This section outlines only some of the issues raised by the community and may be of assistance in helping you express your individual concerns.
Although the number and sizes of project reports submitted in the Settlers Landing proposal may seem daunting, we encourage you to review the documents related to your concerns for the specific details. We have found that the reports use language that downplays or minimizes both impacts and the voiced concerns of the community. You may find that many statements are misleading or misrepresent the complete picture, since they remove the personal perspectives that have been shared. All the reports are found at the Capstone website under Documents:
Objections of a technical nature carry more weight with the Ministry of the Environment in its decision-making. Some of you may hold additional knowledge or expertise that can identify technical errors or omissions to challenge. Remember to let us know!
To help get you started, we offer below descriptions of some of the many, shared concerns voiced at community meetings by you and your neighbours, and the names of Settlers Landing Reports that contain related detail. If any of the content speaks to your concerns, you are most welcome to copy, edit, paste, and paraphrase anything to communicate your concerns in your submissions to the EBR.
When writing your comments, keep in mind that personalized statements reflecting your own perspective and situation related to the IWT location are most effective.
Table of Contents:
1.1 The Oak Ridges Moraine (ORM)
1.2 Hydrologic Concerns
1.3 Proximity to Pontypool and Two Other IWT Projects
1.4 Setbacks from Homes
1.5 Impact on Rural Quality of Life
1.6 Additional Concerns re: Project Location
– Turbine Location Discrepancies
– Coordinate Discrepancies
– Risky Proximity to Pontypool
– Board of Health Rsolution
2. Human Health
2.2 Noise Impacts on Children
2.3 Shadow Flicker
3.1 Property Values
3.2 Interference with Area Economic Development
4. Impacts on Natural Heritage – Flora
4.1 Stewardship of the ORM
4.2 Woodlands in the Project Location are Significant
4.3 Misrepresentation of Site Clearing Requirements
4.4 Myth versus Reality
4.5 Road Construction and Interconnection Facilities
5. Impacts on Natural Heritage – Fauna
5.3 The Avian Baseline Survey
5.4 Species Considered by Proponents
5.5 Threatened Species Ignored by Proponents
5.6 Endangered Loggerhead Shrike
5.8 Osprey at Risk
5.9 Unsatisfactory Mitigation Strategy
5.11 Impact of IWTs on Animals
5.12 Impact of Infrasound on Domesticated/Farm Animals
6.1 Municipal Consultation
6.2 CoKL is an Unwilling Host
6.3 ORMCP Technical Paper Series
6.4 Conservation Ontario – Technical Study Requirements
7.1 Wireless Communications will be Impacted
8 Aquifer Contamination Risks
8.1 IWT Concrete Foundation
8.2 Spills and Leaks of Petroleum, Oil and Lubricants
8.3 Contamination from Erosion and Sedimentation
8.4 Salt, Sand and Chemical Contamination
8.5 Contamination from Detergents and Solvents
8.6 Risk of Dewatering
8.7 Introducing a Permanent Contamination Risk
9 Dirty Electricity and Stray Voltage
1.1 THE OAK RIDGES MORAINE (ORM)
See Settlers Landing Project Reports:
The Settlers Landing proponents plan to locate 5 industrial wind turbines and a substation on the Oak Ridges Moraine. The Oak Ridges Moraine is an environmentally sensitive, geological landform with a unique concentration of environmental, geological and hydrological features that makes its ecosystem vital to the residents of south and central Ontario. The Moraine’s ecological functions are critical to the continuing health of the entire region. Its beauty and quiet tranquility also forms part of our rural consciousness.
➢ Unlike the Green Energy Act, 2009, the Oak Ridges Moraine Conservation Act and Plan of 2001 were carefully developed and legislated to preserve this “water barrel” in perpetuity. The ORM legislation was the result of years of combined effort and collaborative work of an inter-Ministry team of senior government officials, a 13 member Advisory panel from environmental stakeholder groups and input from public consultations and Standing Committee Hearings.
➢ While the Act allows for ‘power transmission lines”, it does not allow for industry or for private, for-profit industrial energy power plants. The ORM vision cannot be reconciled with a proposal to excavate the Moraine, alter its ecological and hydrological features, and install five 146.25 metre (480 feet) tall for-profit, industrial turbines.
➢ Conservation authorities and environmental activists are actively opposed to
the incursion of IWTs into the Moraine. The permanent destruction of ORM landscape for a meager amount of intermittent energy supply is unacceptable. The ORM must be safeguarded from this kind of rule-bending development in order to preserve it for future generations. In its own Technical Guide for Renewal Energy Project Approvals, the Government of Ontario has emphasized:
“In addition to the specific requirements related to provincial plans in O.Reg.359/09, applicants should broadly consider the policy intent of the relevant plan when designing their project in a protected area.” (Page 98)
➢ In several of the Settlers Landing Reports, the proponents state that the project is exempt from the restrictions of the ORMCP. This is at odds with Ministry of the Environment materials sent to the proponents. The REA Technical Guide clearly states that renewable enrgy projects at project locations that are located entirely or partly on land subject to the ORM Plan have special provisions that must be considered in an application for a Renewable Energy Approval (REA). Applicants must also consider the full intent of the ORMCP when evaluating the potential for negative environmental effects.
➢ The construction of industrial wind power plants, which also require multiple access roads, staging areas, transformer stations and excavations for huge permanent concrete bases, will not support the objectives or vision set out by the government for the Oak Ridges Moraine. If approved the Settlers Landing project will open the door to other large-scale IWT installations and industrial land use on this unique and crucial landform.
1.2 HYDROLOGIC CONCERNS
- See Settlers Landing Reports:
- Project Description Report
- Natural Heritage Records Review Report
- Construction Plan Report
- Water Assessment Report
- Design and Operations Report
The proposed IWT installation at Settlers Landing is located in elevated areas with several watercourses, which are tributaries of the Pigeon River system flowing north. It is located at the mouth of the Kawartha watershed as it flows north from the Oak Ridges Moraine and is situated upland from the Pontypool community. These facts suggest that installing IWTs in this area creates a permanent risk, that sensitive ecological systems could be irrevocably impacted. Yet, a full environmental assessment has not been conducted, and the proponent has not demonstrated that the hydrologic functions of this area of the Moraine will not be adversely affected, or possibly irreparably harmed.
➢ An accurate understanding of the area’s groundwater conditions and inherent vulnerability to contamination is critical to ensuring the aquifer in the Pontypool area is protected. The Settlers Landing Project Location sits in an area of high aquifer vulnerability, meaning it is an area where aquifer contamination is more likely to occur as a result of surface contamination. The two key attributes to be considered are the depth to the water table and the hydraulic conductivity of geologic material above a confined aquifer. Fractured or coarse, porous media, such as is to be found in the area under consideration for Settlers Landing, provide faster travel times with less retardation and consequently more vulnerability to contamination during construction phases and following post construction spills.
➢ IWT impacts on ground water at Settlers Landing would affect the drinking water source for homes in Pontypool. In their report, the proponents admit that it is possible for the local ground water and drainage facilities to be impacted by project activities.
• Spills and leaks of petroleum, oil and lubricants
• Surface water impacts due to erosion and sedimentation
• Frac out from directional drilling
• Salt and sand contamination
➢ The complex surface and groundwater system in the Settlers Landing Project Area is still not fully understood. The vast range of local well depths combined with a fluctuating water table, demonstrates the variability and unpredictability of water resources in this area. The area aquifer is designated as highly vulnerable and the Pontypool sands geology makes the area one of high water infiltration. Chemicals and hazardous material used on site during and after construction will include petroleum oil, lubricants, coolants and concrete admixtures and the proponents admit the potential for their uncontrolled release by way of spillage and leakage.
➢ The community remains very concerned about the possible impacts of the proposed Settlers Landing IWT installations on local ground water. The City of Kawartha Lakes formally requested a hydro-geological report and the proponents refused the request. Before the project should even be considered, there needs to be an independent, field-based assessment by a hydro-geologist and a qualified engineering firm, on the hydrologic effects of excavation for turbine bases, roads, staging areas, buried or surface cables and required removal of vegetation.
1.3 PROXIMITY TO PONTYPOOL AND TWO OTHER IWT PROJECTS
- See Settlers Landing Reports: Project Description Report
Settlers Landing is not proposed for a sparsely populated area. In the north end of Pontypool alone, close to 200 homes are approximately 1500 metres from the project location. Although still being ignored by the Ontario Government, harm to human health in a significant percentage of the population has been well documented in peer-reviewed journals, and is actually acknowledged in significant new findings from the provincial government’s own study (as reported in November 2013). Locating turbines literally on top of this community would be both reckless and irresponsible.
➢ Based on the number of noise receptors and a housing study of Pontypool, there is an average of 2.47 people per household. A conservative estimate of as many as 2060 people would be living well within a 2 km zone of wind turbines.
➢ The number of children under the age of 6 in this area is higher than the provincial average, at 30%. Similarly, the number of people in their reproductive years is 60%, which is also higher than provincial average.
➢ There is a large commuter population living in Pontypool – sleep deprivation presents a serious risk to employment.
➢ In response to public concerns, the Haliburton, Kawartha, Pine Ridge Board of Health met on June 20, 2013 and adopted a resolution that the Ministry of the Environment require proponents to comply with larger setbacks based on the cumulative number of turbines. This resolution received the support of the full board.
1.4 SETBACKS FROM HOMES
- See Settlers Landing Reports: Project Description Report
- Consultation Report
- Design and Operations Report
Three IWT Projects are planned in close proximity within Manvers.
➢ In 2009, the Pontypool community was originally approached by Ingo Stuckman of Energy Farming Ontario (EFO) and Zero Emissions People (ZEP), about a single 30 IWT installation in a study area encompassing Pontypool and Bethany. Subsequently in April 2010, without the community being aware of a change in plans, Feed in Tariff (FIT) contracts were offered by the Ontario Power Authority to numerous projects – three of which are situated in the same study area originally proposed by EFO/ZEP:
• Wpd Canada –Ballyduff Wind Farm, Pontypool – 11.5 MW
• EFO/ZEP – Settlers Landing Wind Park, Pontypool – 10.0 MW
• EFO/ZEP – Snowy Ridge Wind Park, Bethany – 10.0 MW
➢ During the course of their development, all of the above projects have changed either ownership or name. Of the three projects in Manvers, the most unsettling have been the EFO/ZEP projects, variously named Ballyduff/Settlers Landing/Snowy Ridge, morphing as they have from a single large project into three smaller ones.
➢ The Settlers Landing Project Description Report is almost word-for-word identical to that of the Snowy Ridge Project, as are many of the details in all the reports for the two projects. We do not see that these two projects have been given separate consideration by any of the proponents, so should be treated as a single project, subject to greater setbacks.
➢ The interconnectedness of the projects is reflected in official reports prepared by M K Ince and Associates. In some cases, identical wording is used in reports for two different projects. For example, a single study for one project is used to support three projects – the “Avian Study” was prepared by M K Ince for EFO in 2008-2009 for the original 30 IWT project. This same 6-year old study is currently being used to support statements made for three separate project submissions: Sumac Ridge, Settlers Landing and Snowy Ridge. The proponents will not release that study for community perusal.
➢ Even the Ministry of Natural Resources (MNR) had to remind the proponents that the projects needed to be addressed separately in the reports.
➢ Under the Green Energy Act, a 15-turbine power plant must respect a further setback than 550 m – from 650 m to 800 m per turbine. Given their proximity and ownership history, these projects should be treated by the EBR as ONE project, subject to greater setbacks.
1.5 IMPACT ON RURAL QUALITY OF LIFE
- See Settlers Landing Report: Consultation Report
Aesthetics is a quality of life issue for many residents in rural communities like Pontypool. While some Manvers residents have lived here for generations, many others have moved here to escape the towering structures and constant movement of urban existence. The peaceful, quiet rolling hills of the countryside in this part of the Oak Ridges Moraine, and rural quality of life is possibly the Pontypool area’s strongest attraction for residents.
➢ The turbines at Settlers Landing are industrial machines that will have a significant impact on the surrounding landscape no matter where they are sited, an impact that will last for decades. There is no way to mitigate for their extreme visibility in a rural landscape. Even a single turbine will detract from the natural aesthetics of the countryside, providing an alien, industrial feeling of a structure out of place and dominating the landscape. There are no locations in the ORM, where landscape would not be negatively impacted by the installation of looming industrial towers, additional power lines and substations.
➢ Wind developers place their IWTs where they can find a willing lessor. They have no stake in the health and welfare of the communities they disrupt.
➢ Turbines are painted and have pulsating lights to make them stand out, to address air safety and bird migration concerns. In the draft reports the proponents confirm that three of the five turbines will be lit, generating light pollution of the night skies.
➢ Wind developers argue that the aesthetic concerns of non-participant residents are unsubstantiated and that people will grow used to the presence of IWTs or even find them attractive. Yet, City of Toronto property owners made it clear to the government that they don’t want to see IWTs installed in a 5 km sightline of lake front properties and successfully staved off a proposed installation. Why should rural property owners want to live right next door to IWT installations?
