Bullet Points

EBR #   012-2430                 Snowy Ridge Wind Farm –City of Kawartha Lakes

 

Maps, surveys and Assessments produced on behalf of Zero Emission People do not support the proponent’s contention that the Snowy Ridge project will have little or minimal effect on the environment or the social, economic, and cultural health of the area residents.

 

There are many errors and omissions in the reports provided by ZEP (now Capstone) for the 60 day period prior to submission of the REA application to the MOE.

This submission is based on those reports.

 

Setbacks/noise receptors

…..Section 4.5.6. and 4.5.8 (p25&26) of Stantec Cultural Heritage report indicates that 173 Beers Road and 785 Hwy 7A are located at a distance of approximately 500M from Several turbines. The noise receptor table prepared by M.K. Ince lists 172 Beers Road as Receptor No. 42 located 550m from T5, but does not show the distance to T4. The table on Page 9 of the Design & Operations report states that non-participating Receptor No. 42 is located approximately 500m north of T4 and T5. The noise receptor table does not list the actual distance Receptor No. 42 is from T 4.

…..Non-participating Receptor Vacant Lot No. 11 is not a vacant lot.  It has a “receptor” known as Vida Loca and has been there for several years. V011 is marked on the proponent’s maps as being approximately 100 metres north of Twigg Road. The residence is actually located close to Twigg Road and Google Earth places V011 much closer than the 550 metre mandated setback distance from Turbine No. 3.

…..it appears that non-participating receptor R017 as well as non-participating receptor R020 also falls within the 550 m setback, not beyond as indicated in noise receptor Table 3-4 in the Design & Operations report..Calibration tools and Google Earth maps were used to confirm the scale and setbacks delineated in the Snowy Ridge Draft Site plan.

….. Receptor 28 received a building permit to construct a cottage-like structure on the property in August 2010.Where this cottage is to be built will be within 550 metres of Turbines Numbers 1 and 2.

It has not yet been built since the homeowners do not want to subject the family and especially their son who has health issues to the noise produced by these industrial machines.

…..due to concerns about the proximity of T 4 and T5 to the Bell and Rogers communication towers, they have been relocated however, as of the date of the reports submitted with the REA application there had not been a response from Bell or Rogers therefore the turbines may still have to be relocated.

…..Page 4 of the Communications Impact Assessment dated November 2nd 2012, states “most recently the project layout has been revised to consider an alternative location for Turbine No. 1” to address concerns raised by NAV Canada. Depending on NAV Canada’s response, the location of Turbine No. 1 may not be suitable and will have to be relocated again

Several issues have been identified that require much more attention :

  1. new measurements Must be taken R17, R 20 and R 42 as well as R 28 . All appear to be within the mandated 550m setback.
  2. Vo11 is not a vacant lot and the receptor is closer than the mandated 550 metre setback
  3. building permit for cottage for receptor 28 within 550 metre setback of T 1 and T2  
  4. confirmation from Bell and Rogers still required that the turbine layout will not interfere with the cell/communication tower
  5. confirmation from Nav Canada that the layout will not interfere with airport operations

Noise Studies and Maps

….. According to the proponent, Turbine # 5 which is included in all of the maps is no longer an option – instead, the proponent plans to use Turbine Alt # 5 which is located between Turbines # 3 and 4.

-None of the cumulative noise maps account for Turbine Alt # 5. Only two maps on pages 18-19 show Turbine Alt #5.

…..The cumulative noise maps are labelled Snowy Ridge and Settlers Landing. In fact they are maps displaying the cumulative noise impact for Snowy Ridge and the wpd Canada project Sumac Ridge. There is only 1 turbine from the Settlers Landing project included in the maps – and that turbine is no longer an option for that project.

….. It is stated in the charts and text that Settlers Landing Turbine Alt #1 is being considered in the cumulative noise study.It’s location does not appear on any of the maps

…..The cumulative noise impact mappings at the time of the review were not accurate.   The first two maps do not indicate the position of Turbine Alt #5 – only the location of Turbine #5. The final two noise maps dated October 31st 2012 in the report show Turbine Alt #5 as being removed

…..The cumulative noise studies are dated as being fed into the WindPro 2.8 program in the early morning of October 31st, 2012. However, the Noise Impact report is dated October 30th, 2012.

….. There are 13 missing receptors on Beers and Lifford Road alone. It may be possible that these missing receptors are also within the mandated 550 metre setback distance.

…..– maps in the Noise Assessment are dated November 2, 2012 and under each of the maps located (pages 16-19) is captioned: “Figure….: Noise Lines with all  …receptors, turbines and transformers substations”. T5 Alt along with several other receptors are missing on almost all the maps.

 

Several errors and omissions have been identified on the maps, therefore they cannot be considered to be accurate.

1..How could the noise impact report be before the information was fed into the windpro 2.8 program?

2.The first two maps do not show the position of AT5 Alt. only the location of T5 while the final two noise maps dated October 31, 2012 in the report show T5Alt as being removed.

3.Maps in the Noise Assessment are dated November 2, 2012 and under each of the maps located (pages 16-19) is captioned: “Figure….: Noise Lines with all  …receptors, turbines and transformers substations”. Turbine No. T5 Alt as well as other receptors are missing on all the maps.

  1. Cumulative noise assessment map is entitled Snowy Ridge and Settlers Landing but is in fact a map of Snowy Ridge and Sumac Ridge-a wpd project.

5.It appears that the final layout of the project is not yet known as virtually all of the turbines may have be to relocated. Relocation of one of more tubines would require a new noise impact study

The maps cannot be relied upon to be accurate and must be redone.

 

More on Noise

….. The first two maps do not indicate the position of Turbine Alt #5 – only the location of Turbine #5. The final two noise maps in the report show Turbine Alt #5 as being removed. The maps are dated October 31st, 2012, therefore the information reviewed was inaccurate.

…..the noise assessment maps dated November 2,2012 (pages16-19) have captions under each stating “figure….noise lines with all …receptors, turbines, and transformer substations.” BUT T5 Alt is missing on all of the maps and the location of the transformer station has also since been changed.

….The noise measurements for the Snowy Ridge project are based on an abstract theoretical model not tangible physical findings. This abstract modelling is based on assumptions made and outlined in Section 3.4 of the Environment Noise Report (p. 9). The assumptions presume that the project site terrain is flat and clear of all vegetation with a ground source absorption factor of 0.7%. . The report did not indicate what meteorological conditions were factored into the model.

The presumed ambient sound level is not mentioned in the assumptions. Snowy Ridge is located within and adjacent to the Oak Ridges Moraine. The moraine is dominated by ridgelines, hills and valleys the topography of the area varies from 250 to 350m. Snowy Ridge is located at an elevation much higher then the wpd Canada Sumac Ridge project which forms part of the cumulative noise study. The location of the Snowy Ridge project is on a slope of approximately 35 degrees. The land slopes from an elevation of 360 m at the Beers Road location for Turbines Nos. 3, 4, and T5alt to 350 metres for Turbine No. 2 and then another 10 metres to 340 m for Turbine No.1. This is a 30 m or 99 foot slope from east to west across a distance of 1400 metres.

location.”http://www.drnoise.com/PDF_files/Detailed%20Introduction%20to%20Acoustics.pdf

….The Stantec Cultural Heritage Assessment defines the study area as: “This physiographic region is characterized by large drumlins with deep valleys, particularly towards the south end of the region where the Study Area is located”. (p.6)The model excludes the terrain found on the Oak Ridges Moraine– “Sound movement through the atmosphere is affected by wind shear, which can bend the wave front, causing sounds to be heard where they normally would not, or vice versa. Wind turbines are affected by wind shear. Vertical wind-speed profiles result in different wind speeds at the blades nearest to the ground level compared to those at the top of blade travel, and this in turn affects the turbine operation.” Heier, Siegfried (2005). Grid Integration of Wind Energy Conversion Systems. Chichester: John Wiley & Sons. pp. 45.

…..There are 8 woodlands in the project area; at least 4 are dominated by coniferous species which can amplify the sound created by operation of the turbines. “The most likely sources of wind-generated noise are interactions between wind and vegetation. A number of factors affect the noise generated by wind flowing over vegetation” http://www.windcows.com/files/WindTurbineNoiseIssues.pdf

…..Sections of the Snowy Ridge project area are clay and clay loam, the project area also contains sandy soils known as the Pontypool soils. It is unknown how the ground absorption factor was arrived at for the computer software program used in the simulated noise modelling. Attenuation coefficients can range from 2 db per cm for nodulous, loose soils to greater than 25 db per cm for finely divided soils and sand. The incorrect ground factor will result in a different noise interpretation.  The baseline noise study conducted at Receptor # 30 contains sandy soils.

…..The wind power level (dBA) at a wind speed of 10 m/s for the REpower MM92 turbine model is 104.2 dBA (95% rated capacity) at a hub height of 100 m. According to the Technical Guide, a supplement to O. Reg. 359/09, the setback from receptors of turbines that have an overall weighted sound power level (at 95% rated capacity) between 103-104 dBA are required to respect a setback of 600 m – not 550 m  which the proponent  has employed to site the wind turbines. http://www.ene.gov.on.ca/stdprodconsume/groups/lr/@ene/@resources/documents/resource/stdprod_088422.pdf

…. According to Figure 6-1 as well as the other figures in the Environmental Noise Impact report for Snowy Ridge, 9 receptors along Beers Road are marked including non-participating, participating and vacant lots.  The fire signs along Beers Road include: 308, 272, 241, 227,220,202,183,177,172,108,104,59,41, and 26 – 14 receptors….a difference of 5. Along Lifford Road from Beers Road to Hwy 35, the Noise Impact Assessment map lists a total of 8 receptors. Fire sign counts include the following – 320,313,303,298,294,260,243,235,230,213,200,176,167,152,153 and 137 for a total of 16 receptors….. a difference of 8The draft site plan mapshows the City of Kawartha Lakes work yard as being a vacant lot (Receptor # 25). Three receptors in the same vicinity of Receptor # R081 between Hwy 7A and Lifford Road are missing including address numbers 1283, 1287, and 1291. A vacant lot along Hwy 35 at the corner of Hwys 7A and Hwy 35 address number 1113 is not marked on the noise maps or draft site plan.  Two receptors along Pitt Road – residences constructed in 2003 are missing on the maps.

…..94 residences will be considered as “noise receptors” for Snowy Ridge, while 162 are considered noise receptors for Settlers Landing. Combined with WPD Sumac Ridge some 367 residences will be subject to noise over the next 20 years.

Because all three wind projects –the wpd Sumac Ridge as well as the two Zep(now Capstone) Settlers Landing and Snowy Ridge share the same study area within 5 km of each other the noise levels should be assessed as a cumulative number of 15 industrial wind turbines and a sound power level of 104.2dBA (all projects are using REPower MM92 model turbines) as per the Technical Guide to Renewable Energy Approval increasing the setback distances to between 700-850 m.

—  Non-participating receptors numbers: 2, 5 and 13 listed in the Sumac Ridge noise study are within 700 m of a turbine.  Non participating receptors numbers: 17, 20, 26, 28, 30, 42, 48, 63 and 85 noted in the Snowy Ridge receptor study are located within 700 m of a turbine..  Non participating receptors 13, 18, 21, 23, 24, 27, 31, 33, 34, 37, 40, 41, 44, 47, 49, 67, 70, 71, 72, 74, 84 and 86 are within 850 m of a turbine. Non participating receptors numbers 12 and 16 are within 850 m of a turbine for the Sumac Ridge project   The Settlers Landing project indicates that non-participating receptors 1, 2, 3, 4, 5, 6, 7, 8, 21, 22, 23, 32 and 33 fall within 700 m of a turbine.  Non participating receptors 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 24, 25, 26, 27, 28, 29, 30, 31, 34, 43 and 161 are within 850 m of a turbine.

…..The case Four map in the Noise Assessment Impact Report appears to indicate that at a distance of approximately 100 metres the audible noise produced by the substation will register at 40 dBA. There is no explanation or rationale in the noise report that explains and justifies this measurement especially since a transformer model had not been selected.

 

There are several inaccuracies in the mapping as well as changes from T5 to T 5Alt turbine and to the transformer sub station,all of which will affect the project and the studies. Many of the studies need to be redone.

1.Information provided at the interim public meetings as well as the final public meetings held in December 2012 and January 2013 stated that Scott Penton of Novus Consulting reviewed the noise data and found it to be accurate. The review Mr. Penton of Novus Consulting conducted had inaccurate information as T5 Alt was not included while the transformer substation location has changed since the calculations in the original maps presented to the public. Therefore his statement agreeing that all non participating receptors will be below 40dBA may not be accurate.

  1. “Collection of long term data is necessary to capture the variability of natural sounds. Since a change of 3 dBA is noticeable by a person of normal hearing engaged in an activity other than attentive listening. (Brüel & Kjær 2000). Analysis of several year-long datasets (2005) show that summer and winter natural ambient sounds are significantly different from each other, and that a minimum sampling period of 25 days in each of those two seasons are required.

http://www.faa.gov/about/office_org/headquarters_offices/arc/programs/grand_canyon_overflights/documentation/GCNPNaturalAmbientSiteSelectionAugust2005.pdf   Was this done for this project?  

3.The omission of a turbine and change to the transformer station indicates that all of the noise calculations in the noise assessment report as well as all of the maps are inaccurate

4.The cumulative noise calculations in the Environmental Noise Assessment Report are mislabelled. They are all marked Snowy Ridge and Settlers Landing. The cumulative noise report models indicate that these cumulative studies are for Snowy Ridge and the adjacent wpd Canada project Sumac Ridge. How can we be sure the studies are accurate?

  1. As many as 16 receptors have been omitted from the environmental noise impact report. This study needs to be redone to ensure all receptors have been taken into consideration.
  2. The Construction Report also states “As described in Section 4.2 above, the substations will be modeled based on a typical transformer noise spectrum, as the exact model has not been selected yet.”There are many transformers models available; all with variable noise emission output. Where a transformer is sited also creates variable noise spectrums How is it then possible for the audible noise levels produced at the substation at a distance of 100m to be 40dBA?

7.With the 2 other adjacent projects in such close proximity for a total of 15 turbines a minimum distance of 700 and 850m from receptors must be respected for this project.

There are enough inaccuracies to warrant a complete new measurement be taken for the whole project.

 

Other Noise and Health Issues

…..The Ontario Environmental Review Tribunal Decision, July 18, 2011 states:

“This case has successfully shown that the debate should not be simplified to one about whether wind turbines can cause harm to humans. The evidence presented to the Tribunal demonstrates that they can, if facilities are placed too close to residents. The debate has now evolved to one of degree.”

The tribunal also stated: “The evidence presented to the tribunal demonstrates that they can, if facilities are placed too close to residents.”

….-There have been several studies including peer review studies done on the impact that noise, indirect noise and infrasound has on human and animals living when Industrial wind power plants are improperly sited.

Some of those links follow:

Effects of industrial wind turbine noise on sleep and health. Noise Health [serial online] 2012 [cited 2012 Nov 2];14:237-43. (Peer reviewed) Noise & Health, September-October 2012, Volume 14:60, 237-43
Michael A Nissenbaum, Jeffery J Aramini, Christopher D Hanning

Wind Turbines and Proximity to Homes: The Impact of Wind Turbine Noise on Health
by Barbara J. Frey, BA MA and Peter J. Hadden, BSc, FRICS (January 2012)

A recent ongoing noise study being conducted by the University of Waterloo reveals that noise can lead to serious health issues..

University of Waterloo Wind Turbine Health Effects Poster
poster_cpaller_oct15.pdf Download File

On June 20th, 2013, the Haliburton Kawartha Pine Ridge District Board of Health which is responsible for the well-being of area residents passed a motion that input from residents is critical in the siting of industrial wind turbines. The motion also includes the need for increased set-backs applied to the cumulative number of turbines in a proposed area. There are two other proposed projects within the same area beside Snowy Ridge – Settlers Landing and Sumac Ridge

http://www.northumberlandview.ca/index.php?module=news&type=user&func=display&sid=23014#.UceUYqzfL-K

 

There have been many reports of health issues relating to the placement of Industrial Wind Turbines since the original reports provided by the Chief Medical Officer of Health stated there is no direct impact to human health. Citizens should not have to live with the health impacts created by Wind Turbines that are sited too close to their homes.

 

1.At the final Snowy Ridge public meetings, Dr. Ollson and Dr. Knopper from Intrinsik Environmental were brought in by the proponent to provide assurances that there are no adverse health impacts from wind power plants. According to the Intrinsik website Dr. Knopper and Dr. Ollsen “provide risk communication support for wind turbine projects, natural gas fired stations, energy-from-waste facilities, oil sands environmental assessments, refineries, pipelines, and coal power plants”.

Dr. Knopper was presented to the residents at the final public meeting as an expert on noise impacts of industrial wind turbines on human health. According to his profession profile posted on the Intrinsik Envrionmental website, Dr. Knopper has 12 years of experience in the field of toxicology with an emphasis on ecological risk assessment.”.. He is also an accomplished field biologist and has extensive experience working under diverse field conditions with a wide variety of species (e.g., amphibians, mammals (from hamsters to seals), and birds (e.g., terrestrial and marine)).

He is not a noise specialist or expert.

2.Why would two toxicologists be given more credibility by the MOE than Dr Nissenbaum a medical Doctor, Dr Hanning, a retired expert in Sleep Disorder Medicine or Dr Aramini a consultant and past Senior Epidemiologist with the Public Health Agency of Canada.

3.At a Public Information Meeting the VP Steven Simpson of Capstone the latest owner of the Snowy Ridge project stated that Capstone’s only wind project located in Port Burwell has never received any noise complaints. This is certainly contrary to reports by the media that noise being produced by the facility has resulted in complaints but that to date have remained unresolved

http://www.sunnewsnetwork.ca/sunnews/politics/archives/2013/01/20130109-163106.html

 

http://ontario-wind-resistance.org/2009/02/06/more-turbine-health-complaints-in-norfolk-county-ontario/

 

http://www.windturbinesyndrome.com/2009/my-entire-house-was-vibrating-along-with-all-the-contents-including-me-ontario-canada/

 

http://ruralgrubby.wordpress.com/blade-failure-in-port-burwell/

 

Infrasound

….. the MOE does not recognize that low frequency sounds are problematic creating adverse effects on human and wildlife populations, the wind industry organization CanWEA acknowledges that industrial wind turbines do produce infrasound.

 

A new study on the possible adverse effects of infrasound produced by industrial wind turbines was conducted in December 2012.

 

  1. Four acoustical consulting firms included: Channel Islands Acoustics (ChIA) has derived modest income from wind turbine development projects while Hessler Associates has derived significant income from wind turbine development projects. Rand Acoustics is almost exclusively retained by opponents of wind projects. Schomer and Associates have worked about equally for both proponents and opponents of wind turbine projects. The conclusion reached by all four consulting firms: “The four investigating firms are of the opinion that enough evidence and hypotheses have been given herein to classify LFN and infrasound as a serious issue” The summary report can be accessed in the following link:

http://docs.wind-watch.org/Shirley-LFN-infrasound.pdf

 

 

2.Dr. Alex N. Salt, Ph.D with Department of Otolaryngology Washington University School of Medicine St. Louis, Missouri, 63110, USA has written several articles about Industrial Wind Turbines and the negative effect of infrasound on people’s health  – he states 550 metre setbacks are insane

http://www.epaw.org/documents.php?lang=en&article=n14

 

In Section 4.5 (page 24) of the Design & Operation Report it is stated that  “A complaints and monitoring system will be set up as described in Section 6.3”  Section 6.3 indicates that a simple log will be kept. It is also stated that the project operator “will respond to all public inquiries’, but there is no mention of a complaint resolution process

3.If the MOE is unwilling to recognize the adverse effects of Infrasound then a more stringent complaints and monitoring system should be mandatory. Several experts have weighed in the serious issue of LFN and infrasound

 

Switching Station/ Transformer Station

 

.

