April 18, 2002
POTENTIAL ISSUES ASSOCIATED WITH PEAKING AND PONDING ON THE ST. MARY'S RIVER,
MICHIGAN AND ONTARIO
In response to a request from the International Join Commission (IJC), ERM has
prepared the following report on potential ecological issues and concerns related
to peaking and ponding operations at the hydroelectric facilities on the St. Mary’s
River (the River) operated by Edison Sault Electric Company (ESE) on the U.S.
side and Great Lakes Power Limited (GLP) on the Canadian side. The International
Lake Superior Board of Control (ILSBC) and Acres International Limited (working
for ESE and GLP) submitted reports on peaking and ponding operations to the IJC
in February 2002. These reports outlined the regulatory framework for peaking
and ponding operations and the influence these operations have on flows and navigation
in the River. These reports concluded that while peaking and ponding influence
River levels and flows in the immediate vicinity of the generating facilities,
these effects do not significantly affect the hydraulics of the St. Mary’s Rapids
(the Rapids) and the effects of peaking and ponding on flows and water level quickly
diminish downstream of the generating facilities. Furthermore, the ILSBC report
concluded that impacts of peaking and ponding are negligible below Rock Cut. While
these documents contained thorough discussions of the effect of peaking and ponding
on flows below the hydroelectric projects, they provided very little information
on the potential impacts of peaking and ponding on natural resources in the River
or on the ecology of the area.
In discharging its responsibilities for the St. Mary’s River, the IJC wishes
to identify all potential impacts that peaking and ponding may have on the River.
To date, though solicited, the IJC has been unable to obtain much input from the
resource agencies and other parties with management responsibilities for or an
interest in the River.
This report provides additional detail on the potential impacts that peaking
and ponding on the St. Mary’s River may have on the ecology of the River, and
on concerns that regulatory agency personnel and other interested parties have
voiced regarding potentially sensitive species and resources that may be affected
by these practices. During the preparation of this document ERM considered comments
and information that the IJC and ERM received from agency personnel. The content
of this report is not limited, however, to only those concerns voiced by the agencies.
ERM also relied on its own prior experience with hydropower projects to evaluate
the significance of those concerns and make suggestions on how those concerns
should be addressed. This report does not address the effect of peaking and ponding
on navigation, as that topic has been addressed in the above-mentioned reports
prepared by Acres and the ILSBC.
In addition to various reports supplied by the IJC and Acres in response to the
IJC’s request for comments on peaking and ponding in the St. Mary’s River and
the effect of these operations on sensitive resources, the Chippewa Ottawa Resource
Authority (CORA), Michigan Department of Natural Resources (MDNR), Ontario Ministry
of Natural Resources (OMNR), Michigan Department of Environmental Quality (MDEQ),
Sea Lamprey Control Centre (SLCC), and City of Sault Ste. Marie, Michigan submitted
comments on issues and concerns they had regarding peaking and ponding in the
River and its effect on natural resources in the region. ERM contacted personnel
from MDEQ, CORA, MDNR, Great Lakes Fisheries Commission (GLFC), United States
Army Corps of Engineers (USACE), and the SLCC directly to solicit further comments.
ERM staff also reviewed the Atlas of the Spawning and Nursery Areas of Great Lakes
Fishes (Atlas) compiled by the U.S. Fish and Wildlife Service (USFWS) in 1982
and accessed the Michigan Natural Features Inventory online to obtain State and
Federal listed species known to occur in Chippewa County, MI. The most current
inventory of listed species available for Chippewa County is from 1999. Therefore,
the current state and federal status of species in Chippewa County that could
potentially be affected by peaking and ponding should be confirmed.
Issue Summary by Resource Area
Spawning Habitat - Although the 1982 Atlas of the Spawning and
Nursery Areas of Great Lakes Fishes is a relatively old information source, personnel
from the MDNR noted that it remains the most complete collection of information
of its kind for the region (personal communication with Dave Fielder, 4/1/02).
