Category Archives: Amherst Island

2750 Front Road

As part of the approval process for the Amherst Island wind project the proponent must undertake a study of the heritage properties on the island.  The proponent farmed this task out to a consultant, Stantec, who then produced the Heritage Assessment (52 MB).  Stantec did a 2-day survey back in July of 2011 and came up with 23 island properties (a 24th property was on the mainland) that they judged to be “heritage resources” along with 4 “Cultural Heritage Landscapes”.

One of the properties was 2750 Front Road, now owned and occupied by realtors David and Diane Hieatt.  Their property was listed as BHR (Built Heritage Resource) #6, described in their section  5.3.6, on their pages 53-56 (PDF pages 52-55).  They also have a map showing its location in their Figure 4, on PDF page 24.

The Cataraqui Region Conservation Authority, APAI and the Loyalist Council are all on record as considering the proponent’s studies incomplete and error-prone.  2750 Front Road stands as a glaring example of just how error-prone these studies are.  You see, Stantec GOT THE WRONG HOUSE.

The picture in 5.3.6 is in fact 2750 Front Road, and the description sort of matches as well.  But the map in Figure 4 indicates that BHR #6 is the home of Paul and Gwen Lauret, at 1900 Front Road.  The description in 5.3.6 has a number of errors, as if they co-mingled the homes.  But one thing is certain – the distances they quote to the nearby turbines were figured using the Lauret’s home.

You can imagine the surprise and outrage of the Hieatt’s.  This project not only puts their amenity and health at risk, it also puts their very home at risk.  Perhaps most galling of all is how Stantec explains away all of these risks and in the end concludes that things will be just fine.  After all, Stantec is being paid by the proponent and the proponent isn’t going to pay for unfavorable studies.

The Hieatt’s wrote a submission to the EBR explaining all this and I am pleased to include it here.  There is no way to spin your way out of this – the study is in error.  It will be interesting to see how the MOE handles this.  Will they care?  I’m betting not – they haven’t seemed to care about anything except getting the approvals done before the next election.

LINK

David and Dianne Hieatt, submission to the MOE

 

Other Submissions

People send me stuff all the time.  Generally I assume they want me to post it on this site.  If something is well-written and makes valid arguments I will likely post it even if I don’t agree with all of the points.  I seem to be a serious skeptic, even of my own opinions.

The public comment period for the Windlectric Amherst Island project is coming to an end and there will no doubt be hundreds of submissions concerning it.  If anyone wants theirs posted, I’ll be only too glad to do so.

Submissions

Hall

My Submissions

As part of Ontario’s process to approve any wind energy project, there’s a 60 day comment period following the MOE’s acceptance of a project’s proposal as complete.  To date the MOE has pretty much ignored any evidence or comments from the public concerning these projects and I expect nothing different this time.  Still, I felt I should say some things to the MOE.  I sent in two submissions, reproduced below.

Submission #1

I am against the pending approval of the Windlectric project on Amherst Island for many reasons and I am not alone in my opposition.  After the public “consultations” and Windlectric’s submission of its draft documents the Loyalist Council submitted their Municipal Consultation Form where, by my count, they listed 51 areas where the documents submitted to date were deficient. These were not trivial matters.  The engineering company, AECOM, hired by Council to review the study concluded “In our opinion, approval of the REA application is pre-mature until the above documents have been completed to the satisfaction of Loyalist Township.”

In the intervening months between the draft documents and the final documents released in January Windlectric summarized the changes contained in the final documents in two short listings, each with 41 changes: the Public Consultation Report and the REA Report Changes.  Presumably some of these changes were in response to Council’s concerns.

How many of Council’s 51 items were addressed?  By my count, just one – the Operation and Maintenance building opposite the Pentland Cemetery was eliminated.  The other 50 items were either ignored, or even explicitly blown off by Windlectric.  In spite of this total disregard for the Council, the MOE judged that Windlectric’s REA application was complete.

As just one example of how Windlectric and now the MOE have ignored the local government, consider Council’s concern about the narrow streets in Stella and how hundreds (if not thousands) of cement truck loads would impact the residences, many of them heritage properties.  Here is the wording Windlectric used in response, in the Heritage Assessment, section 5.3.25.

“With respect to any necessary road improvements that may be required, widening of paved roads, gravel shoulders, etc., should be avoided throughout the Stella CHL, and if such widening cannot be avoided for the Project, improvements should be designed as to not impact on the heritage character of individual and collective heritage resources.”