…..Section 4.2 of the Construction Report indicates that “The substation contains a transformer that operates at a distribution voltage of 44 kV. The exact model has not been selected yet.”

The Construction Report also states “As described in Section 4.2 above, the substations will be modeled based on a typical transformer noise spectrum, as the exact model has not been selected yet.”

…..Setbacks for Associated Transformer Substations (from the technical guide for REA approvals)

Transformer substations that are part of a wind facility and are capable of operating at a nominal voltage of 50 kV or more require siting considerations to avoid impacts from transformer noise. To mitigate noise impacts transformers can be set back 1000 metres from the nearest noise receptor. An alternative setback of 500 metres is permitted if the transformer is surrounded by an acoustic barrier with a density of 20kg/m2. The acoustic barrier must break the line of sight from top of the transformer to the nearest noise receptor. As a further alternative, the proponent of a wind facility may opt to submit a noise study in accordance with the Ministry of the Environment’s 2008 “Noise Guidelines for Wind Farms” that covers the noise from the transformer. For the purpose of identifying noise receptors at Class 4 wind facilities that may be impacted by noise from transformer substations, these are subject to the same noise receptor rules discussed in Section 2.5 in respect of wind turbines.

-noise complaints from transformer noise emissions have been reported to the Ministry of the Environment as noted in this CBC news story (including MOE correspondence documents) http://www.cbc.ca/news/pdf/MOE%20Tomlinson%20email%20June%2029%202009%20detailing%20problems.pdf

….. Gassing from step-up transformers associated with industrial wind turbines is a new and growing problem posing a health risk to nearby residents. http://www.eng-tips.com/viewthread.cfm?qid=339981

…..Transformer fire causes spill in Sherman County –report dated November 29,2013

A transformer caught fire at the base of a Bigelow Canyon wind turbine over the weekend, spilling an estimated 600 gallons of transformer oil. A representative of the Oregon Department of Environmental Quality’s (DEQ) spills unit reported that PGE, the owner of the wind farm, reported the fire and hired SMF Environmental to clean up the spill. DEQ asked for a spill report identifying what happened, what actions were taken to clean up the site and to restore it to its pre-spill condition. No waterways were affected

The transformer “over-pressurized, released oil and caught fire,” said Dale Coyle, Bigelow Canyon site manager. “When we got here it was at a slow burn.”

http://www.thedalleschronicle.com/news/2013/nov/29/transformer-fire-causes-spill-sherman-county/

 

There are many issues that have not been addressed regarding the siting of the Transformer Station

  1. Noise complaints from transformer noise emissions have been reported to the Ministry of the Environment as noted in this CBC news story (including MOE correspondence documents) http://www.cbc.ca/news/pdf/MOE%20Tomlinson%20email%20June%2029%202009%20detailing%20problems.pdf .Proper setbacks need to be in place to ensure there are no noise impacts to residents.

2.Gassing, a new environmental hazard has been identified which could cause harmful health effects. There are several receptors too close to the transformer station, as noted in #4 below.

 

  1. Fires and spills caused by fires pose a huge health risk to the environment.

 

4.Receptor No. 048 is only 217.58 metres from the proposed step up transformer at Site 2. Receptor No. 044 is located   only 102.18 metres north of the substation. Receptor No.049 is located 192 m west from the substation and Receptor No. 047 is located northwest at 181.8 m away; all in the area where prevailing winds would direct gas emissions. There is nothing in any of the reports prepared for the proponent that satisfactorily address possible noise and air pollution as a result of construction of the substation and that may adversely affect the health and safety of the these close receptors. This transformer station is much too close to 4 of the receptors in the project.

 

Flicker  

…...The flicker report for Snowy Ridge dated July 12th, is labelled Snowy Ridge and Settlers Landing which is incorrect. The flicker shadow report does not include the Settlers Landing project.

….. the flicker effect caused by the strobe-like effect of shadows cast at certain times of the year by the turbines can impose stress and adverse health effects. There is no approved standard methodology for project developers to employ when introducing environmental and site specific data into shadow flicker assessments.

…..computer models used by the industry such as WindPro use an assumed but not defined “worst case scenario‟ approach. The simulation does not take into consideration factors such as wind speed, local terrain and historic meteorological patterns.   Windpro simulation does not take into account obstacles between the turbine and the receptor, such as trees or buildings. A review of computer modelling systems including Windpro found: “It is assumed in all of the models that the rotor yaw angle is set at 90° to the receptor to model maximum interference. In reality, the yaw of the turbine would vary with the wind direction; therefore the shadow impact would be variable.”

“Most turbines in use today are two or three bladed, constant speed types, producing shadow flicker rates in the range of 1-3 Hz. Variable speed turbines may produce a 2-6 Hz flicker rate. Therefore the shadow flicker from turbines has frequencies that could in the right conditions produce light flicker effects to susceptible persons.” (Page 93) http://www.decc.gov.uk/assets/decc/what%20we%20do/uk%20energy%20supply/energy%20mix/renewable%20energy/ored/1416-update-uk-shadow-flicker-evidence-base.pdf

 

 

….. “Shadow flicker should be limited to a maximum of 30 minutes per day. The laboratory study by the University of Kiel (Pohl et al 2000) noted that even a one-off exposure to 60 minute duration of shadows can cause stress reactions. For precaution, shading duration is therefore limited to 30 minutes per day.

…..According to the flicker report for Snowy Ridge, receptors R028, 063, 70, 72 and 86 will be exposed to flicker shadow over 30 minutes per day.  Receptor 017 may be exposed to flicker shadow 1 hour per day.

The Sprott project manager, Dave Eva responded to a query about the flicker effect as follows:

Based on local meteorological data this receptor is expected to receive closer to 25 hours per year spread over 85 days with a maximum exposure of one hour per day. This exposure occurs primarily in the mornings during winter months when the sun is low.”

 

-The reports prepared for the proponent state that in order to mitigate the flicker effect that “shutters or curtains be installed, physical barriers such as fences, sheds, walls, awning, patio shelters be constructed or vegetation planted.” Having to put up fences walls awnings etc. will change the vistas and landscape views presently enjoyed by the residents. Having to create visual barriers will dramatically reduce the enjoyment of their properties.

The report does not state who will be responsible for bearing the cost of these mitigation measures. If the proponent fails to mitigate the flicker effect, it is possible that the proponent and the approval agency could be made liable to cover such expenses.

 

-Figure 5-1 of the Shadow Flicker Report indicates that two provincial highways, Hwy 35 and Hwy 7A will be subject to flicker shadow.  Highway 35 could be subject to 30 to 50 hours per year; Highway 7A could be subject to as many has 20 to 30 hours per year. According to MTO traffic volume records from 2009,

http://www.raqsa.mto.gov.on.ca/techpubs/TrafficVolumes.nsf/fa027808647879788525708a004b5df8/f51986ea499a13b08525745f006dd30b/$FILE/Provincial%20Highways%20traffic%20Volumes%202009%20AADT%20Only.pdf,

Highway 7A between Cavan and the junction of Highway 35 sees an average daily vehicular traffic volume of 4500 vehicles, including many school buses. The stretch of 7.6 kms of Highway 35 and the junction at Highway 7A sees an average daily volume of 6300 vehicles per day. Both of these highway routes are more heavily used in the summer months since they are popular destination routes to cottage country. Highway 35, due to increased summer traffic volume is slated to be widened in the project area.

 

This could result in driver distraction. Driver distraction is one of the leading causes of accidents in Ontario. Driver distraction is a factor in about 4 million motor vehicle crashes in North America each year…84% of distracted-driving-related fatalities in the US were tied to the general classification of carelessness or inattentiveness (National Highway Traffic Safety Administration, 2009)… 80% of collisions and 65% of near crashes have some form of driver inattention as contributing factors (National Highway Traffic Safety Administration, 2010…Driver distraction is a factor in about 4 million motor vehicle crashes in North America each year…

http://distracteddriving.caa.ca/education/

 

…..There are two elementary schools that will be affected by the combination of the Snowy Ridge, Settlers Landing and Sumac Ridge. Grandview Public School and Rolling Hills Public School have a combined enrolment of 427 elementary grade students. There is also a daycare facility onsite at Rolling Hills Public School caring for children from 1.5 to 12 years of age.  According to the Snowy Ridge noise receptor report the two schools are located 1036 and 1159 metres from Turbine No. 1. The schools are situated between 1400 and 1500 metres away from Turbine No. 2. The flicker shadow report for the adjacent wpd Canada Sumac Ridge project indicates that two of the turbines for this project will cast strobing shadows across both schools. wpd Canada Turbine No. 1 is located 1447 metres and 1589 meters respectively from each school. If the wpd Canada turbine which is located 400 to 500 metres further away but in the same locale as Snowy Ridge Turbines Nos. 1 and 2 will create flicker shadow effect, then it is reasonable to assume that flicker shadow created by these turbines will also affect the schools.

….. there are school children that will be affected not only by the noise and flicker affected during school hours, but at home as well. There are children who attend the school who also reside in homes designated as noise and flicker shadow ‘receptors”. Not only will they be subjected to Flicker but also to infrasound. Several children with behavioural problems and/or learning difficulties attend these schools. There are at least 3 students who display a level of ASD (Autism Spectrum Disorders). Autistic children are peculiarly sensitive to noise.  Several students have medical conditions that can become exacerbated and dangerous under increased stress levels.

….. the flicker effect produced by industrial wind turbines has also been demonstrated to impact those suffering from Autism Spectrum Disorders (ASD). Studies conducted have suggested that people suffering from ASD experience a certain effect due to common fluorescent flicker. The flicker effect produced by industrial wind turbines as evidenced in this video http://youtu.be/MbIe0iUtelQ may affect children attending the schools located adjacent to the Sumac Ridge and Snowy Ridge projects

Flicker effects will have an inpact on those living in the project area:

1.The important flicker report was prepared by a temporary student

2.-According to the flicker report for Snowy Ridge, receptors R028, 063, 70, 72 and 86 will be exposed to flicker shadow over 30 minutes per day.  Receptor 017 may be exposed to flicker shadow 1 hour per day.As noted above the University of Kiel even one off exposure to 60 minute durations can cause stress reactions. Precaution should ensure that these receptors are not exposed to flicker shadow for extended periods.

3.Driver distraction due to flicker on a major highway could cause accidents resulting in injury or even death. The turbines need to be repositioned in order to avoid this potential result.  

4.Children in the nearby schools could be affected by the noise, infrasound and flicker from the industrial wind turbines. The students will also be impacted by noise and flicker from the nearby Sumac Ridge project. The turbines need to be repositioned in order to ensure the health and safety of the children. As many of these children also live in the project area they could also be exposed at home resulting in virtually 24 hour exposure.

  1. Why should residents have to create visual barriers to mitigate flicker,(install curtains and shutters, fences etc)resulting in the loss of enjoyment of their properties ?

 

 

Safety

….. page 30 of the Design & Operations Report – Emergency Response Plan, notes only ONE address as an emergency location – 59 Beers Road.

…..The project will be remotely monitored from the United States and/or Germany

-Two of the turbines are located in a different locale. They are located further along Hwy 7A between the Highway 7A and Lifford Road.  One of the participating receptors resides on Twigg Road.  There is no 911 number for participating landowner/receptor P005 situated along Twigg Road. Someone calling in an emergency and providing the 59 Beers Road address it is likely EMS personnel would be sent to the wrong location which could imperil the lives and safety of individuals.

…..Turbine fires can be caused by technical defects or mechanical/electrical malfunctions – usually gearbox failures. In many incidents, lightning has been the source of the fire. According to the Environment Canada Weather and Meteorology website the region where the Snowy Ridge project is to be located is listed as one of Canada’s lightning “hot spots”. http://www.ec.gc.ca/foudre-lightning/default.asp?lang=En&n=42ADA306-1

 

…..The Snowy Ridge project will be constructed within 8 woodlands. Worldwide, there are scores of documented cases of industrial wind turbines catching fire. To date about 220 wind turbine fires have been recorded. These incidents are only the ones that have been captured by the following two websites. As more industrial wind turbines are constructed, more fires occur. Unlike other existing wind installations across the province, the Snowy Ridge project is proposed for a geologic area with numerous valleys and hills that act as accelerants for wildfires.

http://www.caithnesswindfarms.co.uk/fullaccidents.pdf

http://turbinesonfire.org/

 

…..Industrial wind turbines require highly flammable lubricating agents.

…..The region is heavily forested. The ecologically significant Fleetwood Creek and Pigeon River watersheds are within the project area.  A devastating wildfire on the Moraine will affect the complex hydrologic system.

….. In 2011 a conference was held in Sweden to address specifically the problems of industrial wind turbines in cold weather climates including REpower MM92 turbine models that will be used in the Snowy Ridge project: http://www.winterwind.se/2011/programme.html Blade icing and blade throw continue to present serious problems. “…rotating turbine blades may propel ice fragments some distance from the turbine— up to several hundred meters if conditions are right. Falling ice may cause damage to structures and vehicles, and injury to site personnel and the general public..” (GE turbine manual)

….. According to the Property Line Impact Assessment it is stated that there is the possibility that the turbine might collapse. Structural failure is the failure of major components under conditions which components should be designed to withstand. This mainly concerns storm damage to turbines and tower collapse. However, poor quality control, lack of maintenance and component failure can also be responsible. Soils in the Snowy Ridge project area are prone to erosion and are considered to be unstable.

…..According to the Design & Operations Report prepared by the proponent, under Emergency Monitoring Plan and Contingency Measures (p.39), in event of fire the project manager will be contacted and 9-1-1 will be called. The project will be monitored from a remote location.

……an oil spill on the Moraine could cause irreversible harm to drinking water for which than a quarter million people in Ontario rely

 

There are several issues relating to fires ice throw and oil spills that could cause devastating harm to human health and the environment .

  1. Incorrect addresses could cause significant harm. No one from M.K. Ince, EFO, Windworks, Zep or Sprott Capstone have ever met with the City of Kawartha Lakes staff to discuss an emergency plan.

2.There is no road sign for Beers Road as road signs are continually stolen, therefore using the address of 59 Beers road could result in delays should any emergency arise.

  1. The region is heavily forested. The ecologically significant Fleetwood Creek and Pigeon River watersheds are within the project area.  A devastating wildfire on the Moraine will affect the complex hydrologic system.

4.There is one pumper truck at the Pontypool fire station, but the volunteer fire crew will not be able to extinguish the turbine fire; it must be left to burn out.  Fire fighters primary concern is extinguishing secondary fires caused by burning debris especially during windy conditions, storms or when the burning blades cannot be shut down and continue to spin uncontrollably at high speeds. 

In 2007, within a very short period of time, 125 acres of pasture and forest were burned along Ballyduff Road which is in close proximity to the Snowy Ridge project. This grass fire required fire crews from Ops, Lindsay, Omemee, Oakwood, Emily as well as from the nearby township of Cavan Monaghan to extinguish the wildfire. http://www.mykawartha.com/print/125116 There is a potential for great loss of residential, agricultural and commercial structures. There are three towns that could be placed in danger, Janetville, Pontypool and Bethany

5.An oil spill from a transformer fire as just happened in Oregon could be devastating on the Moraine and affect the drinking water for more than 250,000 people who rely on it. http://www.thedalleschronicle.com/news/2013/nov/29/transformer-fire-causes-spill-sherman-county/

6.The threat of post construction of ground water contamination including on the very sensitive Oak Ridges Moraine has not been considered in the application for approval.

7.The proponent has not indicated what, if any, responsibility will be borne in the case of a fire event.

  1. There is no evidence in the Snowy Ridge reports of a detailed workable protocol if ice throw occurs… all that is stated on page 40 of the Design and Operations report is: “Ensure that the project is operated in a manner that minimizes the risk of ice throw”. .

9.Turbine collapse could result in personal injury or loss of life.  The setback report prepared for the proponent indicates that a turbine is within 85 m of property line of a non-participating landowner-not in compliance with the 100m setback indicated in the technical guide for REA projects. There is no indication in the report that the non-participating receptor has been made aware that the potential of personal harm or death exists from the construction of this project.

Until all of these issues have been resolved with the City of Kawartha Lakes staff and emergency personnel, this project should not be allowed to proceed.

 

Air Transportation and Safety

…..three of the 259 airports and 102 heliports in Ontario use the airspace within the Snowy Ridge project daily-2 municipal airports, Peterborough and Lindsay (City of Kawartha Lakes) and one private airport at the Elmhirst resort. This is in addition to many private airstrips.

http://www.navcanada.ca/navcanada.asp?content=contentdefinitionfiles/publications/aeronauticalinfoproducts/publications/cfs/default.xml

…..The Peterborough airport uses include charters, cargo shipments and flight training. The Peterborough Airport has the longest runway between Ottawa and Toronto at 7000 ft.and is a full service airport http://www.peterborough.ca/Visiting/Airport.htm

…..with the recent expansion of the airport a 737 aircraft will be taking off from the Peterborough Airport. The October flight from Peterborough to New York’s Newark Airport will mark the first time a 737 has taken off from the municipal facility.

http://www.magic967.net/index.php?option=com_content&view=article&id=12778:a-second-737-flight-will-take-off-from-peterborough&catid=1:local-news&Itemid=77

 

…..The Peterborough airport has recently been expanded to accommodate 150 students for the Seneca College Flight Training School. .www.thepeterboroughexaminer.com/2012/09/13/city-planning-to-expand-building-at-Peterborough-airport-to-accommodate-seneca-colleges-flight-training-school

…..There are several flight based businesses including Angels of Flight Canada Inc., who transport for ill and injured persons worldwide. A flight training school W.M. Aeroflight for recreational, and private pilot licences. An executive class air charter service, Vector Air Ltd. for domestic and trans border for business execs. An Ultralight Flight School Aerostrike Aviation has operated since 1999 .   http://www.peterborough.ca/Visiting/Airport/Businesses___Services.htm

Flying Colours a global leader in aircraft completions and maintenance has recently expanded their operations at the airport. http://www.flyingcolourscorp.com/about2.html

-It is a very busy airport that uses the airspace over the Snowy Ridge project area.

 

-Lindsay Airport in the City of Kawartha Lakes also uses the airspace over the Snowy Ridge project area and accommodates 1000s of small aircraft annually. http://www.klma.ca/information.jsp

…..The Elmhirst resort on Rice Lake has its own airstrip http://www.elmhirst.ca/adventures/air/

…..ORNGE helicopters use the airspace where the Snowy Ridge project is located as a transportation route. –they fly directly over the site of the proposed Snowy Ridge project often at very low altitudes.

…… In July of 2012, a report was filed with the County of Peterborough seeking that a permanent air ambulance base of operations be set up at the Peterborough Airport

…..One private airstrip is within the proposed Snowy Ridge project area and another private airstrip borders the project area. Participant 006 (P006) has a private airstrip on the property. There is another private airfield located on Lifford Road on the delineated border of the Snowy Ridge project area.

 

…..Trenton Air Base A serious concern is the possible disastrous impact to the operations of Trenton Air Force base. A CF-17 transport plane crosses through or near the air space where turbines Nos. 3, 4 and 5 are to be constructed, on a daily basis. It flies at a very low height.  According to the Design and Operations report http://www.zeroemissionpeople.com/images/stories/projects/5%20–%20DRAFT%20Snowy%20Ridge%20Design%20and%20Operations%20Report%202012-11-02%20-%20App%20IV.pdf,  It was indicated in March of 2012 that it was unlikely that there would be any interference of concern with the Department of National Defence.

Radar and flight operations section of the DND stated If however, the layout were to move, please re-submit that proposal for another assessment using the assigned WTA number listed above WTA2033. http://www.ottawacitizen.com/technology/Wind+farms+creating+dead+zones+military+radar

 

The project should not be allowed to proceed as it could cause serious harm to the many planes in the light path to the Trenton Airbase and the Peterborough Airport and put putting passengers at great risk.  