According to the Atlas, at least 35 species of fish spawn in the St. Mary’s River
and of those species northern pike, lake whitefish, rainbow trout, white sucker,
lake sturgeon, slimy sculpin, walleye, lake herring and sea lamprey spawn in the
Rapids and in areas downstream of the generating facilities (Goodyear et al.,
1982). The MDNR, CORA, MDEQ, and the SLCC all indicated in their comments to the
IJC that they were concerned that peaking and ponding could have detrimental effects
on spawning habitat. The agencies expressed concern that the variations in flow
induced by peaking and ponding could increase sediment transport and deposition
downstream, thereby reducing the amount of microhabitat available to spawning
fish in downstream habitat areas, including the Rapids. Resource agencies also
voiced concerns that varied flows also have the potential to redistribute eggs
downstream, possibly exposing them to increased predation, redepositing them in
areas where they would likely be smothered by deposited sediment, and/or redepositing
them in areas that are not suitable for incubation. Studies by MDNR staff have
documented drift of lake herring eggs in multiple areas in the River (Fielder,
1998); it is unclear what effect flows may have on the relocation of eggs of other
species. As a general rule in the St. Mary’s River the most intense spawning activity
by desirable fish species takes place in the spring and fall. Occasionally, smallmouth
bass will spawn through June, but during July and August the only species of concern
to spawn in the St. Mary’s River is the sea lamprey, an undesirable invasive ectoparasitic
species. To the extent that flows could be managed to facilitate spawning during
the spring and fall and impede lamprey spawning during the mid-summer, regulation
of flows could aid efforts by fisheries personnel to manage spawning fish stocks
in the St. Mary’s River (personal communication with Chuck Krueger, 4/3/02).
MDNR commented to ERM that the flow variation could have an impact on habitat
and fish by 1) increasing sediment transport and 2) interfering with access under
low flows by dewatering habitat. MDNR staff assumes this potential effect to be
minor because of the short duration of low flows in the river (personal communication
with Dave Fielder, 4/1/02). However, dewatering of nursery areas during low flows
could have a significant effect on juvenile fish that are forced to move into
the main channel and are therefore exposed to increased predation during ponding
Potential effects on spawning habitat would not be limited by season due to
the temporal distribution of spawning activity by different species in the River.
Previous studies have concluded that the effects of peaking and ponding do not
affect water levels in the Rapids, therefore we do not consider peaking and ponding
to have a significant impact on spawning habitat in the Rapids. We agree that
there is some potential for adverse effects due to dewatering from the foot of
the Rapids downstream to the vicinity of Rock Cut. We expect that the potential
effects of sediment transport would be negligible for two reasons: 1) lack of
a sediment source in the Rapids and/or passing the dam and lock works and 2) small
variation in flows over 24-hour and 7-day periods compared with natural variation.
Sediment transport tends to be proportional to flow for non-extreme conditions,
therefore the fluctuations in flow seen in the St. Mary’s River due to peaking
and ponding are not expected to significantly increase or decrease sediment transport.
MDNR also assumes that potential velocity-related effects on most fish populations
migrating to or from spawning beds would be minor because most of the species
that use the Rapids are large species capable of swimming in strong flows (personal
communication with Dave Fielder, 4/1/02). Depending on timing and fluctuation
magnitude, however, peaking flows may affect smaller baitfish species’ ability
to complete their spawning migrations and could potentially have a cumulative
effect on predatory fish stocks that rely on smaller species for forage. Because
of the typically high fecundity of this group of fishes, and the multiple habitat
types that they can occupy, we suspect that baitfish would adapt over time and
render insignificant any overall effects on populations related to peaking and
MDNR staff recommended that if the IJC proceeds with its plan to monitor flows
in the Rapids area during the coming year, that a monitoring station should be
placed in the Rapids and data from that station should be compared with data from
a study of benthic drift. Based on our previous experience, ERM is concerned about
the practicality of flow monitoring within the Rapids. Flow monitoring depends
on developing stage and discharge relationships, which would vary widely across
the Rapids due to the morphology of the Rapids. Furthermore, we question the usefulness
of such a study in the Rapids given that previous studies have concluded that
the effects of peaking and ponding do not affect water levels in the Rapids. We
do, however, agree that some type of flow/drift analysis could yield valuable
information on how changing flow patterns influence the redistribution of eggs
and/or juvenile fish in areas downstream of the Rapids that have been mapped as
important spawning areas if flow monitoring in those areas proved to be practical.