1.6 ADDITIONAL CONCERNS RE: PROJECT LOCATION
Apart from its location in the Oak Ridges Moraine, we are also concerned about errors,omissions, and misrepresentations we have found in the Draft reports about ProjectLocation. We would expect that reports being provided by the proponents in theirapplication would provide accurate information about the exact location of the Project.
In just one example, in Section 2.2 of the November 5, 2012 Project Description Report it states that “The project will be located approximately 1.5 km west of the community of Pontypool, near the intersection of Highway 35 and Highway 12.”
This statement is incorrect. Highways 35 and 12 do NOT intersect – Hwy 12 becomes 11 and meets up with Hwy 35 in Huntsville…nowhere near the project area.
Turbine Location Discrepancies
There have been inconsistencies in reports regarding the exact locations of the turbines themselves. This has tremendous importance related to accuracy of setbacks from “receptors” (people’s homes). The Draft reports previously submitted contain glaring errors in reference to locations and we have no way of ascertaining if the associated measures have also been corrected every time a turbine location has been changed. Errors are evident in Table 1-1 in the Draft Construction Plan Report, which provides the UTM coordinates for wind turbine locations at Settlers Landing. We had assumed these to be the official and final coordinates for the turbines, since these were thones being provided in the REA application. But they weren’t.
- The proponent has been moving the turbine locations. At this point in time, we cannot be sure where exactly the turbines will ultimately be located. Changes in the UTM coordinates, after having been used for reported setbacks, may have resulted in inaccuracies and place some homes closer to the turbines than reported.
- If the turbine locations are incorrect or have changed, then how can the setbacks have been applied correctly to the receptors? In fact, if the turbine locations are inaccurate, so too could be any of the measures used. For example, measures for the natural features are questionable, since uniform measures were not used. As was noted in the December 2, 2010 letter from the MNR to EFO in reference to the Natural Heritage Records Review:
“Furthermore, setback distances from natural features should be measured uniformly from the outer extent of the project location, as defined by the Renewable Energy Approval Regulation. Measurements within Table 2-1, Table 2-2, and 2-8 refer to different fixed points including individual turbines or tap-lines. It appears that the turbine locations as well as the tap- lines are known, as distances are provided in the above listed tables therefore it is unclear why the project location was not mapped accordingly.” We don’t know if this has been corrected.
Coordinate Discrepancies During Planning
February 21, 2012 Coordinates
The UTM coordinates for T2, T4 and T5 differ from coordinates used in different reports and correspondence, simultaneously. These inconsistencies mean that no one in the community has known exactly where the turbines were to be located. The UTM coordinates have changed over time and were provided in letters dated February 21, 2012 from MK Ince to Milan Vujosevic at Rogers Communications and to Esam Ghanam at Xplornet Broadband, asking for their advisement of potential signal interference.
- T5 Easting 687972 Northing 4885981
- T4 Easting 688414 Northing 4886135
- T3 Easting 687415 Northing 4885682
- T2 Easting 687672 Northing 4885878
- T1 (Alt) not given
- T1 Easting 686470 Northing 4888310
- An email dated February 28, 2012 from Milan Vujosevic to M K Ince reminded them of a previous email dated September 2011, (sent by Mr. Vujosevic to M K Ince 6 months previously) instructing M K Ince that T4 needed to be moved, either northwest or southwest of its current location, because it had the potential to block/reflect their signal for south-east Pontypool.
- An email dated June 13, 2012 from Esam Ghanem of Xplornet informed Ingo Stuckman and Dan Albano that T1 must move 100 m west and T3 must move 100 m east. We don’t know if this happened.
- A belated response from Dan Albano, dated September 18, 2012 told Mr. Ghanem that
“Moving T3 is virtually impossible for us, however, we feel confident we can move T1” so that it no longer interferes with your microwave link…We are willing to commit fully to moving T1 if we can get a sign off on the present T3 location” In reply, Mr. Ghanem of Xplornet agreed to double check, and was sent the coordinates, which show that T2 and T5 had been moved and are no longer at the February location, T4 remains as previously recorded and T1 Alt has been identified.
- T1 Alt Easting 688252 Northing 4885866
- T2 Easting 687603 Northing 4885855
- T5 Easting 687871 Northing 4885948
- On October 5, 2012, Mr. Ghanem informed Dan Albano:
“We have looked carefully and rechecked data, location and calculation. It seems T1 still needs to move 100 m to the east while T3 needs to move 100 m to the west.” Lucky for them T1 has been removed from the plan, but what has happened about T3, or is that still under consultation/mitigation?
- In an email from M K Ince dated November 1, 2012, to Milan Vujosevic at Rogers, the following statement was made:
- “Please be advised that the layout of the proposed Settlers’ Landing Wind Farm has been revised as Turbine 4 has moved slightly (36 m) since our last correspondence (Oct 5, 2012). No other turbines have moved.”
- UTM coordinates provided in the November 5, 2012 Construction Plan Report in Table 1-1, as well as in Draft Site Plan Maps 1 and 2 confirmed the new coordinates for T2 and T5 and introduced new coordinates for T4
- T4 Easting 688379 Northing 4885948
- In another report of the same date, (the November 5, 2012 Design & Operations Report in Table 3-2), the UTM coordinates for T4 remain unchanged from the September 18th coordinates, reported as still being 688414 Easting and 4886135 Northing.
- Other required associated measures have not changed as the turbines moved and we find that confusing, since even a change of 36 m would impact on ground elevation and total height. It would also impact on receptor distance from the turbines, as would the insertion of T1 Alt. We are uncertain as to whether any adjustments have been made to the distances reported and measures used for such reports as that for shadow flicker.
- The proponents now report that consultation is still ongoing with 5 parties (including Rogers, Xplornet and Bell) and mitigation is non-committal, non-specific and undetermined. We cannot even be certain that the turbines are firmly established in their present locations. The proponents reveal in their latest submission that “Consultation with the tower operator of Site 879931 (Rogers communication Partnership) has identified potential impacts. Consultation with the tower operator of Site 889968 (Bell Mobility) began in 2013 and is ongoing. Consultation with the City of Kawartha Lakes and licensees of antennas on the Cantel tower are ongoing. Discussions surrounding appropriate mitigation measures are ongoing.” After 5 years, why are these still ongoing?
- The exact location of turbines was not revealed to the community until the EBR posting, and prior to that, the community was misinformed. We still do not know with absolute certainty have confidence that the turbines will remain as presently located. The absence of this certainty after almost five years of planning is deeply worrisome, especially since turbine placement at Settlers Landing will impact on the large number of non-participants living nearby.
The information being provided about the turbine locations is confusing, misleading and likely contains inaccurate relative measures. It now appears as though the consultations may not be complete or may even have expired, since most of the mandatory consultation responses would have expired during the given time and will have required updated information.
This project should not be considered for approval until all consultation is complete and all mitigation measures clearly detailed, with a commitment to ensure that residents will not be negatively impacted in any way.
Risky Proximity to Pontypool
Based on the uncertain locations in the report, it is still evident that the Settlers Landing Project is planned for a fairly densely populated area. The following map, taken from the Settlers Landing Draft Site Plan, is marked to show 500 m setbacks from the marked receptors, not including the densely populated Pontypool subdivision just east of the project.
The illustration clearly depicts how the turbines are being injected into a significantly populated area, ignoring the fact that to fit them in, 2 of the turbines would have to be placed in the middle of ORM environmentally significant woodlands.
The nearly 200 homes in the north end of Pontypool village (illustrated by the pink triangular demarcated zone east of the Project Location) are approximately 1500 m from the project site. Harm to human health in a significant percentage of the population has been well documented in peer-reviewed journals, and is acknowledged in significant new findings reported in November 2013 from the provincial government’s own study. Locating turbines literally on top of this community would be both reckless and irresponsible.
Board of Health Resolution
The Haliburton, Kawartha, Pine Ridge Board of Health met on June 20, 2013 to vote on a resolution which had been taken forward in December 2012 in response to public concerns expressed to Counsellor Heather Stauble. Many residents had taken the trouble to show up at public meetings and sent in a total of 2500 pages of letters and emails voicing their concerns. The Medical Officer of Health, Dr Lynn Noseworthy, was provided with a copy of the communications. There were also many emails and letters submitted directly to the Board of Health by residents. The adopted resolution asked that the Ministry of the Environment require proponents to comply with larger setbacks based on the cumulative number of turbines. This resolution received the support of the full board.
2. HUMAN HEALTH
In as much as there continues to be an increasing body of evidence that physical harm is being inflicted on many humans living in close proximity to wind turbines, and Health Canada is in the process of conducting a human health study, no further wind turbine projects should be approved until health impact issues have been resolved.
See Settlers Landing Report: Noise Assessment Report
The Settlers Landing proponents give short shrift to legitimate health concerns related to noise produced by industrial wind turbines. Basing conclusions on an outdated (now 5 year old) review of literature entitled “Wind Turbine Sound and Health Effects” conducted by the American and Canadian Wind Energy Associations (with vested interests in promoting wind projects), the proponents argue that there is no evidence that the audible or sub-audible sounds emitted by WTGs have any adverse physiological effects. Yet even conclusions from that review acknowledge that IWT noise, including low frequency noise, cause annoyance, stress and sleep disturbance and as a result people may experience adverse physiological and psychological symptoms.
➢ In an interim report of the Government of Ontario-funded research being carried out at the University of Waterloo through the Ontario Research Chair for Renewable Energy Technologies and Health, the researchers confirm that there ARE studies showing that high sound pressure levels of audible noise and infrasound have been associated with learning, sleep and cognitive disruptions, stress and anxiety. They confirm also that research supports the possibility that exposure to the infrasound component of IWT noise could affect the physiology of the ear and recommend that future research should focus on the effects of IWT noise on sleep disturbance and symptoms of inner ear problems.
➢ As part of their own research, eight Ontario wind farm communities were analyzed with data collected in 2013. The following statistically significant findings were drawn:
• as distance increases (moving farther away from an IWT), sleep improved
• both vertigo and tinnitus were worse among participants living closer to wind turbines
➢ In 2009, the World Health Organization released a 184 page peer-reviewed summary of research regarding the risks to human health from noise induced sleep disturbance. Some of the adverse health effects documented in the report include poor performance at work, fatigue, memory difficulties, concentration problems, motor vehicle accidents, mood disorders (depression, anxiety), alcohol and other substance abuse, cardiovascular, respiratory, renal, gastrointestinal, musculoskeletal disorders, obesity, impaired immune system function and a reported increased risk of mortality.
➢ Based on the best available science the following conclusions can safely and unreservedly be made:
• Wind turbine noise, including low frequency noise, can cause annoyance, stress and sleep disturbance.
• Wind turbine induced sleep disturbance occurs at common residential setbacks and when sound levels are higher than 30 dBA.
• The consequences of sleep disturbance can be serious. Acknowledged symptoms include annoyance, stress, fatigue, headache, sleep disturbance, insomnia, nausea, nose bleeds, palpitations, pressure in the ears or head, stress, hypertension, abnormal heart beats, tinnitus, visual blurring, panic attacks and general irritability.
• Annoyance associated with sound from wind turbines can be expected to contribute to stress related health impacts in some persons
➢ A 2011 Environmental Review Tribunal Decision confirmed that industrial wind turbines CAN cause harm to humans. Legal opinion has closely followed this finding, concluding that IWT project proponents have the responsibility to fully and accurately describe health issues related to any of their projects in Ontario and that failure to include such information could be viewed as negligent misrepresentation and be actionable. As part of the Renewable Energy Approvals process, proponents are required to fully and accurately describe any potential health effects of a Project.
2.2 NOISE IMPACTS ON CHILDREN
There are NO precautionary measures proposed or in place for children in public or private child care centres, schools or other institutions that care for children part or full-time. Parents and caregivers are unable to protect the health of their children and their capacity to learn, from the possible effects of exposure to Low Frequency Noise (LFN). Due to the proposed Settlers Landing and two other IWT project locations in close proximity to Pontypool residences, daycares and schools, some children will not be able to escape the noise, and will experience 24/7 exposure.
➢ Impairment of early childhood development and education caused by noise may have lifelong effects on academic achievement and health. There are studies and statistics available on the negative impact of chronic exposure from noise on children, which have found the following:
• Consistent evidence that noise exposure harms cognitive performance
• Consistent association with impaired well-being
• Moderate evidence of effects on blood pressure and catecholamine hormone secretion
➢ Excerpts from The World Health Organization’s “Training Package for the Health Sector” on “Children and Noise” identify vulnerable groups of children as:
• The fetus and babies
• Preterm, low birth weight and small for gestational age babies
• Children with dyslexia, hyperactivity, and attention difficulties
• Children on ototoxic medication
• Those with developmental and learning disabilities
➢ The growing body of research, and peer reviewed studies on LFN and the related effects of sleep deprivation, as well as related impacts like learning disabilities and behavioural problems in children, demonstrate the need for caution. The planned incursion of three wind developments into our community, with turbines located near a densely populated area and near two schools and a daycare, will mean that many students will be exposed to IWT emitted LFN both when in school and at home.
