Comments received >

September 14, 2006 - Mr. Ken W. White, Ithaca, New York and Hambly Island, Ontario

Dear Secretary:

I totally support Plan A+ as replacement for the current regulation plan, Plan 1958-D, for management of the water level and environment in the Lake Ontario - Thousand Islands Region, part of the world's largest fresh water resource.

I write as a "local" to this region: a 50 year resident, an island owner (Hambly Island in Canada), a boater, and informed observer of water level issues and behavior, the water-connected economic system, as well as the environmental system we share. My background is control systems engineering, and I am a member of The Thousand Islands Association (TIA) and former member of Save the River (STR). And a tax payer.

Plan A+ offers distinct advantages over the "seemingly attractive" Plan B+, with D+ not even to be considered. Dr. Raymond S. Pfeiffer stated in a very thoughtful and perceptive letter to the IJC his support of Plan A+ as it is the "most balanced, environmentally advantageous and foresighted" of the three potential choices. I would add "most stable and most technologically advanced" to his list.

It is with deep concern that I encourage the IJC board to take a systems approach when making a final decision, looking beyond the simple distinctions of the plan and beneath the surface, where the true distinctions can be found, and the real long-term implications may be seen.

I am concerned that so many supposedly experienced boaters and shoreline residents have been "seduced" into supporting Plan B+ through oversimplification by organizations with a very narrow charter and agenda, a plan they would soon come to regret. I trust the IJC board will not be similarly seduced, as they approach final evaluation on a systems basis, looking beneath surfacy descriptions and the trap of averages.

Here are a few of the major reasons I encourage you to choose Plan A+.

• Plan A+ is Most Stable & Balanced – Most Controlled Water Level Range

  This precious and unique body of water offers an opportunity unachievable in many lake and river supply and ecosystems. It is possible to control with a stability others in North America and the world only dream about. (see also Section 4 on Technology)

  Elsewhere, many people and ecosystems somehow "just survive" as they cope with the wild swings of their water based environment from disturbances ranging from drought to ravaging floods. We can best respond to inevitable disturbances with Plan A+, a hands-on approach versus Plan B+, a hands-off one allowing chaos with no provable benefit.

  The Stabilization Advantage of Plan A+ is HUGE

  To see the truth, IJC's Lake Ontario Water Levels graph (showing all the plans at the 99% confidence level) has been labeled for clarity and included below. (Plan A+ & Plan B+ Normal and Worst Case Ranges are shown as labeled vertical colored bars).

  The truth is NOT in the Averages!! They're bunched together with no significant statistical difference between Plan A+ and B+!

  Real understanding lies only in the statistical variability of the distribution, easily seen looking at the 99% confidence level Ranges.

  

  Plan A+ promotes stability with the Normal Range for spring peaks:
  Plan A+ is only ~2 ½ ft versus Plan B+ a much larger ~4 ½ ft
  The Worst Case Range (Highest Spring Peak vs. Lowest Winter Dip):
  Plan A+ is only 4 ¼ ft vs Plan B+'s huge 5 ½ ft. This is Unacceptable!!

• Plan A+ is Most Environmentally Stable

  Plan A+ is more gentle on the environment, minimizing the stress of wild swings in water level, while still occasionally flushing and filling wetlands. In many ways, winter storm disturbances are likely to do the most structural environmental damage by rapid raising and lowering of ice filled water levels, uprooting whatever is in its icy grasp. These storms are uncontrollable, but best handled by a stable, well managed and firmly entrenched shoreline ecosystem. Plan B+'s huge water level swings only exacerbate the problem.

  Recent years of reasonable water level stability have encouraged a major increase in formation (or reformation) of large wetland areas, complete with cattails and resident birds, lily pads and the like in the Canadian Navy Group at and near Hambly, our family island. The animal population has grown as well to include muskrat, otter, and mink, plus huge increases in waterfowl. Loons are now plentiful, and thanks to the elimination of DDT (a chemical not water level solution), Blue Herons are ubiquitous. We're kidding ourselves to think we can somehow improve on the blessing of water level stability!

• Plan A+ is Most Economically Stable

  Like ecosystems are forced to respond to wild swings in water level, so too are the human economic systems, from residents to municipalities plus federal, state and provincial organizations. The costs of major, near uncontrolled water level swings, both human and economic, are practically incalculable. Swings that may benefit one species may be disastrous to another.

  Consider how many people make their livelihoods living in harmony with Our River, and count on reasonable water level for access and use of existing infrastructure, both public and private. Others are property owners who provide a substantial cash infusion into the region. Much depends on water level stability. The tourism industry is a very significant and prime example and huge economic stimulus.

• Plan A+ is Most Technologically Advanced

  While we are not in charge of either the weather or incoming water supply to the Lake Ontario - St. Lawrence River region, we certainly have the ability to plan, respond, and to some degree react to a wide variety of climatological and meteorological variables.

  Today's computers, using sophisticated modeling and simulation programs, combined with real-time water level measurements (from level gauges to satellite level triangulation) and weather observation, offer a degree of level (flow) control previously unattainable. Plan A+ benefits from this technology using tighter predictive and feedback control to minimize range fluctuations far better than Plan B+, improving level control and water storage over weekly to seasonal timeframes.

  It is of utmost importance that the IJC's final recommendation include funding requests for implementation and integration of the latest modern control technology to accomplish its mission.

• Plan A+ has Most Foresight - Preserves Precious Natural Resource - Fresh Water

  Inherent in Plan A+ is the wisdom of conserving water. The Middle East has its oil, we've been blessed with abundant fresh water. During low water supply times, be they normal winter dips or disruptive temporary weather pattern shifts, Plan A+ responds best to preserve this natural resource and maintain relative stability.

  A recent news report increases the water supply side uncertainty, with forecasts of significantly lower levels, in Lake Erie I believe, to occur in the next several years. No one knows what future supply challenges we will face, but we will have our best chance to stay within the control limits of the IJC's stochastically modeled 99% confidence water level curves with proactive Plan A+ adopted, funded and in place.

I would be grateful if you would share my letter with all the IJC decision makers as they seek to chose a Plan that is best to maintain and enhance the pristine beauty of this valuable resource and health of the environment (ecological and economic), overall.

Last update: