This document provides an analysis of two articles that discuss run-of-river hydroelectric projects in British Columbia - one arguing for the projects and one against. The analysis finds that both articles contain logical fallacies and biases in their arguments. The article opposing the projects relies on appeals to authority and emotion while misrepresenting data. The article supporting the projects uses biased sources and commits the fallacy of composition. Improved arguments would include discussing alternatives to run-of-river projects, performing a full cost-benefit analysis, and acknowledging all potential environmental impacts. Moving forward, run-of-river projects could benefit from increased environmental governance, an ecosystem approach to management, and adaptive management techniques.
1. Run-of-the-River: A Friend or Foe to the Environment?
Mariah Mund (301227242)
REM 200 (12:30 Tutorial with Jesus)
April. 7th, 2016
2. Introduction:
In 2007, the Watershed Watch Salmon Society decided to enlighten the public on run-of-
river hydro projects. In their report, they said that many believe run-of-river power is the
greenest form of energy production in BC, but the Society believes these projects have been
mostly hidden from the public, so they decided it was time to educate the masses.
The Watershed Watch Salmon Society (2007) explains that these projects are being
developed as an alternative to previous sources of hydrological electricity. They explain that run-
of-the river projects involve water diversion from a river into a turbine for electricity generation.
This diverted water is returned to the river after it has been used. For successful electricity
generation, a site requires a small dam, pipes to carry the water, a powerhouse to hold the
turbines, and a tailrace pipe to return the water to the river (Watershed Watch Salmon Society,
2007).
On paper, these projects seem relatively safe for the environment, but risks still exist. For
example, the disruption to river flows can damage water quality, habitat stability, and fish health
(Watershed Watch Salmon Society, 2007). The Society also mentioned that small dams disrupt
fish migration while building up dirt, gravel, and other substances. This buildup can damage
natural river habitats. The Society notes that impacts to the environment also occur on land: these
projects result in new roads and powerlines through forests – causing habitat fragmentation and
endangering the lives of various vulnerable species.
Most importantly, the Watershed Watch Salmon Society emphasized the importance of
cumulative impacts for the run-of-river projects. This means that one project could be deemed
environmentally safe, but the combination of all the projects impacts together could irrevocably
3. damage the environment. The Society firmly asserts that the examination of cumulative
environmental impacts must occur before approving new projects.
Run of River in BC:
On January, 30th 2014, CBC News released an article in response to an independent
review on run-of-river projects conducted by the Pacific Salmon Foundation (PSF). Petrovich,
the author of the article, explained that the review was commissioned, in part, by Clean Energy
BC which represents independent power producers. Petrovich found that the review does not
think salmon populations will be greatly impacted by run-of-the-river projects. He also
mentioned that the review found instances in which fish were killed by these projects, but the
death rate was insignificant when examining the broader picture (Petrovich, 2014).
Interestingly, Brian Riddel, the CEO of PSF, made it clear that this review was not
completely accurate. Many run-of-the-river sites do not have monitoring systems, so the review
could not include them, and some of the data from sites with monitoring mechanisms may have
been faulty (Petrovich, 2014).
Petrovich (2014) emphasized that this review was conducted by the private sector to
examine run-of-river practices to ensure that the individual projects maintain good standards.
Paul Kariya, the executive director of Clean Energy BC, points out that out-of-date monitoring
only exists in old projects which were built when monitoring was unimportant (Petrovich, 2014).
The article also mentions that the review was kept confidential because of the societal risks
associated with revealing which hydro development project may cause environmental damage
The conclusion of this article included a recommendation of more data collection for run-
of-river projects; this recommendation has been endorsed by Clean Energy BC, but not
necessarily by individual sites (Petrovich, 2014).
4. Opposition to Run of River Projects:
One day prior to the publication of the independent review by the Pacific Salmon
Foundation, Fumano (2014) wrote an article opposing the development of run-of-river projects.
His biggest argument against these projects was their environmental threats; he also seemed
aggravated about the promise of environmentally friendly which often turn out to be
environmental horrors (Fumano, 2014).
One of the biggest concerns, outlined by Fumano, is the threat to fish because of
diversion. To understand these risks, the Wilderness Committee asked for more information from
the government. Government reports found that in 2012 only 4 of 22 projects had good
management procedures; 2 years later, that number rose to 6 out of 24 projects (Fumano, 2014).
Gwen Barlee, the Wilderness Committee’s policy director, believes that management of
run-of-river projects has failed and most of the projects have encountered accidents because of
improper procedures (Fumano, 2014). On a more positive note, Fumano mentions that the
industrial side of run-of-river projects is attempting to ensure that development is green with the
help of Green Energy BC who has commissioned an independent review on run-of-the-river
projects in BC.