  1. On a recent Sunday afternoon a local resident counted 6 planes going over the project area within a 1 hour time frame, many at a low altitude. The turbines could cause a serious accident to the many planes that cross the area.    

2.There is no indication that the proponent has resubmitted their proposal for another assessment to the DND since changes have been made to the several turbine and transformer station locations.

  1. There is no indication that a review has taken place by Nav Canada since an email sent to the proponent on April 4 2012 stated: “Please consider that the letter and file 11-4305 is now cancelled. Due to the changes in the locations of the turbines the file will have to be reviewed again as this site has impacts to our approaches at Peterborough airport. A new letter will be sent out once further review has been completed.”
  2. There is no indication in the application for approval that managers of the Kawartha Lakes Airport were contacted about the proposed placement of five industrial wind turbines within this well-used airspace.
  3. There is no evidence in the reports posted for public review that the proponent contacted ORNGE services to confirm travel routes.  

https://peterboroughcounty.civicweb.net/FileStorage/6123F10E4F604433A51544862E13F625-EMS%20Departmental%20Report%20-%20Permanent%20Air%20Ambulance%20.pdf

  1. There is no indication in any report that the residents with private airstrips have been contacted and that the function of the airstrips will not be compromised by the erection of five industrial wind turbines, or that the two turbines in close proximity to the private airstrips will not be affected.

 

Telecommunication and Radar

 

…..There are two communication towers in close proximity to several of the proposed wind turbines in Snowy Ridge. There are indications through various agencies in the Communication Impact Assessment Report that turbine locations changed several times since October 2011.

….. Correspondence dated March 30, 2012 with Rogers indicates that ‘the layout of the wind park has changed” Correspondence dated April 3, 2012 indicates that locations for Turbines Nos. 3 and 5 were changed.  Correspondence dated August 14th, 2012 indicates that the location of Turbine # 4 has shifted. Correspondence as late as October 4th, 2012 states: ‘Further to our correspondence dated August 8, 2012, please be advised that the layout of the proposed Snowy Ridge Wind farm has since been revised to include an additional turbine”. On page 4 Section 2.4 of the Communications Impact Assessment dated November 2, 2012, it states the ‘project has been revised to consider an alternative location for Turbine 1”.

…..According to correspondence from Rogers Communications April 4 2012 there is an indication

that T4 needs to move 45-50m for microwave clearance and that T4 and T5 are expected to have a negative effect.

-April 4 email from M. Vujosevic, Rogers Communications requests a conference call to discuss steps to mitigate the potential impact of the Rogers’ installations. Response from Dan Albano Wind Works Power requests maps with precise widths of Rogers signals relevant to current turbine locations “because we are so constrained by inflexible setbacks”

…..communication from Rogers April 4 2012 states

Dan,

I can do that for microwave, for which Ingo said is possible to move turbine T4 further away for about 45-50m, which will be enough for clearance. However, regarding our cellular coverage, the turbines T4 and especially T5 are expected to have negative impact to TM57A (T4 is ~ 400m away and T5 less than 200m away from our cell site).

Thanks,

m     No further correspondence is indicated until October 12 2013 when the proponent advises that there may be a change to the location of T5.Some correspondence from David Barrie refers to Settlers Landing Wind Park however coordinates indicated in the correspondence are not available to check if indeed he is referring to Snowy Ridge or Settlers Landing.

-Adin Switzer of Military Air defence stated in his letter that:   “ Finally, the concurrence offered in this email extends only to the subject projects and current proponent. Should the project or any part of it be altered, or be sold to another developer, this office must be notified and we reserve the right to reassess the project

 

There are still many issues that have not been resolved with Rogers and Military Air Defence. Approval must not be given to this project until these issues are resolved.

  1. 1. It is difficult to determine how many changes have been made to the locations of the turbines and if the cell company is aware of the various changes made. There is no confirmation from Rogers that the various changes to the turbines locations are acceptable to them.

2.Correspondence from Rogers would indicate there is an issue with the location of the turbines 4 and 5 however there is no evidence that the issue has been resolved.  

3.There is no indication that Bell Mobility has confirmed the turbine locations.

4.There is no indication that RCMP has confirmed the change of layout sent by proponent October 4th

5.There is no indication that Military air defence have been notified of the changes in ownership as per the correspondence dated March 13 2012 nor is there any evidence that confirmation has been received to the correspondence advising of the changes in turbine location and the addition of a turbine.

6.. The public was not made aware during the second public meeting that there are plans for an “additional” met tower. There is no indication in any reports where the “additional” met tower will be located. This could pose an aviation hazard . The existing met tower toppled during the ice storm on April 12th, 2013. It has not yet been replaced. On several maps prepared for ZEP, but not all, the met tower that fell over has been recorded as being a ‘permanent’ met tower.

 

Environmental Impact Assessment

 

…..Section 4.3 and Table 4-5 of the site investigation report lists wildlife habitats carried forward as a result of a review or records and site investigations. It states that only two candidate bat maternity roosts were found and they were outside the 120 m setback and thus was not carried forward to an EIS.

……The woodland on the property of Receptor 28 is overlapped by the mandatory setback for Turbine # 1. Although permission was not granted by the non-participating landowner to assess the property, the woodland is clearly visible and along the perimeter where Turbine # 1 is proposed to be constructed, snag cavity trees along that perimeter could have been easily recorded.

 

…..Section 4.3 under SP – Seeps and Springs indicates that none were found. There are three springs that are clearly marked as part of a tile drainage project all within 120 metres of project components for the construction of Turbines Numbers 3, 4 and 5.

 

….. Section 4.3 under BOH-Bald Eagle/Osprey it states that suitable habitat was not found yet the field notes indicate the presence of Osprey in the project area.

….. Under ABH – Amphibian Breeding Habitat discounts breeding habitat for amphibians yet field notes indicate the presence of amphibians including the species at risk Western Chorus frog.

…… Section OCBH (Open Country Breeding Bird Habitat) indicates that no candidate habitat was found in the project area. There is such habitat north of the location of Turbine # 3 and in July 2013 species at risk bobolinks were recorded on the site.

-Table 4.5 TWA – Turtle Wintering Habitat, states that ‘suitable candidate overwintering habitat does not exist”, indicating that turtles ‘require permanent standing water with sufficient dissolved oxygen and at a depth that does not freeze entirely during the winter months”. Terrestrial turtles pass the winter underground, either in burrows that they excavate or that are preformed.

Snapping turtles overwinter in shallow water, and may either sit on the bottom, or shelter themselves by digging into the mud or staying under debris or overhanging banks. Many common snapping turtles may congregate in one area to overwinter. http://www.dnr.state.mn.us/rsg/profile.html?action=elementDetail&selectedElement=ARAAB01010

http://www.mnr.gov.on.ca/en/Business/Species/2ColumnSubPage/MNR_SAR_WOOD_TRTL_EN.html

 

…..CBN – Colonial Bird Nesting Sites indicate that there are no steep slopes to be found in the project area. While not a large colonial site such as to be found along the Great Lakes there is a steep slope clearly evident on Google Earth maps within 120 metres of the proposed site of the substation, access roads and cable trenching. It may serve as breeding habitat for bank swallows or bat hibernacula. There is no evidence that this sandy slope was assessed.

 

The consultants’ surveys were relatively superficial, characterized by short visits and short observation periods that failed to identify much of the flora and fauna present in the area including species at risk already known to local residents.

It is apparent that many habitat were overlooked in the project area. A more stringent reassessment is necessary in view of the presence of Osprey, Western Chorus frog and Bobolinks.

It has been assumed that suitable overwintering habitat does not exist for turtles., however as noted above there are several areas that could in fact be wintering habitat for turtles.

An independent avian bird survey conducted in 2014 revealed three species at risk birds breeding within 120 m of the sites for three turbines although the proponent claims there is no candidate habitat

The sandy slope located within 120 metres of the proposed substation must be reassessed before any access is allowed for roads,or cable trenching as it may serve as a breeding habitat for bank swallows or bat hibernacula.

Species at Risk

 

…..field notes taken during the Natural Site Investigation revealed that the western Chorus frog and Eastern Meadowlark were spotted in the project area. The appendix reveals that species at risk hart’s Tongue Fern (Asplenium scolopendrium) is present in woodland No.6 but woodland No. 6 does not appear on the site investigation Natural Heritage Features Map – figure 4-5. Local sources indicate that the Eastern hog-nosed snake habitat is located within 120 metres of the project components.

…..The records review report indicates that only one rare species is identified as being in the project area; long stalked panic grass but further search identified black tern green-winged darner, azure bluet, stiff gentian, hooded warbler and Braun’s holly fern as possibly being in the area however, there is no mention of searching for the azure bluet (Enallagna aspersum).

-MNR correspondence to Ingo Stuckman the CEO of Energy Farming Ontario dated December 10th, 2010 states: “A review of our known data records indicate that Snapping Turtle, Butternut and Bobolink are known to occur in the general area… Please note the habitat of Loggerhead Shrike is protected under the ESA, 2007”.

…… According to the MNR Significant Wildlife Habitat Technical Guide http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@fw/documents/document/mnr_e001285.pdf

“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.”

 

Loggerhead Shrike

…..As previously noted correspondence provided by the MNR species at risk biologist stated

“Please note the habitat of Loggerhead Shrike is protected under the ESA, 2007”. Issuing that statement indicates a possibility that that critically endangered Loggerhead Shrike (Lanius ludovicianus) either inhabits or uses the project area as a flyway to the Carden Plain.Information received from Wildlife Preservation Canada, the agency involved in the loggerhead shrike recovery program indicates the exact migration route of the loggerhead shrike is unclear, but all three projects are in the Carden core area.

.….Local avian experts acknowledge that the area encompassing the proposed sites for Sumac Ridge, Snowy Ridge and Settlers Landing have been known to be a loggerhead migration route for at least 20 years.

Some residents indicated to a Councillor for Cof KL that the area seemed to be part of the northern route probably to the Carden Plain. It was also mentioned that mice were found place on thorny branches, a characteristic of the shrike.MK Ince staff indicate in field notes a presence of hawthorn and buckthorn trees, along several hedgerows in the project area, often favoured by loggerhead shrikes.

…..Former residents where Receptor #31 is located for Sumac Ridge, which is adjacent to the Snowy Ridge project reported that loggerhead shrikes were present on their property. Receptor #31 is located 785 metres from T2. They apparently did not inform the MNR in fear of being unable to do anything with their property.

 

 

The Natural Heritage Site Investigation Assessment Report is not complete as there was no further discussion regarding species at risk. Further information needs to be provided. For example :Breeding bobolinks within 120 metres of the site of Turbine # 3 were registered with the MNR in the summer of 2013.

 

NHIC biodiversity Explorer is no longer in existence as of July 2013, therefore the list of species at risk listed in the records review of species at risk cannot be verified in the Records Review

 

A conservation land agreement is being negotiated with Kawartha Land Trust and one of the landowners of property adjacent to the Snowy Ridge project. As part of that agreement, the Trust has advised the property owners that the conservation agreement will indicate species at risk bobolinks, Eastern meadowlarks and barn swallows must be accommodated. There is no indication that the proponent met with these property owners or reviewed the natural heritage assessments for these lands.

 

There are several species at risk identified in the area however there is no indication of what mitigation measures will be taken to protect these species.

The MNR correspondence to Mr. Stuckman would indicate there is a possibility of Loggerhead shrikes in the area “ Please note the habitat of Loggerhead Shrike is protected under the ESA, 2007”. Further investigation needs to take place. Only 22 pairs of loggerhead shrikes were recorded in 2010 and 2011; 21 in 2012. To lose even ONE loggerhead shrike could mean extirpation of the species from Ontario and aid in their extinction. This would indicate that further investigation should be undertaken for their presence.

 

Even though the MNR Significant Wildlife Habitat Technical Guide suggests local citizens such as hunters anglers,trappers,etc are aware of seasonal wildlife there was no indications that anyone was contacted regarding information about local species.

 

The bird survey area for the Snowy Ridge project is listed as being 17PJ88. According to the Breeding Bird Atlas of Ontario, the matching UTM coordinates for this square are 680000 easting by 4880000 northing. When these coordinates are plugged into Google maps… the location appears in the Long Sault Conservation area a location 25 kilometres southwest of the project area.

An independent avian bird survey conducted in 2014 revealed three species at risk birds breeding within 120 m of the sites for three turbines although the proponent claims there is no candidate habitat

 

 

Oak Ridges Moraine

…..The Plan states that transportation, infrastructure and other utility works will not be approved in certain areas of the moraine unless the need for the project has been demonstrated and there is no reasonable alternative.” http://www.ecoissues.ca/index.php/Waiting_for_a_Change:_The_Oak_Ridges_Moraine_Conservation_Plan

……The REA Technical Guide – specifically section 9.3 on p. 132, states:

“Applicants for a REA are encouraged to refer to the O. Reg. 140/02 made under the Oak Ridges Moraine Conservation Plan Act and to consult with local municipalities and conservation authorities who have additional experience interpreting the plan as it relates to the project location.”

…...A wooded section of the Oak Ridges Moraine will be cleared to accommodate the switching /transformer station as well as access roads. Construction in the form of trenching for cables will also cross sections of the Moraine. Page 10 of the Design & Operations Report in Section 2.4 it states: “A small portion (near the substation and associated cabling) lies within the Countryside portion of the ORMCP area. The majority of the project lies outside the area subject of the ORMCP”. However, in Section 5.4.5.4 on page 55 of the same report it states: “The project will be constructed in an area managed under the Oak Ridges Moraine Conservation plan (ORMCP). The majority of the project location lies within the Countryside portion of the ORMCP area with a small segment of cabling within the ‘Natural Linkage’ area. A small portion of cabling lies outside of the area subject to the ORMCP”.

 

……On May 17th 2012, the Board of the Ganaraska Region Conservation Authority passed a resolution seeking a moratorium on industrial wind developments on the Moraine until full environmental assessments are made a mandatory requirement as part of O. Reg 359/09.  On September 27th, 2012, the board of the Kawartha Conservation Authority also adopted a motion with a special emphasis on industrial wind projects stating full environmental assessments must be made mandatory for renewable energy projects.

-According to the ORMCP plan allowable uses for sites designated ‘Countryside’  include:The following uses are permitted with respect to land in Countryside Areas, subject to Parts III and IV:

Transportation, infrastructure, and utilities as described in section 41.

  1. (1) Transportation, infrastructure and utilities uses include,

(a) public highways;

(b) transit lines, railways and related facilities;

(c) gas and oil pipelines;

(d) sewage and water service systems and lines and stormwater management

facilities;

(e) power transmission lines;

(f) telecommunications lines and facilities, including broadcasting towers

Power transmission lines are not the same thing as an energy generating power plant which the Snowy Ridge project is. Nowhere is it stated in the ORMCP that power plants or components other than transmission lines are allowed to be constructed on the Moraine.

 

 

This project does not follow the intent of the Oak Ridges Moraine Plan

 

On page 10 of the Design & Operations Report and restated in several other sections of several other reports is the following:

“The Green Energy Act exempts renewable energy projects from the restrictions of the ORMCP.” This statement is incorrect -According to page 98 of the Technical Guide for Renewal Energy Project Approvals: “ 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.”

The Plan states that transportation, infrastructure and other utility works will not be approved in certain areas of the moraine unless the need for the project has been demonstrated and there is no reasonable alternative.”There is no indication that the proponent has searched for a “reasonable alternative”

 

 

According to the Government of Ontario (a) protecting the ecological and hydrological integrity of the Oak Ridges Moraine Area; (b) ensuring that only land and resource uses that maintain, improve or restore the ecological and hydrological functions of the Oak Ridges Moraine Area are permitted. Building an industrial power plant will not improve or restore the ecological and hydrological functions of the Oak Ridge Moraine.

Even though the technical guide suggest consultation with the Municipality regarding the Moraine there is no indication that the proponent has had any discussions with the Municipality.  

There are two additional proposed projects adjacent to the Snowy Ridge project – Settlers Landing and Sumac Ridge. Both will also be built on the Oak Ridges Moraine.   Allowing the construction of power generating plants on the ecologically sensitive Oak Ridges Moraine will set a dangerous precedent.

The complex surface and ground water structure of the Moraine dictates that full environmental studies including hydrogeological studies must be made mandatory.

The project may result in serious and irreparable harm and thus should not be approved.  All of these projects are in violation of the City of Kawartha Lakes Official Plan which includes sections specifically intended to protect the Moraine.

 

Avian Impact Assessment

…..Page 21 of the Draft Natural Heritage Records Review Report indicates that the monitoring program which saw 53 species of migratory birds during spring migration and 52 different breeding species dates to 2008 – predating the Green Energy Act of 2009. At the time the project was part of the EFO study area. That large area has now divided into three separate projects, Sumac Ridge, Snowy Ridge and Settlers Landing, encompassing thousands of acres.

…..The project area is part of the Atlantic Flyway migration route with migratory birds taking advantage of the diverse terrain of the Snowy Ridge project area during their travels, which as previously indicated may use this region as a flyway to the Carden Plain, rated among the top 5 birding locations in Ontario and among the top 200 in the world.

….. The Fleetwood Creek Conservation area found just south of the Snowy Ridge project area is also noted as one of the top 10 local birding sites.  Kawartha Conservation Authority has a monitoring program dedicated to assessing species and biodiversity within its venue and watershed.

http://www.kawarthaconservation.com/projects_services/watershed_monitoring/natural_heritage/species.html

-Species being monitored include vulnerable avian populations including 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. Local reports indicate that the red-headed woodpecker has been consistently observed in the project area over the last three years, golden winged warblers are present in the site. On June 19th, 2011, an independent avian survey of the Snowy Ridge project area specifically where Turbines Nos. 3, 4 and 5 are to be located in the Beers/Twigg Road area was undertaken by several birdwatchers; several were not residents of the area. The project area was divided into sections. According to Environment Canada it was a clear day, low temperature of 8 degrees C. Rising to 25 degrees with a dewpoint of 7.4 degrees C., calm winds and a humidity level of 96%. The bird survey for the area where turbines numbers 3,4, and 5 for the Snowy Ridge project revealed the following species on site: mourning warbler, house wren, mourning dove, red-eyed vireo (abundant numbers) , Baltimore oriole, common yellowthroat, song sparrow, Eastern peewee, common grackle, ovenbird, American robin, American crow, yellow-bellied sapsucker, magnolia warbler, cedar waxwing, blue-headed vireo, downy woodpecker, hairy woodpecker, flicker, least flycatcher, grasshopper sparrow, chipping sparrow, cat bird, brown thrasher, blue jay, savannah sparrow, killdeer, red-headed woodpecker, black-capped chickadee, kingbird, vesper sparrow, song sparrow, goldfinch, red-breasted grosbeak, red-wing blackbird, great crested flycatcher, tree swallow, turkey vulture, cardinal and bobolink.  The notes indicate that that area contained ‘excellent habitat’ for grassland birds in particular. Nests were spotted in the hedgerows. One of the most productive sighting areas was along the unassumed hedgerow section of Twigg Road that is only partially passable by vehicle. This section lies immediately north of Turbines, 3, 4 and 5.Species at risk birds spotted in the Snowy Ridge project include red headed woodpecker, hooded warbler, Canada warbler, golden winged warbler and bobolinks.

…..In 2013, bobolinks were recorded nesting within 100 metres of the proposed site of Turbine #3. This sighting was reported to the MNR. The Canada warbler is known to inhabit the surrounding lowlands in the project area, while hooded warbler populations have been increasing in the Pontypool area and have been observed in the Snowy Ridge project area

– The handwritten survey notes (ELC report polygons one and two – 11/05/27) by staff of M.K. Ince note that the species at risk, the Eastern meadlowlark was also spotted in two locations.

 

…..M.K. Ince the consulting firm that conducted the avian impact assessment studies for the Snowy Ridge project indicate avian studies are summarized in the Ballyduff Wind Farm preconstruction Avian Baseline Survey and Risk Assessment Report Draft. As these documents were not included in the draft documents provided to the public for the 60 day public review what these surveys/studies consist of and include are unknown to members of the public. Multiple requests were made of Zero Emission People to make public the Ballyduff Wind Farm Preconstruction Avian Baseline Survey and Risk Assessment Report Draft. October of 2013, project manager Dave Eva in an email stated that this report would not be made available to the public, even though it is referred to as an important tool in Natural Heritage Assessments as part of the application for approval. Mr. Eva indicated that this critical avian survey would also NOT be made available to the MOE.

This report contains important information that must be made available to the public and to the Ministry of the Environment .

There is nothing in the EIS that addresses the possibility that several or all components of this industrial project could have a negative impact on several at risk avian species.

In just one day “birders” noted about 50 avian species in the Snowy Ridge project area including several species at risk.

There is no list of bird species in the Snowy Ridge project to be found in any of the natural heritage reports provided. This is unsatisfactory and further investigation must be undertaken as there is nothing in the EIS that addresses the possibility that several or all components could have a negative impact on several at risk avian species.

Turbine blades that each sweep 6720 square metres and can rotate at a speed of 72.6 mps will imperil

grassland species.

 

 

Winter Raptor Survey

……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.

….. page 5 under section 3 of Methodology and Significance as part of the Natural Heritage Evaluation of Significance Report – two hour surveys were conducted on January 8th, February 13th and March 19th of 2009, before the passage of the Green Energy Act of 2009 which occurred on May 14th, 2009 and received assent on September 24th, 2009. This survey makes reference to the 2008 Ballyduff Wind Farm Preconstruction Baseline Survey and Risk Assessment as a base guideline. This Ballyduff baseline survey covered the original entire project area now playing host to 3 wind projects, Snowy Ridge, Settlers Landing and Sumac Ridge. It appears that the site investigation may have covered the entire region and was not specific to the Snowy Ridge project area. According to one of the M.K. Ince reps at one of the public meetings for Snowy Ridge they did drive around in a car in the winter of 2011 to see if there were any raptors.

….. The Natural Heritage Site Investigation Report (p. 34) indicates that there is no candidate habitat identified as all fields within the project location include row cropping, pasture and hayfields. According to most field guides for winter raptor sites, agricultural fields in combination with several contiguous woodlands make for ideal winter sites.

– The site investigation was conducted by Tim Brophy. . There is no reference to Mr. Brophy anywhere else in any of the natural heritage assessment reports and there is no indication as to the Mr. Brophy’s credentials and his experience in identifying and monitoring winter raptor grounds.

-The Natural Heritage Site Investigation Report (p. 34) indicates that there is no candidate habitat identified as all fields within the project location include row cropping, pasture and hayfields. 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

-While a raptor wintering area was not carried over to an Evaluation Of Significance, local birdwatchers have recorded Red Tailed Hawk, Sharp Shinned Hawk Coopers Hawk and Northern Goshawk have all been overwintering in the Snowy Ridge Project area.

 

….. There have been winter influxes of raptors such as the great grey owl and this winter the snowy owl. Record numbers of barred owls have been spotted in the area by birdwatchers. One of the handwritten surveys by a rep of M.K. Ince indicates the presence of lark buntings in the project area. Also, in winter months in search of food sources, snow buntings migrate in large numbers to parts of southern Ontario. In the area of Millbrook, flocks of snow buntings can be found. The Snowy Ridge project area is frequented by these flocks.  The open fields in several areas make this region an ideal region for foraging.

…… Ospreys breed in forage in the project area. In the field notes for Snowy Ridge dated June 11th, 2010, it is noted that three Ospreys were observed perched on one of the two communication towers in the project area along Beers Road. These may be the same ospreys that have a nest in the nearby proposed Settlers Landing project. The communication towers are within 300 and 500 m respectively of Turbine # 4. Turbines Numbers # 3 and 5 are also in close proximity. Local residents have spotted osprey in the Snowy Ridge project area carrying fish across in a diagonal northwesterly direction during the summer of 2013. This flight path crosses the path of Turbines # 3, 4 and 5.

……A stick nest RN019c) was identified within ‘0 metres’ of Turbine Alt. No. 5 in a ‘very large basswood tree’.  Stick nest locations were searched on April 14, 2011. There is no indication that the stick nest site was resurveyed in 2012.  The report dismisses the nest as being that of crows’. This determination was made due to the presence of crows in the vicinity.  There is no photo of the nest supplied in the application for approval for independent confirmation. Field notes dated May 26th, 2011, indicate the presence of a red-tailed hawk in the area. According to raptor expert, Tim Dyson, a red-tail hawk nest can be mistaken for a crow’s nest.

As indicated in the final public meetings of January 10th and 11th of 2013, Turbine No, 5 will not be implemented – instead Turbine Alt. No 5 will be which would put any bird using the stick nest within harm’s way of Turbine 5Alt.

….. “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 may be chilled, or older chicks may tumble out. Raccoons, fishers, and black bears may follow human trails and eat eggs or chicks. Hawk eggs are also eaten by ravens, and adults and chicks may be killed by great horned owls that have been attracted to the site by noise… page 9 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

….. Turkey Vultures are present in the Snowy Ridge project area and do roost in trees along the unopened Twigg Road .

 

 

One drive by is not adequate to arrive at a conclusive result as to the number of overwintering raptors. A survey was conducted back in 2008 before the green energy act was passed and before the O.reg 359/09 was implemented and before the placement of the turbines was known. It was conducted for the entire region which now plays host to three separate projects. This is not suffient and a further study must be undertaken using the MNR guidelines.

Further information needs to be provided about the individual (Tim Brophy) that conducted the site investigation as there is no reference to Mr. Brophy in any of the Natural Heritage reports as to his credentials and experience.

The EOS was not conducted therefore there is not a statement of a strategic plan to determine how deaths or injuries will be avoided.

The presence of a red tailed hawk was confirmed in the NHA of May 26 2011.The adjacent Sumac Ridge also confirms the presence of the red tailed hawk that overwinter in the area. The Kawartha Conservation Authority species breeding monitoring lists include 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.

Local birdwatchers have recorded the Red Tailed Hawk, Sharp Shinned Hawk, Coopers Hawk and Northern Goshawk.

Repeated requests for the avian baseline survey have been denied by the proponent.  

As it has now been determined that T5Alt will now be the location of the turbine, and as a stick nest

(RN019C) was located at 0 metres from T5Alt a new study needs to be conducted.

 

 

Animal Movement Corridors

…..The Site investigation report indicated that animal movement corridors were not carried to a site investigation, however in correspondence with the Ministry of Natural Resources it is indicated that there are several areas of deer concentration within the study area.

…..The Records Review report on page 23 indicates that there is a deer yard within 140 m of the project. Several deer trails can be found in the project area. The unopened section of Twigg Road is used by deer and one can find many deer tracks along this stretch yet there is no indication in the Environmental Impact Assessment report that a search, identification and monitoring of deer movement routes and corridors was conducted.

…..The substation which is to be located in an area bounded by a woodland and which acts as a conduit to the deer yard, will be fenced. Fencing will interfere with the trail route. The Snowy Ridge project area also connects to a movement corridor southwards towards Fleetwood Conservation Area and where the wpd Canada Sumac Ridge project is proposed

…..A fox den was spotted in a culvert within 120 m of the access road and switching station in the spring of 2013.

There are many studies that indicate that wildlife are even more affected than humans by the infrasound and vibration of Industrial wind Turbines however there is no evidence in the reports of any mitigation.

There is evidence of animal movement corridors throughout the project area. The configuration and construction of the turbines will place in peril these corridors. Deer tracks were found all along Twigg Road.  Further investigation for other wildlife animals including the fox den noted within 120 m of the proposed access road is required.

Amphibian Survey

…..The cover letter dated October 26, 2012 to Ingo Stuckmann at WindWorks Power Corp which presents the draft copy of the Natural Heritage Site Investigation Report for the Snowy Ridge wind project states, “It reflects the finalized layout for the project as of October 2011”.however correspondence with various agencies in the Communication Impact Assessment Report indicates that turbine locations have changed several times since October 2011.

…..According to the Natural Heritage Site Investigation (p. 30) “no candidate amphibian breeding habitat “was identified. Yet, on page 32, two sites, one within 82 m of the blade swept area of Turbine # 1 and another site 118 m south of the proposed road to be built to gain access to the site of Turbine # 3 were identified.  Note: the potential amphibian breeding site near Turbine # 3 has not been identified in the Water Assessment Report. There is no indication in any of the reports or on any of the maps as to the size and depth of this body of water or its hydrologic connection to the surrounding area.

…..The Oak Ridges Moraine Wetland WE01 which is within 120 m of components of the transmission station was dismissed as not providing open water and thus not suitable breeding habitat for amphibians. Yet, according to Google satellite maps, this .03 hectare, a 3229 square foot wetland is clearly identified as carrying standing open water, and as such could prove to be a viable breeding habitat for species of amphibians.  According to local residents, WE01 is a small gravel pit that was once used by the MTO to supply gravel for Highway 7A. They advise that this gravel pit/wetland fills with water in the spring which lasts late into the summer months. According to local information, this body of water plays not only host to amphibians, it is also provides habitat for the endangered hog nosed snake.

 

…..Field notes indicate that a cedar swamp of unknown dimensions was located on the property of 32 Twigg Road as well as a spring-fed pond that overflows into a stream. There are also indications of seepage areas in the field notes but no indication in relation to components of Turbines Nos. 1 and 2 where these natural features exist.  Field notes dated May 26th, 2011 indicate that frogs could be heard. The physical description of the features within the brief field notes suggest that this is a habitat that would support all manner of herpetofauna.

 

…..Even though the NHSI report stated there was no amphibian candidate sites located, the field notes contain 4 NAD UTM co-ordinates for Snowy Ridge and Toad Surveys. This can be found along with UTM coordinates for unrelated projects on the reverse side of Field Notes Sept 8, 2011 page 2 of 2. Furthermore, it appears 7 amphibian surveys were conducted as indicated as part of the handwritten field notes section. However, the UTM coordinates do NOT match up with the UTM coordinates given for the Snowy Ridge Frog and Toad surveys.

 

…..most confusing is the Snowy Ridge Amphibian survey map dated 11/05/26 carries the following UTM coordinates on the back – 557836 Easting 4907526 Northing as well as 557486 Easting 4907123 Northing . These coordinates indicate an area known as the 4th Line over in Grey Highlands Township, nowhere near the project in Manvers, although the same proponents own the Grey Highlands project.

 

…..The amphibian surveys were conducted at the least productive time and date for a period of 5 minutes a piece during the midmornings of May 26, 2011 and June 13, 2011. It is not surprising that the majority of the surveys state ‘no frogs/toads calling’. Ttwo of the surveys however indicate the presence of Western Chorus Frogs – a species at risk.  It is indicated on the May 26th visit a short search was undertaken for frogs near the location of Turbines 3, 4 and 5 but the area is not specified and, there is no indication on any of the maps, what this water feature is. There is a pond located within 120 metres of the site of Turbine # 3 that is visible on Google Earth but is not marked on the Natural Heritage Assessment maps.

….. Receptor No. 28, the property owner adjacent to the site of Turbines Nos. 1 and 2, has indicated there are many vernal pools formed on this property and there are literally hundreds of frogs.. ..so many in fact that the property owner had to install a barrier to prevent them from entering one of the buildings. The MK Ince survey indicated there was only a handful in that specific area – less than 10.

It is apparent that inadequate surveys were conducted. The turbine locations have changed several times with many of the studies conducted prior to these changes. New studies need to be conducted to ensure accuracy. It is difficult to determine if the surveys were conducted in the proper area as the UTM coordinates were incorrect and indicated an area in Grey Highlands not Manvers. Note: Zero Emission People also have a potential project in Grey Highland

It is well known that amphibians are particularly sensitive to noise disturbance. It is quite likely that the noise disruption caused by wind turbines would result in abandonment by this part of the system’s population. The normally referred to 40-50 db is the noise at a point of reception usually 300 to 600 metres away from the turbine—well above the normal background noise in this exceedingly quiet area). But the “noise at source” from modern turbines is usually about 100 db. Clearly any animals in close proximity to the turbines may encounter db levels much higher than 40-50 db.” http://www.gwag.ca/media/pdf/Arran_Lake_REPORT.pdf

Since the western chorus frogs are the first to be heard each spring, a survey should have been conducted in March or April, not May & June. Western chorus frogs begin breeding in March and April. Females attach clumps of up to 100 eggs to vegetation. The eggs hatch within 18 days, depending on water temperature. The tadpoles turn into frogs within 90 days after hatching.

http://www.naturewatch.ca/english/frogwatch/species_details.asp?species=22

 

http://www.habitatproject.org/webdocs/frogs/FrogSurveyProtocol.pdf

There are several wetlands in the area which are ideal for breeding yet were not included in the studies.

.

 

Salamander Survey

 

…..one of the handwritten field notes dated May 16, 2011, there is a note to ask ‘Kelly’ about salamander surveys. The field note goes on to say: “haven’t seen salamanders on prop”. One does not find salamanders in May during a simple stroll around a property.  The best time to monitor salamander population is in March and April by checking vernal pools. Because of the hilly topography and the numerous springs in the area, the project site contains many vernal pools.

 

…..EMAN monitoring protocols indicate in order to conduct proper salamander monitoring one needs to set up ‘houses’ as well as nets and trenches.  The houses are untreated planks laid down over slight depressions, which attract salamanders as lairs.

 

EMAN salamander protocol..

http://www.ec.gc.ca/Publications/7F4E3C01-BAB1-48EB-823D-D914FC8F5A18%5CTerrestrialMonitoringProtocolPlethodontidSalamanders.pdf

 

 

-Weather greatly influences when egg masses are laid. Wood frogs and spotted salamanders migrate to vernal pools in the winter and early spring on rainy or foggy nights when night temperatures are above 10-12°C .

http://www.pwrc.usgs.gov/monmanual/techniques/eggmass.htm Summer months are dry and unfavourable for salamanders, so monitoring at this time should be avoided (Cook, 1984, Davis, 1984)

 

 

Normal protocols for monitoring salamanders were not followed and studies were conducted at the wrong time of the year

Species known to be in the region according to the Kawartha Conservation Authority include: Blue Spotted, Yellow Spotted, Northern Two Lined, and Four-Toed Salamanders, as well as Mud Puppies and Water Newts.

There is no indication that the proponent conducted a proper and thorough salamander survey.

 

Vernal Pools

…..Vernal pools are critical to the maintenance of healthy, functioning surface and subsurface water systems. Vernal pools or ponds play an important role in groundwater recharge and flood control. While some vernal pools are created by spring run-off, others are formed when the water table breeches the surface and results in depressions in the landscape filling with water. The water table within sections of the Snowy Ridge wind power plant project area is very high. The over-extraction of groundwater can effectively destroy vernal pools formed by breeches. There are indications in the Construction Report it may be necessary for the proponent to pump out 1000s of litres of water in order to facilitate the construction of the wind turbine bases which could have a dramatic effect on the water table in the area.

 

…..The Snowy Ridge project extending from the western area of Beers Road to the east near the junction of Highways 35 and 7A follows a 30 degree decline in elevation. There are also higher elevations to the north in the Twigg Road and Lifford Road area. As a result of lowlands being surrounded by higher elevations, there is much spring run-off after the winter season.  The run-off creates vernal pools on many of the lands within the project area.

 

There are indications in the Construction Report it may be necessary for the proponent to pump out 1000s of litres of water in order to facilitate the construction of the wind turbine bases which could have a dramatic effect on the water table in the area

 

The destruction of the vernal pools or ephemeral wetlands decreases the ability of the land to absorb water after heavy rainfall events or during the snowmelt in the spring. The increased water runoff can result in more frequent and severe flooding, lowering of water tables, the destruction of fish habitat, a reduction in water quality (higher nutrient, pollution, and sediment loads), and loss of recreational fishing and boating areas. The cost of mitigating these impacts can be a great burden on society; including flood and erosion control, water treatment, agricultural losses due to drought and erosion, dredging, and habitat restoration. The implications of poor water quality can be catastrophic and expensive, as seen in the Walkerton Water Tragedy when the town’s water supply was contaminated with Escherichia coli bacteria resulting in 7 deaths and the illness of 2,300 in May 2000. On top of the human losses, it has been estimated that the Walkerton water tragedy cost the Town of Walkerton and the people of Ontario between $64.5 and $155 million. Maintaining wetlands and vernal pools to maintain and enhance water quality and quantity is essential to the continued health and vitality of our communities.” http://www.ontariovernalpools.org/pages/hydro.html

 

.

 

 

 

 

 

 

Other Herpetofauna – Snakes

 

…..According to the NHSI Report, 6 candidate snake hibernacula (deep rock piles) were identified throughout the project site. Three of the potential sites were identified as being less than 30 m from the project location.  Two of the sites SH01 located beside Turbine No. 1 and SH04 located near Turbine No.5 were identified as being over 30 m but less than 120 m of proposed infrastructure and were then deemed as significant and moved forward to EIS Report. The proponent used plywood boards and sheets to conduct snake surveys. The boards and sheets were erected at the rock piles on September 8th, 2011 and were lifted on October 4 and 22nd, 2011 to see if any snakes were underneath. There were none. The temperature on the days of October 4th and 22nd, 2011 ranged between 8 to 15 degrees Celsius. Snakes would not seek refuge under boards in these temperatures. In fact, at this time of year, snakes would be seeking or already sequestered in hibernacula.

 

…..Area residents indicate that species at risk milk snakes abound on the project site. It appears that SH04 may provide hibernacula for the milk snake. Local residents have identified the Eastern hog-nosed snake as being present in the location of the proposed substations. The Eastern hog-nosed snake is currently listed as Threatened under the Ontario Endangered Species Act, 2007 and threatened under the federal Species at Risk Act. The species has also been designated as a Specially Protected Reptile under the Ontario Fish and Wildlife Conservation Act. These acts offer protection to individuals and their habitat. The habitat of this species is further protected in Ontario by the Provincial Policy Statement under the Planning Act.

 

……Snakes are extremely sensitive to acoustic vibrations in the ground. New evidence suggests that snakes also possess auditory capabilities.

“Having shown that snakes are sensitive to sound-induced vibrations rather than sound pressure, the team is keen to investigate the hearing of other earless animals.” http://jeb.biologists.org/content/215/2/ii.full

…… Many reptile species are dependent on rocky outcroppings or accessible geologic features for hibernation and features such as the stone deposits identified on the lands within the Snowy Ridge wind power plant.

…… According to the Section 5.4.8 of the Design & Operation report, “Construction personnel will be educated about the location and significance of these features (snake hibernacula) and will be trained to avoid snakes in the spring and fall.” As a mitigation strategy construction crews will be advised to conduct visual monitoring for wildlife species. If a construction crew member sees a 2 foot long milk snake that will shake its tail in a rattle when approached, or an Eastern hog-nosed snake rising up in a cobra strike position, what are the chances that the crew member will gently move the snake out of harm’s way? Nil. And, since milk snakes generally hide under rocks, in holes  and under deadfall along the edges of woodland, what are the chances that a heavy equipment operator will see a hidden milk snake. Nil.

…..The milk snake breeds in the spring. Females lay from three to 24 elliptical eggs, often in rotting logs, stumps or the burrows of small mammals. The eggs hatch in seven to 10 weeks, and the snakes mature in three to four years.  They do not breed in the hibernaculaum. The proponent proposes in the EIS as a mitigation strategy that a buffer zone will be created around the two hibernacula.  This strategy will be of little use, if surrounding habitat is destroyed.