MDNR staff further noted that flow models exist that can be adapted to predict
the effect of different flows on fish eggs and that it would be appropriate to
apply such a model to the St. Mary’s River to determine the effect peaking and
ponding may have on spawning fish in the River (personal communication with Dave
Fielder, 4/1/02). A likely tool of utility is a simple 2-D hydrodynamic model
of the River with I-P data (ichthyoplankton data ) driven as passive particles
to assess day-age class distributions over space and time as affected by the pulsing
flows from peaking and ponding.
ERM has found that in most cases where peaking and ponding contribute to significant
impacts to riverine habitat, river levels typically vary much more widely than
they do on the St. Mary’s River. While ERM considers the potential impacts of
peaking and ponding on spawning habitat to be insignificant compared with naturally-occurring
variation on the River, the potential for flow-related impacts still exist. Typically,
this type of question is addressed using a habitat model, such as the PHABSIM
component of the Instream Flow Incremental Methodology (IFIM) approach. This type
of analysis predicts large-scale changes in available habitat from relatively
small-scale fluctuations in flow. ERM used an IFIM (including the PHABSIM) analysis
to describe this type of relationship and determine appropriate bypass flows and
release patterns at the Oswego Falls Hydro Electric Project and used similar methodologies
on the Black River and Hoosic River, all of which are in New York. This approach
is highly sensitive to site-specific hydrological and biological parameters and
channel morphology, and is particularly useful for areas of high biodiversity
like the St. Mary’s River because it can predict impacts to individual species
and trophic guilds depending on how it is applied. We expect that some resource
agencies will press the IJC for this type of analysis and wish to impress on IJC
that data requirements to respond to such a request are not insignificant.
Wetlands - The extent to which peaking and ponding affects
wetlands downstream of the hydroelectric projects is not clear; wetlands were
not mentioned in agency comments to the IJC. However, personnel from the MDNR
commented that high quality wetlands and aquatic macrophyte beds exist downstream
in Lake Nicolet and around the shoreline of Sugar Island (personal communication
with Dave Fielder, 4/1/02). The MDNR indicated that there are “considerable wetlands
on the north west corner of Sugar Island” and that “this area is in the direct
path and close proximity to the Soo Locks area”(email from Dave Fielder, 4/17/2002).
Although the potential effects of peaking and ponding on these habitat areas are
probably small due to the minor influence that peaking and ponding have on downstream
water levels, MDNR staff noted that some of these wetland areas are important
spawning and nursery habitats (personal communication with Dave Fielder, 4/1/02).
Peaking and ponding could potentially affect the wetted perimeter in wetlands
and aquatic macrophyte communities. Low water levels in the river during ponding
operations could desiccate wetland and/or macrophyte habitat on the upland or
shoreward margins of these communities. Based on our analysis, the effect of peaking
and ponding on water levels in this area would likely be overwhelmed by the effects
of low water levels that occurred in this area recently as a result of the overall
low water years in the Great Lakes region. Again, the magnitude and type of impact
could be quantified using an IFIM or other approach, if needed.
ERM attempted to better define the location of these wetlands by querying
the National Wetlands Inventory (NWI) through the U.S. Fish and Wildlife Service
website. No data is available in the NWI for wetlands in Chippewa County, however
the USGS 7.5 minute quadrangles for that area indicate that there are no wetlands
between Sault Ste. Marie and Rock Cut. According to the USGS topographic maps,
the closest wetlands to the hydroelectric facilities are on the southern tip of
Neebish Island, downstream of the point where peaking and ponding have an appreciable
affect on water levels. We also discovered that MDNR maintains a collection of
GIS data that shows wetlands in the River. ERM further understands that the MDNR
maintains databases with bottom contours and other geographical and hydrographical
information for the St. Mary’s River watershed. If the IJC wishes to pursue a
more detailed analysis of the potential effects of peaking and ponding on wetlands,
ERM recommends that IJC request MDNR to undertake a detailed inventory of their
GIS data to identify high-quality wetlands with hydrologic connections to the
River between the hydroelectric tailraces and Rock Cut and submit detailed, field-truthed
maps of wetlands of concern to the IJC.