➢ IWT noise is an issue for our community! We have very serious concerns about noise impacts on residents, and statements made by the proponents in their reports do not offer substantive reasons not to be concerned. We know that noise will affect unwilling receptors within the area of the Settler’s Landing Wind Project and do not find any reassurance in the project reports where it states boldly that “…no significant impacts are expected”.
2.3 SHADOW FLICKER
See Settlers Landing Report: Design and Operations Appendix III Shadow Flicker
Shadow flicker occurs under sunny and moonlight conditions, when light hits the rotating blades of a turbine and casts moving shadows on the ground, resulting in alternating changes in light intensity. This produces strobe-like flickers of light, bright enough to pass through closed eyelids, and moving shadows cast by the blades on windows can affect illumination inside buildings. The timing, intensity, and location of shadows are influenced by: the size and shape of the turbine, landscape features, latitude, time of day, weather and layout of the wind project. Moving shadows have their longest reach when the sun is low in the sky, so there are also seasonal influences on how far and where shadows are cast.
➢ The potential shadow flicker assessments, completed in the pre-construction stage of the Settlers Landing project, have determined that shadow flicker will be a potential nuisance impact. The unspoken message is that nuisance or annoyance does not impact on health. Many studies suggest otherwise. Shadow flicker is recognized as one of the least tolerated “annoyance” effects of IWTs.
➢ The National Research Council and a variety of peer-reviewed studies have determined that wind turbine shadow flicker induced adverse human health effects include annoyance and/or stress.
➢ There are well-recognized, serious health impacts from shadow flicker at differing cycles per second. For example, photosensitive epilepsy is known to occur at 3 Hz. “Flicker vertigo”, has been studied in psychology and is relatively well known by helicopter pilots, whereby a steady light flicker, at a frequency between approximately 4 to 20Hz can produce unpleasant and dangerous reactions in normal subjects, including nausea, vertigo, convulsions and unconsciousness.
➢ The Settlers Landing proponents argue that potential shadow flicker resulting from the project occurs at a frequency below 2.5 Hz and in their words, “…is thus considered a potential nuisance impact, as opposed to a health impact.” Even if this estimate is accurate, it approaches the realm of photosensitive epilepsy – too closely for comfort.
➢ Photosensitive epilepsy aside, the intrusion of any amount of sustained shadow flicker at any frequency into homes will be a stressful annoyance, and we are convinced that for many, it will lead to health impacts.
➢ In their draft projections, the proponents concluded that the Settlers Landing Wind Project location will result in a maximum of 66 hours and 42 minutes of (daytime) shadow flicker occurring over the course of a year, impacting non-participating residences under “worst case meteorological conditions”. This doesn’t sound like much in total. However, one is looking at hours spread over many days, for some receptors, spread over as much as 100 days and for the worst case – almost half the year during which a resident would have be exposed.
➢ This “nuisance” will impact a substantial number of families. When one examines maps provided in the Shadow Flicker Report, it is absolutely clear that shadow flicker will occur for many homes within a much wider area than the required setback distance of 550 m. Given the report findings, the furthest area being impacted is actually over 1.5 km away. A minimum of 74 of the possible 196 homes (‘receptors’ who are families) will be affected.
➢ Since numerous residents in the north end of Pontypool will be exposed to shadow flicker in their homes, the community should have been appropriately involved and informed of this issue. They were not.
➢ There has been no mitigation whatsoever of the impact of shadow flicker on what is a sizeable portion of the Pontypool community. In fact, in the draft report the proponents argued: “Given the relatively large distance from proposed turbine locations to potential receptors, and the corresponding low impacts expected from shadow flicker, no mitigation measures are deemed necessary.” But, the greatest impacts are on receptors that are farther away than the 600 m setback about which the proponents boast so the “relatively large distance” does not have anything to do with need for shadow flicker mitigation.
➢ It has been too easy for the proponents to be dismissive of the concerns of the community – the ‘receptors’ whose lives would be negatively affected. For example, the proponents follow their impact statement with a suggestion that if mitigation is ‘desired’, several options are available. The strategies, designed to block the ‘incoming shadow flicker’ place the burden on residents:
• Residents can cover their windows with shutters or curtains (a strategy which has been found to be inadequate)
• Residents can install vegetation in front of their windows
• Residents can install a barrier (like an awning, shed, fence or wall) in front of their windows
This is not mitigation – more accurately these will be acts of desperation by residents to eliminate the problem they would be forced to live with.
See Settlers Landing Report: Consultation Report
3.1 PROPERTY VALUES
In spite of allegations by wind lobbyists to the contrary, there is clear evidence that the presence of industrial wind turbines negatively impacts property values. In fact, proximity to an IWT installation makes some homes impossible to sell. The growing concerns about quality of life and health impacts from IWTs is making it more difficult, if not impossible, for non-participants who wish to, or must for health reasons, relocate.
➢ American and Canadian wind associations have sponsored real estate studies, which conclude loss in property value near IWTs does not occur to any significant degree. However, an independent analysis carried out on those studies reveals the statistical manipulations relied on to minimize statistical significance of results and support the desired conclusion. These include the following:
• use of a large and undefined study area in which most homes sold were in the view shed but as far as 5 miles from the project
• not using house distance from IWT as a study variable
• including sold homes that have been bought out by wind companies
• not counting listed homes that had not yet sold
➢ There are several more recent studies that indicate property values fall between 20 to 40%.
➢ For most Pontypool residents, life savings are invested in their homes and properties. Rural properties are often used as old age security or retirement collateral. Depriving residents of their hard-earned savings in order to benefit corporations for unreliable and currently un-needed energy is not acceptable.
➢ Diminished property value poses a catastrophic loss for those who have life savings tied up in their properties. This is particularly so for local Pontypool residents where there are many older, long-time residents who may need to relocate to access the kinds of elder care and assisted living only available in urban centres. Any reduction in property value or inability to sell, will impact on their ability to relocate to have their needs met.
➢ Common sense alone dictates that the majority of people will avoid property ownership near an IWT, thus diminishing the pool of potential buyers and reducing property value. Realtors know this, and do not advertise the presence of IWTs to draw perspective buyers. For example, one of the Settlers Landing participants (leasing land for the IWT project recently listed his property and not one word about turbines was mentioned in the ad.
3.2 INTERFERENCE WITH AREA ECONOMIC DEVELOPMENT
The Buddhist Association of Cham Shan Temple began purchasing properties in the Bethany and Pontypool area 20 years ago, in a plan to construct a cultural and religious destination for millions of Buddhists from around the world. The project covers about 7,800 acres of land, and involves an investment of more than $40 million. The vision for the complex is modeled after a Buddhist pilgrimage involving four great mountain temple sites in China – Wutai Shan, Putou Shan, Omei Shan and Jihua Shan. Visiting all four sites is a sacred pilgrimage for the world’s 350 million Buddhists, and takes pilgrims about six months to complete. Sham Chan here in Manvers has been designed to become the North American equivalent, offering an alternative, shorter pilgrimage to that in China, and requiring pilgrims less than a week to complete. The four planned temples will create a unique destination for spiritual, cultural and architectural purposes – a meditation and education destination for visitors, open not only to millions of Buddhist pilgrims but to the community at large. Construction on the massive main temple near Bethany has already begun and one of the smaller complexes is located in Pontypool.
➢ The approval of a single industrial wind turbine project in this area, let alone the three being proposed, threatens this investment in the economic health of the area. The locations of the four temple complexes were selected so that visitors would be able to visit each of the sites easily and would also be able to see the other three temples from viewing platforms. However, the three wind turbine project locations proposed for Manvers lie within the direct sightlines of the key temple lookout points, making the views and temple environments so negatively distractive that the plan is now in jeopardy. Industrial wind turbines, with their associated noise and flicker in the vicinity of the temples, would impact on the meditative/contemplative qualities and natural beauty of view sheds of the temple locations, handicapping their purpose and destroying their appeal.
➢ The economic stakes are high. Any small percentage of 350 million people coming here would have a huge economic impact on the community. Diane Chen, Property Development and Special Projects Manager at Cham Shan Temple, and other temple officials have revealed that the IWT projects would have a direct impact on the planned temples and meditation gardens and would derail the project. If the IWT projects are approved, investment in the temple complexes is unlikely to continue, since the temple views of serene and natural environment will be so negatively impacted.
➢ All the anticipated tourism and culture gains from the Temples would be lost, should the turbine sites be approved. This is upsetting not only to the community, but to the municipality, since economic development is extremely important in this part of CoKL.
➢ The Cham Shan project would have a much greater financial impact, with more permanent jobs and economic development in the area, than would all of the proposed IWT projects put together.
➢ Local Pontypool businesses will also face risk. In Denmark, concerns
around recognized health impacts on people living and working near wind turbines, is having an impact on businesses located near industrial wind turbine developments. For example, as a direct result of an IWT project location within 400 to 700 m of 3 wind turbines, the local nursery, a 43 year old business with annual sales of 2.1 million dollars, had to close down after a local mink breeder was able to establish a causal link between the operation of nearby wind turbines and the loss of a third of the breeder’s mink pups, which were deformed or stillborn. When this fact became known, one third of the nursery staff resigned and the rest were only willing to work sporadically, in fear of serious illness or birth defects. Boye Jensen, the nursery business owner has been unable to sell the property and is seeking compensation through the courts.
➢ The City of Kawartha Lakes cannot afford the loss of the existing industrial/commercial tax base, let alone the resulting destruction of any new business interests in the area. Settlers Landing will result in the loss of land use in and around the project area, which will limit future economic development in the area. Settlers Landing will also be burdening the community with unnecessary power infrastructure and causing a financial strain on municipal and emergency services.
4. IMPACTS ON NATURAL HERITAGE – FLORA
See Settlers Landing Reports:
– Natural Heritage Reports (There are 5 Natural Heritage Reports)
Wildlife habitat will be destroyed by the Settlers Landing project. The project calls for the removal of thousands of trees in an ORM significant woodland. The Project Description Report states, “…The facility was designed to remain on agricultural land and avoid wooded areas to the extent possible.” However, the project requires the removal of almost 2 hectares of woodland, which amounts to 20% of the total woodland. The meadowland and woodland that will be destroyed for roads, crane pads, lay down areas, cables, etc. is 2.7 hectares.
The proponents consistently make use of minimizing language in their reports, trivializing the extent of damage being done to the natural environment at the project location. For example, they make statements such as the following:
• “The Settlers Landing Wind Park is not anticipated to have significant negative residual impacts on land use and resources in the project area.”
“A small amount of clearing of vegetation and trees is required for the operation of Settlers Landing Wind Park.” and that
• “Most of the infrastructure is located within agricultural areas, which will not require clearing.”
In fact, 3 out of 5 turbines plus their project road, pads, cabling, etc. – in fact most of the project is located WITHIN the significant woodland, requiring extensive tree removal and the total area that will be cleared is 2.7 ha. According to Gord Miller, the Environmental Commissioner of Ontario, biodiversity on the Moraine is in serious decline. Massive destruction of an environmentally sensitive ORM landscape, threatening area biodiversity and resulting in a degraded local ecosystem is unacceptable.
The Official Plan for the City of Kawartha Lakes stipulates that development and site alteration in or within 120 meters of a significant woodland area may only be permitted if it is demonstrated that there will be no negative impacts on the natural features or on the ecological functions of the area. The Natural Heritage Site Investigation Report admits there are 11 woodlands in or within 120 m of the project. The woodland most impacted is deemed significant.
Various wildlife species inhabit the natural heritage corridors established between the 11 woodlands, hedgerows and meadowlands in the project location. The construction of turbine bases, access roads, transmission lines, crane pads etc. will remove large portions of woodland and fragment the existing natural heritage corridors, restricting and interfering with the movement of wildlife and will lead to habitat abandonment.
4.1 STEWARDSHIP OF THE ORM
We are both surprised and disappointed that the province would even consider permitting the installation of industrial wind turbines in the Oak Ridges Moraine, and what that means for the protection of natural heritage flora. Local residents have received very different guidance from the Ontario government about protecting the natural heritage flora in the ORM.
The Rural Landowner Stewardship Guide (2007) was developed by a consortium of organizations and Ministries, to guide rural ORM landowners in practices that protect the natural environment of the Oak Ridges Moraine. It is distributed by the Government of Ontario and describes the history of ORM forestry and appropriate sustainable land management strategies.