 

..

 The surveys conducted were inadequate and at the wrong time of year. The proponent had well over two years to conduct relevant specific snake surveys, but did not.

There is no indication that the proponent sought local expert advice or knowledge as to the presence of snakes and especially species at risk.

According to the MNR,on warm days in spring, the immediate vicinity of known or potential hibernacula can be searched for recently emerged snakes. ….Most snakes emerge from hibernation sometime in April or May.”

http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@lueps/documents/document/mnr_e001791.pdf yet the surveys were done in September and October when they would be very unlikely to see any snakes.

 

According to the MNR in order to facilitate life processes including foraging, thermoregulation, mating and dispersal, it is recommended that, in areas of Ontario where Eastern Hog-nosed Snakes …..occur, areas of contiguous natural habitat including open areas (meadow, sand, beach and beach dunes, open forest, brushland, rock barrens), wetlands, forest and forest edge within five kilometres of sightings be prescribed as habitat in a habitat regulation.

 

http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@species/documents/document/stdprod_086030.pdf

Considering that the proponent identified six candidate locations for snake hibernacula and is unaware that the species at risk milksnake and endangered species Eastern hog-nosed snake are present in the project location, the Natural Heritage Site Investigation report must be considered as being incomplete

The Eastern hog nose snake and milk snake sites are registered with the Ontario’s Reptile and Amphibian Atlas site number: ON3820.

Since it has been established that industrial wind turbines not only create audible noise, they also create varying degrees of inaudible or vibratory infrasound, it would appear that the installation of the Snowy Ridge wind power plant project could seriously impact the resident milksnake and Eastern hog-nosed population. 

 

 

 

 

 

BATS

.….Bats are in danger of extinction, especially little brown bats. WNS (white nose syndrome) has ravaged populations since its introduction in 2006. Population declines of greater than 95% have been recorded (St. Mary’s Hugh Broder study). Bat Conservation International (batcon.org) reports that 5.7 million bats have died since the introduction of the disease in New York in 2006. WNS is in Ontario. Their severe decline has immediate implications for agriculture and pathogens affecting humans that are transferred through insects, not to mention the unknown long term impacts to ecosystems.

 

…..Migratory bats are attracted to industrial wind turbines. The frequency and number of bat kills at wind turbines are much greater than for any other type of human-built structure.

http://www.naturvardsverket.se/Documents/publikationer/620-5571-2.pdf

 

….. The site of Substation # 2 which according to the proponent is the final site calls for the removal of a deciduous woodland of approximately .05 hectares does not show any evidence that this site was searched for potential bat maternity colonies.  There is also a steep embankment as part of the old quarry within 44 m of the site for the switching station that contains several cavities that might possibly serve as hibernacula. There is no evidence in the reports that these cavities were investigated.

 

…..There are snag trees within 120 metres of Turbine # 1 on a non-participant’s property located in W002 (WODM5 –Fresh-Moist deciduous Woodland Ecosite). There is no indication that this site was investigated. Residents on this property report numerous bat sightings. Receptor No. 28 whose property and woodland is overlapped by the 120 setback from Turbine No. 1 leaves outside lights on all night that illuminate the clearing in the woods.   The lights are an insect magnet and bats come on a nightly basis to feed

…..The woodland along the unimproved section of Twigg Road contains numerous candidate snag trees. Little brown and big brown bats prefer to swoop and skim water bodies in search of food sources.The vast pond complex on the north side of Twigg Road is a draw for bats as reported by area residents.

…… A large pond located on the land of participating landowner (P005)  which is not marked on any natural heritage map since it was man-made and in near vicinity to the proposed site of Turbine #1  would also attract bats. .

There is also an abandoned barn located within 120 metres of Turbine # 4 known to house bats.

 

…….According to the Kawartha Conservation Authority, breeding species known to be in the area, in addition to little brown and big brown bats, the breeding bat records include: Eastern small footed bat, Northern long-eared bat, silver-haired bat, Eastern Pipistrelle, Red Bat and Hoary Bat.

http://www.kawarthaconservation.com/projects_services/watershed_monitoring/natural_heritage/species.html

 

….. Section 4.1 of the Natural Heritage Site Investigation report prepared for the Snowy Ridge project, indicates a 4 hour survey  to ‘search for significant wildlife habitat” was conducted on June 11th, 2010 when trees are in full leaf Foliage would obscure possible bat maternity sites. Other SWH surveys were conducted on May 26th, 2011, June 15th, 2011and September 8th, 2011 when foliage would also obscure possible sites. A one hour search for ‘significant wildlife habitat” was conducted on December 9th, 2010. It takes longer than one hour to survey the extensive area for SWH.

 

-The Design and Operations report states that 5.4.7.2 Disturbance Potential Effects

“….It has also been shown that many bats habituate to the presence of WTGs, and this reduces the potential for significant displacement during operation.” No studies are included to back the claim that bats become accustomed to wind turbines. The reference given to support this claim is a fact sheet prepared by the National Wind Coordinating Collaborative; information that dates to the late 1990s to 2004 when only a very few and smaller turbines had been erected across the United States.

 

:

 

The Snowy Ridge site needs to be re-surveyed  taking into consideration possible bat habitat within 120 metres of the Site # 2 for the switching station that was not evaluated, the barn within 120 metres of Turbine # 4 that was not evaluated, the woodland on the non-participating property within 120 metres of the site of Turbine # 1 that was not surveyed as well as potential habitat components originating outside of 120 metres that appears was not taken into consideration.

The unopened section of Twigg Road is inaccessible at all times of the year.  It takes a minimum of three hours to walk the Snowy Ridge project site during fair summer weather and that is without investigating possible SWH for all manner of wildlife, not just bat

The Snowy Ridge site needs to be re-surveyed as the proponent did not conduct any bat surveys according to the MNR Guide Bats and Bat Habitats: Guidelines for Wind Power Projects    

Section 4.4.3 of the Natural Heritage Site Investigation Report for Snowy Ridge indicates that there were only two candidate snag trees in WOD05 near the site of Turbine # 1. The UTM coordinates are not provided to confirm the assessment that the two sites are outside the 120 metres at 167 metres and 205 metres respectively.

.

The Design & Operations report states:

Monitoring Plan and Contingency Measures

“No post-construction behavioural monitoring or contingency plans are proposed.” It seems that the proponent by claiming that there are no significant bat populations or habitat in the project area, even though contrary to what local residents witness, will not engage in post construction monitoring. This statement contradicts the Natural Heritage EEMP report that states: “For bats and birds, a monitoring year is considered to be from May 1 – October 31…..Post-construction monitoring is required for 3 years at all Class 3 and 4 wind power projects.”

There is no evidence in the Snowy Ridge Site Investigation Report that protocol was followed for the two candidate trees located close to Turbine # 1 so as to comply with the recommendation set in Section 2.3 of the MNR Guide Bats and Bat Habitats: Guidelines for Wind Power Projects: including

Candidate roost trees should be monitored for evidence of maternity colonies through exit

surveys as follows:

o Exit surveys should be conducted during the month of June.

o Observers should choose a viewing station with a clear aspect of cavity opening or

crevice (multiple observers may be required if multiple openings are present in one

snag).

o Cavity opening or crevice should be monitored from 30 minutes before dusk until 60

minutes after dusk for evidence of bats exiting.

o A bat detector should be used in conjunction with visual surveys to determine

species

 

Trees/Woodlands

…..According to the Construction Report re: Section 2.2.2 Site Clearing

“A small amount of vegetation and trees in locations proposed for infrastructure will need to be cleared. Infrastructure was designed to remain on agricultural land and avoid wooded areas to the extent possible. These areas are shown in Figure 1-2. Any trees that are cleared will be removed following standard forestry practices using equipment such as fellers. Bulldozers will be used for grubbing and to clear smaller vegetation. Subject to landowners’ direction, marketable trees will either be sold or put aside for landowner’s use. Unmarketable vegetation cleared from the site requiring off-site disposal will be taken to the nearest municipal waste facility or to a private waste transfer station or put aside for landowner’s use.”

 

.…..None of the NHA or EIS maps identify the site of Switching Station # 2 located on the Oak Ridges Moraine determined only at the time of application for approval as the final site for the switching station (transformer).

The woodland where the switching station (Site # 2) is to be constructed is an extension of a 3.7 hectare woodland (WO08) identified as being within 120 metres of project components. This un-assessed area is identified as a thicket on the ELC maps, a thicket being a thick or dense growth of shrubs, bushes, or small trees.   This area should not be considered a thicket. It is composed of 8 to 10 metre tall mixed deciduous/coniferous trees (Fraxinus, Pinus, Populous, Acer, Abies species) bordered by shrub growth extending in the pasture area.   This woodland acts as an erosion control measure.

……  According to the topographic measurements for the area there is a rise in elevation from 336 m to 345 m covering a distance of approximately 30 metres documenting the steep rise to the north. Tree removal will result in serious soil erosion towards Beers Road as well as Hwy 7A. Alteration of the topography will be necessary to construct the station.The impact of removing part of a hillside and what it will have on the environment as well as the high vulnerability aquifer has not been documented.

……. The land to the west was used as a quarry from the 1960s to 1980. It has not been rehabilitated. After some 30+ years, there are exposed sand/gravel areas visible from satellite imagery produced by Google Earth. Cavities in the quarry cliff sides can be seen from a distance, suggesting that it may provide habitat for several species including bats and possibly cliff sparrows. Species at risk hog-nosed snakes have been reported in area of the abandoned quarry.

…….The woodland where the switching (transformer) station is to be constructed has been recorded as breeding habitat for foxes in 2013. It has not been assessed by the proponent for species SWH.

…..Figure 1-2 in section 2.2.2 of construction report does not identify in what areas vegetation and trees will be removed. The NHA and EIS reports fail to include an inventory of what type of vegetation (herbaceous perennial, annual, shrub, coniferous, deciduous, trees etc.), species involved, or total amount.

…….The Construction Report only states there is an expectation that .5 hectares of vegetation will be removed.

……...There is no indication in the Natural Heritage Assessments or Environmental Impact Studies that the areas that will be subject to tree and vegetation removal have been surveyed in specific detail.

……..None of the maps indicate the access road to Switching Station # 2 or lists what vegetation will be removed to construct this road. Section 2.2 of the Decommissioning Report indicates that Figure 1.2 shows the existing roads to be used for project decommissioning as well as the locations of new access roads. There does not appear to be an access road from the switching station to the turbines in the figure.

……… Beers Road which extends from Hwy 7A northwards is a steep curve following the contours of the topographic rise. Woodland W008 extends to both sides of Beer Road. Tree removal will likely be necessary in order to transport turbine components up this hill, often difficult for car and truck traffic to access, especially in the winter months. The trees on these lands are NOT on the lands of a participant. There is no agreement with adjacent property owners as well as the City of Kawartha Lakes that own the property on either side of Beers Road to remove trees.

……..The proponent states in the Construction Draft Report that even though Significant Woodland (W001) is located only 67 metres from the turbine foundation, turbine assembly, rotor assembly, underground electrical cabling as well as an access road for Turbine # 1, that “No impacts to feature anticipated” as well as “minimal disturbances to wildlife that may use wooded area”.

……….woodland # 1 is part of a large complex ecosystem evident in Ecological Land Classification Map # 1 included in the Natural Heritage Site Investigation Report. It contains sections of FODM5-1 Sugar Maple dominated deciduous forest, FODCM2-2 a  cedar dominated coniferous forest , WODM-2 woodland dominated by white ash,  FOCM2-2 mixed hemlock/cedar forested area as well as a very large swamp – SWCM1-2.

………. The area between W001 and Woodland  # 2 (W002) is defined on the ELC maps as OAG – Open Agriculture. However, this area is not used for agricultural purposes. It is former pasture land that is dotted with springs and has been allowed to revert to an open country habitat with mixed scrub trees such as buckthorn and hawthorn. The section to the north end of the field has been planted with Eastern white pine. This section acts as a movement corridor from W001 to W002, sections which are not mapped on the ELC maps. W002 contains FOCM4 dominated by cedar and poplars but only in the southern section, not the entire area. The centre section to the north not classified on the ELC map is an equal mixture of grassland mixed with small shrubs and red pine. The northern section that abuts Twigg Road contains a mature deciduous forest containing a mix of beech, sugar and red maple and red oak.

…….W002 is described by the proponent as fragmented woodland but it is not. It connects to the unassessed large woodland along Twigg Road. This entire section should be considered as one woodland area. In addition, an extensive woodland across the unopened trail section of Twigg Road to the north of the unassessed woodland which connects to W002 has not been mapped.

…….This woodland complex supports a movement corridor for many species along the unopened section of Twigg Road as well as to the PSW Lifford wetland complex. The diverse ecosystems host numerous species of wildlife. Deer laydown areas are in evidence in the pasture area in W002 and deer tracks can be seen along Twigg Road. Coyotes and bears are frequent users of the area. Flying Squirrel nests have been recorded along the southern perimeter of W002 within 120 metres of Turbine # 1. W002 is studded with ground dens – none that have been assessed by the proponent.  Bats reside in W002 and have been recorded by the landowner.  Wildlife species traverse the connective field from W001 to W002 to the unopened Twigg Road trail and beyond to the wetland complex.

 

The assessment of the woodlands is totally inadequate

The woodland where switching station # 2 is to be located has not been assessed nor is this site shown on any of the maps. Several woodlands as noted above have not been assessed by the proponent and some vegetation and trees have not been identified.

The NHA and EIS reports fail to include an inventory of what type of vegetation (herbaceous perennial, annual, shrub, coniferous, deciduous, trees etc.), species involved, or total amount. The Construction Report only states there is an expectation that .5 hectares of vegetation will be removed.

 There is no indication in the Natural Heritage Assessments or Environmental Impact Studies that the areas that will be subject to tree and vegetation removal have been surveyed including in any specific detail.

Much more investigation of these woodlands that provides a movement corridor for the extensive wildlife in the area needs to be undertaken.  

HEDGEROWS /FENCEROWS

…….Fencerows and windbreaks have a long history of providing farmers with wind moderation and soil conservation. Where large fields force increasing gaps between natural forests and wetland areas, fencerows and windbreaks have provided important habitat for pollinators, birds and other wildlife

……….Fencerows are essential for at least 15-20 vertebrate species and preferred habitats for over 74 more. The type of vegetation and the width of a fencerow will affect what species use it. Species using fencerow habitat include bobwhite quail, ring-necked pheasants, screech owls, red-tailed hawks, red-headed woodpeckers, bluebirds, buntings, cardinals, various sparrows, white-tailed deer, cottontail rabbits, squirrels, woodchucks, red and gray fox, box turtles, skinks, rat snakes, king snakes, and many others..

…….Fencerows are one of the most important wildlife habitat components in southern Ontario’s agriculture dominated landscape. Fencerows provide food and shelter for a wide variety of birds, mammals, reptiles and amphibians. They also provide protected escape and travel corridors for wildlife movement between two larger areas of forest cover.” http://www.ont-woodlot-assoc.org/sw_Fencerows.html About 77% of all forest plant species (including some endangered taxa) occurring in the neighbouring forests are also found in the adjacent hedgerows. (Biological Conservation Volume 142, Issue 11, November 2009, Pages 2522–2530)

……. Environment Canada has conducted many studies on hedgerows…and concludes: “Biodiversity was always highly significant between hedgerows and fields at all trophic levels” as well as: “Habitats are important to wildlife in agroecosystems”. The removal of The removal of hedgerows will remove habitat that will affect many generations of avifauna. The Ministry of Culture identifies that existing hedgerows are of historical cultural importance to be retained as part of the cultural heritage of Ontario. http://www.mtc.gov.on.ca/en/publications/Strength_Heritage.pdf

…….NHA and EIS maps indicate that an access road will be constructed next to or in place of a designated ELC TAGM5 hedgerow from Beers Road west past Turbine # 4  for a distance of approximately 250 metres.  125 metres of hedgerow will be impacted by construction of an access road which will also cross the hedgerow to construct Turbine # 3. It would seem that removal of a section of this hedgerow will be necessary for the construction of a crane pad. This hedgerow connects to a small wetland that has been designated amphibian habitat in the Site Investigation reports. Approximately 450 metres of hedgerow will be impacted by underground cabling connections from Turbine # 2 to Highway 7A. Approximately 600 metres of hedgerow between Turbines # 4 and #5Alt running south towards the switching (transformer) station will be impacted.

……-The fencerows are identified on the ELC maps. Not all hedgerows are identified on the Natural Heritage Features Map. Hedgerows in the project area within 120 metres of project components are not identified in the Natural Heritage Records Review map.

 

……In Section 4.4.2 entitled Hedgerows in the construction report it states:

“Hedgerows in of themselves are not individual features as identified in O. Reg. 359/09; however, they may contain significant wildlife habitat. Isolated hedgerows, those separated from a woodland by greater than 20m, are not considered woodlands. Hedgerows connected to a woodland, those that adjoining or separated by 20m or less, will be considered part of the woodland.” Hedgerows will be assessed for their potential to be used as movement corridors if required within the Evaluation of Significance Report

The hedgerow that extends in a north-south direction between Turbine # 4 and Turbine #5Alt connects to an extensive woodland corridor found on both sides of the unopened section of Twigg Road. It functions as a movement corridor. These woodlands have not been assessed by the proponent. The woodlands that the hedgerow connects to are NOT marked on any natural heritage assessment maps. There is no assessment of this hedgerow and its role as a movement corridor in the Evaluation of Significance Report.

……If there is severe dieback along the fencerows, this will impact their function as erosion control and as water flow containment/diffusion system. The land from Beers Road slopes to the west creating an extensive decline. The north-south hedgerow between Turbine # 4 and Turbine #5Alt acts as a water flow reduction and containment system in the spring. Despite this, in the spring of 2013, the numerous rain events caused washouts extending beyond this barrier.  Turbines No. 4 and #5Alt will be constructed on Class 1 agricultural lands. Removal or death of this hedgerow could potentially affect the future viability and productivity of these agricultural lands.

…… As noted in one of the field surveys, there are invasive plant species in the project area.  The soil will be compacted by heavy machinery traffic. Compacted soil will not be able to support strong seed germination numbers of native plants. What the cleared soil along the hedgerows and compacted soil will support are invasive opportunistic species such as dog strangling vine (Cynanchum rossicum) noted by the proponent to be in the project area.   Cynanchum rossicum is incredibly difficult to eradicate and smothers out all native plants in its vicinity.  The only effective measure at this time to deal with Cynanchum rossicum – dog-strangling vine is by the use of herbicides.  If an herbicide is used, remaining native species will also be eradicated. A long functioning ecosystem will be lost. Worldwide, experts agree that whenever possible, it is best to protect and preserve already active, viable ecosystems.

 

It appears an inventory of the hedgerow has not been completed so it is not possible to know the extent of dieback that might occur causing irreversible damage. An inventory and assessment needs to be conducted prior to any approvals or before any construction is allowed to begin.

 

The fencerows are identified on the ELC maps, however not all hedgerows are identified on the Natural Heritage Features Map. Hedgerows in the project area within 120 metres of project components have not been identified in the Natural Heritage Records Review map.

The hedgerow that extends in the north-south direction between Turbine # 4 and Turbine#5Alt connects to an extensive woodland corridor found on both sides of the unopened section of Twigg Road however there is no indication that this was assessed by the proponent. The woodlands that the hedgerow connects to are NOT marked on any natural heritage assessment maps. There is no assessment of this hedgerow in the Evaluation of Significance Report . There is no indication In the Construction Report that a buffer zone will be observed between the hedgerows and road construction as well as the trenches required for the underground transmission cable, in section 3.1.4 Table 3.3 Cabling Specifications in the Construction Report. Buffer zones should be mandatory and specified.