Threatened and Endangered Species - Resource agency personnel
did not identify any threatened or endangered species potentially affected by
peaking and ponding on the St. Mary’s River. Lake sturgeon, however , which has
been known to use the Rapids and areas downstream as spawning habitat is listed
as threatened in Michigan. The lake herring, or cisco, is also listed as threatened
in the state, although this species mainly uses areas downstream of the area affected
by peaking and ponding. To the extent that peaking and ponding could affect wetland
and aquatic macrophyte communities, these operations also have the potential to
affect listed species that use these habitats such as the American bittern, a
species with state special concern status in Michigan, and the piping plover,
which is endangered in Michigan and listed as Endangered-Threatened federally.
Both species were known to occur in Chippewa County (where the St. Mary’s River
is located) in 1999 (Michigan Natural Features Inventory, Michigan County Element
List, accessed 3/26/02). Based on the predicted relatively minor hydraulic effect
in the downstream areas, though, ERM projects that any habitat effects would be
minor, if even measurable. These species are habitat opportunists as adults, and
altered operations would not affect their range in the area.
Sediment transport - Although the MDNR and MDEQ have both
expressed concern over loss of fish spawning habitat via increased sediment deposition
as a result of peaking and ponding, (personal communication with Dave Fielder,
4/1/02, and e-mail from the DEQ to the IJC dated 3/18/02, respectively) no resource
agency identified specific accretion areas in the St. Mary’s River downstream
of the ESE and GPL facilities. Therefore it is not possible to determine whether
erosion and/or accretion is currently having a detrimental effect on ecosystems
in the St. Mary’s River or if natural sediment transport mechanisms operating
in the River are being altered significantly by regulation of the River’s flow.
As discussed earlier, while the potential effect on sediment transport is not
zero, we expect that is would be insignificant, given the flow regime, geology,
and morphology of the affected reach.
It should be noted that only slight changes in grain size or seasonal sediment
deposition patterns can have significant effects on the suitability of potential
spawning habitat for a wide range of fish species. ERM understands that the Detroit
office of the U.S. Army Corps of Engineers maintains flow data and geometric data
for the St. Mary’s River. These data, in addition to the GIS data maintained by
MDNR, could be used to model sediment transport, egg transport, and dewatering
in the River under a variety of hypothetical or real flow conditions, thereby
providing resource agency staff and the IJC an estimate of how peaking and ponding
could be affecting the River currently and how potential changes in flow management
on the River could affect natural resources there in the future.
Dams do not typically contribute increased sediment loads to areas downstream
of the dam, although they do alter sediment transport patterns to varying degrees.
Typically, sediment accumulates upstream of the dam, starving the downstream side.
Northwestern Lake, impounded by the Condit Hydroelectric Project on the White
Salmon River in Washington is an example of this phenomenon. We have found that
typically where a hydroelectric dam is constructed at a natural or pre-existing
grade control (such as the St. Mary’s Rapids) the effect of that project on natural
sediment transport is less than for dams that create new grade controls in the
river. Effects on upstream sedimentation aside, we believe that the effect of
peaking and ponding on sediment transport in the St. Mary’s River is probably
not significant or has reached an equilibrium state.
Sea Lamprey Control - In their comments to the IJC, the
SLCC indicated that changes in water levels in the St. Mary’s River as a result
of peaking and ponding can have a negative effect on their efforts to trap adult
lamprey. Fluctuating water levels can dewater the traps, and require frequent
readjustment of the traps to ensure that the traps remain in the water. The SLCC
asserts that readjustment of the traps is time-consuming and costly, and that
more stable flows in the St. Mary’s River would benefit them by reducing the effort
and expenditure required to capture lampreys for their adult male sterilization
program (e-mail to the IJC dated 1/14/02).
