Tag Archives: Environmental Reports

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

 

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.

AI – November 5, 2011

Stantec has just released the second draft environmental report, dated November 2011.  It follows the first draft report which was dated May 2011, and about which I’ve already posted.  There are two significant differences.  Most importantly Algonquin has replaced the Vestas 1.8MW turbines with Siemans SWT-2.3-113 turbines.  These are monsters.  They sweep a full 10,000 sq meters, compared to 7850 for the Vestas.  The blades are 113 meters in diameter, compared to 100.  From the ground to the tip is about 156 m, or 512 feet.  The second change is some waffling on the temporary dock –  it is now either a temporary or permanent dock, to be decided.  Still Stantec is confident they won’t trigger a federal environmental screening.

For the neighbors this change of turbines is probably bad news.  Although Stantec hasn’t released as much information about the Siemans as they did about the Vestas, my calculations show that they are slightly less efficient at pulling energy from the wind, but have a wider wind speed operating range.  Of more concern is that the larger and higher blades will create more turbulence and be more affected by wind shear – thus producing more noise.  A recent study showed that turbines closer than 15 diameters lost efficiency due to turbulence, and on narrow Amherst Island there’s little doubt the turbines will be closer than that.

Links:

AI – September 20, 2011

September 20, 2011. I’ve had some time to read over the Notice and the Draft Report from Stantec that was posted on the project web site, amherstislandwindproject.com. Here’s some quick comments.

  • The project study area has enlarged and moved since the first Algonquin public meeting several years ago. The KFN property is now included, and the grid connection point which used to be a Lennox (which was an obvious point) is now west of route 4, in the Taylor-Kidd industrial area.
  • The Draft Report mentions a “temporary” dock, location unknown. I have to assume this is an effort to avoid triggering a Federal Screening, which would likely further trigger a Cumulative Envirnomental Assessment. I’d bet the dock will end up being “temporary” only in the sense that the 40-year+ span of the project is temporary. It is nonsensical to think anyone would support a quarter-billion dollar project with a temporary facility. I just hope the Feds don’t fall for this.
  • They are planning on using high-efficiency, low-wind-speed (Class III) turbines, Vestas V100-1.8MW models. They will install anywhere from 28 to 42 of them, for a capacity of 56 to 75 MW. There’s no indication of where they will be placed, or where the substation will be. I’m unaware of any Vestas plant in Ontario, so exactly how Algonquin will be able to certify the Ontario construction quota is unknown. I suspect they’ll come up with some scheme acceptable to the government – a pretty low bar, to be sure.
  • Algonquin expects to submit the final report in June 2012, and get approval to proceed in December 2012. Construction would start shortly afterwards with the project going live in February 2014.
  • What about the birds? From the Draft Report: Birds, mammals, amphibian and reptile species are known to use the Project Study Area. Construction and operation of the Project has the potential to disturb wildlife (including mortality from direct collisions with project infrastructure) and wildlife habitat.The majority of Project infrastructure will be located on lands that are already a source of disturbance to wildlife, including right-of-ways and agricultural lands.
  • So you can see they are already minimizing Amherst Island’s world-class bird populations. Stantec presided over Wolfe Island’s destruction as an excellent habitat for birds; I guess they are going for a repeat on Amherst.

AI – August 11, 2009

August 11, 2009. As mentioned earlier (August 2008), the Federal government (in addition to the Province) has an Environmental Assessment process that gets triggered by a variety of circumstances.  I opined that Windlectric would do everything in their power to avoid these triggers, as: 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. A Cumulative Effects Assessment would be a big deal, covering the entire eastern end of Lake Ontario. One of the triggers is if the Federal government: Exercises a regulatory duty in relation to a project, such as issuing a permit or license that is included in the Law List Regulations. Amherst is an island and is separated from the mainland by a navigable body of water. The necessary underwater power cables thus require a permit (as they did on Wolfe), which would trigger the EA, which in turn would trigger the CEA. There have been rumors – which they will not comment on – that Algonquin has abandoned the project. There are also reports that Gaia/Windlectric has started releasing some option grantees from their obligations, and reducing payments to others. If this is significant remains to be seen.