 

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Section 5.4.4.2 of the Construction Report states: “Areas with temporarily cleared vegetation will have native plants replanted to permanently affect erosion control.”   According to the Decommissioning Report erosion control by native plants is established,   but will be cleared again as part of the decommissioning process. – twice in 20 years vegetation and trees will need to be cleared. This arguably will cause serious harm to a natural landscape being dramatically altered twice in a very short time span.

What impact removing part of a hillside will have on the environment as well as the High Vulnerability aquifer has not been documented. A full assessment needs to be undertaken.

.

 

 

Water Assessment

…...Some 65 rivers or streams begin on the Oak Ridges Moraine and run either south directly into Lake Ontario or north to Lakes Scugog, Simcoe or Georgian Bay (Lake Huron). Water collects in the high grounds of the Moraine and forms the headwaters of the Pigeon River. Components of the Snowy Ridge project may interfere with the headwaters of the Pigeon River. According to the online ARCIMS viewer map, three tributaries of Pigeon River are located in the project. These tributaries are also evident in MAH maps of the Oak Ridge Moraine and beyond. http://www.mah.gov.on.ca/Asset1909.aspx

…..In Section 3.2.7 (p. 9) of the water assessment report, the MNR states that there are several watercourses, some which are cold water systems and more importantly, “little information is available for watercourses in the area” Kawartha Conservation Authority. Section 3.2.8 indicates that ‘the streams that traverse through the general project are of coldwater habitat and have excellent water quality

…….According to Figure 1-2 SOLRIS map, and Figure 3-1 map located on page 7 of the Water Assessment Report a long tributary including headwaters extends between Turbines Nos. 1 and 2. Another tributary including headwater locations traverses between Turbines Nos.3 and Turbine 5 Alt (now T5). Conveniently the sections of stream between these turbines disappear from the Natural Heritage Site Inventory map Fig. 4-5 as well as Figure 4-3 map on page 15. The water assessment report indicates that one stream has been ploughed over and the other is no more than a drainage ditch. This despite handwritten field notes that indicate the stream flows east to west from the area of Beers Road and that there appear to be connections with two ponds one to the east of Beers Road; one to the northwest of the location of Turbines Nos. 1 and 2.  As well, in the field notes  pt. 91 on page 2 it states that  rock piles in the area of where turbines are to be erected that ‘sounds like a steam running underneath”. Field notes indicate that the pond located north of Turbines No. 1 and 2  is fed by a ‘stream that flows year round’. The headwaters for this stream originate between the location of Turbines Nos. 1 and 2.

…….The Environmental Impact Study map also indicates that the two headwaters have disappeared. A thousand metre plus stream once present, has vanished. The map indicates that the headwaters now originate in WOO2 north of the location of Turbine No. 1. The headwaters once located right in the middle of the area to host Turbines Nos. 3, 4, and 5, according to the Environmental Impact Study map now are located a distance of over 1000 metres to the west north of Turbine No. 2.  There is no evidence provided by the proponent that the location of the two headwaters has changed. According to Fig 1-2 SOLRIS map as part of the Heritage Records Review access roads as well as electrical lines will traverse the two streams containing headwaters of Pigeon River tributary No. 20; streams that vanish in the EIS map.

Trent Source Protection mapped these streams that cannot be found by agents on the behalf of the proponent during field visits in 2010 and 2011.

Cold Water Streams Map:

http://www.trentsourceprotection.on.ca/theplanningprocess/assessmentreport/pdf/trent_ar_final_maps_pdf/ch_2_watershedcharacterization_maps/kawartha_haliburton_spa/trentar_map2-14(kh)_aquatic_habitats.pdf

 

The streams are clearly marked on the Aquatic Features map as part of the Natural Assessment and Water Report prepared for the adjacent wpd Canada Sumac Ridge project: http://canada.wpd.de/fileadmin/pdfs/Sumac%20Ridge/10%20-%20Sumac%20Ridge%20DRAFT%20Water%20Report.pdf. Ontario Base Mapping makes clear reference to these streams which are headwaters as part of tributary No. 20 of Pigeon River.

 

…….The Stantec Cultural Heritage Assessment report prepared for the Snowy Ridge proposal defines the project area as: “Wetlands and smaller watercourses were noted throughout the general Study Area”.

-Maps prepared for the Sumac Ridge project and posted on public information panels – the tributaries that M.K. Ince claim do not exist are clearly marked with a buffer zone. If they do not exist then this means the wpd Sumac Ridge mapping is faulty.  This map showing the missing Snowy Ridge project Pigeon River tributaries was prepared September 2, 2010

http://canada.wpd.de/fileadmin/pdfs/Information_Panels_Final_Sumac_Ridge_POH1.pdf

 

…..The tributaries deemed non-existent for the Snowy Ridge project also appear in the satellite imagery map prepared for the adjacent Sumac Ridge project  in March 23rd, 2012.

http://canada.wpd.de/fileadmin/pdfs/Sumac%20Ridge/60960731_2012-06-19_POH-2_ALL_8.5x11website.pdf The missing tributaries are clearly marked in the Cottage Country Backroad Mapbook, Third Edition, c .2009. They also appear in the most recent maps produced by Mapart as well as maps produced by Canadian Cartographic Map services – www.cccmaps.com.

 

…..While the streams have been erased in the impact assessment maps, in the water assessment report reference is made to both bodies of water – WA01 and WA02.  The Water Assessment report dismisses the two bodies of water, WA01 and WA02 which contain headwaters of Pigeon River as not qualifying as water bodies under the REA. While it is possible that one stream has been partially ploughed over and one has been diverted into a drainage ditch, they are still headwaters and tributaries of Pigeon River and still flow.

 

…….What the proponent perceives as a small “agricultural drainage ditch” (page 14 of the Water Assessment Report), newer satellite images indicate the drainage ditch in the direct area of the location of Turbines Numbers 3, 4 and 5 is clearly a “wet meadow/cattail/sedge” wetland.  Even the field notes prepared for the assessment reveal that the project area contained numerous ‘wet spots’.

…….KRCA File No. 11663 Kawartha Conservation correspondence with project manager Andrea McDowell dated January 11, 2011 states:

Our records indicate that these watercourses are designated as ‘coldwater’ habitat. Our current policies indicate that for new development proposals, a minimum 30 metres vegetative buffer zone should be maintained adjacent to all coldwater courses”.

 

……….Receptor # 28, the property owner adjacent to the Sites of Turbines Nos. 1 and 2 who denied permission to M.K. Ince to survey his property has indicated that there are seasonal streams that flow across this property and across the sites of Turbines Nos. 1 and 2 and which partly drain into a culvert to the west along Highway 35.  The property owner has indicated that there are numerous springs on the 50 acre property as well as on the sites for Turbines Nos. 1 and 2. Note: When the residence of Receptor # 28 was constructed in the year 2000, tractors sunk in and became stuck in the adjacent meadowlands because of the many springs and seeps.

…….“Any alteration to the channel or shoreline of a river, creek, stream or watercourse requires permission from KRCA. This includes activities such as, but not limited to, culvert placement or replacement, bridge construction, installation of bed level crossings, enclosure of watercourses, installation or maintenance of pipeline crossings, cable crossings, maintenance of by-pass, connected or online ponds, straightening and diversions as well as any work on the bed or the banks of the watercourse such as dredging or bank protection projects.” http://www.kawarthaconservation.com/projects_services/environmental_advisory_services/Plan_Reg_Policies_28Mar2012.pdf

 

.……...It has also been indicated that there are a number of springs that rise up near the location of the original Turbine No. 5 location. Disturbance on the westerly slope of this significant geological moraine land feature where Turbines Nos. 3 and 4 as well as the revised location of Turbine No. 5 are to be located might create a negative impact on the springs and water courses and the complex hydrology of the project area.  The well of the receptor closest to these three turbines is a shallow well of 19.8 feet or approximately 6 metres.

http://www.downloads.ene.gov.on.ca/files/wells/EN/E7/D0/wellrecord10071370.html

 

……..The streams in the project area are coldwater streams which play a very important role in supporting local trout populations. This has been made clear in the Natural Heritage Assessment reports prepared for the adjacent wpd Canada Sumac Ridge project. According to Simpson’s Diversity Index, there are six sites in /Snowy Ridge and adjacent Sumac Ridge project area, four which register at the high end .61 to 1.0, the highest score of 1.0 is located in the Snowy Ridge project area.

http://www.trentsourceprotection.on.ca/theplanningprocess/assessmentreport/pdf/trent_ar_final_maps_pdf/ch_2_watershedcharacterization_maps/kawartha_haliburton_spa/trentar_map2-16(kh)_simpsons.pdf

 

……..Aside from the necessity to preserve and maintain the directional flow of streams in the project area so that interconnected bodies of water may retain functionality, such a large scale industrial project such as Snowy Ridge to be constructed in an area of high vulnerability presents the potential to interfere or contaminate area water supplies that many residents depend upon. Trent Source Protection identifies sections the project area as being one of High Aquifer Vulnerability

http://www.trentsourceprotection.on.ca/theplanningprocess/assessmentreport/pdf/trent_ar_final_maps_pdf/ch_6_landscape_scale_gw_analyses/trentar_map6-3a-d_khspahvawaterqualityriskassess.pdf

 

……..The Snowy Ridge project area is crisscrossed with underground springs. Just south of  the cell towers on the west side of Beers Road at a high point, there was once a large pond that covered approximately a third of an acre. This was filled in around the year 1999-2000 by the participant who has signed land lease agreements with the developer for several components of the Snowy Ridge project. As a result of the filling in of this pond and other springs located along the ridgeline, water flows throughout the proposed project site. It should be noted that according to the Site Plan, the parking lot and maintenance buildings for the Snowy Ridge will be constructed over the site of the pond. It is unknown if the proponent is aware that a pond was once on this site.

……The property which will contain Turbines Number 4 and 5 was tile drained at a depth of three feet in an attempt to deal with the underground stream flows in 2003, but in times of heavy rains, large sections are washed out and were washed out in 2013.  The unassumed road just north of Turbines 3, 4 and 5 – Twigg Road – is inaccessible to any kind of vehicular traffic since it is washed out creating large deep gullies to depths as great as 1.5 metres. There is also a spring along Twigg Road north of the location of Turbine # 3 that has not been assessed or marked on maps in the Water Assessment report.

…..No hydrological report or in-depth hydrogeological surveys were conducted. The water assessment report was not conducted by hydrologists.

…..Under Table 101 of the Design and Operations report: Ontario Regulation 359/09 (page 4) a description of the time period and duration of water takings expected to be associated with the operation of the facility has been left blank. Yet under Section 3.4 Re: Water Takings – while this section states the only water they anticipate is through rainfall to accumulate in excavated areas, and that water will be pumped into adjacent field, it also indicates that accumulated rainwater might exceed more than 50000L/day. Not only would this be an extraordinary amount of rainfall equivalent to that which caused major flooding recently in June 2013 in parts of Alberta, this action would require a PTTW.

…..As indicated, the aquifer in the area of components of the Snowy Ridge project has been identified as being in an Area of High Vulnerability. Despite assurances from the proponent, it could become contaminated during the construction process or through post-construction maintenance. Turbines 3, 4 and 5 will be constructed in a ‘high infiltration’ area, as will the switching station.

…...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 NOT applied to secondary roads in the Manvers area of the City of Kawartha Lakes… one of the reasons being, that residents rely on wells for their drinking water. In nearby Welcome, application of salt contaminated an aquifer in the early 1980s…. it is still contaminated. http://www.northumberlandnews.com/community/health/article/1570091–fresh-water-would-be-welcomed-in-welcome  Considering the many springs, seeps, tributaries as well as high water table in the area, there is a possibility 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)

http://www.trentsourceprotection.on.ca/theplanningprocess/assessmentreport/pdf/trent_ar_final_maps_pdf/ch_2_watershedcharacterization_maps/kawartha_haliburton_spa/trentar_map2-18(kh)_pgmn.pdf

The Water Quality Index rates the water quality in the area from good to very good.:

http://www.trentsourceprotection.on.ca/theplanningprocess/assessmentreport/pdf/trent_ar_final_maps_pdf/ch_2_watershedcharacterization_maps/kawartha_haliburton_spa/trentar_map2-15(kh)_hilsenhoff.pdf

The area is Significant Groundwater Recharge region:

http://www.trentsourceprotection.on.ca/theplanningprocess/assessmentreport/pdf/trent_ar_final_maps_pdf/ch_6_landscape_scale_gw_analyses/trentar_map6-7_signifgwrechargeareas.pdf

 

…..On page 16 of the Water Assessment report, it stated that – “groundwater is not anticipated to be reached”.  Without a hydrogeological study, this can not be determined. Aside from the tributaries and headwaters of Pigeon River and there are numerous seeps and springs and wetland within 44 m of components of the project. This Oak Ridge Moraine wetland is dismissed 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. What that source of water supplying 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.

 

……Section 3.4 indicates that dewatering may occur. Any dewatering during construction of Turbine No. 1 will definitely affect the Pigeon River tributary as well as the small headwater pond 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 configure a complex water system that has its origins within the Oak Ridges Moraine.

……….The residences closest to the location of the turbines are all supplied by very shallow wells:

Turbine # 1 – 8.5 feet

http://www.downloads.ene.gov.on.ca/files/wells/EN/E9/D5/wellrecord10072895.html

Turbine # 2 – 16.8 feet

http://www.downloads.ene.gov.on.ca/files/wells/EN/E7/D1/wellrecord10071371.html

Turbines # 3, 4 and 5 – 19.8 feet

http://www.downloads.ene.gov.on.ca/files/wells/EN/E7/D0/wellrecord10071370.html

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.

 

 

There are numerous errors and omissions relating to the water assessment that require further investigation .

 

It is stated on page 30 of the Natural Heritage Site Investigation Report “no seeps or springs were detected”.

There is a spring along Twigg Road north of the location of T3 that has not been assessed or marked on maps in the Water Assessment report. Residents known as R053 reported numerous springs and an artesian well in the project area.  The property owners designated as Receptor #054 did report to the proponent that there are many springs on their property.

These springs feed the watercourse that forms part of the Fleetwood Creek system which is a waterway indicated as an environmentally protected area on the Oak Ridges Moraine OPA Schedule G.

There is much evidence that the streams that are missing on the maps prepared as part of the water assessment report do exist.

 

KRCA File No. 11663 Kawartha Conservation correspondence with project manager Andrea McDowell dated January 11, 2011 states:

Our records indicate that these watercourses are designated as ‘coldwater’ habitat. Our current policies indicate that for new development proposals, a minimum 30 metres vegetative buffer zone should be maintained adjacent to all coldwater courses”. There is no indication that this requirement will be followed.

 

There are enough issues with respect to water and mapping for this project that a full hydrogeological study needs to be conducted first before this project should be considered.

 

As outlined in the MOE’s own legislation this should be a requirement :

MOEE hydrogeological technical information requirements for land development applications (1995)

https://archive.org/details/moeehydrogeologi00ontauoft

 

2.1.5 Why are Hydrogeological Studies Required?

 

“Land use changes may result in changes to the quantity and quality of ground water naturally occurring beneath a propeny as well as that of adjacent properties. Hydrogeological studies are required in support of development applications involving a change in land use to ensure that ground water quantity or quality and its users will not be adversely affected and that existing users of the groundwater are not adversely affected. In some cases, existing or past land use may have resulted in adverse ground water impacts. In such cases hydrogeological studies are required for purposes of redevelopment of a property. The scope of investigations depend upon the severity of the impacts and the proposed use of the property.

Hydrogeological studies must be made mandatory for this project.

Geotechnical and Construction

……..The geotechnical report dated is dated February 25th, 2013. The fieldwork was conducted January 16th and 17th 2013 with ten test pits to a depth of 3.1 m below existing grade. The report lists the UTM coordinates for the site of the five wind turbine bases. One site Turbine # 5 is inaccurate. The report lists the UTM coordinates for Turbine # 5 as being 4894292 689691. This location is NOT the final location for Turbine # 5 as presented in the public meetings. Instead, the site of Turbine # 5 has shifted to UTM coordinates 4893868 689157. The report states that both the surface topsoil and the silt level below was categorized as being “very moist to wet at the time of the fieldwork” (Page 3) in mid-winter when the ground is usually frozen. The report also states that while groundwater was not encountered at the site of Turbine # 2, “moderate flow of perched groundwater seepage was encountered at a depth of 1.2 to 2.1 metres at Turbine Locations 1, 3, 4 and 5”. (Page 4) Note: As indicated previously, Turbine 5 is not the correct location. The report also states ‘seasonal fluctuations and local variations in the groundwater would be expected.” As previously indicated, serious issues with spring run-off have been reported in the project area over a number of years. Groundwater is very close to the surface. There are numerous springs and sections of the project area which contains an aquifer designated High Vulnerability. Some residences require continually running sump pumps to deal with the high water table.

 

……..The preliminary report states that “During excavation of the footings the groundwater seepage must be controlled” (Page 5) because free groundwater was encountered within the upper 3.0 metres of the 4 of the 5 turbine base locations. The report recommends dewatering … and recommends that the amount of dewatering be confirmed by a hydrogeologist. Part of the Snowy Ridge project area is within the Oak Ridges Moraine. The turbine locations are just off-Moraine.   Groundwater does not respect political drawn boundaries. The complex water systems found within the project area which aside from the massive turbine base locations will also require crane pads, miles of access roads and trenches for cables, will be put in jeopardy since a full hydrological and hydrogeological assessment has not been conducted.

 

………..According to the ZEP website for Snowy Ridge Mr. Jenner has stated in a Q&A that

The surface area, construction materials, and construction approach for the foundations are essentially the same as for a concrete/rebar foundation for a 2,000 square foot residential home.” http://www.zeroemissionpeople.com/images/stories/projects/20130104%20Snowy%20Ridge%20Final%20POH%20Jan%2010-11%202013%20-%20Mailing%20-%20SPC%20Cover%20Letter%20Final%20(1).pdf

 

According to, : How Much Concrete Is in a Typical House Foundation? | eHow.com http://www.ehow.com/info_12193212_much-concrete-typical-house-foundation.html#ixzz2Hv4GkoVC

“ The size and shape of a home’s footprint has a major impact on the amount of concrete that goes into the foundation. A two-story, 2,000-square foot home may have a base that is 50 feet long and 20 feet wide. This means that the basement floor has a surface of 1,000 square feet. Given a thickness of 4 inches, the floor alone requires almost 12.5 cubic yards of concrete. If the same home has 8-foot-tall basement walls that are 8 inches thick, and no footings, the total amount of concrete in the foundation is around 40 cubic yards.”

 

However according to the construction report prepared for the adjacent wpd  Canada Sumac Ridge WPD project  which will be using the same model of turbine REpower MM92

“Turbine foundations:  120 concrete trucks – 5-7 steel delivery trucks & 200 dump trucks – 363m3 of ready-mix concrete – 43.5 tonnes of steel plus an additional 6m3 of concrete for each step up transformer.”

 

The turbine base will require a minimum of 363 cubic meters of concrete which equals 474 cubic yards. This is approximately twelve times the concrete required than a 2000 square foot house. The statement made is inaccurate and calls into question, all other answers being provided by the proponent.

Location of turbine 5 has changed therefore an updated geotechnical report is required

It is apparent that groundwater is close to the surface when the report of a survey done in January indicates both the surface topsoil and the silt level below was categorized as being “very moist to wet at the time of the fieldwork” (Page 3) in mid-winter when the ground is usually frozen.