Windlectric “should” avoid reworking the streets there, but apparently if it is convenient they can go right ahead.  They’ll “try” not to impact the homes, but if it is convenient it seems that they can go right ahead with that as well. It is up to Windlectric, and only Windlectric, to decide what can and can’t be avoided and what impacts are acceptable.  No wonder the Council found the draft documents inadequate.  Sadly, the final documents do nothing to fix their concerns.

The history of large corporate projects shows developers will disregard the damage they do to the locals to the extent the government will allow them.  After all, their prime responsibility is to their shareholders.  It is shameful that the MOE has allowed this impending disaster to continue.  I urge the MOE to think seriously about what their decisions will do to the residents of Amherst Island and force Windlectric to come up with real studies and real plans before they are given carte blanche to proceed.

Submission #2

The list of reasons the Windlectric project on Amherst Island should be rejected is rather long and includes damage to wildlife (much if it endangered), damage to the health of the residents and damage to the Island’s heritage properties.  The residents of the Island and the local government have made numerous serious submissions to the MOE that have conclusively demonstrated just how much damage would be done by this project.  In spite of this mass of evidence it seems that the MOE is likely to approve it.

I had considered reviewing this evidence in several personal submissions to the MOE but decided it was a waste of both of our times. It seems that the MOE is inclined to accept without question the studies submitted by the proponent, Windlectric, and their contractor, Stantec.  And it also seems that the MOE is inclined to reject again without question the studies submitted by the Islanders.

I have to ask: what level of evidence would it take to convince the MOE to ever stop a project?  Does that level of evidence even exist?  So far it seems not.  Imagine the most sensitive areas in Ontario, areas like Ostrander and Amherst Island.  What would ever get the MOE to not approve a project in such an area?  Is there anywhere in Ontario, at least rural Ontario, where a project would not be approved?

As I relate this situation to my American friends at first they don’t believe it.  When the details are exposed they are incredulous.  When in a hole the most important thing to do is to quit digging.  Rejecting Windlectric’s proposal for Amherst Island would be an excellent way to do just that.

APAI Goes to Court

APAI, the Association to Protect Amherst Island, has filed a lawsuit in the Ontario Superior Court of Justice that contests the MOE’s acceptance of Windlectric/Algonquin’s proposal as complete.  The objective of the suit is to get the court to review the MOE’s acceptance and discover how the MOE didn’t follow the requirements of the law when they issued this acceptance.  And finding such, to overturn the acceptance and force the MOE to force Windlectric to do a more serious study of the project’s impacts before proceeding.

LINKS

The Kingston Whig article, March 6, 2014

APAI, Press Release

WeirFoulds, serving papers

APAI on Public Safety

APAI has recently sent a letter to the MOE detailing the problems the project has with respect to handling emergencies.  It goes for 11 well-written pages, followed by a 3-page snailmail/email exchange with Ontario’s fire marshall. Careful if you’re on dial-up, it’s almost 15 MB, due to the pictures.  I recommend reading the letter in its entirety.  It is remarkable just how vulnerable the island would be.

APAI, Public Safety Letter

The letter starts out be reminding the MOE of the requirements of the GEA for the proponent to create:  “measures to provide information regarding the activities occurring at the project location including emergencies.”  The letter goes on to remark on the following 10 aspects of emergency responses:

  1. Municipal consultation form:  Loyalist has rejected the submission as inadequate.  Earlier post.
  2. Island contraints: everything must come by ferry.
  3. Water supply: must be sucked out of the lake, no hydrants or other supply.
  4. Fire department: good people, limited equipment.  Earlier post.
  5. Island roads: lightly traveled, not up to mainland standards.
  6. Ambulance protocol: the ambulance must come from the mainland.
  7. Response times: first responder averaged almost 12 minutes, ambulance averages over 30.
  8. Fire incidence: especially marsh fires.  Earlier post. And this.
  9. Turbine emergencies: no way for local department to handle.
  10. Turbine toxicity:  there’s some nasty stuff up there.

The simple fact is that Algonquin has never submitted any even minimally-acceptable emergency plans, and the MOE seems not to care.  As their proposal has been deemed “complete” we the public have only until March 9 to comment upon it.  But how can anyone comment on something that doesn’t exist?

