Jack King's Comment On The Draft Assessment

I am approaching this feedback for your consideration around questions that I have had during this latest stage of environmental assessment.

What is the need for the Lake Manitoba – Lake St. Martin channel project?  This perhaps the easiest question to address. I can tell you about the hardship that Lake Manitoba residents, farmers, ranchers and fishers endured during floods of 2011 and 2014. I will leave it to the political leaders who responded tothat question as they did in a news release following the press conference where both levels committed funding of $540 million.

Brian Pallister said, “After 60 years of inaction, we are proud to stand today alongside our partners in the federal government to announce this vital project,” said Pallister. “We are focused on completing this project in a timely fashion to better protect Manitobans who have sacrificed so much.”

Jim Carr added, “This funding shows that the Government of Canada is taking concrete steps to protect the vulnerable communities around Lake Manitoba and Lake St. Martin from disasters like the 2011 and 2014 flooding,

 Mitigating the effects of natural hazards before they happen is critical to reducing the devastating social, personal and economic costs of recovering after the fact.”

Many articles and op eds spoke to the need for action and captured the mood of people in the affected areas:  $1B needed to shore up Manitoba flood protection or risk damage: study | Winnipeg Sun (https://winnipegsun.com/2016/01/20/1b-needed-to-shore-up-manitoba-flood-protection-or-risk-damage-study)

In my thirteen years as president of the Twin Lakes Beach Association and the Association of Lake Manitoba Stakeholders (ALMS), I never heard anyone voice an opinion that a northern egress was not needed. To the contrary, meetings with the Province and Federal representatives started with the belief that something had to be done to compensate for the inflows of water into the lake, particularly through the Portage Diversion.

What alternative plans are being developed in the event that this will not be approved by the environmental review and licencing process?

From a cost-benefit analysis, it seems obvious that not acting is a non-starter. The financial cost of these last floods may exceed a billion dollars – consider two class action lawsuits, the Flood Assistance Program, Federal improvements and construction in the Lake St Martin area. In other words, the cost of not acting is greater.

Following the Regulatory Review commissioned report a Public Forum ( Manitoba Government Powerpoint Template (https://www.gov.mb.ca/mti/wms/lmblsmoutlets/consultations/pdf/information.pdf))  was held where recommendations and discussions with the public were presented. These reports and recommendations should not be historical footnotes. They may be helpful in charting a course correction.

The Association of Lake Manitoba Stakeholders presented an option to the proposed channel to the Premier and several cabinet ministers in 2016. Our presentation and discussion was led by our science advisor is Dr. Scott Forbes from the University of Winnipeg. Critiques were presented by two objective experts unaffiliated with our group: Garland Laliberte, Dean Emeritus of Engineering from the University of Manitoba and Jim Collinson who is an internationally recognized expert in water management and economics. Both concluded that the plan is ‘project ready’ and a preferred option to manage Lake Manitoba water levels.  The option was described as more cost effective by utilizing existing infrastructure such as access roads and hydro and less disruptive for the Lake St Martin community.

How should plans be categorized?

Consider the bathtub analogy to our flood potential. Water comes into the tub at varying amounts. The drain is blocked. The tub floods. We can solve the problem one of two ways: limit the inflow or create a drain.

• Consideration should be given to limiting “water in”. Recommendations have dealt with improved diking along the lower Assiniboine and creating storage other than the Lake similar to the Shellmouth Reservoir.
• We are coming off historical highwater in Lake Winnipegosis which contributes to high water events. The pumping option previously mentioned addresses that issue by pumping water out of Winnipegosis.
• Regulate Lake Manitoba. Note that the post-flood enhancement and repairs to the Portage Diversion have actually increased the potential for flows into the lake, bringing with it pollution, debris and invasive species all of which are environmental impacts and which occurred during the current review.

The attempts at providing mitigation north of Lake Manitoba have been failures. The channel created at Lake St Martin was in the wrong location. It did nothing for Lake Manitoba and its potential was never used for Lake St Martin. Secondary cuts such as the one diverting water around Dauphin River has similarly never been utilized with the predictable outcome of flooding from the spring melt. Other options including the pumping recommendation is one of the only alternatives to moving earth.

If the current project is doomed, as it seems to many of our constituents – what is your alternative plan?

How can the process be amended to increase inclusivity?

In the current phase of the review Lake Manitoba has been largely ignored. Representatives from an ever-expanding number of reserves have met on their own. There has been no attempt to involve a single rep from southern communities to monitor if not participate in these discussions. As the project implies, this is a Lake Manitoba-Lake St Martin project. One would think that discussion of the project from an environmental perspective should review the implications of rejecting any egress.

The result of excluding our voice is that the focus has been entirely on the Lake St Martin community. Not surprising news outlets report solely on those communities in the surrounding area. It leaves a bitter taste in the mouths of Lake Manitoba reps who suffered tremendous loss and who have overcome financial and political roadblocks to rebuilding communities. We too have histories. Many residents have had generations of family living at the lake. There are farmers and ranchers still enduring hardships and challenges since 2011 and 2014 with reduced arable lands and pastures. It is unfair that the reports by omission do not recognize the sacrifice, displacement and resilience of Lake Manitobans.

The solution seems clear. Create a more representative body to provide feedback and input to future plans that include both areas affected by flooding. Your process should continue to look at implications and impact on the environment for completing the project but allow for discussion on similar impact for not proceeding.

What has been striking is the lack of commentary on the environment with more on historical and cultural concerns of Aboriginal communities. One would think that the primary focus be on environmental concerns. Leave the other more political discussion to the licencing phase.

The assessment should be concluded. Through this assessment process the affect of the flood on the environment in the Lake Manitoba area has been largely ignored if meetings with groups are an indication. The destruction of habitat, introduction of species of fish introduced since the flood is significant in the destruction of marshland and in the short-term traditional livelihood of Metis and recreational fishers. The ongoing issue of soil salinity has impacted farmers reducing farming and their livlihood. My point is that the project identifies two regions but one seems to have had more prominence to the detriment of the other.

All of which brings me to a conclusion. There was a flood. It created a financial and human toll. The risk with the inflow from the Portage Diversion is now greater than in 2011. All agree a permanent solution must be found to ensure the protection of communities against future flooding. Therefore, what is the plan? If not the Lake Manitoba-Lake St. Martin project what is the alternative? Our Association proposed a pumping option as a less costly solution using existing infrastructure that was less intrusive than moving earth. It was rejected. So, what is the plan? If a northern egress from the lake is not deemed viable then by deduction controlling inflow should be a lynchpin of future planning be it regulating the the Diversion or enhancing diking -  thereby reducing the need for water to be diverted into the lake.

I do know this. Any future plan that does not involve both Lake Manitoba and Lake St Martin reps will lack credibility and work against reconciliation and become a wedge issue for ongoing talks. At a meeting in Winnipeg convened as part of the review of the flood, I sat with members from Fairford and Lake St Martin. I learned a lot by listening. I gave my assurance that ALMS works on the principle that we did not support passing on our problem to other communities. Their response has not apparently changed, “We will never allow channels through our land”.

The issues are huge. The problem is real. You owe it to all sides to come to a comprehensive plan that address future flooding. We wish you well in that endeavour and are prepared to work shoulder to shoulder rather than nose to nose to accomplish that goal.