The Guide stresses that: “The forest is ecologically important. It adds to Ontario’s biodiversity, absorbs pollutants, sequesters carbon and provides habitat for wildlife. The presence of healthy forests is critical to the health of ecosystems, watersheds and communities.” (Page 17)
The history of this region, outlined in the Guide, illustrates this. By the 1930s, settlers in the ORM had cleared trees to such an extent that areas of the ORM resembled desert. Deforestation and poor agricultural practices had degraded animal habitat, resulting in population declines and extirpation of native species. The loss of natural cover impacted on 65 creeks and rivers, which had their headwaters on the ORM. Efforts to reforest the moraine began in the 1940s, with the planting of millions of conifer seedlings (plantation style). Sustainable forest management was initiated to recreate the hardwood forests. As a direct result of these steps, wildlife species have recovered or returned and many are still being reintroduced, especially as the wooded areas mature.
In the woodlands that would be impacted by the Settlers Landing project location, there is a mixture of mature trees and younger growth, with some trees estimated as being as much as 80 –100 years old. Rather than finding an area away from significant ORM woodlands, the proponents are proposing to install industrial wind turbines right in their midst, without regard for the negative impacts.
The reports prepared by the proponent do not indicate the total number or species of trees to be removed, and trivialize impact by referring to designated significant woodlands as a “woodlot”. In discussing the characteristics of the woodlands in the project reports, the proponents describe each as “…likely to be a plantation due to the row-like formation which the trees are growing in” (Natural Heritage Records Review Table 8-1). They fail to mention that row-like planting is typical of crucial steps taken to renew denuded areas of the Moraine, and would be a natural characteristic of many wooded areas in the ORM.
The construction of the Settlers Landing project will impose a hugely negative impact on the natural features and ecological functions of significant ORM woodland. Removal of woodlands and hedgerows will affect wildlife habitat, corridor movement and breeding grounds in this area of the ORM.
In the different project reports, there is confusion as to the number of woodlands in the project location, reported in separate reports as 9 and 11 woodlands. We would have expected that after 5 years planning, the information provided would be accurate and consistent throughout reports.
4.2 WOODLANDS IN PROJECT LOCATION ARE SIGNIFICANT
The significant woodlands in the project location should be protected – why else refer to them as significant? Trees filter air pollutants, replenish oxygen, cool the earth and provide home to many species of plant, birds and wildlife. Trees and forests play a vital role in counteracting CO2 emissions through carbon storage and atmospheric CO2 . “The size of trees is important when it comes to carbon sequestration and speaks to the need for sustained growth. Carbon sequestration rates can be up to 90 times greater for healthy large trees than healthy small trees.” http://www.treesontario.ca/learn/index.php/tree_facts 2013/06/27
One significant woodland in particular will be heavily impacted if the project is approved. The location of T3 and T5 turbines, as well as their laydown areas, permanent crane pads and blade swept areas, and the connecting project road and underground electric cabling for T2, T3 and T5, fall entirely within significant woodland WO11. If the proponent’s estimates are accurate, (and we believe them to be conservative) 1.8 hectares of trees will be removed, resulting in approximately 20% total habitat destruction of the 10 ha woodland.
Project activities with impacts on significant heritage features and habitat are outlined in the reports. They include removal of vegetation; soil compaction; erosion and sedimentation; contamination due to accidental spills and leaks and winter road salt; disruption of wildlife. Trees and vegetation will also have to be removed to accommodate construction vehicles roadways and so-called “interconnection facilities”.
4.3 MISREPRESENTATION OF SITE CLEARING REQUIREMENTS
A number of statements are made throughout the Settlers Landing reports, which we believe attempt to trivialize the destruction of the natural environment in the Settlers Landing Project Location. We find that the descriptions and wording used misrepresent the true picture. Throughout the reports, the proponents downplay the very real damage planned for this part of the ORM in the City of Kawartha Lakes.
For example, in the Project Description Report, they state: “The Settlers Landing Wind Park is not anticipated to have significant negative residual impacts on land use and resources in the project area.” Nothing could be further from the truth.
Under Item 2.3.2 of the Project Description Report, the following statement is made:
“The facility was designed to remain on agricultural land and avoid wooded areas to the extent possible.” This statement is a gross misrepresentation and is repeated in many reports (with only minor word changes), as if making the statement multiple times will actually make it true.
While the facility and infrastructure may have been designed to remain on agricultural land, in actuality it doesn’t. The only way the proponents can squeeze 5 turbines into the limited area they have been able to contract to lease, is to remove almost 2 hectares of mature ORM forest habitat. How is this deemed to be “…remaining on agricultural land to the extent possible.”?
No one is forcing this choice of location on the proponents. The fact is, they were unable to acquire leases on sufficient farmland to be able to place five turbines, so they have decided to clear ORM significant woodland out of the way instead. How can the removal of 1.8 hectares, close to 20% of mature ORM woodland even be considered? Why not fewer turbines and avoid the woodland altogether?
In the Design and Operations Report they continue to use descriptive language that downplays the extent of the damage: “A small amount of clearing of vegetation and trees is required for the operation of the Settlers Landing Wind Park. Most of the infrastructure is located within agricultural areas, which will not require any clearing. However some components of the project have been designed to be located within areas presently vegetated. These areas will be kept clear for the life of the project for operation purposes. The total area that will be kept clear for the project will be 2.7 ha.” This is blatant misrepresentation. 1.8 ha of trees out of 2.7 ha overall area to be cleared is not a “small amount”.
Furthermore, three out of five turbines, plus their project road, pads, cabling, etc. is most of the project – and they are located within woodland requiring clearing, not “in agricultural areas” as claimed above.
4.4 MYTH VERSUS REALITY
We are disturbed by the proponent’s continual downplaying of the damage that will be done to the woodlands in the project location in order to seek a Renewable Energy Approval. For example, the following is a description provided in the Natural Heritage Site Investigation Report, a statement which we find to be particularly misleading: “The general habitat of woodlands in the area was observed to be damaged by grazing cattle and having a high degree of human impact…The habitat of the Woodlands near T4 and T5 (WO10 and WO11) were found to be disturbed by logging practices. The presence of large trees was extremely rare.” We disagree with this assessment. The grazing damage described refers only to the outer edges of the named woodlands. Instead, WO10 and WO11 present dense, mixed age forest in the areas where forest clearing would be required for turbine placement. Tree removal would be expected to have occurred since appropriate forestry management requires strategic removal of some trees to permit new growth as other trees mature.
The Reports contain many contradictory statements, again, as if simply saying something makes it so. For example, the Design and Operation Report states: “…within the Natural Heritage Assessments, evaluation criteria and setbacks to certain natural features within areas subject to the ORMCP have also been applied where applicable.” (Section 2.4) That statement is inaccurate. Reg. 359 specifies a setback of 120 m from significant woodlands. Yet, the Proponents are planning to install two turbines and peripherals fully within a significant woodland in the ORM, totally ignoring setbacks and cutting out 1.8 ha of mature forest. Setbacks from significant woodlands as designated by the Ministry of Natural Resources have been ignored, with Turbine 3 sited in dense pine and spruce woodlands and Turbine 5 sited in a mature hardwood (primarily maple and oak) bush. Turbines planned for project locations within 120 m of significant woodland should not be approved.
According to the Construction Plan Report, the proponent states: “Vegetation and trees where infrastructure is proposed will need to be cleared. Infrastructure has been designed to remain on agricultural land and avoid wooded areas to the extent possible.” The suggestion that they are avoiding wooded areas is a misrepresentation of what will happen if this project is approved.
4.5 ROAD CONSTRUCTION and INTERCONNECTION FACILITIES
In addition to the obvious tree removal for the turbines, pads and laydown areas, the construction of 3.8 km of access roads and 8.5 km of buried cable will require even more woodland removal. As described in Section 2.2.3 of the Construction Plan Report: “Non- paved gravel surface roads will be constructed to allow access to each individual wind turbine site and substation…These roads will be designed and constructed to support the heavy machinery and trucks…The process of constructing roads will include the excavation and removal of topsoil, placement of aggregate and gravel materials, and further grading and compaction as necessary.” That description clearly indicates the degree of destruction of woodland habitat that will be required, but tree removal is not even mentioned.
A five-meter wide access road for three of the planned turbines is routed to proceed directly through significant woodland. According to Section 3.1.5 of the Design and Operations Report: “A total of 3.8 km of gravel roads will be built to facilitate the construction of the project, 371m of which will be temporary. The roads will be 5 m wide and their construction will reach a depth of 0.5 m consisting of 0.4 m of aggregate with 0.1 m of gravel on the surface.”
In the Project Description Report, (and repeated in the Construction Plan Report), the following statement is made: “Roads have been designed to follow existing pathways, where possible, and be located to minimize the impact on current land uses.” This is another misrepresentation using language to trivialize the impact of road construction on the natural environment in the project location. The access road for three turbines runs through the significant woodland WO11, necessitating the removal of more trees, before road excavation can even be started. There are no existing pathways in the woodlands.
In the Design and Operations Report, the proponents state, “A total of 8.5 km of direct buried electrical collection cabling will be used to connect the project to the substation.” The associated Table 3-3 indicates that the cabling requires a trench 1 metre wide by 1 metre deep. A huge percentage of this will require more tree removal, but the proponents do NOT even mention the substantial tree removal required. All 5 of the turbines will have an impact on wooded areas. As is clearly illustrated on Figure 1-2 and 1.3 in the report, far from avoiding wooded areas, the majority of the project will result in the removal of major portions of significant woodland. In their submission, the proponents have selected pictures taken facing directions that do not reflect the full picture of the woodlands being impacted. Why weren’t pictures for all four compass directions around the turbine locations submitted so that the full extent of forest impacted is clear for REA purposes?
The decision to locate turbines in the middle of significant woodland
in the Oak Ridges Moraine is a choice the proponents have made and
should not be approved. They should be required to find a different
project location that does not require so much destruction of mature
ORM forest habitat.
5. IMPACTS ON NATURAL HERITAGE – FAUNA
Various wild life species found locally use the natural heritage corridors established between the 11 woodlands in the Project location, as well as established interconnecting trails. The construction of turbine bases and turbines, in addition to access roads, transmission lines, crane pads, will remove large portions of woodland and fragment the existing natural heritage corridors, thus restricting and interfering with the movement of wildlife. The project creates the potential for species flight from the area, and thus loss of biodiversity. This is a serious concern for the ORM and for our community. According to a recent special report on biodiversity prepared by Gord Miller, the Environmental Commissioner of Ontario, “A Nation’s Commitment, An Obligation for Ontario”, biodiversity on the Moraine is in a state of serious decline. There is no evidence that the local sources were contacted for information on the whereabouts of significant wildlife habitat. There is no evidence of the protocol used to search for species at risk, neither is there evidence that, as promised in the Natural Records Review, “These species are discussed further in the Natural Heritage Site Investigation Assessment Report”.
A walk through the woodlands and the nearby cornfield reveals clear evidence showing that the project location is a well-used deer habitat, something that has been glossedover by the proponents in their reports. Apart from the destruction of their natural habitat, sections of the Project will be fenced, which will prove a movement impediment, especially to deer populations.
The proponents were informed by the MNR that there are several large contiguous woodlands within the “study area” which based upon size alone could produce interior habitat and that consideration of these wooded areas as potential wildlife habitat is necessary.
In the Natural Heritage Records Review Report with regards to Winter Deer Yarding Areas, core wintering areas are described as:“…areas of many coniferous trees (Pine, Hemlock, Cedar, Spruce) with conifer canopy of more than 60%; may also include areas of deciduous forest. Land surrounding the core area is usually agriculture, or mixed or deciduous forest. A core deer yarding area, however, is predominantly woodland habitat with minor components of cultural lands.” This description fits Settlers Landing Woodland 11. However, the proponents are not even investigating this issue.
The report draws a convenient conclusion: “Habitat was not identified by the MNR – habitat not present.” This was used to justify a decision not to carry these items forward to Site Investigation. We would argue that they cannot find what they don’t look for.
In their letter, the MNR requested that “…draft monitoring protocols or procedures should be submitted to MNR for review to ensure that work is completed in accordance with MNR guidelines or procedures or requirements.” We cannot see that this was done.
It is widely recognized that bird fatalities will occur as the result of any IWT installation.
The proponent admits the possible adverse impacts:
• Birds will avoid the area under construction;
• Breeding behavior could be impacted
• Avoidance may cause habitat fragmentation
• There will be habitat loss
However, in the Project Description Report, the proponents trivialize concerns about Bird Mortality, Disturbance and Habitat Loss. They state: “Pre-construction site investigations in the project study area conducted as part of the Natural Heritage Assessment identified no significant bird habitat. The project study area, as it consists of already disturbed primarily agricultural lands with low value for bird species, is not sensitive habitat, nor is it a major migration route for birds. Impacts of the wind farm on birds are thus expected to be low.” These statements are a complete misrepresentation of the project location and we have concerns related to these statements and others made in separate submission documents on the topic of avian impacts.
It is important to recognize that the project location is part of the Atlantic Flyway migration route and during their travels, migratory birds take advantage of the diverse terrain found in the Settlers Landing and other nearby wooded areas. The Settlers Landing Project Location has been monitored for bird species for the last 16 years, by members of the Ontario Field Ornithologists, initially for the Ontario Bird Atlas in 2000 and on a continuing basis.
