I just couldn’t help myself. I sent in a second submission about Windlectric’s bid to get a permit to “adversely affect” three threatened bird species. This one is quite different from the first one, but still focuses on the inevitable failure of Windlectric to really benefit any of these species.
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.
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.
MNR, EBR Search Page, where you can enter the above numbers and look at what they’ve posted.
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.
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.
Kurt Hennige has conducted a study of birds of concern on Amherst Island. A summary and neato-keeno map are now available to convey the results to all of you. In summary, he looked at the numbers of Bobolinks and Meadowlarks on the island and found large numbers of both. The summary and link to the map can be found at:
Ontario’s Ministry of Natural Resources (MNR) is well aware of Amherst Island’s value as bird habitat. Whether MNR cares is an open question. Judging by their decisions at the Summerhill project the indications are not good. NextEra, the developer there, was given a permit to remove an active bald eagle nest. Just as bad as the decision itself was the dishonest way MNR handled the entire affair, as I documented at Windfarmrealities.
Reaction from the public was swift and furious, not that MNR apparently cares. There was also reaction from Amherst Island.
The Whig reported that Peter Large, acting on behalf of APAI, sent a letter to MNR Minister Michael Gravell urging him to not approve the project. Given MNR’s interest in protecting wildlife, the letter emphasized the significant avian population on the Island. It also mentioned that an independent study conducted by a well-known ornithologist has been undertaken.
The Kingston Field Naturalists have been concerned for quite some time about the planned proliferation of wind turbines around the eastern end of Lake Ontario. Below is a picture of what they are talking about, from ontario-wind-turbines.org.
Under their auspices, two naturalists studied the bird traffic that flies through the above area every year. No surprise, lots of birds – huge likely slaughter. The Kingston Whig-Standard has an article on their findings.
APAI has put together a very nice 10-page document on how the Amherst Island wind project will seriously degrade the habitat of the numerous threatened and at-risk species who inhabit it.
During this last winter one of my guests was a photographer and got these pictures of a snowy owl. Algonquin and Ontario have little right to cause the type of anguish to people they will cause when the project goes in. But to put these magnificent and increasingly rare creatures at risk is downright pathological. Clickable.
Bob Runciman is a member of the Canadian Senate, which under Canada’s parliamentary system isn’t nearly as powerful as, for example, the United States Senate. Several months ago he sponsored a bill in the Senate which called for a moratorium along the northern shore of Lake Ontario from Wolfe Island to Prince Edward County, specifically including Amherst Island, due to the importance of this area to birds and bats. The bill was passed unanimously.
Unfortunately, the Province controls the wind turbines and thus far they have ignored the call for a moratorium and Runciman himself. Won’t even return his calls. In an effort to bring more heat on them he went on Goldhawk Fights Back to discuss the moratorium and the hypocrisy of destroying bird and bat habitats in order to save them. The 22-minute program is well worth listening to.
The Cataraqui Region Conservation Authority has issued a report concerning the project on Amherst Island. The CRCA is a regulatory agency that reviews development permits in the area around Kingston. They are also the owner of about 90 acres that abuts the Owl Woods, an internationally-recognized wintering spot for large number of owls of differing species, some of which are quite rare.
Their concerns with the project are summarized in the following paragraph:
Information and discussions with the proponent indicate an awareness of the ecological features of Amherst Island (owl woods, wetlands, forests, aquatic features etc). The extent to which these features are being addressed or investigated is not clearly understood (in part related to the required timing in the approval process).
By “not clearly understood” I think they really mean “likely to be ignored” but they are far too diplomatic. The Report goes on for 7 pages containing some of the details of their concerns.
“You’ll toast your bread in the blood of owls” is the title of a posting on Doug Green’s blog. Doug is a resident of Amherst Island. His business is gardening, and he has written a number of books on the subject and runs a successful gardening business.
I urge you to read this essay. At the end he asks: And yet, this green energy “solution” is beloved by politicians and city consumers. You’ll heat your waffle iron in the blood of our owls. And that’s all right with you?
Bob Runicman represents the Thousand Islands and Rideau Lakes in the Canadian Senate. Recently he introduced a motion calling on Ontario to place a moratorium on more turbines between Wolfe Island and Prince Edward County, including on Amherst Island.
The Senate voted unanimously to back this motion. While it makes for a nice sentiment, the resolution won’t have any significant effect, as the government of Ontario is in control of these projects. Still, it was nice to see that we obtained somebody’s attention.
