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19 septembre 2007 : M. Steven Wallach, Clayton, New York

I am a seasonal (seasonal now defined as May through late August due to the IJC's failure to properly maintain adequate water levels through the fall) resident of Grenell Island in the US Thousand Islands. I am a member of the IWLC and Save the River and am a kayaker and boater.

As a former government attorney, I have urged patience on the part of my friends and neighbors in the Thousand Islands as the IJC pursued its five year study and subsequent eighteen month delay since the study was published in March 2006. I explained to them the lengthy process the IJC needed to comply with. That five-step process is clearly outlined on the IJC website at http://www.ijc.org/en/activities/losl/process.php.

This summer, I urged my neighbors to await the September 17 release of the draft plan while water levels continued to drop and seasonal residents left the Thousand Islands. I was dismayed to see the press release on September 10 on the IJC website which in full was as follows: "IJC extends consultation period with governments on New Regulation Plan for Lake Ontario and St. Lawrence River water levels and flows." No mention of a new date for release of a draft decision. This action completely contradicts the IJC's own schedule and "process." Step 1 (comment period) was supposed to end on September 15, 2006 but had been extended until this month. Step 2 (developme nt of a draft decision) is what the IJC has supposedly been doing since the study's release eighteen months ago and a draft decision was scheduled for September 17. Stage 3 (public hearings and comments on the draft decision) were scheduled for October and November. Step 4 (consultation with governments) was not to take place until after a draft decision had been release, public hearings held and comments obtained. Step 5 is supposed to be a release of the final decision.

Instead of following its own protocol, schedule and "process" the IJC leaps from Step 1 to Step 4 and appears to intend to be going back to Step 2 after that (despite Step's 2 and 3 already being scheduled for this fall). More disturbing are IJC Public Information Officer Frank Bevacqua's comments in a September 16 interview published in the Watertown Times:

1. "In my view, the commission will not be able to issue a decision by the end of the year."
2. The IJC needs more time to discuss the outflow options with state and provincial governments.
3. The IJC needs more time because it has concerns about providing compensation if a new plan were to cause any damage on the lake or river

It appears to those seasonal residents who enjoy the St. Lawrence River that the IJC is simply buying itself another year of regulation "by hand" using outdated data and without the use of modern technology or science. The IJC apparently is unmoved by the fact that its use of the outdated 1958 plan has shortened the 2007 vacation season in the Thousand Islands by approximately two months and will cause irreparable harm to the economy of the region. Based on its current schedule, it appears water levels for the 2008 season will be similarly mismanaged by failing to make use of the results of a five year, $20,000,000 study released eighteen months ago.

There has been absolutely no reason given as to why the IJC cannot release a draft decision and allow the process to continue under the IJC's own schedule. Interestingly, other than the press release, the IJC website continues to publicize the process it is now ignoring as though a draft decision is imminent.

I intend to urge my fellow residents of the Thousand Islands to contact their state and federal government representatives to intervene and take control of the process which the IJC is apparently unable or unwilling to move forward for the benefit and protection of the Lake Ontario-St. Lawrence River region and its residents.

Steven Wallach
Grenell Island
Clayton, NY

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