The 3-page exchange at the end is also illuminating (it’s in reverse chrono order).  Deborah Barrett writes to the Ontario fire marshal asking for his assistance in getting the MOE/Algonquin to come up with an acceptable plan.  He replies after a month that the GEA requires municipal consultation.  Apparently he believes that this should be sufficient.  I guess he has a different idea of what constitutes “consultation” than the MOE, which thinks of it as a one-way deal.  Debby quickly responds that the project is proceeding regardless of any municipal consultation.

The proponent and the MOE will likely dismiss all of this as just Nimby Noise, saying that the odds of an emergency are pretty small.  I’d agree, they may be small, but they are not trivially small.  Regardless of how large or small they may be, it is pretty much standard practice in modern western countries to have plans, people, equipment and materials in place to handle problems.  I guess those standard practices are no longer being followed in Ontario.

APAI Letter to Wynne

APAI wrote a letter to Kathleen Wynne late in January, requesting that her government take a look at the cumulative effects of all the industrial projects now underway on and around Amherst Island.  Right now there are 4 major projects in the works: Windlectric’s wind turbines, MOT’s ferry dock, TransCanada’s gas generating plant and LaFarge’s cement plant expansion.  As the letter states, “To call this ‘public consultation’ is ludicrous. It is simply impossible for the Association and the Island community to make meaningful comment when the Government has not put in place the processes required to fully understand the impact of multiple concurrent projects.”

The letter is 3 pages long and is well worth a read, and provides a sense of just how angry most island residents are at the government’s continuing disregard for their welfare.  The last 4 pages are copies of the public notifications of 3 of the 4 projects (LaFarge hasn’t been published yet).

APAI, Letter to Wynne

APAI Bulletin #8

APAI published bulletin #8 several weeks ago and I am just now getting caught up and posting it here.  It deals mostly with giving ideas to those who want to send a comment into the MOE following Windlectric’s application being deemed “complete”.  The public comment period runs until March 8, 2014 and I would urge everyone to write in and voice their opinions on the project.  Unfortunately, the MOE seems to be completely under the control of the developers, so I cannot offer much hope that any comment will have any effect.  Still, if you do comment at least you know you did what you could to stop this project.

APAI Bulletin #8

Who Runs the MOE?

On January 2, 2014, the MOE posted the Amherst Island project on the EBR for public comment.  This is a significant step forward for the project, as the MOE now regards the draft documents Algonquin submitted as complete, in spite of widespread submissions that the draft documents were anything but.  Within 10 days of the posting, Algonquin was due to post their final documents, and the 60-day window for public comments would begin.

But a strange thing happened.  Within the description of the EBR posting, the area being studied was listed as Lots 29 to 76 in Concessions 1, 2 and 3.  If this were true, it would reduce the project to a fraction of what it was originally – of the 36 turbines in the draft plan only 16 are left.  Below is a clickable picture with the original turbines in red and the “new” project area in green.ai-ebr-pic-140105

For the human residents of Amherst, this new picture was very good.  It eliminated most of the turbines that were close to the far more numerous shoreline properties.  I and most of the anti-wind campaigners didn’t put much credence in this picture, as it almost certainly would have made the project non-viable.

However, the lot and concession numbers were not accidental.  If the MOE wanted a project that protected the residents as opposed to one that provided Algonquin with profits, this is what they’d likely come up with.  So maybe, just maybe, the MOE finally decided to stand up to the wind industry and actually protect the neighbors.

Numerous inquiries were made of all the appropriate parties.  By Monday the 6th, it was reported by Algonquin (not the MOE, curiously) that the EBR posting was inaccurate and that the project remained basically unchanged from the draft documents, and that the posting would be corrected.  Dutifully, on January 7 the January 2 EBR posting was replaced with the offending location now changed to “Various locations, Loyalist Township, County of Lennox and Addington”.  Algonquin’s deadline was also moved back, as was the 60-day public comment period.

“Various locations”?  Are they kidding?  The MOE posts it and isn’t aware, apparently, of the locations where the project will have impacts?  This entire episode raises a number of questions.  What was the intention of the MOE by posting it?  You cannot creditably claim it was a typographical error.  Perhaps the MOE had several alternative project plans and grabbed the wrong folder when it came time for the posting.  But that’s a pretty significant miscue on the MOE’s part, indicating at the least that the MOE is fundamentally incompetent.

