Why the IWLC Supports Plan B+

In late 2000 the United States and Canada decided to support a 5-year study to be conducted under the supervision of the International Joint Commission (IJC). The study was to determine if the current 1950's water levels regulation plan should be replaced with an updated plan that would additionally take into account environmental concerns and the much expanded recreational boating industry. The study cost of $20 million (US) was shared equally by both countries and concluded in 2005. Herein we describe our rationale for supporting one of the plans proposed - Plan B+.

The IWLC was founded on the basis of looking for a regulation plan equitable for all, not just for one interest or one single area. We felt that both recreational boating and the environment should be added considerations in any new plan. We also thought that regulation should try to return the system closer to its natural order - more out of just common sense than any specific environmental studies. These were our stated aims well before any of the plans came forth.

Many of our originating members were from the boating industry, owners and operators of marinas. They, along with many of our members, stated that the most important issue with water levels was the rapid "draw-down" of levels from the late summer to autumn. A common comment was "they just pull the plug in August and put an end to our boating season". Marina owners stated that they needed higher autumn levels for "haul-outs" in October. A first year boating survey by the Public Interest Advisory Group (PIAG) reinforced this when 96% of those identifying water level problems associated with a time of the year, cited low levels in the late summer to autumn as their greatest concern.

We examined the five plans offered to the public in 2005 as well as the newest proposed plan, Plan 2007. Two of these were reference plans: 1) Plan 1958DD, currently in use, and 2) Plan E, a plan that very closely mimics the natural outflows prior to the St. Lawrence Seaway Power Project. There were three new proposed regulatory plans: Plan A+, Plan B+, and Plan D+.   Plan 2007 is a slightly modified version of Plan D+, which is very similar to the present plan – 1958 DD.  So why did we finally choose to support Plan B+?

Using the latest data models, Plan A+ would produce very few cases of low boating water levels from May through August (for Lake Ontario and the 1000 Islands - almost zero). However, both Plan A+ and Plan D+ require rapid "draw-downs" beginning in late August - similar to the current plan. The "draw-down" for Plan A+ is essentially the same as the current plan and the "draw-down" for Plan D+ is more severe. Plan A+ is definitely the best plan for May - August boating levels only in Lake Ontario and the St. Lawrence River down to the Cornwall-Massena dam.

What Plan A+ doesn't do is add any length to the boating season, provide marina owners with levels for October "haul-outs", or alleviate the "they pulled the plug in August" syndrome. It also does nothing to restore the natural order to the system or to restore the environmental damage we've done to the system over the past forty-six years. Using the latest models, both Plan A+ and Plan D+ perform poorly environmentally. As an example, on page 84 of the Study Board's Final Report it states "Plan A+ is not allowing the needed lows for the regeneration of the wetlands. These results are consistent with the 50,000 year stochastic run of the Lake Ontario wetlands model which shows Plan A+ to be the worst plan (including Plan 1958DD) for both the meadow marsh and emergent marsh".

However, if there is an interest in a longer boating season without the rapid "draw-downs" in the late summer and autumn and in the environmental health of the lake and river, Plan B+ is preferable. Marina owners have indicated to us that the longer season is very important to them. Because Plan B+ follows the more natural outflow patterns, the water levels are spread out more evenly over the year, with less variation within a year. However there are greater year-to-year variations as did occur in the natural system. Providing for "the needed lows for the regeneration of the wetlands" would cause occasional boating problems with Plan B+. During these times it would be difficult to boat, even during the summer months.

Under Plan 2007, average autumn water levels will drop even faster than they do with the present outdated plan.  This is done to reduce Lake Ontario levels so they won’t cause shoreline damages to the south shore.  The plan does almost nothing to help the environment over the current plan.  It will just allow the environmental damages to continue.  

Plan 2007 is opposed by almost all who have seen it with the exception of the south shore landowners.  The IJC chose to design this plan behind closed doors without the knowledge of the public.  This plan was not vetted with the public.  The NYS Department of Environmental Conservation (NYSDEC), the NYS Department of State (NYSDOS), US Congressman McHugh, NYS Senator Darrel Aubertine, as well as a host of local government officials and environmental groups have all voiced their opposition to Plan 2007.

So, as expected, it all came down to a series of compromises. None of the plans are ideal for all interests and all areas. How well does each of the plans meet our stated concerns and objectives? What do we give up with each of the plans? In the end we looked for the best fit. In keeping with our original aims, we chose not to exclusively consider only one interest or one exclusive area.

We feel that Plan B+ best meets the original concerns and aims of the IWLC and represents the best compromise. It addresss the most repeated concern of our recreational boaters and marina owners in that it would alleviate the rapid decline in water levels in the late summer and autumn and extend the boating season.  It is the only plan that begins to return the lake and river to their natural patterns of level changes. It is the only plan that helps to restore our environment and fisheries. Many of our members have stated that the occasional very low water years (about 3 out of 101) is a reasonable price to pay for the other clear advantages. Most all would like the availability of a longer boating season combined with environmental improvements. We also believe that the "do-nothing" option (i.e., staying with Plan 1958 DD) or adopting Plan 2007, which is very similar to the present plan, would be highly irresponsible.  After $20 million and a great deal of work and effort from those involved in the Study, we certainly all know better than to accept the past status quo.

In the end, we felt we should act responsibly and "do the right thing" for this incredible resource (the Lake Ontario - St. Lawrence River system) that we have the very good fortune of sharing and enjoying. We believe that means recommending Plan B+.

We believe the adoption of Plan B+ would be a very positive first step in an ongoing process of constant review, updates and improvements to water level regulation through adaptive management. We likewise support changes to the Advisory Group and the St. Lawrence Board of Control to make them more inclusive of, and more responsive to, a broader array of interests.

The IWLC pledges continued support for a regulation plan that attempts to achieve water level control that is equitable for all interests as well as sustaining the ecology of the Great Lakes-St. Lawrence River system.