involve clear-cutting a wide strip of mature trees in the Lock 22 Maple-Beech Woods NA and other land for a 15m-wide canal.

On the other hand, the still-waiting-for-action, “Stewardship Plan for Trent University Nature Areas” (www.trentu.ca/biology/tna), presented to President Patterson in October 2002, explains in detail that all of the land suggested for canal construction and hydroelectric station in the proposal is ecologically important because of the great diversity of habitats, vegetation communities and associated wildlife present and is part of the proposed Lock 22 Nature Area. The land is probably important as a north-south wildlife corridor. Certainly, deer tracks are evident in the snow throughout this area and many tracks lead down to accessible places on the Otonabee River’s edge where deer can gain access to water.

The vegetation on the land proposed for the hydroelectric facility consists mainly of large sugar maples, beech, and white cedars. At the north end of the University property there are more than 20 large black cherry trees, one of which, with a girth of 2.22 m (7 feet 5 inches) at a height of 1.3 m from the ground, is by far the largest black cherry tree I have seen in the Peterborough area. This tree is probably more than 100 years of age and, along with many of the other black cherry trees, will be felled if a canal is dug. Professor McGee, a forester who has been teaching “Management of Forest Ecosystems” (ERSC-320) at Trent for 15 years, considers this particular wooded area on the west bank of the river to be “the best example of a late succession tolerant hardwood stand on campus, even though it is only a forest fragment.” He says the large sugar maple trees are in the age range of 121 to 156 years, and the beech trees are probably older. I collected cores from seven large white cedars and the oldest tree sampled had at least 102 annual growth rings. Several other courses in the Biology and Geography departments use the forest and woodland for teaching purposes, and the Peterborough Field Naturalists have used the Lock 22 NA for field trips to identify, observe, and study plants and animals, particularly birds.

Thus, while it is understandable that Trent University needs to undertake projects that generate revenue, and that more non-polluting electricity generation is required in Ontario, there is more at stake than the economics of a hydroelectric power generation project. Such a project may well wreak significant, irreversible damage to the ecology, vegetation, environment and aesthetics of a magnificent stretch of river bank.

“Such a project may well wreak significant, irreversible damage to the ecology, vegetation, environment and aesthetics of a magnificent stretch of river bank.”

The original east bank idea for hydroelectric generation should be seriously reconsidered now that the economic climate for hydroelectric projects has improved. Here a seasonally dry wetland, consisting of open, shrubby communities with patches of cattails, sedges, grasses and low shrubs, mainly willows, would be involved. This wetland could be flooded to form an artificial lake by constructing a berm or dam at its southern end to provide a similar head of water as a canal would on the west bank of the Otonabee River. The possibility of culverts, rather than bridges, for water to pass under the River Road could be explored. An artificial lake also could have other beneficial uses for educational, research and recreational purposes, not only for university students but also for local schools and the public. The Rotary Greenway Trail makes an excellent platform for viewing migrating waterfowl and other bird species using this lake and its marshy edge. There well may be potential funding from organizations and foundations to assist with the costs of creating such a lake.

If the hydroelectric on the west bank proceeds, then scenic river drives along the river road, views from the parking lots and picnicking areas and other points between locks 22 and 23, and for people fishing and plying the Trent Severn waterway may well alter dramatically for the worse. There may be tall chain-link fences to keep people out of the 5-m deep flowing water; thickets of the invasive alien shrub European buckthorn growing beneath remaining trees; dead or dying trees on the narrow sliver of land between the canal and river’s edge; and in the river, wire encased rock-filled gabions placed there to prevent bank erosion. The current beautiful view of healthy, almost pristine forest and woods and the longest stretch of such vegetation on the west bank of the Otonabee River between Peterborough and Lakefield must be maintained.

If you are concerned about the potential impact of this hydroelectric project on the deciduous forest and mixed woodland growing on the west bank of the Otonabee River at the north end of the Trent University Campus and its potential impact on the Otonabee River and the river bank itself (see below for some potential adverse ecological, environmental and aesthetic impacts) and believe that this project is not in the public interest then please send a letter expressing your concern to the Director of Waterpower, Parks Canada Agency not later than February 8, 2006.