July 10, 2011. The APAI made up this flyer about the likely effect of the turbines on AI’s famed raptor population.
December 11, 2008. Over on Wolfe Island the Federal final screening report, 0.5mb. has been issued and there were some additions to it that concern Amherst Island (section 8.4, page 59). I have extracted that section below and added my commentary. You might also visit the Wolfe Island Bird Page just to see what is in store for Amherst. I hope the raptors on both islands will adjust to the turbines; but if they can’t, there will be no effort to save them.
As part of the regulatory oversight of wind projects, the federal government conducts an assessment of the developer’s plans and approves them. As part of Wolfe Island’s process, this Screening Report, 0.5mb. was issued by mostly NRCan (Natural Resources Canada). It contains a summary of the enviromental issues and my larger commentary upon it is contained in the Wolfe Island commentary on this site. One section (8.4, page 59), added to the final report, concerned Amherst Island.
To provide some background, when a project might be part of a larger environmental problem than just itself there ought to be some consideration of the larger problem. In WI’s case, while that project in itself might not be globally significant to (for example) migrating birds, the WI project in conjunction with 500 other proposed turbines around the eastern end of Lake Ontario might be. Such a study would be a big deal, potentially involving the United States and treaty obligations.
CREC dodged the bullet by saying that AI would not be developed in the “foreseeable future”. So CHD (CREC’s parent) dropped out of AI’s project, thus washing its hands of the problem. But that didn’t stop others from picking up the options and proceeding with a new project on AI. The kindest thing that can be said is that CHD could forsee very little future. My guess is that the whole dodge was planned by all the parties long before the switcheroo happened. The section below covers the government’s response to this ploy.
I’ve reproduced most of section 8.4 below, and within the brackets inserted my commentary on it. Before getting to the text, I thought I should explain some of the abbreviations.
- ERR = Environmental Review Report, the scaled-down EA, created by CREC, my commentary is on the WI bird page.
- EA = Enviromental Assessment, the full monty of assessments, never done.
- CEA sometimes = Canadian Environmental Assessment, the catch-all term for the process.
- CEA but also = Cumulative Effects Assessment, the study of the larger problems, if any.
- CEA which is sometimes = Cumulative Environmental Assessment.
- WIWP = Wolfe Island Wind Project, the project being developed on WI by CREC
- PCFP = Post Construction Follow-up Plan, created by CREC, my commentary is on the WI bird page.
- EC = Environment Canada
- MNR = Ontario Ministry of Natural Resources
- CHD = Canadian Hydro Developers, CREC’s owner. CHD also had a number of options on Amherst Island.
- CREC = I have no idea. Probably Renewable Energy something. They were bought up by CHD after CREC got WI started.
Now we start the text in section 8.4.
Cumulative Effects Assessment – ERR
[There’s 5 paragraphs in here restating the history of the ERR. You can read them if you wish by using the link to the entire report above.]
Future Wind Power Projects – Requirements Beyond the ERR Commitments
As documented above, the ERR included a CEA and considered other reasonably foreseeable and certain projects within the study area, including wind energy projects, in arriving at its conclusions. For continued reference, the CEA spatial study area included the tip of Amherst Island. In developing the WIWP, Canadian Hydro relinquished its land rights to a wind plant on Amherst Island. However, it is understood that a wind farm has been recently proposed on Amherst Island by another proponent.
[No surprise here.]
In the event that a wind plant is developed on Amherst Island, or any other new wind energy facilities are proposed within the Project’s CEA study area, it is expected that the new project(s) will conduct a cumulative effects assessment if a federal EA is triggered. This should include the WIWP and any other reasonably foreseeable and certain projects at that time.
[This sounds good, but it has two problems. First, the word “expected”. Not “required”. Second, only if a federal EA is triggered. There’s a number of ways to avoid triggering a federal EA and I’d bet Windlectric will explore all of them. Perhaps they will maintain that “federal EA” means “full (comprehensive) federal EA”, and no wind project in Canada has ever triggered a full federal EA.]
[I guess there’s always a chance the Federals will have a change of heart and actually take a hard line on enforcing this. A properly done CEA covering the eastern end of Lake Ontario would take years and cost a ton of money, probably dooming the project. Unfortunately, my observations of the Feds’ decisions regarding Wolfe lead me to the conclusion they’ll approve whatever study (if any) Windlectric comes up with, however poorly done. Just for reference, here’s a paragraph that decribes a CEA, from Parks Canada.]