Water is of great importance on the Oak Ridges Moraine and surrounding watersheds. A quart of oil can contaminate 2 million gallons of water. A single drop of oil can pollute 2 litres of water. A transformer fire at the base of the wind turbine can cause serious groundwater contamination. http://www.thedalleschronicle.com/news/2013/nov/29/transformer-fire-causes-spill-sherman-county/

A Hydrogeological   study must be a requirement

Cultural Heritage

 

………  The proposed Snowy Ridge site is to be located on one of the most visible ridges in the area. Because of this elevated location, the five industrial wind turbines will be visible for distances arguably further away than any other wind project in Ontario. Being the largest structures in the region; with only 35 buildings in Toronto being taller, the turbines will dominate the skyline. The magnificent views that provide the framework for and define all of the heritage properties listed on Lifford Road and Beers Road will be obstructed by the five turbines.

……….The turbines will be clearly seen from Yelverton located 8 kms away, and from the historic towns of Bethany, Janetville and Pontypool. There are many cultural heritage and natural sites within the region. The visual impact of the Snowy Ridge project on these features has not been considered in the Cultural Heritage report.

There are many discrepancies errors and omissions in the reports.

 

………UTM codes for the positions of the turbines are given in the legend that accompanies three maps in the archaeological report. The maps are dated October 12, 2011. Two maps list identical UTM codes; however Map # 3 does not list the same codes. Four of the UTMs are for the positions in proposed adjacent Settlers Landing project and the UTM code for Turbine # 1 places it in the ocean off the coast of Spain. Furthermore, the UTMs for Turbines 3 and 4 are NOT the same as those presented in later maps. It appears that the positions of both Turbines Numbers 3 and 4 changed in position ranging from 50 to 100 metres between 2011 and 2012. Turbine Alt # 5 which the proponent has opted for instead of Turbine # 5 is NOT marked on any of the three maps nor is there a matching UTM code for it. Switching Station # 2, the final site decided for the Snowy Ridge project, is NOT marked on any map nor is there a UTM marker in the legend. Inaccurate mapping indicates that the surveys were based on inaccurate site information.

 

……..In Section 4.1.2 it states that during the February, 2012 site visit, 18 built resources were uncovered in the project area that might potentially satisfy the criteria outlined under O.Reg. 9/06. These were documented and recorded during a windshield survey. All 18 of the built resources recorded during the visual survey were evaluated against O.Reg.9/06 criteria. Yet, according to the Stantec Built Heritage Resources map produced February 2012 there are actually 19 locations identified not 18. Clarification is required as to which property was not included and should it have been.

Making this report even more confusing, under (Table 1 in the report, it appears only a total of 13 of the evaluated resources meet the criteria for determining cultural heritage value or interest as outlined under O.Reg. 9/06.

however the letter from the Ministry of Tourism Culture and Sport dated May 10th, 2012 refers to a total of 18 built resources and 12 identified meeting the criteria for determining cultural value. Again, clarification is required as the Stantec report which refers to 13 properties not 12.

 

……The Cultural Heritage report lists different setback distances than the Noise Receptor list. The differences are noticeable. For example the Cultural Heritage structure listed as BH 10 is noted to be 1000 m from the nearest turbine. The same structure is noted on the receptor list as being only 707m from the nearest turbine. Cultural heritage structure number BH 11 is listed at 1500 m from the nearest turbine. The Noise receptor list positions the same structure as being 1182 m from the nearest turbine. There are other similar discrepancies. Are the receptor distances accurate or could some be within 550 metres.

……..The Cultural Heritage Report was completed on February 7th, 2012 by the consulting firm Stantec. There are indications in correspondence in the application to various agencies by the staff of M.K. Ince dated March and April 2012 that turbine locations have changed since completion of the Stantec report. The turbine locations on the site map provided by Stantec on page 5 dated February 2012 in the Cultural Heritage report do not correspond with the Snowy Ridge Draft Site Plan dated October 31st, 2012.

 

-The Draft Site map, http://www.zeroemissionpeople.com/images/stories/projects/5%20–%20DRAFT%20Snowy%20Ridge%20Design%20and%20Operations%20Report%202012-11-02%20-%20App%20I.pdf, has FIVE of these sites marked BHR. Incomplete mapping should be considered as inaccurate mapping. There is a map included in the Cultural Heritage report that lists 13possible sites, but the report only covers 12.  The map within the Cultural Heritage report contains the following locations: 137 Lifford Drive, 167 Lifford Drive, 235 Lifford Drive, 308 Beers Road, 172 Beers Road ,  77 Twigg Road, 1201 Hwy 35,  832 Hwy 7A , 754 Hwy, 785 Hwy 7A,  990 Hwy 7A,  905 Gray Road and  902 Gray Road.  Even though the properties 176 Lifford Road and 905 Gray Road are marked on the study map, they are not assessed and there is no explanation in the Cultural

Heritage report as to why these properties have been omitted.

 

………The Ministry of Tourism and Culture outlines seven negative impacts that may affect heritage properties. One of those negative impacts is “shadows created that alter the appearance of a heritage attribute or change viability of a natural feature on plantings such as gardens.”  The Cultural Heritage report states that heritage houses along highway 7A, and Beers road are not expected to experience negative impacts caused by shadows. The flicker shadow report prepared by the proponent indicates that several of the cultural heritage buildings will be potentially subjected to the flicker shadow effect:  167 Lifford Rd 33.10 hrs per year; 137 Lifford Road 13.01 hrs; 235 Lifford Road 21.02 hrs; 1201 Hwy 35 4.49 hrs; 77 Twigg  Road 7.28 hrs and 832 7A 6.12 hrs. This shadow effect is cited as one of the negative effects on heritage resources provided by the Ministry of Tourism and Culture.

The Ministry of Tourism and Culture in its outline of seven potential negative impacts on heritage resources, also states, “Direct or indirect obstruction of significant views or vistas within, from, or of built and natural features” will detract from heritage resources. The Cultural Heritage report states that the turbines will have a minimal visual impact on these heritage properties but there is no visual modelling in the report to back this statement of claim.  The proposed Snowy Ridge site is to be located on one of the most visible ridges in the area. Being the largest structures in the region, the turbines will dominate the skyline. The magnificent views that provide the framework for and define all of the heritage properties listed on Lifford Road and Beers Road will be obstructed by the five turbines.

 

…..The Cultural Heritage report indicates that the residence located at 785 Highway 7A may incur structural damage as result of the project construction.  While the proponent indicates that as a mitigation measure an engineer will be retained to ensure the structure is not harmed, there is no guarantee that structural damage will not occur.

Construction vibrations effect structures in two major ways. Those vibrations may produce direct damage to structures and make damage due to vibration-induced settlement structure vibrations depend on soil-structure interaction which determines a structure response to the ground excitations. Structure vibrations measured from construction operations vary in a wide range of frequency content and intensity. There is no indication in the report that the proponent is willing to repair any damage caused, offer compensation or to purchase the property in question. Nor is there any indication in the report that the owner has been advised of the possibility of structural damage. There is no indication that the insurer of the property has been notified of the possibility of structural damage. The other mitigation strategy proposed in the Stantec report is that a 50 m buffer zone be created. There is no elaboration in the report as to what this buffer zone would be comprised of, how its creation would prevent possible structural damage. According to the Draft Site Plan and on all maps,  P006 (785 Highway 7A) appears to be located  approximately 8.95 metres from where the proposed Turbine # 1 access road and connection line is to be constructed.

 

 

Many of the heritage properties could be impacted by negative impacts outlined by the Ministry of Tourism and Culture which will detract from the their heritage resources .  

The Ministry of Tourism and Culture outlines seven negative impacts that may affect heritage properties. One of those negative impacts is “shadows created that alter the appearance of a heritage attribute or change viability of a natural feature on plantings such as gardens.”  

The Ministry of Tourism and Culture in its outline of seven potential negative impacts on heritage resources, also states, “Direct or indirect obstruction of significant views or vistas within, from, or of built and natural features” will detract from heritage resources

 

 

Archaeological Reports

 

……The archaeological report is titled: 2011 Stage1-2 Archaeological Assessment for Snowy Ridge & Settlers Landing Wind Farms indicating that close proximity of both projects warranted one study and can be argued is ONE industrial energy project. Amick Consulting conducted archaeological surveys for M.K. Ince for the Snowy Ridge project on December 7th 2010, May 26th 2011, June 2nd 2011, November 30th 2011, and December 1st 2011. The site maps for the turbines as well as other project components in the Amick report used as survey reference points are dated October 12, 2011. Three of the five surveys were conducted before the site maps were produced. Correspondence dated January 23, 2012, states on page 2: “any portion of the study area which has not been subject to a Stage 2 assessment be restricted from any ground altering activity”.  Correspondence from M.K. Ince to various agencies dated March and April of 2012 indicate that turbine and turbine locations have changed. In addition, the proponent has not indicated where the access road to be built to construct the switching station will be located. The proponent has also not indicated the route that will be taken for the underground cabling that will extend from Turbines Numbers One and Two to the switching station.

……There is no evidence in the Cultural Heritage report that First Nations peoples were consulted as to their local knowledge of potential sites of important aboriginal heritage.  There is evidence that ossuaries have been found in the area and that the project site was once the scene of a great battleground and maybe rich in aboriginal artifacts. . A second ossuary is reputed to be located in the area. A local historian with an extensive background in the ancient aboriginal heritage of the area it appears was also not consulted. It is stated on page 26, Section 10 of the Amick report that” Local knowledge (local heritage organizations, First Nations etc.) are to be consulted if “potential is determined.”

“Virtually all of the land within the subject property has high potential for the recovery of precontact aboriginal sites. This is due primarily to the presence and proximity of Fleetwood Creek and Pigeon River tributaries along the eastern and northern edges of the study area.”, according to the archaeological reports prepared for the adjacent WPD Sumac Ridge project.

http://canada.wpd.de/fileadmin/pdfs/Sumac%20Ridge/11-1%20Sumac%20Ridge%20St%201%20Final.pdf

There is the possibility that the project site may contain the second yet to be discovered ancient burial ground. Considering that Snowy Ridge project area is so rich in ancient cultural heritage, the invitation to First Nation people to participate in this process should have been extended by the proponent as indicated under ‘best practices’  Moreover, representatives of aboriginal communities should be involved in all aspects of decision-making in regard to the construction process to ensure that their ancient cultural heritage is not destroyed.

……….Quite by accident it was discovered that a company known as ZEC (Zero Emission Consulting)has been retained by Sprott. When asked why the company ZEC had not been made known to the public or included in the Cultural Heritage Report for the 60 day public review the response from the proponent was “we are using the services supporting aboriginal consultations and so the firm was would (sic) not have come up in the course of the public consultations.

 

Turbine site locations have changed since Amick consulting prepared their report and there is no evidence that they were retained to investigate the alternative sites.

There is no evidence in the report that the sites for the transformer station Site 1 and Site 2 were evaluated

There is no evidence that First Nation representatives were actively involved in the archaeological assessment.  

Why would the aboriginal community members not have been part of the public consultation process?

There is no indication if anyone was consulting with aboriginal communities from 2010 or if they were,the nature of those consultations were not made public. Consultation should be compulsory prior to any approvals taking place.

 

Design and Operations Report

 

……There are several inconsistencies found in the Design and Operation report prepared for the proposed Snowy Ridge project by the proponent and while most if not all of these inconsistencies have been addressed in other sections below is a summary:

 

 

 

1.In Section 2.4. it is stated:

“Portions of the project will be developed in an area managed under the Oak Ridges Moraine Conservation Plan (ORMCP). A small portion (near the substation and associated cabling) lies within the Countryside portion of the ORMCP area. The majority of the project location lies outside of the area subject to the ORMCP.”

“The Green Energy Act exempts renewable energy projects from the restrictions of the ORMCP. However, within the Natural Heritage Assessments, evaluation criteria and setbacks specific to certain natural features within areas subject to the ORMCP have also been applied where applicable.”

Further along however in section 5.4.5.4. which addresses the potential impacts relating to the Oak Ridges Moraine it states:“The project will be constructed in an area managed under the Oak Ridges Moraine Conservation Plan (ORMCP). The majority of the project location lies within the Countryside portion of the ORMCP area, with a small segment of cabling within the “Natural Linkage” area. A small portion of cabling lies outside of the area subject to the ORMCP.”

These are contradictory statements : (i) the majority of the project is outside the area under the auspices of the ORMCP (ii) the majority of the project is within the area of the ORMCP. This is a very important distinction .

 

2.In Section 3.1 of the Design and Operation Report  in the Table provided under Wind Turbine Specification it states that the Sound Power level is 103.2db(A)

However the brochure for the REpower MM92 turbine to be used in this project, states sound power level LWA 95% to be 104.2 db(A) which would require a setback distance of 600M for 1-5 Turbines.

http://www.repower.de/fileadmin/download/produkte/PP_MM92_uk_2013.pdf

 

  1. Section 3.1.3. re lighting states

“While confirmation from Transport Canada is pending, it is expected that three of the five turbines will be lit for aeronautical safety.”

In Table 3-2 it states that lighting will vary depending whether T5 or T5 Alt location is built. In the event T5 is built T 1,3,5 will be lit but if T5Alt is built T 1 and T4 will be lit. As the proponent has now indicated thatT5Alt will be used does that mean only 2 turbines will be lit? Has Transport Canada been advised of this change? There is no evidence in any of the reports that they have been notified. In fact in table 3-2 it indicates “turbine lighting coordinates and heights confirmation from transport Canada is pending.”

Section 3.1.4 Re: interconnection facilities it states that the routing of the colletor system is shown in Appendix l however the proponent has elected to use the site marked S2 (substation 2) The appendix shows S1 as the collection system line however the collector line from S2 is not indicated on the map in Appendix 1.

 

  1. Section 3.3. re cleared areas it is stated :

“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 0.5 ha.” There is no indication what areas are planned to be cleared.

 

  1. Section 3.5.1 regarding Noise Setbacks: it states 113 noise receptors are within 2000m  of project components, however this is not correct. There are many missing receptors as well as 2 unaccounted non-participating receptors. According to the Stantec Cultural Heritage report there are two properties within the 550 metre setback. The draft site plan indicates there are several receptors just outside the 550m setback limit : i.e. R017(569), R020(571) R028 (568) R063 (627)R048 (611) R085 (614). In light of the many discrepancies all the setback distances need to be re-measured and verified. The setback distances measured from V011 (592) and V014(587) appear to have been measured from the middle of the lot not where a residence (receptor) might be likely to be built.

As previously indicated V011 is NOT a vacant lot. It is a residence, a non participating residence that arguably is within the 550 metres of turbine #3.

 

  1. section 4.2. re: Maintenance -the report states “In general, each turbine is expected to be serviced quarterly.”

In section 5.4.4.1 Spills and Leaks (Servicing and Inspections) it is stated “regular scheduled inspections of oil and hydraulic systems will be made during the semi-annual maintenance visits, and any leaks found will be repaired immediately”. Has the maintenance plan been formulated ?As the above statements are contradictory. A specific plan needs to be detailed for post construction maintenance as this is critical in ensuring the performance of the turbines and the safety of residents in the area.

 

  1. Section5.3 Summary Table5.4.5.4 Construction Performance under objectives it is stated : evaluate Natural heritage features according to guidance specific to the ORMCP’. UnderMitigation Measures it is stated: “Natural Heritage studies were undertaken using guidance specific to the ORMCP as applicableand therefore No Monitoring or Contingency Measures are proposed”

Section 2.4 of the Design and Operations report says: “The Green Energy Act exempts renewable energy projects from the restrictions of the ORMCP.”  These contradictory statements pose one question – what guarantee is there that natural heritage features were in fact evaluated specific to the ORMCP.

 

8.Section 5.4.2.2 Noise under Mitigation Measures, states:

“To mitigate noise disturbance all construction activities will adhere to the City of Kawartha Lakes noise prohibitions as per by-law 2005-025. As such construction activities will not be undertaken outside the hours of 7:00 a.m. to 9:00 p.m. to minimize disruption to local residents and businesses. No commercial construction equipment will operate on Sundays and Statutory Holidays. In cases of urgent necessity, authorization to work outside those hours may be sought from the Municipality.”

It is also indicated that erection of turbines may be required to occur during day and night. It is not stated that authorization will be sought for the turbine erection from the municipality of the City of Kawartha Lakes. It must be a condition that authorization be a requirement in order to not disrupt residents as per the Municipal noise by-law.

 

9.Section 5.4.6 – Birds 5.4.6.1. Monitoring Plan and Contingency Measures states: “Post construction follow up monitoring surveys will be conducted in accordance with Appendix V: Natural Heritage EEMP. However under the section entitled Monitoring Plan it is stated “No post construction behavioural monitoring or contingency plans are proposed. “

Post monitoring must be a condition.

 

  1. The Construction Report indicates that the turbine foundation design will depend on a geotechnical investigation. This report was not made available to the public.

It has been suggested that preliminary test holes drilled quickly filled up with water. It is indicated that the foundation is expected to be about 3-4m deep but the geotechnical report may recommend deeper foundations. The City of Kawartha Lakes who will ultimately be responsible for the safety and health of its citizens should be a recipient of this report.

The proposed site for Turbines Nos. 4 and 5 are on lands that have been extensively tile-drained in an attempt to divert the flow of numerous springs. Construction of the bases will impede the tile drainage system. On decommissioning it is indicated that “heavy machinery will break the top one metre of turbine foundations the rest will remain buried”. Have the participants been advised that the concrete will remain buried? There is no indication in the reports that they have and this could make if very difficult to reclaim the area for agricultural purposes

 

11.Table 5.2 in the Construction Report under Impacts to Natural Heritage Features and Significant Wildlife Habitat, in each section states: “In the event of an accidental spill, the MOE Spills Action Centre should be contacted and emergency spill procedures implemented.”

What responsibility will the company have to ensure accidental spills are reported?

It must be a condition that the wording be changed to the MOE spills Action Centre WILL be contacted and emergency spill procedures implemented.

 

It should be noted that  To date, there is NO indication that there is a completed IESO connection report/commitment for the for the Snowy Ridge project.

http://www.ieso.ca/imoweb/connAssess/caa_StatusSummary-Committed-Generation.asp

 

 

Inconsistent and/or contradictory statements, many of great importance regarding the placement, construction and post-construction monitoring and maintenance of the Snowy Ridge project such as the ones indicated above and also found in other reports, calls into question many aspects of the proposed project.

 

 

 

Switching Station

……Section 4.2  of the Construction Report indicates that “The substation contains a transformer that operates at a distribution voltage of 44 kV. The exact model has not been selected yet.”Two proposals for possible switching(transformer) stations were presented to the public in the Draft Site plan for the Snowy Ridge project.  They are of different size. This is confusing since as stated in section 4.2 of the Construction Report, a model or make of step up transformer has not been decided. The rationale for the size difference and configuration is not explained in the Design & Operations Report. According to the Draft Site plan map, it is unclear as to how the proposed construction sites for the switching (transformer ) stations # 1 or # 2 will be accessed. The site of switching station # 1 appears to be inaccessible by any existing road on the maps so it is unclear as to how the switching station will be constructed. Historic requests for land severances on the proposed location of S1 were denied by the municipality citing visibility issues and safety concerns with access to Hwy  7A.

Access from Hwy 7A would be difficult if not impossible since there is a very steep embankment between the provincial roadway and the proposed site of the switching (transformer) station.

……. Sites 1 and 2 as possible locations for the switching station are ONLY marked on the Draft Site Plan and the Water Bodies Map in documents posted for the 60 day public review.the Natural Heritage Site Investigation Natural Heritage Features Map,  the Environmental Impact Study Map, Working Layout Maps for Archaeological Assessment, Alternative Site Investigation Map, Ecological Land Classification Map and Evaluation of Significance Maps display ONLY Switching Station # 1 which is NOT the preferred site. It would appear then, that environmental and archaeological assessments were based on the switching(transformer) station being in the position of Site # 1 not Site # 2 which is now the preferred option. This indicates that full and complete natural heritage and archaeological assessment have NOT been conducted.