Migratory birds use this region, possibly as a flyway to the Carden Plain, which is rated among the top five birding locations in Ontario and among the top 200 in the world.
Fleetwood Creek Conservation Area, found just 2500m west of the Settlers Landing Project Location is also noted as one of the top 10 local birding sites. The Natural Heritage Records Review does not provide a list of less common bird species in the Settlers Landing Project Location, nor is there any to be found in the Natural Heritage Assessment Report. Yet, local experts could have provided greater detail, had the proponents bothered to ask, which they were encouraged to do in the MNR Significant Wildlife Habitat Technical Guide: “Landowners with potentially significant wildlife habitats on their property might be able to provide more information. Hunters, anglers, trappers, members of cottage associations, fish and game, and naturalist clubs, as well as people working in the outdoor recreation sector (outfitters and resort operators) are often aware of seasonal wildlife concentrations.” http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@fw/documents/document/mnr_e001285.pdf
Kawartha Conservation Authority has a monitoring program dedicated to assessing species and biodiversity within its watershed. Species being monitored include many vulnerable avian populations such as the Least bittern, Henslow’s sparrow, Bald eagle, Red-shouldered hawk, Peregrine falcon, King rail, Caspian and Black tern, Short-eared owl, Red-headed woodpecker, Olive-side flycatcher, Prairie, Hooded and Cerulean warbler and Louisiana water thrush.
WO10 and WO11, the significant woodlands planned for destruction for T3 and T5, as well as the contained grasslands within, are home to at least 90 species of birds during the breeding season, 7 of which are on the SARO List. (These include Common Nighthawk, Whip-poor-will, Red-headed Woodpecker, Hooded Warbler, Bobolink, Eastern Meadowlark and Golden-winged warbler.) The Red-headed woodpecker has been consistently observed in the project area over the last three years. Evidence of Pileated woodpecker was noted in the field notes. Golden-winged warblers are known to be present in the project location and the Canada warbler is known to inhabit the surrounding lowlands. Hooded warbler populations have been increasing in the Pontypool area and they have also been observed in the Settlers Landing Project Location.
In May of 2010, Stantec Consulting Inc. released an important study on post construction impact of a wind farm on Wolf Island near Kingston, Ontario. It examined the impact on both birds and bats over a 6 month period between July 1 and December 31, 2009. A shockingly high number of fatalities of both birds and bats was reported. Over 600 birds were killed, equivalent to 6.99 birds per turbine for the reporting period. The casualties included Bobolink, Tree Swallows, Purple Martins, Red-tailed hawks, Turkey Vultures, American Kestrals, and Merlins, among other species.
A particularly troubling finding was the selective impact inflicted by turbines, with a serious impact on aerial insectivorous birds, like swallows and martins (which are in serious decline), as well as on raptors and migratory bats. The reporting period did not include the spring migration period, so the degree of kill was deemed surprising. (Nature Canada Website).
Avian surveys were not conducted in the Settlers Landing Project Location. Instead, the proponent is relying on survey data collected in 2008-2009 for the Sumac Ridge project.
5.3 The Avian Baseline Survey
In the Natural Heritage Records Review Report, the proponents list as evidence the field work summarized in the “Ballyduff Wind Farm Pre-Construction Avian Baseline Survey and Risk Assessment Report Draft”. This study was carried out in 2008-9 for EFO by the consulting firm M K Ince, and the observation location used for the study is not identified, other than by the name Ballyduff, which became the wpd Canada project named Sumac Ridge. The study predates the Green Energy Act of 2009 and the subsequent reorganization of wind projects in the area. In 2008, the project area being considered by EFO at the time encompassed all three current Project Locations, including the Project Locations for Snowy Ridge, Settlers Landing, and wpd Canada’s Ballyduff, aka Sumac Ridge. The study was not specific to the Settlers Landing project location and we understand that the study completed for the Sumac Ridge project lasted a maximum of one hour. We have no way of confirming this since it is not being released by the proponents.
This (now 6 year old) study is being used to justify statements about candidate birds in three different projects, with different sets of habitats in an area encompassing 1000s of acres/hectares.
The specific location and timing of observations is not identified and the proponents refuse to share the information. Without more information about the study itself, or targeted study in each project location, the conclusions are open to question.
The Ballyduff Wind Farm Pre-Construction Avian Baseline Survey and Risk Assessment Report Draft does reveal that there are a lot of birds in the Manvers area, making it doubly important that the details of the report be made available.
The proponents do not provide sufficient information, either about the study or the conclusions drawn from it, in regards to risk assessment to avian populations in the Settlers Landing Project Location. Only the most commonly observed species were named.
The proponents claim, without naming them, that all observed species were common. Given the numbers of different species observed and the historical record of species observation in the area, this is surprising. The proponents do not provide sufficient information about the avian study and its findings.
In October of 2013, Settlers Landing project manager Dave Eva stated in an email response that this pivotal report would NOT be made available to the public, even though it is used as an important tool in Natural Heritage Assessments as part of the approval application and would NOT be made available to the MOE either.
When there are real questions about the validity of using a dated report from an unidentified area, carried out for a different IWT development and being used for two other supposedly unrelated projects, this report should not be kept secret, especially from the REA process.
Approval for Settlers Landing Wind Project must at the very least be withheld until all documentation is made publicly available for the required 60 day period of time.
5.4 SPECIES CONSIDERED BY PROPONENTS
In Section 7.1.2 of the Natural Heritage Records Review Report, the proponents state: “Those [species] listed as endangered or threatened under the Species at Risk Act will be dealt with in a separate Endangered Species Report.”However, the only two avian “Species of Conservation Concern” looked for during the Settlers Landing site investigation were the Black Tern and the Hooded Warbler. The survey was not conducted at the Settlers Landing Project Location.
For Black Tern the proponents conclude “There were no Black Terns identified in the Preconstruction Avian Baseline Survey and Risk Assessment. Additionally, the lack of water bodies in the area suggests that a suitable habitat may not be in or within 120 m of the Project Location.” There is a large pond on nearby nonparticipant property which was not accessed during the site visit.
For Hooded Warbler the proponents conclude “There were no Hooded Warblers identified in the Preconstruction Avian Baseline Survey and Risk Assessment. This bird prefers the interior of large tracks (sic) of deciduous and mixed forest as well as ravines. It seeks out dense growth of low understory shrubs within woodlands.”
This bird’s habitat is present at the Settlers Landing location. Historical observations have cited its presence in the Project Location (Ontario Breeding Bird Atlas; Audubon Christmas Bird Count)
In the Natural Heritage Records Review Report, Hooded Warbler is recognized as a species of conservation concern and the Report describes its preferred habitat. The description fits exactly that of WO11, which will have 1.8 ha of trees removed should approval be granted for T3 and T5.
5.5 THREATENED SPECIES IGNORED BY PROPONENTS
There is no indication in any report that a search was conducted for other avian species known to frequent the area and which are threatened or at risk. On page 3 of a letter dated December 2, 2010 from the Peterborough Office of the Ministry of Natural Resources to Ingo Stuckman, the following statement is made: “A review of our known and available data records indicate that Snapping Turtle (Special Concern), Milksnake (Special Concern), Butternut (Endangered) and Bobolink (Threatened) are known to occur in the general area”. Yet, in Section 7.5 of the Natural Heritage Records Review Report, regarding discussions with MNR Peterborough Office, the proponents only mention the need to look for Snapping Turtle and Milk Snake during site investigation. They omit even mentioning the Bobolink, which was clearly identified in the same letter as Threatened. In the letter, the MNR also informed Dr. Stuckman that Bobolink is listed on the Species at Risk in Ontario (SARO) List as Threatened and went on to stress: “Species listed as endangered or threatened on the Species at Risk (SARO) List are protected under the Endangered Species Act, 2007 (ESA, 2007). Section 9(1) of the ESA, 2007 prohibits a person from killing, harming, harassing, capturing or taking a member of a species listed as endangered, threatened or extirpated on the SARO List. Section 10(1) of the ESA, 2007 prohibits the damage or destruction of habitat of a species listed as endangered or threatened on the SARO List.”
The fact that the MNR made that statement, indicates that there is a reasonable expectation that the threatened Bobolink inhabits and would likely be found in the project area.
The absence of any mention in their Reports of Bobolink as a threatened species generally found in the area, is a disturbing omission. The proponents did not target Bobolink in their Site Investigations, nor did they mention it in their draft reports.
Their own field notes reveal the presence of Bobolink during the 2011-06-13 Site Investigation (carried out by Nigel Ward, Yves Scholten and Daniel Stuart). In their field notes, there is a notation that a Bobolink was heard in the field in proximity to the Project Location.
The proponents have not carried out a targeted search for Bobolink. Their seemingly purposeful omission makes suspect their claims that no species at risk have been found.
5.6 ENDANGERED LOGGERHEAD SHRIKE FREQUENTS THE REGION
Of special note is local monitoring of the critically endangered Loggerhead Shrike (Lanius ludovicianus) which is found in the general geographic area. Search for the Loggerhead Shrike should have been carried out and it wasn’t. There is a reasonable expectation that this critically endangered species either inhabits or uses the project area during migration. Only 22 pairs of Loggerhead Shrikes were recorded in 2010 and 2011, decreasing to 21 in 2012. The loss of even one could mean extirpation of the species. The MNR comment sheets for both the Settlers Landing and Snowy Ridge Wind Projects advised Ingo Stuckman of the possible presence of Loggerhead Shrikes in the Project Locations, as were the proponents for Sumac Ridge. If the one bird study is accepted for three IWT developments in the same general area, they should be required to exercise the same degree of care for endangered species known to inhabit the area.
While Wildlife Preservation Canada, the agency involved in the Loggerhead Shrike Recovery Program, notes the exact migration route of the Loggerhead Shrike is unclear, all three proposed projects in our community appear to be in the Carden core area.
Local avian experts acknowledge that this area of Manvers has been known to be a Loggerhead Shrike migration route for at least 20 years, part of the northern route, likely to the Carden Plain.
It was mentioned to one CoKL Councillor that mice have been found placed on thorny branches, a characteristic of shrike behaviour.
Field notes taken by M.K. Ince staff indicate the presence of hawthorn and buckthorn trees among several hedgerows in the nearby Sumac Ridge project area, thorny trees which are favoured by Loggerhead Shrikes. A species inventory is not available for Settlers Landing and a targeted search was not carried out.
The prevalence of mature trees, combined with open fields and sources of water make the Settlers Landing project location an ideal breeding habitat for species of raptors. Kawartha Conservation Authority species breeding monitoring lists for this area include Osprey, Bald Eagle, Northern Harrier, Sharp Shinned Hawk, Cooper’s Hawk, Red Shouldered Hawk, Northern Goshawk, Broad-winged Hawk, Merlin and Peregrine Falcon. Their breeding and monitoring list also includes Great Horned Owl, Barred Owl, Long Eared Owl, Northern and Saw-whet Owl. Short-Eared Owl is of special concern and may be found in the project location.
The importance of raptors to a healthy ecosystem cannot be stressed enough. “A new study reveals how ecosystems crumble without the presence of top predators be keeping populations of key species from growing too large. It also provides a cautionary lesson to humans, who often remove top predators from the food chain, setting off an eventual collapse.”
According to most field guides for winter raptor sites, agricultural fields in combination with several contiguous woodlands make for ideal winter sites. “The agricultural areas of eastern Ontario in winter can be home to a number of raptors that come to feed on large vole populations. Snowy, Short-eared, Long-eared, Northern Saw-whet, Barred, Boreal, Northern Hawk, and Great Gray owls, Red-tailed and Rough-legged hawks, Bald and Golden eagles, Northern Harrier, and Northern Shrike are all species known to the area.” http://fieldguides.com/itineraries/ont13-ITIN.pdf
Fields within the Settlers Landing project location include row cropping, pasture and hayfields, however, all fields used for row crops were excluded from consideration. The proponents did not even bother looking. In the Project Description Report they state: “The project study area, as it consists of already disturbed primarily agricultural lands with low value for bird species, is not sensitive habitat, nor is it a major migration route for birds. Impacts of the wind farm on birds are thus expected to be low.”
This statement is a misrepresentation and we question why a survey was not done. The field notes indicate a short mid-day visit in June to the project location resulted in sightings of Northern Goshawk, American Kestrel, Eastern Nighthawk and in another note, Red-shouldered Hawk.
40% of the project is to be installed within Woodland 11 and another 20% within its edges.
MNR guidelines under the SWHTG indicate winter raptor surveys must be conducted in areas with a combination of 20 ha of combined forest and upland habitat and with at least 15 ha of upland habitat, and that these surveys be conducted in a consistent manner over multiple years. Settlers Landing covers a greater area than that and is situated in “rolling upland of natural/cultural coniferous plantation, deciduous forest, graminoid meadow and naturalized plantation habitats…” (Natural Heritage Site Investigation Report)
Raptor experts have confirmed that it takes weeks of constant monitoring to know what raptor species inhabit an area, including nest searches. An appropriate survey of the Settlers Landing project location would very likely have identified the presence of even more raptors than noted in the field notes.
