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.

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