The article by Dan Fumano on the Wilderness Committee website is clearly biased
against run-of-the-river hydro projects in BC. This article commits illogical fallacies including
appeal to authority, appeal to pity, and the fallacy of the slippery slope. Appeals to authority
involve using a prestigious name to make your argument seem more credible. In this piece,
Fumano discusses various opinions held by Gwen Barlee, a Policy Director at the Wilderness
Committee. As a layperson reading this article, we could easily believe that a Policy Director for
an environmental committee is an expert on this project – she claims that the projects are
5. detrimental to the environment and that the government has failed to manage the problems. If we
believe she is an expert, we would likely assume that her claims are true. But upon further
examination Gwen Barlee is not an expert on run-of-the-river projects. Instead she has a
background in political science and her focus is on endangered species (Wilderness Committee,
n.d.). By implying that she is an expert, Fumano may have been attempting to mislead readers
into thinking that the projects are as bad as Barlee has declared.
Analysis of the Argument Against Run of River:
This argument is misleading when discussing the fish deaths near run-of-river sites. The
independent review from the PSF found that some fish die because of the projects, but deaths are
insignificant (Pacific Salmon Foundation, 2014). Fumano mentions that fish are dying, but
ignores the assertion that the deaths are insignificant. The inclusion of potential deaths is an
appeal to pity – Fumano wants readers to be angered by unjust fish deaths, so that readers will
also fight run-of-the-river projects. Rather than using facts to prove their point, they
misrepresented data to evoke emotions in readers in hopes of swaying opinions in their favor.
The last illogical fallacy that Fumano committed was the fallacy of the slippery slope.
This fallacy involves the assumption that one problem will inevitably lead to another; the usage
of this fallacy is a clear depiction of Fumano’s bias. He seems to claim that improper monitoring
and procedures for run-of-the-river projects will lead to environmental problems, but he has no
solid data to prove this – only opinions. Because of his bias, Fumano does not realize improper
management and environmental challenges are not fully correlated.
Analysis of Argument For Run of River:
The article posted by CBC News is also, at times, biased and misleading. Petrovich
commits to the fallacy of composition, contradicts himself, and omits relevant information on the
6. independent review by the PSF. The fallacy of composition occurs when one assumes that what
is true about one thing, should be applied to all other parts of that thing. For the run-of-the-river
case, the claim being made by Petrovich is that the projects are not a threat to salmon population,
but he is assuming that what is true for the tested sites, will hold true for the 18 untested sites.
This fallacy is clearly a problem, without actual investigation there is no way of knowing if the
untested projects are safe: they could have completely different practices that are very dangerous
to salmon. This weakness in his argument means that the safety of these projects might need to
be called into question.
Throughout the piece, Petrovich seems to contradict himself. At the beginning of the
article, he explains that the review by the PSF found that run-of-the-river projects are a minimal
threat to salmon, but the remainder of his article seems to criticise the review. By criticizing the
review, he may have been attempting to remain unbiased, but it resulted in a weakening of his
argument: if the review was so flawed, how can readers be sure that the review is accurate and
that salmon are safe?
Finally, the information Petrovich supplied from Clean Energy BC and its executive
director, Paul Kariya, was biased. This organization openly supports green development and
run-of-river projects, so their claims would consistently be biased towards run-of-the-river
development. Throughout his article, Petrovich includes opinions and excuses from Clean
Energy BC and Kariya. Readers who are unaware of the link between Clean Energy BC, the
Pacific Salmon Foundation, and green development would take the information in this article as
the truth. But this is misleading, an article that uses biased sources cannot inform a reader on the
truth of the issue, and may cause a reader to formulate an opinion based on biased claims.
7. Recommendation for Improved Arguments:
As with many environmental topics, both these articles could include other information to
better inform a reader on the potential future of run-of-the-river projects. These include potential
alternatives, a more succinct cost/benefit analysis, and potential other threats.
On the most basic level, these articles discussed the potential risks to salmon populations,
but did not include the other threats associated to run-of-river projects. The Watershed Watch
Salmon Society (2007) acknowledged that threats to the marine habitat and terrestrial land may
occur with development of these projects. It seems odd that Fumano, who opposes these projects,
would choose to exclude potential environmental threats – when he could be using these threats
as further ammunition against run-of-the-river development.
While understanding the threats of run-of-the-river projects is important, it is also
essential to compare them to other energy producers to determine their viability. By including
the capabilities, pricing, and economic/social/environmental risks associated with other energy
producers it becomes easier to determine if run-of-the-river projects are the safest and most
logical option for BC. Neither article provided alternative solutions, but it seems necessary for
the Fumano piece to provide alternatives – he shoots down run-of-the-river plans without
providing another option which is illogical because BC will continue to need electricity, so we
need an alternative if we are going to end run-of-river projects.
Another important piece to include in these articles would be a cost/benefit analysis. To
make a fully informed decision, a reader must understand the benefits and detractors of a run-of-
the-river project. Both these articles touched on the environmental costs, while completely
ignoring the environmental benefits of not using fossil fuels for electricity. They both, also,
failed to include the costs and benefits to society and the economy. While a cost/benefit analysis
8. in these articles would enable readers to make a more informed decision, it is unlikely that it
would be included in either article. Both pieces are primarily focusing on the environment by
discussing the review by the Pacific Salmon Foundation which focused on salmon health, so the
inclusion of other factors would have been inconsistent with their argument.