Other explanations are worse.  Was the January 2 posting a surprise to Algonquin? Did Algonquin call the MOE to complain?  Did the MOE, in response to the call, make the changes?  If this scenario was the case, we shift from fundamental incompetence to outright corruption.  Or, was this the MOE’s idea of a sick joke, something to give the natives some hope before dashing it.  Now we’re into psychopathic corruption, something North Korea seems to be fond of.

Kathleen Wynne, the Ontario premier, has made noises about running a more transparent government, particularly with regard to the wind turbine issue.  So far, that’s all it’s been – noises.  This would be an excellent time for her to show us all that she means what she says; by performing an investigation that supplies us with truthful answers to these and other questions about this affair.  I am not holding my breath.

Hatch’s Map

Some members of APAI (the anti-project group, the Association to Protect Amherst Island) decided to send a one-pager to all the island residents letting them know what to expect in terms of noise and flicker.  As they dove into the developer’s noise map and flicker study they quickly discovered that the noise map was largely unusable and the flicker study made no sense.

As a result, one Deborah Barrett, who fairly recently moved to the island, wrote a letter to Doris Dumais at the MOE, stating that in view of such shoddy work the application ought to be deemed incomplete and returned to Windlectric/Algonquin.  The letter is six well-written pages long and is very readable, and it gives you a sense of just how uncaring/careless/arrogant/entitled (your pick) the wind project developers are.

LINKS

Barrett, Letter to Doris Dumais

Windlectric/Stantec/Hatch, Design and Operations Report.  The map in question is on pdf page 124 of the 147 pages.

Windlectric/Hatch, Flicker Study.  Their table B.1 lists the amounts of flicker the affected receptors get, and it makes no sense.

Update on AI Viability

John Harrison has just published his updated study of how the project on Amherst Island is not financially viable.  This is the third of these studies, the previous two were also published on this site, here and here.  The overall conclusions remain the same, that given any reasonable set of parameters this project is a loser, even for Algonquin.

This study has one major new area: it estimates the costs of decommissioning and provides an estimate of the scrap value of the wind turbines.  Wind project developers typically claim that the scrap value will cover the decommissioning costs, so the neighbors shouldn’t be worried about having a rusting junk yard at the project’s end.  Harrison’s study doesn’t support this; decommissioning at Amherst will likely cost multiple ten’s of millions of dollars while the scrap value will almost certainly be less than ten million.  I have an earlier post on this topic.

Another noteworthy part of this study is that Harrison now has one more year of observations on the decline of capacity factors with age, and this additional year confirms the earlier observations.  Below is his picture of Ontario’s measured normalized output.  I’ve been posting on this topic for some time over at windfarmrealities.
harrison-decline-130922

APAI – Fire and Decommissioning

In the last month APAI has written two more letters to the powers-that-be.  The first one concerns fire protection and the second decommissioning.

First, fire protection.  Back in October of 2011 the Ontario Fire Service, part of the Ontario Ministry of Labor, issued a Guidance Notice concerning fires in wind turbines. This Guidance Notice contained a list of general planning steps that were recommended.

“In cooperation with the wind turbine owner, fire departments should develop response safety plans that address issues such as:
1) Access to sites and contact numbers (24/7) for site supervisory staff
2) Safe collapse zones
3) Rescue options for workers trapped in the nacelle in non-fire situations
4) High-voltage components and combustible materials within the wind turbine.”

In February of 2013 APAI sent a letter to Algonquin, asking if Algonquin had prepared such plans.  No answer was ever received, leading APAI to conclude that “Algonquin is ignoring ‘Fire Fighters Guidance Note # 6-35: Issue: wind turbines,’ and, apparently does not consider safety from fire on Amherst Island to be a priority.”

In August 2013  APAI wrote a letter to the Minister of Labor, seeking “further advice on this matter.” 

APAI, Letter to Minister of Labor, plus attachments

Second, decommissioning.  Algonquin has stated that it is responsible for decommissioning the turbines at the end of their lives.  What they haven’t done, and are apparently unwilling to do, is to put up a bond or escrow to insure that this is done.  Algonquin is claiming, in what seems to be an industry-wide practice, that the salvage value of the turbines is enough to provide for their decommissioning.

There are at least two problems with this.  (1) what about the stuff that has no recycling value?  Or, even worse, no method of safe disposal at all?  The blades come to mind.  (2) Will the salvage value actually cover the decommissioning?

John Harrison did some research and discovered that the value of the materials, in current dollars, is a little over $6M, while the labor to install the turbines (and probably close to the labor to take them down, according to Stantec) is somewhere about $100M.  Recall that these materials are on an island and will have to be taken down and transported to an industrial recycler.