The adjacent project, Sumac Ridge confirms the presence red-tailed hawk and rough- legged hawks that overwinter in the area. Kawartha Conservation Authority species breeding monitoring lists include Osprey, Bald Eagle, Northern Harrier, Sharp- shinned Hawk, Cooper’s Hawk, Red-shouldered Hawk, Northern Goshawk, Broad- Winged Hawk, Merlin and Peregrine Falcon in the area.
There is no evidence in the Natural Heritage Assessment Report that indicates a survey of raptor nests was conducted at all. The prevalence of mature trees, combined with open fields and water sources make the Settlers Landing Project Location an ideal breeding habitat for species of raptors.
A study/survey over an appropriate period of time is needed to identify the populations whose habitat is Woodland 11.
In addition, depending on Arctic conditions, there have been winter influxes of raptors such as the great grey owl and during the winter of 2012-13 the snowy owl. Record numbers of barred owls have been spotted in the area by birdwatchers.
Birds of prey are especially sensitive to disturbance near their nests. The adults may abandon a site if they are disturbed early in the breeding season (esp. during nest building). When the adults are flushed from the nest, the eggs or young chicks usually do not survive. (Forest Raptors & Their Stick Nests – Kandyd Szuba & Brain Naylor – Wildlife Consultants, Corbeil, Ontario). http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@forests/documents/ document/stdprod_067326.pdf
Over a 6 month period from Jan to June at Wolfe Island (Kingston, Ontario) 10 raptor carcasses were recovered, compared to the previous 6 months. Seven red- tailed hawks, one osprey, one northern harrier and one turkey vulture comprised the group of 10 raptors killed by the giant blades.”We were hoping (12) was an aberration, but it seems to be steady,” said Erwin Batalla, chairman of the nature reserve committee of the Kingston Field Naturalists. “The raptors are the most concern. It’s probably one of the higher raptor mortality rates at a wind turbine. Wolfe Island probably doesn’t have many (raptors). One osprey could be 10% of the (species’) population.”– Environment Canada – Comments on Wolfe Island Post- Construction Monitoring Report, reported by Mike Norris, The Whig Standard. http://www.thewhig.com/ArticleDisplay.aspx?e=2946372&archive=true
5.8 OSPREY AT RISK
It is a known fact that Ospreys breed and forage in the region. While Osprey prefer hunting in shallow bodies of water and are exclusively fish eaters, they will travel up to 6-10 miles to find food. Osprey use the same nest for many years. Ospreys have a large territory and they appear to be attracted to industrial wind turbines. According to a 2003 study, ospreys are attracted to the turbine nacelles and there have been many documented cases of osprey mortality caused by encounters with industrial wind turbines.
It is puzzling that in their field notes, the proponents missed spotting the long established Osprey nest in the Settlers Landing Project Location, on the communication tower on Telecom Road. This nest had been occupied for the past four years.
That nest was photographed, concerns about it (along with the photo) were submitted to the proponents by a local resident and naturalist. His submission should be provided as part of the proponent’s package. After this submission, the nest was removed! The communications company representatives deny having removed it. Its presence would have required restrictions to activities within required setbacks – so the timing of its removal is certainly suspect.
There are many reports of ospreys being killed by industrial wind turbines all over the world, including Germany, Scotland, Spain, throughout the USA and even at Wolfe Island, Ontario where it was noted that even one osprey could be 10% of the osprey population there.
The Natural Heritage Assessment reports do not state how injury and death of these raptors will be avoided.
5.9 UNSATISFACTORY MITIGATION STRATEGY
We do not believe the proponents take seriously the impact the IWT installation will have on the rich bird population in the site location. The proponents state that they expect the impacts on birds to be low, and that they have mitigation measures and a monitoring program, as if the impacts will be easily resolved. The proponents propose to remove permanently the habitat within which many of these birds breed, by removing 1.8 ha of the woodlands. The wind turbines, once operational, will create disturbance, which will likely prevent most species from using the area as habitat. Essentially, there is nothing that can be done to prevent the negative impacts on birds from the installation of turbines in this habitat. Monitoring is not preventative. The mitigation measures will not make this area a safe habitat for birds.
The proponents are proposing permanent and irreparable habitat destruction that cannot be mitigated.
Migratory bird studies have not been completed on the unique landscape of the area to ensure the safety of species at risk.
The proponents try to downplay the impacts of clearing 1.8 ha of forest and embedding two IWT, pads and roadways in the midst of a significant woodland, by stating in the Design and Operations Report that: ‘Turbines have been sited away from Natural Heritage Features to avoid potential significant bird habitat as much as possible.”
No post construction behavioural monitoring or contingency plans are proposed. They state: “If tree-clearing during breeding season is unavoidable then a trained biologist will search the area before construction to ensure that there are no bird nests present in any work areas.” What will they do if they find bird nests?
A representative of MKI was asked what happens if nests are found in the way of construction during breeding season. Their answer was that unless the nests are identified as belonging to a species at risk, the nests will be removed. Removing nests during breeding season is NOT mitigation.
Bats are already being decimated by white nose disease, and will certainly be impacted since mitigation is insufficient to protect them from wind turbines. In the May 2010, Stantec Consulting Inc. study on post construction impact of a wind farm on Wolf Island near Kingston, Ontario, the impact on bats was reported. The same selective impact inflicted by turbines on aerial insectivorous birds was also seen for migratory bats. Bat kills included Hoary Bats, Eastern Red Bats and Silver-haired Bats. Over1278 bats were reported killed, equivalent to 14.7 per turbine for the reporting period. The reporting period did not include the spring migration period, so the degree of kill was somewhat surprising. (Nature Canada Website).
There are at least two recognized bat maternity colonies in such close proximity to turbine locations at Settlers Landing that they are at extreme risk.
5.11 IMPACT OF IWTS ON ANIMALS
There is growing evidence that animals are affected even more severely than humans by the low frequency noise and vibrations from industrial wind turbines. The hearing and vibration sensitivity of most wild life is far more acute than human sound perception. Animals rely on a large range of sound frequencies, which are inaudible to humans, and their survival is more reliant upon instinctual interpretation of unusual sounds as a source of danger.
The LFN and vibrations projected by wind turbines (and transmitted through the earth) offer confusing, if not threatening stimuli to wild life.
Confusion by sound can impact in a variety of survival mechanisms, such as self- defense, hunting and even reproduction.
The visual impact of shadow flicker can affect perception of movement, with implications related to sensing prey or danger.
Permeating a natural habitat with extraneous noise or visual stimuli will have obvious repercussions for the survival of species who dwell there.
European naturalists have registered growing concern over impacts of IWTs on wildlife, which have been found to move away from the zone of discomfort, an effect described as disturbance and displacement.
European biologists are presenting a growing body of evidence that IWTs placed near important wildlife areas have a long term and destructive impact on these habitats.
Effects appear to be cumulative and have been observed to lead to permanent habitat abandonment by wild life.
We should be especially concerned about this for any industrial incursion into the Oak Ridges Moraine.
5.12 IMPACT OF INFRASOUND ON DOMESTICATED/FARM ANIMALS
Farmers around the world have reported negative health impacts on livestock, affecting gestation, sleep, dietary habits and reproduction. Insufficient attention has been given to this by the proponents. In his literature search, Low Frequency Noise and Infrasound (Some possible causes and effects upon land-based animals and freshwater creatures): A literary Comment, 2006, Ivan Buxton cites articles that include references to the effects of infrasound and vibrations upon humans and animals. It has already been demonstrated that there are associated cardiovascular risks and chronic endocrine effects including increased cortisol production and decreasing antibody production, which inhibits or suppresses the body’s ability to resist disease. In animals, chronically elevated blood cortisol reduces weight gain, which can adversely impact on reproduction. The effects have implications for nearby farmers.
Buxton cites examples including the reduction of egg-laying by domestic poultry; reduced milk production in goats; excessive hormonal secretion as well as water and sodium retention in pigs and in sheep and lambs, increased heart rates, respiratory changes and reduction in feeding.
The proponents have given no consideration to the impact on local farms.
See Settlers Landing Report: Consultation Report
We have serious concerns about the way in which planning and consultation for the Settlers Landing Wind Project has taken place over the last 5 years. An absence of transparency, and a confusing history of ownership change has made it extremely difficult for concerned residents to learn about the project, to understand project implications and to have community questions and/or concerns heard and answered by proponents.
➢ The identity of the proponent is a rapidly moving target, to the extent that we do not know with any certainty who will ultimately assume responsibility for the project and the problems that would arise from it, should it be approved. There has been a lack of clear and consistent ownership and throughout the planning timeline, confusing dissemination of information about project plans.
➢ Without constant research, we could not even be sure with whom we were dealing in terms of ownership. For example, the Settlers Landing project was proposed by Energy Farming Ontario and Zero Emissions People, which subsequently turned into Wind Works Power Corporation. We have since had the following named as Settlers Landing proponents: Premier Renewable Energy, Sprott Power Corporation, Renewable Energy Developers (ReD), Capstone Power Development and Capstone Infrastructure.
➢ The frequent ownership name changes have made accessing information difficult for residents. Ownership changes have not been announced to the community. Even when we do find out, ownership websites become defunct with each new owner and the public is not kept informed in a timely fashion about subsequent changes to the project. To our knowledge, none of the named companies have a long term interest in ensuring the community’s interests are safe-guarded. In fact, we do not believe any of them will even be around to decommission a project at the end of its contract.
➢ It has lately become difficult to trust that any analysis provided in the project reports is objective, since M K Ince, who prepared the Avian Study and the draft REA submissions for both Settlers Landing and Snowy Ridge, became owner of a recent unsuccessfully proposed 4th IWT project for Manvers, (called Stoneboat).
➢ Simply saying meetings have taken place does not verify that consultation has occurred. Coherent and substantive consultation for the Settlers Landing IWT Project has NOT taken place. In fact, over the past 5 years, the proponents seem to have done everything in their power to limit public consultation, following the letter of the law rather than its intent. The number of misinformed posting errors is reported in the Consultation Report. What is missing in the report is an accurate depiction of the whole scale anger of a community that does not welcome this project and total dissatisfaction with a consultation process that simply went through the motions to satisfy the requirements.
➢ Information meetings were characterized by lack of clarity and specificity in response to questions and outright withholding of information, such as the exact locations of the turbines. The consistent and loud message given to the proponents, delivered by those attending the meetings, was that the project was unwelcome to the community. In response, representatives of the proponents stated boldly and dismissively to some attendees that “The Wind Projects will go ahead regardless of community or municipal opposition.”
➢ In a gross misrepresentation of the true community position, the proponents are submitting a video to the EBR of a poorly advertised and consequently poorly attended ‘interim’ meeting (long past the two official ‘consultations’ carried out as required. This video (of a meeting with a bare 30 in attendance) does not reflect the strong, loud and angry opposition among the hundreds upon hundreds of people that attended the official consultations. It is easy to understand why videos from the official consultation meetings are not included in the EBR submission.
➢ Consultation with the CoKL has been reluctant and non-responsive, including refusals to provide additional information requested by CoKL Council. CoKL has made it clear that the project is not welcome in the jurisdiction.
6.1 MUNICIPAL CONSULTATION
The City of Kawartha Lakes requested that Capstone – aka EFO/Sprott/ReD provide a Hydrogeological Study – a routine request for any development on the Oak Ridges Moraine, along with detailed mapping and a Noise Assessment at the suggestion of the Ministry of the Environment. Capstone, previously Sprott and ReD, refused to provide any of the Final Reports to City staff.
The Application was deemed complete by the proponents, without the opportunity for the municipality to review and comment on the requested reports and maps. Municipal consultation was not complete.
The Technical Guide for Renewable Energy Projects advises proponents that projects on the Oak Ridges Moraine face additional requirements:
“Renewable energy projects at project locations that are located entirely or partly on land subject to the Oak Ridges Moraine Conservation Plan have special provisions that must be considered in an application for a REA. These provisions are located in sections 42–47 of O. Reg. 359/09. ,.. applicants are expected to consider the full intent of the Oak Ridges Moraine Conservation Plan when evaluating the potential for negative environmental effects as a result of the proposed project.“
They are also directed to the Ministry of Municipal Affairs website “http://www.mah.gov.on.ca/Page4807.aspx”http://www.mah.gov.on.ca/Page4807.aspx where they are advised to consult with the Municipality, Conservation Authorities and directed to the ORM Technical Papers.