Although the SLCC indicated in their comments to the IJC that the water level
fluctuations’ impact on the adult trapping program is the most significant effect
of peaking and ponding on their operations, they also communicated to the IJC
and to ERM that changes in flow velocity in the St. Mary’s River as a result of
peaking and ponding affects lampricide treatment efficiency in the River. The
Control Center currently uses granular Bayluscide, a product that consists of
inert granular material coated with an active ingredient that is toxic to lampreys.
The product is broadcast over target areas and the active ingredient dissolves
into the water as the product sinks. Low flows allow gentle dispersion of the
product without transporting it outside the target area or over-diluting the application.
Generally, treatments made during low flows are more effective than those made
during high flows (personal communication with Larry Schleen, 3/29/02).
Enhancing lampricide treatment efficiency on the River can have a significant
effect on the cost-effectiveness of lamprey control programs in the Great Lakes
region - a single treatment of the entire St. Mary’s River costs between $20-25
million and is repeated every 5 years (personal communication with Larry Schleen,
3/29/02). The St. Mary’s River is the single largest recruitment area for sea
lamprey in the entire Great Lakes basin, so lamprey control measures on the St.
Mary’s River can have a profound effect on sea lamprey populations throughout
St. Mary’s River Remedial Action Plan (RAP) - In their comments
to the IJC the CORA cited the St. Mary’s status as an Area of Concern (AOC, a
designation given by the IJC) and their involvement with the RAP process for the
St. Mary’s River AOC. In a personal communication with ERM, a representative for
the CORA re-affirmed the agency’s concerns as expressed in their comments to the
IJC, including the St. Mary’s River RAP (personal communication with Mark Ebener,
4/9/02). The current RAP, drafted in October 1998, cites ten impaired uses for
the St. Mary’s River AOC caused by “major point source discharges” and states
“Loss of wetlands and rapids habitat due to urban/industrial development, and
operation of navigational structures are also a concern” (St. Mary’s River RAP,
The background section of the RAP asserts that point source effluent from
wastewater treatment plants contribute significantly to impairment of the St.
Mary’s River, and the IJC has expressed concern that peaking and ponding may influence
the assimilative capacity of the St. Mary’s River. Assimilative capacity is a
regulatory threshold defined (roughly, and varies by state) as a 7-day average
low flow with a 10-year recurrence interval. Use of a defined low flow to define
assimilative capacity has a basis in science, but is simply a regulatory threshold
and is not necessarily indicative of a biologically significant threshold, but
approaches a physically or chemically significant threshold for what regulators
feel is an extended low flow event with significant recurrence probability. This
could be an issue in the St. Mary's River as regulators attempt to balance flows
between the lakes for other purposes, thereby affecting the "normal" flow statistics
of the River used by regulators for assessing waste load allocations. Permits
are written using this flow; flows managed to levels that would increase the likelihood
of seeing flows indicative of 7Q10 (or similar) conditions would be an issue for
water quality compliance — and therefore have some biological significance locally
as well for high-water quality dependent species. In the case of a regulatory
threshold, there is a presumption of protection, as long as the permit holder
is in compliance with the permit.
The applicability of assimilative capacity to natural resource impacts notwithstanding,
peaking and ponding probably does not have a significant impact on assimilative
capacity since peaking and ponding over the range and time frames cannot have
a significant effect on the definition of the low flow. Because assimilative capacity
is a function of the volume of water available to dilute or oxidize effluent under
a specific event, only a major change in the duration of ponding to a longer period
(rather than the 7-day period now used), or introduction of a consumptive use
could result in a peaking or ponding-related impact on assimilative capacity.
The potential for an effect is difficult to predict though, given that flows are
abnormally low for the Great Lakes region generally, and the likelihood of a 7Q10-like
event is greater now than ever.
Two habitat restoration and rehabilitation projects are currently included
as part of the RAP: the Bar River Habitat Project and the Little Rapids Restoration
Project. Assuming that these projects are fully implemented, ERM expects peaking
and ponding to have similar impacts to those discussed above on the restored habitat
areas as it does on habitat elsewhere in the River.
