A concatenation of bureaucratic bumbling, and careful manipulation of legal and administrative regulation by Hydro Quebec, the MDDELCC, and local municipalities have resulted in the NON dissemination of critical lifesaving information to the public.
Regulations crafted to delay & prevent the identification of incomplete enforcement, and false representation of facts to the public.
Goal of the claim (Improve)
a) The current Dam Safety Act denotes that the Emergency Action Plans are to be distributed to all affected parties.
b) The Dam Safety Regulation denotes that Emergency Action Plans be distributed to the municipality where Dams are installed.
c) Result - Emergency action plans are never delivered to all affected parties. 10+ years after creation, our municipality 1.5 km downstream of a Dam had never received the Inundation Plans, or Emergency Action Plans.
a)The current Dam Safety Act denotes plans should take into account the Failure of the Dam and its consequences.
b) Hydro Quebec used old Dam Break Plans, that OMIT the consequences of the failure of the Dam in question.
c) Result - Incomplete information provided to municipalities and consequently flawed preparation & response plans.
a) The current Dam Safety Act denotes monitoring, forecasting and communication of Levels critical to safety.
b) Hydro Quebec refuses to release level information to the public,as it has "financial" value to them.
c) Result - Public is not informed (Ever) how high water levels are projected to be, preventing their proactive preventative protective measures response.
Action plan strategy
Access to Information requests - Identify areas of Improvement
Raise Public awareness, and garner support for initiatives.
High Level Disclosure - Political & Administrative to initiate corrective actions.
Initiate Media strategy if required.
Why a petition ?
Identify to Politicians- Ministere MDDELCC -David Heurtel ,Government Regulators -MDDELCC-Michel Rhéaume -dir, and Public Utilities - Hydro Quebec , of public discontentment with the status quo.
Against who/what is this petition aim at.
Ministere MDDELCC -David Heurtel,MDDELCC -Michel Rhéaume -dir, President Hydro Quebec
Enforce the Dam Safety Act - NOW !
To Ministere MDDELCC -David Heurtel, MDDELCC -Michel Rhéaume -dir & President Hydro Quebec.
As part of your public mandates is to ensure the enforcement of the Dam Safety Act, we call to you now to address, at a minimum the following deficiencies in your organizations. Ideally, a holistic review of your programs in this area are required to ensure they meet with not only the letter of the law but the intent of the law (To Protect its citizens).
A preliminary review of the Dam Safety Act, Dam Safety Regulations, MDDELCC Enforcement of the regulation, and Hydro Quebec performance of responsibilities shows non compliance across all areas with regards to the intent of the law.
This has in addition, been confirmed, as it applies to the enforcement of the regulations by the Auditor of Quebec. Unfortunately the auditor does not review the regulations themselves, and as such, they also fail to ensure the intent of the act is being properly enforced by regulation.
The law calls for 5 main areas of compliance namely.
1) Dam Design regulations.
2) Planning for Inundation and Dam Failure.
4) Execution of Emergency action plans.
5) Updating /Testing of Plans on a regular basis.
Firstly, it is also critical to identify several key flaws in the current implementation and administration of the current regulation.
a) Hydro Quebec currently has been authorized (by MDDELCC) to administer its own "Plans" that correspond in "like terms" with the Government Regulations as they relate to the Dam Safety Act. Unfortunately, since the creation of the Dam Safety Act, the Hydro Quebec plans have never been updated to the same standards as the Dam Safety Act, and as such the regulations are not currently being adhered to from either a technical or schedule standpoint.Public release of Hydro Quebec's "Like" plans has also not taken place.
eg. Inundation Plans and Emergency action Plans are supposed to be updated at least every 7 years for "Important Dams". Hydro Quebec performs this task on a 15 year cycle.
Dam Break Studies are supposed to include detailed Inundation plans to the building and road level but do not. Hydro Quebec complains about too high costs for Lidar data mapping data.