Recommendations for the Future of Run of River Projects:
The future of run-of-river projects is uncertain. The Pacific Salmon Foundation (2014)
concluded that there is no immediate threat to the salmon population in their report, but there are
many other areas of concern for the future of these projects. Going forward, the people who want
to further develop run-of-river infrastructure may want to apply different management strategies
to deal with key problems. These strategies could include increased environmental governance, a
commitment to ecosystem approaches, or adaptive management.
Environmental governance has become an important tool for environmental decision
making. It is when all relevant stakeholders are able to assist in the decision making process
(Knowler, 2016b). For run-of-the-river projects stakeholders would likely include the industry,
government, local communities, and local First Nations. With environmental governance, we
hope that all the various issues and concerns can be raised and dealt with (Bradshaw, 2015). But
for run-of-the-river hydro development, the governance process is fairly difficult to implement.
Firstly, many of the projects are already built, so it is unlikely they will be shut down if the
stakeholders decide it is too hazardous to the environment. Secondly, the private industry will
still have more power and control, even if they were to develop a form of governance.
Ultimately, it is there money and time that will be used to fix the problems, so when it comes
down to it; they will choose the best option for themselves, regardless of the decisions made by
other stakeholders. Moving forward, environmental governance could be implemented for
9. projects that are still being decided upon to ensure that the best sites are chosen through
stakeholder decision making, but for current sites, we should look to other forms of management.
One form of management is an ecosystem approach. With this type of approach,
management becomes all encompassing (Knowler, 2016c). Ecosystem approaches look to
examine the entire system (including humans) and its interactions to understand the system as a
whole, and then manage accordingly (Slocombe, 2010). Managing a run-of-the-river site using
this approach means examining the interactions between salmon, the water, the land-based
surroundings, and human activities. In the past, it is possible that these sites only focused on the
health of salmon populations while ignoring the importance of healthy habitats, nearby prey,
water flow, etc. By accepting an ecosystem approach they would realize that the success of the
project and the health of the salmon are influenced by the entire ecosystem’s functionality, so
they must manage the entire ecosystem. An ecosystem approach would be fairly successful at
ensuring that the owners are able to understand how the ecosystem surrounding the project
functions, but for greater success they should also incorporate adaptive management.
Another promising management technique for current and future run-of-the-river projects
is adaptive management. Adaptive management asserts that humans should not control
environmental systems: rather we should recognize that our management strategies might fail
and adapt them when we need to (Knowler, 2016a). With adaptive management, run-of-the-river
projects would operate under uncertain environmental conditions, embrace this uncertainty,
adopt an experimental approach (e.g. trial and error) to deal with uncertainty, and use a
monitoring system to provide feedback for improvement and success (Noble, 2015). By using
adaptive management, these private companies would acknowledge that their sites are not
perfect, while using experimentation to find the best management strategy possible.
10. References
Bradshaw, B. (2015). Environmental governance in Canada: Are we making progress? In B.
Mitchell (ed.), Resource and Environmental Management (pp. 171-191). Canada: Oxford
University Press.
Fumano, D. (2014, January 29). ‘Horror shows’ on BC rivers: Government given an ‘F’ for
handling of run-of-river power projects. Retrieved from
https://www.wildernesscommittee.org/news/%E2%80%98horror_shows%E2%80%99_b
c_rivers_government_given_%E2%80%98f%E2%80%99_handling_run_of_river_power
_projects
Knowler, D. (2016a, January). Topics for week 2... [Powerpoint slides]. Lecture at Simon Fraser
University, Burnaby, BC
Knowler, D (2016b, January). Sustainable planning and governance for resource &
environmental management [Powerpoint slides]. Lecture at Simon Fraser University,
Burnaby, BC
Knowler, D. (2016c, March). Ecosystem-based management in marine ecology and conservation
[Powerpoint slides]. Lecture at Simon Fraser University, Burnaby, BC
Noble, B. F. (2015). Adaptive environmental management. In B. Mitchell (ed.), Resource and
Environmental Management (pp. 87- 111). Canada: Oxford University Press.
Pacific Salmon Foundation. (2014, January 30). Independent review: Potential impacts of run-of-
river power hydroprojects on salmonids. Retrieved from
https://www.cleanenergybc.org/wp-content/uploads/2015/12/Pacific-Salmon-Foundation-
Report-RoR_Report_140129.pdf
11. Petrovich, C. (2014, January 30). Risk to B.C. salmon ‘minimal’ from run-of-river projects.
Retrieved from http://www.cbc.ca/news/canada/british-columbia/risk-to-b-c-salmon-
minimal-from-run-of-river-projects-1.2516563
Slocombe, D. S. (2010). Applying an ecosystem approach. In B. Mitchell (ed.), Resource and
Environmental Management (pp. 409-433). Canada: Oxford University Press
Watershed Watch Salmon Society. (2007, August). Run-of-river hydropower in BC: A citizen’s
guide to understanding approvals, impacts and sustainability of independent power
projects. Retrieved from https://www.watershed-watch.org/publications/files/RoR-
CitizensGuide.pdf
Wilderness Committee. (n.d.). Wilderness committee staff and board of directors. Retrieved from
https://www.wildernesscommittee.org/who_we_are/staff_board%20