[A Cumulative Environmental Assessment (CEA), as opposed to an Environmental Impact Assessment (EIA), considers the effects of all previous, existing and foreseeable future developments in a given area or resource. It considers both the progressive addition of materials to and the progressive removal of materials from the environment. So when we investigate the cumulative effects on a park, we have to assess not only the potential environmental impacts of a specific activity, but also those impacts from other developments – previous, existing and foreseeable future.]
It is also reasonably expected that, as appropriate, the new project will develop and carry out a PCFP based upon the conclusions of its cumulative effects assessment and with regard for the WIWP. It is each proponent’s responsibility to plan, monitor, and fund their own project.
[The WI PCFP does nothing to mitigate any degradation of habitat on WI. Oh, there’s the mitigation banking provisions, but as I explain on the WI bird page, they are useless. Actually worse than useless, as they provide a green cover for developers who inflict great environmental damage. And I’m betting there won’t be any CEA to begin with, so no conclusions, eh? Notice the separation of the projects in the last sentence.]
Nevertheless, the following outlines the actions that CREC must be willing to take should a new wind plant be developed within the WIWP CEA study area and/or on Amherst Island that, in combination with the effects at the WIWP, has a demonstrable potential to result in significant cumulative adverse environmental effects.
[As you’ll see below, the “actions” aren’t much. And they, as little as they may be, are only taken after a “demonstrable potential”. As the demonstration is entirely under the control of the developer, I’d bet it never occurs. ]
1. Since the completion of the ERR, a PCFP for birds and bats for the Project has been developed. The PCFP was designed within the context of the conclusions of the WIWP’s ERR (e.g. to confirm predictions, identify and adaptively manage any unanticipated adverse environmental effects so they do not become significant). During the timeframe for which the PCFP for the WIWP is being implemented, CREC will be open to discussing with EC, MNR, and NRCan whether its PCFP should be reasonably revised.
[As mentioned elsewhere, “adaptively manage” translates to mitigation banking, and is just bullcrap. And CREC will be “open” to discussing? They’re not even promising to discuss, let alone do anything about it. This section was supposed to have been written by NRCan, but it sure looks like CREC actually wrote it.]
Such a revision may include select study alignment between two projects such that comparisons may be reasonably drawn from the datasets and/or data sharing between projects. For clarity, however, CREC will not be responsible for the impacts, costs, etc., of another project nor have to extend their monitoring program due to effects of another project that is commissioned after the WIWP.
[Sharing data? Boy oh boy, that’ll certainly fix things. Then comes the big disclaimer. In other words, whatever we do will be done at our pleasure.]
2. If, during the time for which the Project is operating, CREC is required to implement adaptive management measures to address unanticipated adverse environmental effects so that they do not become significant, and if the other project is materially impacting on the same valued ecosystem component/species, CREC will be open to discussing with the other wind farm proponent whether a collaborative mitigation plan would be appropriate to address these cumulative effects (e.g. joint purchase of land to gain a larger contiguous area of appropriate habitat).
[Another “open to discussing” statement. No committment. And note their example – they buy some crap land somewhere else and claim it represents appropriate habitat. I ask my readers to just think about how ridiculous that is. For wintering raptors, there are only 4 – that’s right, 4 – areas in all of southern Ontario that are appropriate. WI and AI are two of them. And buying one of the other two doesn’t represent much of a fix, does it? ]
Taking the above into consideration, significant adverse environmental effects are not likely to occur as a result of cumulative effects.
[I’m not sure what they base this conclusion on. I have never seen a study that would answer the question one way or another. In the meantime, they are throwing caution to the wind, and have no plans to fix whatever problems arise.]
November 7, 2008. We assume Windlectric has submitted their bid to the OPA, but of course nothing is public yet, and won’t be until December or so. In the meantime, John Harrison sent this letter, 0.4mb to the OPA. It outlines some reasons they should carefully evaluate (and in John’s opinion, reject) the bid response from Windlectric. Unfortunately, it seems that the OPA does not have a mandate to be responsive to public comments, per this letter, 8kb. UPDATE – The OPA put out bids for 500mw of renewable power in this RFP, with 1500mw to follow later. There are 38 responses to this RFP and if I guess the average capacity is 100mw only a few of the proposals will be accepted. I’ve been checking the OPA web site for any new news and when I hear I’ll post it here.