ORMCP TECHNICAL PAPER SERIES
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4886″Identification of Key Natural Heritage Features
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4887”Significant Wildlife Habitat
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4890”Identification and Protection of Vegetation Protection Zones for Areas of Natural and Scientific Interest (ANSI, Life Science)
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4891”Identification of Significant Portions of Habitat for Endangered, Rare and Threatened Species
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4892”Identification and Protection of Significant Woodlands
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4893”Preparation of Natural Heritage Evaluations for all Key Natural Heritage Features
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4897”Water Conservation Plans
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4898”Hydrological Evaluations for Hydrologically Sensitive Features
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4899”Subwatersheds – Impervious Surfaces
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4900”Wellhead Protection – Site Management and Contingency Plans
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4901”Recreation Plans and Vegetation Management Plans
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4902”Sewage and Water System Plans
“http://www.mah.gov.on.ca/AssetFactory.aspx?did=4903”Stormwater Management Plans
CONSERVATION ONTARIO – TECHNICAL STUDY REQUIREMENTS
Once the constraints on a property have been identified, detailed study may be required. Any technical study requirements would be identified in consultation with the CA reviewing the proposal. The following supporting technical study requirements may be required to assess the impact of the project. As outlined in Section 28 (1)(b) and (c) of the Conservation Authorities Act, the purpose of these studies is to demonstrate the impact of the proposed development with respect to control of flooding, erosion, dynamic beaches and pollution, and to assess interference to wetlands and watercourses. The studies required and scope will be determined through the pre-consultation based on the location of the site, site characteristics and complexity of the proposed works. They include the following:
Channel Crossing Assessment/Design Review
Edge Management Plan
Erosion and Sediment Control Plans
Erosion Protection Work (valleyland and shoreline)
Floodline Delineation Study/Hydraulic Impact Assessment (with detailed topographic mapping and modelling)
Functional Servicing Plan
Geotechnical/Slope Stability Study
Hydrologic Impact Study
Hydrogeological Assessment (Water Balance)
Landscaping/Site Rehabilitation Plans
Letter of Opinion that structure can withstand flood depth and velocity, certified by a professional engineer
Natural Channel Modification/Design
Scoped or Full Environmental Impact Study
Structural elevation and construction details
Stormwater Management Facility Design
Stormwater Management Study
Supporting architectural drawings
Topsoil Stripping Review
Watercourse Erosion Impact Analysis
Off site impact assessment
Meander Belt and Fluvial Geomorphology assessment
Natural Feature and top of bank field verification and survey of verified features, hazards and development limits
For more information visit:
6.2 The City of Kawartha Lakes Is An Unwilling Host
Pontypool and Bethany residents are grateful that CoKL Council has not only listened to the concerns of its citizens, but has acted on their behalves. They have already taken all possible steps to try to ensure the Province not only hears local concerns, but more fairly addresses them in the Renewable Energy Approval (REA) process. They have:
- shared our environmental concerns and asked the Province to place a moratorium on installations of IWTs in the Oak Ridges Moraine;
- sought greater setbacks for IWTs from vacant lot and neighbouring receptors;
- asked the Province to investigate more thoroughly the question of health concerns related to proximity of IWTs before approving more installations;
- sought greater clarity from the Province in terms of the Low Frequency Noise (LFN) originating from IWTs, requesting the establishment of regulations around LFN, including criteria for IWT installations for measuring and monitoring LFN;
- tried to address inequities in the CoKL Building Code with regard to fee structures for such immense industrial developments;
- when wind developers did their best to limit community consultation, assisted with well-advertised “Town Hall” meetings in larger venues to ensure the public is informed; and
- tried to safeguard taxpayers by seeking from the Province a cost recovery process related to the municipal expenses incurred by the imposition of IWT projects in municipalities.The City of Kawartha Lakes Is An Unwilling HostPontypool and Bethany residents are grateful that CoKL Council has not only listened to the concerns of its citizens, but has acted on their behalves. They have already taken all possible steps to try to ensure the Province not only hears local concerns, but more fairly addresses them in the Renewable Energy Approval (REA) process. They have:
- shared our environmental concerns and asked the Province to place a moratorium on installations of IWTs in the Oak Ridges Moraine;
- sought greater setbacks for IWTs from vacant lot and neighbouring receptors;
- asked the Province to investigate more thoroughly the question of health concerns related to proximity of IWTs before approving more installations;
- sought greater clarity from the Province in terms of the Low Frequency Noise (LFN) originating from IWTs, requesting the establishment of regulations around LFN, including criteria for IWT installations for measuring and monitoring LFN;
- tried to address inequities in the CoKL Building Code with regard to fee structures for such immense industrial developments;
- when wind developers did their best to limit community consultation, assisted with well-advertised “Town Hall” meetings in larger venues to ensure the public is informed; and
- tried to safeguard taxpayers by seeking from the Province a cost recovery process related to the municipal expenses incurred by the imposition of IWT projects in municipalities.
7.0 TELECOMMUNICATIONS IMPACTS
7.1 Wireless Communications will be impacted
In pursuit of greater economic development, the CoKL has been extremely proactive (to the tune of millions of dollars in investment), supporting the development of wireless communications and high speed Internet in our area, to bring the entire municipality online.
• Signal interference by IWTs is a recognized problem, which have a negative impact on local residents and businesses in our area. With growing reliance on telecommunications in every aspect of daily living, we are deeply concerned about the nature of impact there will be on telecommunications.in Pontypool and the surrounding neighbourhood.
• In one area of Quebec, the CBC conducted pre and post wind turbine signal in quality measurements, including satellite pickup. They measured signal levels, waveform, tape recordings and subjective signal quality evaluation for two television stations. The IWTs involved were 90 metre towers with non-metallic blades 40 metres long, smaller than the ones proposed for Settlers Landing. The CBC found the following problems in reception near IWT installations:
Static interference or “ghosting”, which occurs when signals are reflected off turbine towers. Following turbine construction, an increase in the numbers and severity of ghosting was found in 11 of 14 channels for one station and in 3 of 14 in the other, the difference resulting from the station’s antennae patterns.
Dynamic interference, a periodic variation in picture brightness or colour, caused by the production of secondary interference signal reflected from the rotating blades. This was found at all 14 channels for one station and in 4 of 10 channels in the other. American studies suggest that dynamic signal interference will most likely occur with HDTV, taking the form of frozen screens and pixilation. Research has also found that other wireless and/or broadcast consumer services suffer similarly, including cellular and wireless networking services. (M. Havas)
• An additional source of interference causing electrical pollution is the strobe lighting installed on towers, which releases a high frequency and high voltage impulse each time the light flashes.
• These impacts can only be addressed during project planning stages. Developers need to factor in the location of all local radio communication towers, over the air RF links and areas of served populations. Mitigation measures include replacing all local air reception with cable, relocating television transmitters and relocating or eliminating turbine construction where the impact is detrimental.
• In the Design and Operations Report Table 5-1, the measures supposedly in place to safeguard local Telecommunications are outlined. The performance objective is listed as “Ensure siting of wind turbines minimizes impacts to telecommunications systems.” The listed mitigation measure is a pre-construction survey, and they speak only of minimizing impact not prevention, affirming there will be impacts. They admit: “Potential impacts to analog and digital broadcast television reception are possible; proponent will explore potential troubleshooting in the event of complaints.”
• In the Communications Impact Assessment they state: “There could, however, be satellite TV receivers at some residences within 10 km of the project site. If reception issues arise after construction of the proposed turbine, mitigation measures will have to be discussed with affected residents on a case-by-case basis.” There is no commitment to ensure residents will not be permanently impacted.
• Mitigation is inadequate. The majority of residents in this area depend on satellite for TV reception. The proponents will only ‘explore troubleshooting’ and ‘discuss’ the matter with affected residents! It is “recommended” on page 10 that they mitigate by “…movement of the receiver dish or other means agreed upon by the proponent and impacted party”. How reassuring, when the proponents have no up-front solutions to offer and will not commit to solve the problem.
• The proposed mitigation steps in the Settlers Landing plan are totally insufficient to address this issue. The proponents have not provided for an independent engineering firm to conduct pre and post construction signal engineering evaluations of interference for television, cell phone and wireless networks, including satellite.
• They have not indicated in any reports that they will restore any and all signal interference impacts to preconstruction levels. What little they offer is minus specific details, without specific timelines and lacking a commitment that restitution would be at their expense rather than that of impacted residents.
7.2 Telecommunications Service Providers Have Concerns
The CoKL has invested a great deal of money in upgrading telecommunications throughout the area, but particularly in the Pontypool area which has been a hard to serve region. In consideration of the economic importance of wireless services to the municipality as a whole and to this part of CoKL in particular, and given the investment already made by CoKL in order to improve access, particular attention must be paid to ensure telecommunications is not disrupted at all.
Local service providers have shared concerns about the turbine locations with the proponents. Both Xplornet Broadband Inc. and Rogers Communications have expressed concerns about the placement of turbines and their potential for signal interference on microwave links and cellular networks, so their locations have been constantly moving.
• Change in locations of turbines were requested after project receptor measures were completed. There is no evidence that these measures were updated. Any change in location of any turbines will impact on all reported measures of potential impacts, such as for receptors, for noise and flicker.
• Rogers has had a long-standing problem with the location of T4, which impacts on cell tower service to Pontypool. Rogers wanted T4 moved southwest in the direction of T5/T2/T3 and/or northwest towards T1. In a February 28, 2012 email to M K Ince, after analysing a modified layout provided by M K Ince, Milan Vujosevic of Rogers reconfirmed his September 2011 message that T4’s location continued to have a negative impact on their cell site OAK and cell service to the Pontypool community. An Email from Mr Vujosevic dated Feb 28 2012 to M K Ince indicates continued concerns: “We analyzed your modified turbine layout and found that there is only a minor change compared to the previous locations. We still expect that the turbine WT4 will have a negative impact on our cell site OAK and service provided to the community of Pontypool. Please refer below to our previous email recommending the changes to avoid the potential negative impact.” A November 1, 2012 email from M K Ince informed Mr.Vujosevic that T4 had been moved 36m but no other turbines had been moved. An email from Mr. Vujosevice dated May 1, 2013 to MK Ince “This is to confirm that the proposed modifications will not cause any objectionable impact on Rogers Communications’ installations and services in the area.”
• In light of the May 2013 email from Rogers, it is puzzling that the proponents currently state in their submission: “ Consultation with the tower operator of Site 879931 (Rogers Communication Partnership) has still identified potential impacts. Consultation with the tower operator of Site 889968 (Bell Mobility) began in 2013 and is ongoing. Consultation with the City of Kawartha Lakes and licensees of antennas on the Cantel tower are ongoing. Discussions surrounding appropriate mitigation measures are ongoing.” There could be a need to move a turbine once again.
• In June 2012 Xplornet expressed concern about blockage of their microwave link by the planned placement of turbines, stating that (in combination with a move of T1 which is no longer in consideration for the project), T3 had to be moved 100m eastwards in order to clear the link. They followed up on June 13th2012 stating if the move did not take place, new POP would have to be built. In September 2012, the proponents asked Xplornet to re-examine their position and on October 2, 2012, the response from Esam Ghanem of Xplornet was:
“We have looked carefully and rechecked data, location, and calculation. It seems T1 still needs to move 100 m to the east while T3 needs to move 100 m to the west.” The M K Ince November 1, 2012 response was that a new layout was being proposed with T4 (not T3) having been moved and a response from Xplornet was outstanding when the Draft report was submitted.
• During all this time, different Draft project reports simultaneously listed different locations for 3 of the turbines, so all other data requiring measures from Turbine locations would have contained errors, and we are not convinced any measures were updated in relation to the new turbine locations. Supposedly the reports we are now seeing contain final turbine locations, but this is not assured.
• If there are no concerns, why doe the proponents state in their 5.1 Recommendations: “Consultation should continue with the companies listed below regarding potential impacts and mitigation measures related to their networks:
• Rogers Communications Partnership,
• Xplornet Broadband Inc.,
• Bell Mobility,
• Stellar Communications, and
• Quinte Co. Ltd.”
• Turbine re-location has a huge impact on all assessment measures regarding receptors. The proponents had to move the turbines as requested by Xplornet and/or Rogers, and their reported setback measurements are now in question. Moves could potentially have reduced some listed setbacks to less than 550 m.
It is unacceptable that the Settlers Landing proposal would be given any consideration before the turbine locations are finalized and all reports updated with related measures.
8. AQUIFER CONTAMINATION RISKS
8.1 IWT Concrete Foundations
During IWT construction, numerous tons of concrete required to form the massive bases for each IWT are poured into enormous excavations. Excavation will displace tons of earth and the foundations will require tons of concrete. In the Design and Operations Report the turbine foundations are described:
“At the base of each turbine will be a poured concrete foundation with reinforcing steel bars. The foundation will contain a mounting ring to which the base of the tower will be attached. Exact specifications of the foundation design will depend on the results of the geotechnical investigation of the proposed turbine locations. However, it is expected that the foundation diameter will be approximately 15 m extending roughly 3 to 4 m deep. Once backfilled, only 5 to 6 m of the foundation would be visible at the base of the turbine.”
