AI – December 11, 2008

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.]

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