In August 2013 APAI sent a letter to Algonquin, reviewing these numbers and opining that these costs (assuming Algonquin actually ends up being responsible for them) make the Amherst Island project that much worse of a business proposition.

APAI, Letter to Algonquin re Decommissioning

My Submission

On July 10, 2013 the MNR posted Windlectric’s request to provide an “overall benefit” to 3 threatened grassland bird species.  I’ve read through the request and I am baffled at how building this project, even with their “mitigations”, will do anything but harm those species, along with many others.

I’ve submitted my comments to the MNR and I can only hope that at some point the MNR will put an end to this madness.

LINKS

Gulden, Submission to 011-9446

APAI Bulletin #5

APAI Bulletin #4

MNR, EBR Registry # 011-9446

Stantec, Species at Risk Report

Letters! APAI Bulletin #5

APAI has released Bulletin #5.  This one focuses on the MNR’s EBR (that’s the Ministry of Natural Resources and the Environmental Bill of Rights) Registry entries regarding the wind project at Amherst Island.  The first EBR (#011-9446) was published on July 10, 2013 and concerns the harming of 3 threatened bird species.  The second (#011-9443) was published on July 17, 2013 and concerns allowing Algonquin the use of Ontario crown land, namely the lakebed.  The bulletin gives all the details on how you can write letters to the MNR to let them know how you feel about these matters.

LINKS

APAI, Bulletin #5

MNR, EBR Search Page, where you can enter the above numbers and look at what they’ve posted.

Harrison to the MOE on Noise

John Harrison has been studying the noise produced by wind turbines for a number of years.  Recently he submitted a report to the Ontario MOE going over (yet again) the many reasons the actual measured noise levels are far above what the Ontario noise limits and even farther above what was predicted by the proponents.  He has every reason to believe that the actual noise levels that will be experienced by many of the residents of Amherst Island will likewise be above Ontario’s limits.

His evidence for this belief is substantial.  In this report he presents 3 case studies where the measured noise levels were above Ontario’s limits.  Two of those case studies (Lormand/Ashbee and Libby) have appeared on windfarmrealities previously.  Added is a case study at an unknown location in the Melancthon area.

If history is any guide, the MOE will do everything in their power to deny the obvious in their zeal to keep the wind turbines turning.  With this report, along with many others, they cannot claim ignorance.  So allowing the violations must be willful.  I’d think there would be a lawsuit in there somewhere.

LINK

Harrison,  SOUND PRESSURE LEVEL COMPLIANCE TESTS

 

Kill, Harm, Harass, and APAI #4

On July 10, 2013, the Ontario MNR published a notice on the EBR for Amherst Island.  The project developer, Algonquin/Winlectric, requested a permit since their project “has the potential to adversely affect Bobolink, Eastern Meadowlark and Eastern Whip-poor-will habitat“,  all of which are threatened.  One has to ask, what part of green is a project that has these types of adverse effects?

APAI just issued bulletin #4 which exhorts people to write responses and send them to the MNR.  No doubt APAI will have its own response as well.

LINK

APAI, Bulletin #4

Bolstered by Ostrander

The Kingston Whig has a short article with APAI’s (in the person of Peter Large) reaction to the Environmental Review Tribunal’s reversal of the Ostrander Point project.  He said most opposition people were happy that, finally, a project got turned down.  Whether that will help or even possibly hurt the chances of stopping the Amherst Island project remains to be seen.  A case can be made either way.

LINK

Kingston Whig-Standard, July 5, 2013, Wind Farm Opponents Bolstered by Decision

Ostrander and Bulletin #3

Just yesterday the environmental review tribunal revoked the MOE’s approval for Gilead’s Ostrander Point project.  This was the very first time in Ontario that a wind project has been rejected.  I’m not sure what recourse Gilead has at this point.  I imagine they could come up with a new plan and new mitigations but at some point you’d think they would just cut their losses and run.  The fact that Gilead is willing to undergo all this effort and expense for 9 wind turbines shows just how lucrative they must be.

This ruling may be important for Amherst Island, as they are close together (30km), have similar characteristics and similar wildlife issues, including Blanding’s turtles.  APAI issued bulletin #3, which celebrated the Ostrander Point decision and related its relevance for Amherst Island.

LINK

APAI, Bulletin #3