Nov, 22, 2019








Dear Commissioners:

Our organization, Restore Our Water International, represents shoreline property owner organizations on both the U.S. and Canadian shores of the Lakes Michigan,Huron and Georgian Bay watersheds. The economic and ecological damages that are occurring as a result of the extreme high water level conditions on these lakes have reached a crisis. IJC action is needed now to address the critically high levels on all of the Great Lakes. Lake levels now meet the “Crisis Conditions” as defined in your excellent 1993 Levels Reference Study Report and Findings.

What is now very alarming are the projections for spring water levels for our lakes– potentially being up to 12” higher than spring 2019. Lakes Michigan-Huron andGeorgian Bay are not being treated equitably by your International Lake Superior Board of Control (ILSBC). In November 2018 and January 2019, ROWI sent letters to the ILSBC recommending immediate attention on cutting-back inflows from theLong Lac- Ogoki diversions because of extreme high supplies in the upper Great Lakes. The ILSBC basically dismissed and ignored our concerns.

The ILSBC has consistently favored Lake Superior interests in lieu of impacts on the lower lakes. This unfair treatment needs to stop now. It is simply unfair to continue to allow a 6.5+ foot range for Lakes Michigan and Huron but only a 4-foot range forLake Superior. This is an artificial water level regime on Lake Superior as the 1914 Orders of Approval for Lake Superior Regulation eliminated the lower foot of its natural range to benefit navigation and hydropower interests. This 100-year plus artificial range modification has had substantial disbenefit to the economic and environmental interests of the lower lakes. The IJC 2012 Upper Great Lakes Study failed to assess these impacts even though reputable concerns were manifested early on that this factor needed to be studied.

In addition, we have conducted important research on the wetlands of GeorgianBay that we would like to share with you. One of our member organizations, Georgian Bay Great Lakes Foundation, has been working with McMaster University, focusing on the impact of water levels on wetland health and water quality. The findings from this research are quite alarming. On Georgian Bay the wetlands at current extreme high water levels have not been able to migrate inland due to the geology of the region. This has compressed the wetlands into a very narrow congested area with no protected area for the minnows and young fish. Also concerning is that the water quality at these previously pristine wetlands is now being degraded with high nutrients load s from overland runoff, leading to significant algal growth.

It is clear that climatic conditions have exacerbated the magnitude and sequencing of water supplies to all of the Great Lakes. The IJC needs to focus attention on implementing as many of the 1993 Crisis Response measures as possible to adapt to changing climate conditions. Adaptive management has been misfocused on land-side measures while viable structural and non-structural measures to reduce water quantity extremes have been totally ignored. The economic and environmental consequences of extreme water levels can be minimized through implementation of these crisis response measures.

We strongly recommend that you advise the ILSBC to deviate immediately from Regulation Plan 2012 and reduce the outflow from Lake Superior as an emergency measure and petition the Province of Ontario to cease diverting water into Lake Superior during these crisis conditions.

We would appreciate the opportunity to address all IJC Commissioners about viable options to reduce the incidence of extremely high and low water levels on the upper Great Lakes. We believe that you would benefit from hearing directly from us in person. Please let us know if you will accommodate this request.


Yours sincerely,