More information about the area to be impacted by the hydroelectric project can be found in the yet-to-be-acted-upon Stewardship Plan for the Trent University Nature Areas presented to President Patterson in October 2002. Visit www.trentu.ca/biology/tna and then pages 249 to 256 in the Stewardship Plan for more information about this area, page 113 for the zoning of this area, and page 191 for the vegetation communities on this land).

At www.trentu.ca/endowmentlands may be seen a draft master plan for the endowment lands on the Symons Campus and the deletion of the Lock 22 Maple-beech Woods Nature Area and part of the Horse-tail-Fern Meadow Wetland Nature Area to make way for a canal and generating station for this hydroelectric project.

To the Director of Waterpower Parks Canada Agency, Peterborough, Ontario Regarding the Dominion Water Power Act Application and Notice of Commencement of an Environmental Screening Hydroelectric Project at Locks 22 and 23 Trent Severn Waterway.

While I understand that Trent University needs to undertake projects to generate revenue and that more non-polluting electricity generation is required in Ontario I am of the opinion that the public interest will not be served by the construction of a hydroelectric project on the west bank of the Otonabee River on public lands administered by Parks Canada and Trent University.

In my opinion there is much more at stake than economics as a result of constructing this hydroelectric power generation project. I am extremely concerned that this project may wreak significant, irreversible, damage to the vegetation, ecology, wildlife and aesthetics of this section of riverbank that is home to a magnificent 1.5 km stretch of relatively pristine hardwood forest and mixed woodland. This is, in fact, the most extensive stand of deciduous forest and mixed woodland on the west bank of the Otonabee River between Peterborough and Lakefield and it should remain in its relatively pristine condition for ecological, environmental and aesthetic reasons.

I am also concerned about possible erosion of the river bank on the west side of the Otonabee River as a result of the project and the possibility that unsightly gabions may be placed in the Otonabee River to arrest erosion.

My concerns briefly are:

1. Ecological and environmental

a. The loss of 150 year old sugar maple and beech trees from the remnant sugar maple/American beech forest, and the loss of 100 year old Eastern white cedar trees and large black cherry trees from the strip of woodland to be clear cut for canal construction.

b. Disturbance to the hydrological regime of the forest and woodland caused by canal construction leading to loss by dessication of trees remaining on the very narrow island that will be created between the canal and river edge.

c. Loss of trees growing on the narrow, artificially created island may well lead to river bank instability and erosion

d. Canal construction will open up the more or less closed canopy of the forest and woodlot resulting in increased light penetration to the forest and woodland floor which in turn will be favourable for the establishment and growth of thickets of the invasive alien species European buckthorn, which is common in the surrounding area.

e. Opening up the forest and woodlot may well increase wind throw and damage to tall trees.

f. Accessibility to the river's edge for drinking water will be denied to wildlife along a 1.5 k stretch of the river by the canal.

2. Aesthetics

a. The likely loss views from the east bank of the Otonabee River of the of the relatively pristine forest and woodland adorning the west bank, especially in the fall. Pleasant views may well be lost from the river road, from picnicking areas and parking lots, and for boaters on the Otonabee River. This idyllic view-scape could be spoiled by chainlink fences, if they are constructed for safety reasons along both sides of the canal and if they become exposed by the death of trees on the artificially created island. Even if native trees are re-planted they may not thrive and survive due to water shortage in the thin soil cover along most of this island.

b. The loss of the current view of a natural river bank to ugly, rock-filled gabions if erosion of the river bank increases.

c. The loss of the opportunity to view accessible 150 year old sugar maples and American beech growing in a natural setting. These trees may be deliberately felled or be detrimentally affected by the opening up of the hardwood forest for canal construction.

d. The potential loss of views between trees in the hardwood forest and in the mixed woodland close to ground level due to the growth of thickets of the invasive alien species, European buckthorn.

e. The reduced accessibility to the hardwood forest and mixed woodland by thickets of European buckthorn.

I earnestly encourage a re-examination of the alternative proposal of a few years for a hydroelectric project on the east side of the Otonabee River. This is where most of the University buildings are located, where development is currently occurring and where extensive development is proposed according to the University Endowment Lands Master Plan. The west bank of the Otonabee River upriver of the North parking lot of the main Campus should be left in its relatively pristine condition to be explored, be studied, be marveled, and be enjoyed by future generations of the public and students.

Yours sincerely,