Summary and Recommendations
Based on correspondence between the IJC, ERM, and various resource agencies concerning
potential ecological issues and concerns related to peaking and ponding operations
on the St. Mary’s River, the most significant concern is the potential for variation
in flows to affect the spawning success of a variety of fish species in the River
in the Sault Ste. Marie area, immediately downstream of the generating facilities.
Although various resource agency personnel identified the potential effects of
peaking and ponding on habitat in the Rapids as cause for concern, the effects
of peaking and ponding have been shown to be limited to the areas downstream of
the Rapids. ERM therefore does not consider peaking and ponding as it is currently
practiced to have an effect on habitat within the Rapids. Potential impacts on
spawning success downstream of the Rapids include loss of habitat through increased
sediment accretion on spawning beds, dislocation of spawned eggs, and temporarily
reduced access to spawning areas, although the effect of flow variation on access
to spawning areas is thought to be minor and limited to forage species. Based
on available information and interviews we believe that there is adequate data
to evaluate habitat related-effects in a simulation model using a tool like the
PHABSIM component of the IFIM methodology. We note the MDNR’s recommendation that
flow data from a monitoring station in the Rapids be used in conjunction with
flow data to develop an estimate of the effect of flow variation on egg displacement.
We recommend that potential studies of the potential effect of peaking and ponding
on egg drift be limited to the spawning areas identified by the MDNR between the
foot of the Rapids and Rock Cut be considered for study at this time.
Peaking and ponding could potentially affect wetlands downstream of the hydroelectric
facilities, but there is currently no data to evaluate this effect. The MDNR maintains
a GIS database that shows wetlands in this area and we recommend that the IJC
use this information to guide any future studies on the effects of peaking and
ponding on wetlands. To the extent that regulation of flows affects habitats used
by threatened and endangered species, peaking and ponding could impact these species,
although specific areas where these effects may be occurring have not been documented.
ERM projects that effects on wetlands and listed species would likely be minor
due to the relatively minor water level fluctuations caused by peaking and ponding
in downstream areas. It is also not clear what effect, if any, peaking and ponding
has on sediment transport in the River as a whole, however some resource agency
personnel feel that more research should be conducted on this matter. We believe
that while there may be some effect it is probably negligible. We believe there
are adequate data to at least perform a first-order assessment of this effect.
Peaking and ponding clearly has an impact on the adult sea lamprey trapping
program administered by the Sea Lamprey Control Center, and can affect the efficiency
of lampricide applications in the River. In general, efforts to control sea lamprey
in the St. Mary’s River and in the Great Lakes may benefit from a more stable
flow regime and relatively low flows during lampricide applications. How significant
these costs and benefits are compared with other alternatives requires additional
investigation and coordination with the SLCC. Based on its review of existing
reports, correspondence with resource agency personnel, and our own experience
ERM does not believe that there are natural resource issues of sufficiently grave
concern to suggest adjustment to peaking and ponding practices planned through
March 20, 2003. It may become necessary, however, to address resource agency concerns
through some focused analysis methods.
We recommend that the IJC consult with the SLCC to determine the cost/benefits
of coordinating low flow events with scheduled lampricide applications. We also
recommend that the IJC request that the MDNR and OMNR collaborate to develop a
detailed statement of their concerns regarding effects on spawning, nursery, macrophyte,
and wetland habitats in the area between the downstream boundary of the rapids
and Rock Cut. The IJC should further request that the MDNR and the USACE provide
any available GIS data on wetland locations and river morphology to help guide
any proposed studies. We expect that the spawning, nursery, macrophyte and wetland
areas will overlap significantly, and that identified areas of concern will be
small. If the MDNR and OMNR provide a detailed description/inventory of wetlands
and spawning/nursery habitats between the Rapids and Rock Cut that could be affected
by peaking and ponding, it may be appropriate for the IJC to consider using an
IFIM, PHABSIM or similar analysis depending on the available data and information
needs to evaluate the effects of peaking and ponding on wetted perimeter (available
habitat) and or water levels.
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