 

……..switching (transformer) station site # 2 is not on level ground. Topographic maps indicate that the slope rises 10 metres on a 45 degree angle. It is on a forested slope. It appears the removal of .4 hectare of woodland on the Oak Ridges Moraine will be necessary in order to construct the switching station.  Site # 2 is not marked on any of the Natural Heritage assessment or impact maps that were presented for 60 day public review. This omission indicates that the site of Site # 2 has not been fully evaluated as to the environmental impact construction of the substation will have on this section of the Moraine. The land north of switching station Site # 2 drops off suddenly and steeply to the south. The woodland has acted as erosion control. Its removal will result in soil erosion that could reduce or undermine the stability of the switching station. A 45 degree slope to the north of the switching (transformer) station will increase the risk of malfunction due to water run-off. The fields directly south of the site for S2 were washed out this year.

……..wetland 01 (WE01) located approximately 100 metres slightly southwest of Site # 2 was once part of an operating gravel pit. The sand and soil composition of the upper strata is still visible.  There is no soil sampling in the Draft Site report that reveals what the soil structure is where the proposed site for the switching (transformer) station at Site # 2.   A large swathe of exposed sand and gravel is located 68.68 metres northwest of the proposed site of S2 (UTM coordinates 689516 4893447). It measures approximately 150 metres across and 100 metres from top to bottom.  It is representative of the Pontypool soil series classification http://sis.agr.gc.ca/cansis/publications/surveys/on/on23/on23_report.pdf

 

……….The proponent has not indicated in the reports why the location of the switching (transformer) station needs to be constructed within the environmentally sensitive Oak Ridges Moraine in close proximity to a wetland within the shadow of a steep slope that sees regular water run-off. Arguably a more appropriate location for a switching station would be on a level area on participant lands not on the Oak Ridges Moraine. Such lands can be found on the properties of participating landowners for Turbines numbers 1 and 2.

 

According to this detailed specification report on the transport of turbine components to be found in this link,

http://mcleansmountain.northlandpower.ca/site/northland_power___mclean_s_mountain/assets/pdf/GE_Specification_Report_on_Site_Roads_and_Crane_Pads.pdf, transport vehicles with a length of 56 metres will be required to transport a turbine blade.

The road clearance required to make the turn will be impossible to complete without interference with private properties located at along Beers Road. The sides of the road are forested and trees on private lands may have to be removed to accommodate transport. There is no indication in the construction report as to how turbine components will be transported up this road that is difficult for all manner of trucks and cars to navigate especially during inclement weather and winter months. There is no indication in the Construction Report that non-participating landowners have been contacted that removal of trees on private lands might be necessary.

 

 

How did the proponent determine that switching station #2 was the best alternative when it is located in the sensitive Oak Ridges Moraine.

Environmental and archaeological assessments were based on the switching(transformer) station being in the position of Site # 1 not Site # 2 which is now the preferred option, therefore a full and complete natural heritage and archaeological assessment needs to be completed at the location of switching station #2

 

The proponent has not indicated in the reports why the location of the switching (transformer) station needs to be constructed within the environmentally sensitive Oak Ridges Moraine in close proximity to a wetland within the shadow of a steep slope that sees regular water run-off. Arguably a more appropriate location for a switching station would be on a level area on participant lands not on the Oak Ridges Moraine. Such lands can be found on the properties of participating landowners for Turbines numbers 1 and 2.

 

 

Property Values

……The City of Kawartha Lakes covers a huge sprawling rural area of 3,083.06 km2 (1,190.38 sq mi). Population density is 23.7 /km2 (61 /sq mi)The main population centres are Bobcaygeon, Fenelon Falls, Lindsay, Omemee and Woodville. The current population of the area is 73, 214, a decline of 1.8% from 2006. The CoKL is dependent on property taxes to maintain and nurture the vast township. Declining property values mean declining revenues for the City of Kawartha Lakes.

……….The Public Information letter posted on the Snowy Ridge website on the same day as the final public meeting, states: “Although, the scientific analysis cannot dismiss the possibility that property values could be impacted for a small number of homes, these cases are either too minor or too infrequent to result in a widespread statistically observable impact. Furthermore, the current Ontario regulations on setbacks (where no non-participating residence can be closer than 550m to a turbine) are larger than historical setbacks for older wind farms and conservative on a global basis. The RE/MAX Market Trends Report – Farm Edition 2012, released September 2012, found that agricultural property value has either stayed constant or increased in all regions of Ontario, including those areas with significant operational and planned wind farms, such as Bruce/Huron County.”

However according to a May 14, 2013 news article regarding another wind plant proposed in the region, indicates that the proponent is aware that property values will be affected. “Representatives from Sprott Power Corp., co-developing with Zero Emissions People … said in the earlier stages of a wind farm, there has been some evidence of a drop in home values….”

http://www.durhamregion.com/news/article/1617318–clarington-an-unwilling-host-to-wind-power

 

……. Properties listed for sale within the Snowy Ridge power plant project are not being sold. On the same day as one of the two final public meetings for Snowy Ridge was held (January 11th, 2013) a sale was lost in Pontypool. The potential buyers did a Google search discovered that there are proposed wind industrial power plants for the area, and withdrew their offer.  Few, if anyone wishes to live next to an industrial complex. Several residences in the project area have been listed for sale for months at a time without receiving any offers. Residents have received inquiries about the status of the Snowy Ridge project from prospective buyers; buyers no longer when they are told that the project is in the application stage.

………The region that contains the Snowy Ridge project is attractive because of the stunning natural vistas. The value of local real estate is tied-in to the views that extend for miles. The 500 foot tall structures will be clearly visible for many miles. They will be the tallest structures in the entire region, indeed between this area and the city of Toronto.

…….Expectations are that the region bounded by Highways 35 and 115 will become a highly desirable settlement area after the extension of Highway 407 is completed. An industrial power plant will prove to be a disincentive to relocate to this area. Bethany, Pontypool and Janetville, are the closest settlement areas to the Snowy Ridge project.  Bethany is described on Wikipedia: “It is a gateway community, in that it services the local winter sport ski hill (Devil’s Elbow) several kilometers north of the village.” Since 2000 there has been significant real-estate development, mostly in the form of individual dwellings. With a small population and a school in the area, there are residential houses ranging from quaint cottages, to extravagant mansions, like the one on Lifford Road. With the expansion of the Highway 407 system, the potential exists for these communities to also expand and thrive.  This will not be possible if an industrial power plant is in close proximity.  Many who wish to reside in an area known for its breathtaking vista will not be inclined to do so if that view is impeded by the sight of industrial power plants. The turbines will be visible from a distance of 10 kms to the west, and over 5 kms from the north. They will be visible from many vantage points of the western edge of the town of Bethany and will be visible from Janetville.

There are 25 vacant lots within the Snowy Ridge project – lots that will be subject to audible and inaudible noise as well as shadow flicker effect. These lots are unlikely to be built upon. City of Kawartha Lakes will be deprived of the financial benefit of development charges and future property taxes.

 

……A case study just completed in October 2012 in Melancthon Township and the MPAC report showing reductions in assessment on Wolfe Island indicate that property values are indeed affected by wind farms.

Ben Lansink of Lansink Appraisals and Consulting (a division of Wellington Realty Group Inc) conducted a case study in October 2012 of properties purchased and sold in Melancthon Township. The decrease in market price of homes located near wind turbines ranged between 23.24-58.56 % with an average drop of 38.81%.

http://ontariowindresistance.files.wordpress.com/2012/10/case-study-wind-turbines-diminution-injurious-affection-oct-12.pdf

…….The Ontario Real Estate Association has issued a new set of disclosures to be complied with. The Green energy clauses :Clause 5 specifically refers to Wind Turbines-Warranty

Clause  GREEN 5 – warrants that the seller is not aware of any renewable energy projects for the immediate area Clause GREEN-5 can be altered to reference solar energy collectors. Green energy is a complicated topic. REALTORS® must be prepared to create specific clauses to deal with unique circumstances as they arise.

 

In addition, REALTORS® should be aware that renewable energy installations can affect the insurability of a property, and clauses may be required to verify the insurability of the property.

 

……….Speaking at a special public meeting convened by the City of Kawartha Lakes, Rose Saller a real estate agent with Landmark Realty made it clear that it is virtually impossible to sell properties in the Sumac Ridge project area. She also indicated that once clients become aware that there is an Industrial Wind Project proposed for the area , they are no longer interested.

 

If as the proponent claims properties actually increase in value, why would the Ontario Real Estate Board include a clause that the seller must warrant they are unaware of any renewable projects in the immediate area and include a clause verifying insurability of the property.

The proponent has not demonstrated that property values will NOT be adversely affected. A local real estate agent stated that properties are not saleable once it is known a wind project is proposed in the area.

If the company is confident that property values will not decline as a result of the construction of this power plant, the company should provide in writing a minimum guarantee on property values on all properties located within a minimum 5 km distance.

The Buddhist Cham Shan Retreat

 

……The Snowy Ridge industrial wind power plant will adversely affect the completion of the multimillion dollar Cham Shan Retreat. Buddhist supporters of the Cham Shan Temple in Thornhill, after two decades of research and development, have now undertaken a mega project with the intent of creating a world class pilgrimage site replicating the four temples of the Four Sacred Mountains of China within the municipalities of the City of Kawartha Lakes and Cavan Monaghan. This project, estimated to cost upwards of 100 million dollars, has the full support of the Chinese government. http://www.sumeru-books.com/2011/07/four-sacred-mountains-re-created-in-peterborough/              http://shengguangshi.blogspot.ca/p/four-great-bodhimandalas-temples.html

…… Lands purchased along Hwy 7A and Lifford Road will be affected by the Snowy Ridge project. As His Excellency Zhang Junsai indicates on the Chinese Embassy website, http://ca.china-embassy.org/eng/dsxx/dsjh/, the fostering of strong economic and cultural ties with China has been, and is of paramount importance to both Canada and China.

On August 26th, 2013 letters of objection were filed by Cham Shan with both Cavan Monaghan council and City of Kawartha Lakes that read:

 

“On behalf of the Cham Shan Temple, please accept this correspondence in regard to the proposed wind projects in the City of Kawartha Lakes and Cavan Monaghan.

Over 20 years ago, Cham Shan Temple bought a number of properties in the Bethany and Pontypool areas for the purpose of constructing four Buddhist Gardens with temples modeled after the Four Great Buddhist Mountains of China, each with its own set of temples. They are namely Wutai Shan, Putou Shan, Omei Shan, and Jihua Shan. Visiting each Buddhist Mountain in China could take up to 2 months to complete the journey, as each site is far from each other. With our local constructions around Bethany, pilgrimages to all four Buddhist Gardens in Canada could be accomplished in one day, at minimum costs too. Cham Shan Temple chose the Bethany and Pontypool areas because of their unique geographic characteristics, their beautiful views, and the serenity offered by these locations.

The first site to be developed is the Wutai Shan Buddhist Garden in Canada, located on 530 acres of land at 775 Ski Hill Road. The other three smaller complexes will be located off Pontypool Road, Ballyduff Road, and Highway 7A west of Bethany. The completion of the overall project over the next two decades will cover approximately 7800 acres of land and will in total cost 40 million .The land at 775 Ski Hill Road was officially granted to be used for religious purposes in July 2007.

This came as a result of 3 years of detailed planning, working closely with over 30 different government departments and their required assessments. On September 23, 2010 an agreement was signed with the Municipality for the overall design proposal. The building permit was granted on March 2, 2011. to begin construction of the Main Temple, styled after the Tang Dynasty Architectural Design.

Construction began in May 2011. What was once barren land has now been transformed into a beautiful haven. Over the last few years, paths were built, trees planted, ponds were excavated and built. When completed, the Wutai Shan Buddhist Garden in Canada will take its place in North American history as an important center for multi-cultural and architectural exchange, where east meets west, where everyone can come to learn more about the Chinese culture, admire the ancient Tang-style architectural buildings, and where Buddhism is freely flourished for the public to embrace and reach spiritual enlightenment. It will have a very significant positive impact on the surrounding community of Bethany, Pontypool, Janetville in the City of Kawartha Lakes and Township of Cavan Monaghan, as well as the Province of Ontario.

We have recently learned of the proposed wind projects Sumac Ridge, Snowy Ridge and Settlers Landing, and Stoneboat Community Wind farm) in the City of Kawartha Lakes and Township of Cavan

Monaghan. All proposed wind projects are in close proximity to the location of our temples. The Buddhist philosophy does not support harming or killing, and seeks to be in harmony with the environment. Throughout the design and planning stage of our project, we worked very closely with the conservationists and various government departments to limit disturbance and harm to all, including the birds and bees. ln light of the increasing number of reports detailing adverse health effects and the impact on the environment and the community, we respectfully advise you of our strong opposition to the proposed wind projects in the City of Kawartha Lakes and Township of Cavan Monaghan. We believe there are better alternate solutions to achieve the same benefits. We hereby urge you to support us in our objection to the proposed wind projects and look to alternate healthier and safer solutions.”

 

……In Scotland, Buddhists were forced to abandon their retreat due to the construction of a wind power plant :

Monks selling retreat at Ae forest

http://www.dgstandard.co.uk/dumfries-news/local-news-dumfries/local-news-dumfriesshire/2012/06/29/monks-selling-retreat-at-ae-forest-51311-31282392/

Jun 29 2012 by Jackie Grant, Dumfries Standard Friday

BUDDHIST monks are selling their spiritual retreat in the forest of Ae because they can’t live near a windfarm.

Scottish Power, which has lodged plans to extend the Harestanes development with a further 19, 125-foot turbines, said it was close to finalising a buy-out deal with the Tharpaland monks.

Concerned monks submitted evidence to a Scottish parliamentary inquiry into the government’s renewable energy plans, claiming they suffered serious side effects when they were praying within five miles of a windfarm.

They say these included: pain in the head and chest, heart palpitations, dizziness, dry retching, anger, heightened emotions and crying

It was founded in 1985 and attracts thousands of people from all over the world.

In their evidence, the monks said: “As Buddhists, we cherish the natural environment and all who live in it and are committed to the development of clean and sustainable forms of energy and are therefore not opposed in principle to the development of windfarms.

“However, in March 2003, following news of a proposal to build a massive windfarm in the Forest of Ae, Tharpaland set about assessing the wider implications this would have on the centre’s ability to provide suitable conditions for meditative retreat, if the windfarm was approved.

“The findings of these studies were so surprisingly negative and adverse that there was little room for doubt that the proposed windfarm, if approved, would force Tharpaland to close.

“It showed a consistent and progressive average 70 per cent loss in ability to develop concentration over the various distances approaching the windfarms and virtually a total loss in ability to develop concentration at the turbine site itself.

“Subjects also reported disturbing negative psychological reactions including confusion, loss of self-confidence, effects similar to depression, effects similar to mania, irritability and anger, heightened emotionality and crying.

“For most of the subjects in these studies, these windfarms were centres of massive and traumatic disturbance, even after only a few hours. They also claim that spiritual centres and communities could be forced to close and disperse.

A Scottish Power spokesman said: “We have been in regular contact with Tharpaland and, after positive discussions, are in the process of finalising an agreement to purchase the property.”

……….On November 4th, the usually reticent Buddhists travelled to Queen’s Park to meet Minister of Energy Bob Chiarelli: at the end of the meeting Minister Chiarelli stated: “this is the first of many dialogues, the start of many more meetings to come” None have taken place.

 

…….Local industries have been, and will be, contracted to build these four projects which will provide a great economic boost to the region. The only workers from China being brought in will be the experts to direct the assembly of the buildings based on Tang Dynasty architecture. These buildings will be constructed like an elaborate puzzle without any nails.

……. Tourists will come from all over the world and certainly from China in great numbers.

The Snowy Ridge project will negatively affect the environmental, cultural, physical, and economic health of thousands of people. The project jeopardizes the completion of the Buddhist Cham Shan mega-project which will arguably enhance the financial prospects for the region. The proponent has not presented a project that will be of equivalent value. . There are, according to Stats Canada, an estimated 400,000 practicing Buddhists in Canada with almost over 200,000 in Ontario.

 

This project would bring much needed jobs to this area. The spinoff employment through more tourist attractions, including restaurants ,hotels could amount to thousands of jobs throughout the region.

Will the developer or the Ontario Government buy the assets of the Cham Shan Buddhist properties and are they willing to compensate the City of Kawartha Lakes and Cavan Monaghan Township for the millions of lost revenues lost because of the construction of these power plants.

The building of some 25 479 foot industrial wind turbines does not meet with the philosophy of why the lands were purchased in the area…… because of their unique geographic characteristics, their beautiful views, and the serenity offered by these locations.

 

 

 

 

Public Consultation

 

2009

……….September 28th 2009 Energy Farming Ontario held an open house in Pontypool. This was before the passing of the Green Energy Act.

Energy Farming has now disappeared. At the time their headquarters were based in Brighton, a subsidiary of the German wind developer Energy Farming GmbH.

……This (information) public meeting was attended by 500 residents. It appeared that Energy Farming Ontario’s sole interest was to seek investors. “For only $10,000 you can blow away one Person’s co 2 footprint”

http://www.energyfarmingontario.com/products/zep.html   Note: links to Energy Farming Ontario no longer work since traces of Energy Farming Ontario have been and erased from online sources.

This very well attended meeting was very short on content leaving most residents confused and with lots more questions than answers.

http://www.thepost.ca/2009/10/05/residents-concerned-over-vagueness :

“Energy Farming Ontario has blown into the City of Kawartha Lakes to trumpet wind farms, but the lack of details of the proposal has frustrated residents and the fact that the company has been quiet about itself.
“They were very vague last night,” Haliburton-Kawartha Lakes-Brock MPP Rick Johnson told The Lindsay Post regarding Energy Farming’s answers at a public town hall held by Ward 16 Coun. Dave Marsh on Sept. 28…”

Meanwhile the Green Energy Act was passed in October 2009 and under the new act new terms for consultation were established.

…… “Under the Renewable Energy Approval Regulation, a proponent of a renewable energy project will have to consult with the following local interests prior to being able to submit a complete submission”: http://www.mah.gov.on.ca/Page6684.aspx

.Municipalities and local boards;

.Members of the public; and

.Aboriginal communities.  

 

The following links of media reports provide a history of some of the consultation meetings that took place

2010 First Public Meeting

http://www.thepost.ca/2010/08/12/wind-meeting-planned-for-winter

http://www.thepost.ca/2010/07/29/wind-meeting-shut-down

http://www.thepeterboroughexaminer.com/2010/08/13/more-space-for-wind-farm-meeting

http://www.thepost.ca/2010/08/12/wind-meeting-planned-for-winterhttp://www.thepeterboroughexaminer.com/2010/08/13/more-space-for-wind-farm-meeting

http://www.thepost.ca/2010/10/05/turbine-powderkeg-eruptsnote – video available at link site

http://www.sprottlending.com/

http://business.financialpost.com/2013/07/03/capstone-infrastructure-set-to-acquire-sprott-power/

 

The Interim Meeting – December 13th, 2012

The visual presentation given on December 13th, 2012 http://www.zeroemissionpeople.com/images/stories/projects/Presentation%20from%20Q%20&%20A%20Session%20-%20Dec%2013%202012.pdf

 

The final Snowy Ridge presentation given on January 10th, http://www.zeroemissionpeople.com/images/stories/projects/SR%20-%20Presentation%20from%20Final%20Public%20Open%20House%20-%20January%2010-11%202013.pdf

 

 “Under the Renewable Energy Approval Regulation, a proponent of a renewable energy project will have to consult with the following local interests prior to being able to submit a complete submission”: http://www.mah.gov.on.ca/Page6684.aspx

.Municipalities and local boards;

.Members of the public; and

.Aboriginal communities.  

CONSULTATION-according to Wikipedia –Public Consultation – a process by which the public’s input on matters affecting them is sought

Unfortunately none of the meetings over the past four years could be considered to be consultation meetings.

 

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