When you look at the facts on a new plan to regulate water levels on Lake Ontario, one starts to wonder, “Is Plan 2014 even about the environment?” First off, neither Plan 2014 or BV7 were among the plans recommended to the International Joint Commission from their own Study Board. To our surprise, these plans came out of nowhere, born in closed-door meetings that did not include all the interests. Next, the primary biologist pushing for water level change is professor Doug Wilcox. Dr. Wilcox stated (on the record) that improving wetlands required high water but no higher than seen under the current plan. Further, it was only needed, on average, every 20 years or so. Dr. Wilcox also said we needed, “lower lows, for longer durations of two years or more,” as a crucial part of restoring wetlands. Environmental groups claim that current regulation interferes with the natural high levels. Checking the facts, we’ve actually had levels high enough to satisfy Dr. Wilcox’s theory in 1952, 1973 and 1993. By my math, that is, on average, every 20 years. Since facts show we already have the required “high” levels in the required time frame, and they occur under the current plan, it would seem that all we are missing are extreme “low” levels that last for years. But, Plan 2014 gives an annual multi-million dollar benefit to hydro power, due to increased power generation, and IJC estimates of shoreline damages are in the millions of dollars annually. How does this occur with lower water for longer durations? Shipping interests would be outspoken if they actually believed there would be low water for years on end, but are silent. You see, it just doesn’t add up. If there is any truth to the low-water side of Plan 2014, supporters should brace for its impacts. The IJC and environmentalists should carefully study the crisis conditions occurring on the upper lakes due to low water. The damages being caused by low water there are exactly what they believe will be corrected by low water here. The IJC could make Plan 2014 add up by balancing the damages and recommending benefit sharing of hydropower windfalls to mitigate those damaged. St. Lawrence River and North Country communities are historical recipients of this type of mitigation from the New York Power Authority, Alcoa, GM and others with huge water-use benefits. This would add up to a plan that kept the IJC promise of no disproportionate damages. Jack Steinkamp of Sodus Point is the founder of the Lake Ontario Riparian Alliance. Its website address is www.loranet.org/