Dam break studies are supposed to include examples of the specific Dams Breaking for the area being studied. Hydro Quebec used older plans, that in some instances didn't even include the Dams the studies were written for. These studies were later APPROVED by the MDDELCC during auditing.
b) The MDDELCC is currently responsible for the creation of the regulations for the enforcement of the Act, in additional to the performance of the regulations as they apply to Dams owned by the government, and enforcement of audits.
i.e. They write the rules that they need to abide by and are also responsible for their enforcement, and auditing after the fact.
A conflict of interest at every possible level.
This has resulted in the creation of 'God Like' powers for key government directors, as well as the unique capability to write their own rule book without oversight.
i) The Dam Safety Act denotes that the Inundation Studies and Dam Break studies are public information and need to be distributed to all those who could be affected by them.
The Dam Safety regulation denotes that the studies need only be provided to the municipality where the dam is built. This in many cases ensured that the plans were/are never distributed to virtually millions of citizens in countless municipalities.
ii) The Dam Safety Act regulation furthermore classified the documents as public information .
The Dam Safety regulation denotes the following.
Not in force
The information contained in the impounded water management plan and in the emergency action plan is public information. The Government shall, by regulation, determine the manner in which the plans are to be made available to the public.
Note: As a consequence (i & ii) this effectively prevents the Safety Plans from being independently implemented and reviewed by countless millions, where their deficiencies could be identified.
iii) The Dam Safety Act classifies all Dams via a complex set of design review parameters in addition to potential consequences of failures to minimize risk.
The Dam Safety Regulations Section 18 (Para 3) initially classify ALL dams in Quebec as low risk by default, lowering design standard requirements to simply that of a 100 year flood level, where few or no humans would be at risk of failure.
iv) The Dam Safety Act requires safety reviews for all Dams deemed higher than Low risk be reviewed every 7 years.
Due to the automatic classification of all Dam as potential low risk, Safety Reviews for those Dams only need to occur every 15 years at which time, at the end of the safety review, they are then and only then properly reclassified to their potentially correct level.
This enable Dams that potentially should have had stringent safety reviews every 7 years to having the "Appropriate Level of Design review" only being done after 25 years.
Note: As a consequence (iii & iv) For a major Hydro Electric provider, with a large Hydro Electric Dams (i.e.Hydro Quebec) this could potentially enable the deferral of corrective expenditures of Billions of $ for up to 25 years, or a fatal disaster....Which ever comes first....
This also creates the opportunity for potential coercion/collusion of the MDDELCC regulators resulting from their omnipotent regulatory powers.
v) The Dam Safety Act calls for a Dam registry to identify all Dams and their state of review to the public.
The Dam Safety regulations call for the Registry to only be updated at the successful completion of a Dam Safety review.
As a result some reviews that should have been done after 7 years are deferred for 15 years. In addition, any reviews that show fault or are incomplete are not updated in the registry.
As a result some Dams operating with major design and reliability issues are not properly identified in the Registry. The Auditor general as a result is unable to comment on the failures other than to denote the registry is not up to date, as no other information is available.
Note: As a result of (i-v) clearly regulatory amendments adopted effectively bypass key features of the Dam Safety act, thereby indicating active acts of bias in favour of Dam Owners versus that of the Public Safety.
c) Deferral of Responsibility - In the ~2000's the government of Quebec took responsibility for all watercourses in Quebec under new legislation. This included the Inundation Mapping of potential floodwaters, monitoring of flow and level of key waterways. In an apparent effort to reduce government bureaucracy , and Public utility expenditures, many of these responsibilities were deferred to the municipal level where Inundation mapping now falls under the responsibility of municipal governments.
Unfortunately, in areas where Dams were built, inundation mapping (historically publicly available) was never performed by Hydro Quebec or previous provincial governments, and are left unfunded by the small municipalities where they lie.
Water level monitoring and flow, the key "Alarm" for event management is not publicly available from Hydro Quebec for its dams to the public, except in rough daily averages rather than real time actual level and flows as mandated by Government policy.
In time of flood, accurate level information and level projections are not communicated to the public from/for Hydro Quebec Dams.
Only general information such as low level flooding may occur is communicated & Residents are responsible for protecting themselves.
Note: As a result provincial budgets, and public utility costs have decreased, while municipal cost have risen, and endangerment to the public has increased . Non uniform flood planning and response for population has also resulted.
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