As part of the approval process for any Ontario wind project the local government can fill out a Municipal Consultation Form. This form can contain the areas that are of local concern. Unfortunately, while the Province provides for this consultation it is then up to the Province (and only the Province) to see that these concerns are addressed. To date, the Province has been pretty much rubber-stamping everything the developers are submitting, so these consultations are only for show. The projects continue to be built, regardless of the problems they cause for the locals.
The Loyalist Township Council has produced an 84-page report [backup copy] that includes not only the Municipal Consultation Form but also a number of studies and comments that are indicative of just how much there is to lose on Amherst, plus Algonquin’s plans are so deficient.
Sections of Council’s report
(page numbers are from the pdf reader):
- Opening Comments, pages 1-12
- Maps and Charts, pages 13-19
- Municipal Consultation Form, pages 20-28
- Additional MCF Comments, pages 29-31
- AECOM’s report, pages 32-45
- CRCA’s report, pages 46-59
- Heritage Committee’s report, pages 60-65
- Cemetery Committee’s report, pages 66-72
- Pentland Cemetery report, pages 73-74
- Shadow Flicker report, pages 75-80
- Holman’s Cultural Landscape letter, pages 81-84
Most of this is quite readable on its own but of course I’ve got some additional comments.
The draft reports prepared by the developer (Algonquin) were passed around to both the Township’s internal departments and two outside peer-reviewing groups, AECOM (an engineering firm) and CRCA (Cataraqui Conservation Authority). In addition several quasi-government groups had input as well. Their concerns included the following:
- Cultural Heritage
- Natural Heritage
- Noise – Batching Plant
- Building Permits
- Emergency Management Procedures
- Groundwater concerns
- Pertinent By-laws
In every one of the above topics there are substantial issues, things like having the batching plant 750 metres upwind of the school, when Ontario’s normal industrial classes would assign a 1000-metre “influence area” to such an operation.
This section of the report is certainly readable so I won’t go through everything here. The money sentence is on page 4: “The [developer’s] consultant’s reports, as presented, lack detail that is necessary to provide informed comments and, as specifically stated by AECOM and the CRCA, an approval of the project is premature until the full scope of the project with an appropriate level of detail is supplied enabling a proper assessment of impact on municipal infrastructure, the natural environment, cultural heritage, and land use compatibility.[my emphasis]”
Municipal Consultation Form
Note that this consultation form addresses only the areas allowed by the Province; major concerns such as health impacts and property value losses are not allowed. Here’s the sections on the form (paraphrased by Council):
- Infrastructure and servicing
- Road access and related issues
- Traffic and related issues
- Municipal service connections other than roads
- Emergency Management procedure/safety protocol
- Easements or covenants
- Issues or recommendations with respect to the proposed rehabilitation of any temporary disturbance area and any municipal infrastructure that could be damaged
- Location of fire hydrants
- Location of buried kiosks and above grade utility cables
- Proposed location of existing and proposed gas and electric lines
- Building permits and licenses
- Significant natural heritage features and water bodies
- Archaeological and heritage resources
Of the 9-page form the first 5 pages are filled out by the developer. The remaining 4 pages, although crammed with Council’s concerns, aren’t enough to hold them all – so Council added 3 more pages of comments to the form, starting on page 29.
Will any of this do any good? While the local government can submit the Consultation Form, it is the Province that decides what items the developer has to actually deal with. So far the history is that the Province (in this case, the Ontario MOE) will approve whatever the developer has submitted. Even with the recent change in leadership there is no reason to believe the rubber stamp has been retired. If nothing else, I applaud Council for trying.