The statement confirms the sheer volume of concrete to be poured, with foundations between 8 and 10 m deep in overall dimension. Each turbine base will be a minimum of 18 m in diameter and will be accompanied by concrete laydown pads, each measuring 50 m by 100 m.
• We are concerned that the proponent does not address an associated risk for the leaching of harmful chemicals from the concrete, which will take place over time. In the Construction Plan Report the proponent clearly states: “Chemicals or hazardous material used on site during the construction of the project will include fuel, lubricants, coolants and concrete admixtures.”
• Admixtures (such as calcium chloride and other chemical derivatives) used as hardening agents have the potential to leach into the groundwater. The exact admixtures to be used are not named, so risks are not clearly identified by the proponent. This is problematic when one tries to assess potential risks to groundwater from the poured concrete bases of multiple IWTs, in an area of high aquifer vulnerability.
• Studies have resulted in growing concern about the leaching of concrete admixtures containing thiocyanate and resin acids. Thiocyanate exhibits both acute and chronic toxicity, making it of immediate environmental concern. Resin acids emitted from concrete are of environmental concern because resin acids are persistent, are subject to continuous diffusion and have the ability to bio-accumulate in aquatic organisms. The concrete being used is most likely to incorporate air-entraining admixtures, to resist the freezing and thawing cycles during the winter. Information about this risk is not provided by the proponent, nor is mitigation against such leaching addressed.
8.2 Spills and Leaks of Petroleum, Oil and Lubricants
There is potential during all project phases – construction, operation and decommissioning, for water quality to be negatively impacted through contamination from accidental spills and/or sedimentation from improper surface water protection methods. Fluids (oils, fuels) used for construction equipment and during on-going maintenance, such as lubrication of turbines, etc. will present a lifetime management risk. As stated in the Settlers Landing Construction Plan Report:
“The potential exists for the uncontrolled release of petroleum, oil and lubricants (POLs) due to accidental spillage or leakages. This would lead to adverse effects on terrestrial habitat and species, soil, groundwater quality and human health and safety.”
• Each Repower MM92 turbine requires 520 litres of synthetic oil and 12 litres of hydraulic oil. The Repower Maintenance Guide states: “Typically each wind turbine requires maintenance four times each year. Each maintenance visit takes one to four days per turbine to complete. Maintenance visits involve changing hydraulic and lubricating fluids.” (M K Ince)
• The proponent lists mitigation measures, which are described by the proponent as “…intended to minimize the potential for any petroleum, oil and lubricants (POLs) spills on soil, vegetation, surface water and ground water.” Greater protection is needed for the aquifer, given the fact that the report admits: “There is some potential for improper storage or disposal of oils, gasoline, grease or other materials used in construction vehicles, turbines or maintenance vehicles which may result in spills or leaks, contaminating soils or groundwater.”
• A leak from a fuel tank in this area resulted in a nearby well being contaminated. The speed with which contaminates can travel in this area of high aquifer vulnerability is a serious risk. Scheduled inspections are semi-annual, so a substantial period of time could pass before a problem is even discovered, increasing the risk of a major environmental disaster ensuing
• Attention is paid to steps that will be taken to address small leaks or spills of a manageable nature. But, other than placing the problem in the hands of the MOE, the proponent does not reveal sufficient plans for what to do to address a more serious environmental catastrophe affecting the aquifer.
8.3 Contamination from Erosion and Sedimentation
In the Construction Plan Report, the proponent admits that clearing, grading, excavating and soil and root compaction during stages of construction, maintenance and decommissioning, will cause changes to storm water patterns throughout the life of the project. The changes are likely to increase erosion and could impact nearby wetlands and water bodies, resulting in reduced water quality, sedimentation, and impacts to aquatic organisms and habitat. Two water bodies exist within 120 m of the proposed project infrastructure. When water crossing by underground drilled cabling is required, there is the potential to contribute further to potential negative impacts, including frac out.
8.4 Salt, Sand and Chemical Contamination
The Construction Report, Design and Operations Report, as well as the Water Assessment Report all indicate that de-icing materials and salt will applied to access roads during the winter months.
• Road salt is usually NOT applied to secondary roads in the Manvers area of the City of Kawartha Lakes, since residents rely on wells for their drinking water. To illustrate the inherent risks, one need only look at the community of nearby Welcome, where application of salt contaminated an aquifer in the early 1980s…. it is still contaminated.
• Considering the many springs, seeps, tributaries as well as high water table in the area, there is a risk that post maintenance activities might compromise the drinking water used to sustain many residents, as well as livestock.
• There is a PCGMN monitoring well at the junction of Highways 35 and 7A (map2-8 Groundwater Monitoring Station –Trent Source Protection) and the area is a significant Groundwater Recharge region.
• In the Water Assessment report, it states that – “…groundwater is not anticipated to be reached”. But, without a hydro-geological study, this cannot be ascertained. Aside from the tributaries and headwaters of Pigeon River, there are numerous seeps and springs and wetland within the project area. This is confirmed in the LVM Report where “perched groundwater seepage” and saturated soils are identified and the need to check with a hydro-geologist about the possible need for a Permit to Take Water is identified.
• The nearby Oak Ridge Moraine wetland is dismissed by the proponents as not having a large section of open water and thus does not qualify as a water feature. The wetland is formed by a source of water. Exactly what that source of water supply to the wetland is, and how it is connected to the numerous springs located in the project area, is not ascertained in either the Natural Heritage Assessment report or the Water Assessment report.
• The proponents admit that dewatering may occur. Any dewatering could affect the Pigeon River tributary as well as the small headwater pond in the vicinity, due to topography of the region. This may affect the coldwater creek systems in the project area as indicated by the Kawartha Conservation Authority in their letter of comment. Dewatering may completely alter or reconfigure a complex water system that has its origins within the Oak Ridges Moraine. The residential area at the north end of Pontypool is served by the Municipal well in that area. The residences closest to the location of the turbines are supplied by very shallow wells:
Turbine # 1 – 8.5 feet
Turbine # 2 – 16.8 feet
Turbines # 3, 4 and 5 – 19.8 feet
These shallow wells are indicative of a high water table.
• The construction of access roads, below ground electrical transmission lines, as well as excavation for the five turbine bases, will impact many water features and may cause irreparable damage. Post construction maintenance poses a serious risk of water contamination. A full hydro-geological study needs to be conducted first before this project can move forward, otherwise the following could occur.
• The glacial geomorphology of this area is similar to an area in Ayrshire Scotland where local private water supplies became contaminated over a three year period from an industrial wind turbine installation called Whitelee, owned by Scottish Power. According to a September 21, 2013 article in The Times, serious contamination was shown over a three-year period before, during and after the second phase of IWT construction. http://www.thetimes.co.uk/tto/news/uk/scotland/article3875305.ece
The Times article referenced Dr Kate Heal, of the School of Geo-Sciences at the University of Edinburgh, who confirmed that the creation of a wind farm, involving the excavation and movement of soil, the laying of tracks and roads for machinery and sometimes, as at Whitelee, forest felling to create space for turbines, can have seriously harmful effects on the water supply. Dr Heal was quoted:
“All these activities can affect the pathways by which rain falling on the site drains away and makes its way into rivers and lochs and can affect the ecology of those bodies of water and drinking water.”
Finlayson, A. G. & Bradwell, T., 2008. Morphological characteristics, formation and glaciological significance of Rogen moraine in northern Scotland. Geomorphology, 101:607-617
8.5 Contamination from Detergents and Solvents
High-pressure water is used to clean the blades, along with detergents. There is nothing in the post construction report stating how frequently cleaning will take place and if detergents will be used. Detergents entering an area of high aquifer vulnerability, pose a contamination risk to the aquifer.
• The Construction Report, and the Design and Operations Report indicate that de-icing materials will be used on the blades and salt will be applied to access roads during winter months. Road salt is not usually applied to secondary roads in the Manvers area of the City of Kawartha Lakes – since residents in the area rely on private wells for their drinking water. In nearby Welcome, the road application of salt contaminated an aquifer in the early 1980s and it remains contaminated.
• In this area of high aquifer vulnerability, there is a risk that even post-maintenance activities could compromise the drinking water of local residents and livestock. Two tributaries of the Pigeon River are within 120 m of the proposed access roads, transmission lines and/or turbines.
• The proposed mitigation strategy is to “complete work as quickly as possible”. What happens if there is a delay – weather conditions, contract problems, illness, etc.?
8.6 Risk of Dewatering
The proponents assert in the Draft Project Description Report and again in the Construction Plan Report (under 2.2.10 Water Taking) that, “De-watering is not anticipated to impact ground water as excavation is not anticipated to reach the water table.”
• However, the LVM Inc. Report identifies two IWT locations where dewatering may take place and one turbine location wasn’t even assessed. The report also recommended that a hydro-geologist be consulted.
• The proponents have not provided sufficient evidence in their planning to address the possibility of dewatering impacting ground water, other than to say they don’t expect it to happen.
8.7 Introducing A Permanent Contamination Risk
Possible contamination of the aquifer is a risk for the entire life of the project. As previously mentioned, post construction the turbines will require oil changes four times a year. Each gearbox contains 500 litres of oil. Other oils and grease components must also be changed on a periodic basis. The Design and Operations Report confirms that:
“Even with the implementation of the above mitigation measures, there is a possibility of accidents resulting in the release of hazardous materials into the environment. In the event that a spill occurs, action will be taken as per the contingency measures outlined in the Environmental Effects Monitoring Plan.”
• The site is not monitored 24/7 during the operational phase, so a prolonged period of time could take place before contamination is noticed. A review of the proponent’s Environmental Effects Monitoring Plan (as set out in the Design and Operations Report outlines only the minimal requirements needed to comply with Ontario Regulation 359/09 – Renewable Energy Approvals under the Green Energy Act, without providing specifics about what exact steps will be taken in the event of aquifer contamination, other than to notify the Ministry of the Environment (MOE).
• The Design and Operations Report states: “In circumstances where insufficient environmental protection results in an immediate threat to the environment, the MOE will be notified and consulted immediately. While awaiting response, interim measures may be implemented under the supervision of the Site Supervisor. Where danger to the environment is not an immediate threat, the necessary remedies will be implemented within 48 hours from receipt of notification of the circumstances.” For what is already recognized as an area of high aquifer vulnerability, the following questions need to be answered:
• What criteria are used to determine that there is “an immediate threat to the environment”?
• Who assesses and determines the degree of threat?
• What actual steps will be taken immediately in the event of aquifer contamination?
• We are very concerned about the possible impacts of the proposed Settlers Landing IWT installations on local ground water. Before the project should even be considered, there needs to be an independent, field-based assessment by a hydro-geologist and a qualified engineering firm, on the hydrologic effects of excavation for turbine bases, roads, staging areas, buried or surface cables and/or subsequent removal of vegetation.
• Before being considered, the project plans should also include steps for construction site monitoring and inspection by an independent professional for effective storm water and erosion management control.
• The plans should also outline compensation and/or infrastructure improvements to offset any actual hydrologic impacts for the municipality or for private landowners, which could include the construction of water systems to replace destroyed aquifers and impacted wells.
9. DIRTY ELECTRICITY AND STRAY VOLTAGE
Across the province, the existing electrical system has been invaded and tapped into by huge wind projects, yet it has not been upgraded adequately to take and manage this power. The system essentially dumps return current electricity into the ground via ground wires on poles and the electrical currents are creating hot spots of dirty electricity and stray voltage. This ground current can impact livestock operations and some homes can become uninhabitable, as they become receptacles for electrical pollution. It has been described as being similar to living in a microwave oven.
One large substation with multiple and ongoing problems has created illness for surrounding families and has forced some from their homes. Exposure has resulted in headaches, high pitched chiming, sleeplessness, nausea and vomiting and debilitating health effects. Long exposure has rendered some homes toxic and uninhabitable. View a YouTube video by David Colling that explains: http://www.youtube.com/watch?v=M4NE8sWBoaQ
Many community members are concerned about stray voltage, extraneous ground current appearing on grounded surfaces of buildings, barns and other structures. Stray voltage is a low-frequency form of conductive electromagnetic interference. Cattle are 10 times more sensitive to electricity and electronic interference than humans, as they are constantly standing in water or moist areas of ground.
The impact of stray voltage on people must also be of concern, considering the addition of more power lines and substations for IWTs.
We don’t know what specific steps proponents have planned to address this issue as it relates to both animals and people – such as:
- grounding requirements that control for and prevent stray voltage;
- a complaints protocol and ensure redress to victims for damages incurred by stray voltage.
We know there are other areas of concern shared by members of the community, and we will be adding them to our post throughout the permitted submission time. Let us know your additional concerns too so we can share them with the community. We will shortly be posting some sample letters to help those of you who need a little assistance phrasing your issues.
In the meantime – the submissions you make are crucial to the success of the Pontypool campaign to keep IWTs out of our community.
Please take the time to make your voice heard.