From: Gilbert <barrie_gilbert@hughes.net>
Date: June 27, 2007 4:11:11 PM EDT (CA)
Subject: wind project/ Wolfe Island
27 June 2007
Hon David Ramsay
Minister of Natural Resources
6630-99 Wellesley St.W, 6th Floor, Whitney Block
Toronto, Ontario M7A lW3
Dear Mr. Ramsay,
As a resident of Wolfe Island and a professional wildlife biologist I am very concerned about the proposed wind project’s effects on native birds, mammals (especially bats), reptiles and amphibians. I wish to request that you review the questions that I raise below, provide me with your assessment of Stantec’s environmental analysis process and the nature of their biological impact study (data and results). I believe that an assessment of the natural resources of Wolfe Island will show that this is an especially inappropriate location for an industrial wind project.
Regarding the ERR process; Ontario’s guidelines point out that minimizing biological impacts depends crucially on appropriate site location of turbines. But I have learned that site selection was completed before the draft ERR was completed! This means that little if any consideration was given to biological aspects including the flight patterns of tens of thousands of waterfowl and raptor aggregation in winter. Indeed it appears that the nature of the biological sampling was so superficial as to be unable to define these flight paths and concentrations.
The Wolfe Island Wind Project is a very large industrial scale wind energy development. In view of the scale and variety of effects on Island residents and wildlife it is crucial that the rigor and scale of the scientific effort to predict impacts needs to be comprehensive over time and space. The exceptional value (IBA, ANSI) and protection by international treaty of the wildlife resources, both resident and migratory, makes the question of whether there should be any turbine introductions a real and relevant issue.
First, the title of the report “Environmental Review” is misleading. The term “review” suggests that there is, contained in the Report for “review”, a summary of scientific studies, field reports, data or analyses of potential negative impacts. Typically the standards for professional environmental assessments of possible or anticipated environmental impacts of a major project require that the consultant(s) search as many relevant scientific reports on empirical studies as possible. Particular attention or emphasis would be placed on peer-reviewed, scientific publications in international journals as well as unpublished literature (e.g. government, private and corporate reports). In my view this has not been accomplished in the ERR.
Additionally the consultant or sub-contract specialist would be expected to design a field study to collect original data from the site for analysis, implications of the project and recommend effective mitigation to minimize or exclude some impacts. On many important questions involving potential negative impacts to terrestrial and aquatic species the ERR for the proposed Wolfe Island Wind Project (“Project” hereafter) has failed to adequately assess the wildlife and aquatic resources, habitats and species that constitute this rich and unique ecosystem. Thus there remains a dearth of reliable knowledge on which to provide predictions regarding the range and intensity of negative impacts on the resource base. A wide range of interest groups and stakeholders remain with only a modicum of information, perhaps skewed or biased by weak generalities from other regions. Especially surprising are the major inadequacies relating to internationally significant birds populations, estimates of their numbers by season, habitats, seasonal timing of habitat occupation, daily flight paths, to cite one group of animals for example. This type of information is essential for appropriate site selection of turbines, developing mitigation procedures or a decision to reject the project by the agencies responsible for protecting the habitats and species.
I find the report unacceptably deficient and totally inadequate as a basis for predicting collision mortality, direct disturbance (alienation from use of typical foraging habitats) or habitat degradation. In contrast to multi-year, 24/7 monitoring of physical variables (wind velocities by anemometers strategically sited around the west end of the Island) the biological assessment is starkly sparse and superficial. The relatively few days of monitoring of bird species and numbers and void of data for a host of other vertebrate species (bats, snakes, turtles, for example) gives the impression of minimal interest and low priority to living systems. This is unacceptable when we are witnessing a massive, widespread decline in meadow-dwelling bird species in Canada and the USA from loss of habitat (Audubon Report 2007 as reported in New York Times, June 19, 2007). The continent’s remaining habitat, as represented by fallow fields, pastures and crop edges on Wolfe Island, is especially significant in the race to avert species extinctions.
In particular I could find no quantitative data, analysis or estimates of the following potential impacts that could answer these questions essential to an EA:
What habitats of Species of Concern (species at risk, special concern, declining nationally) are represented in sites proposed for turbines and construction activities (access roads, destruction by crawler cranes, etc.)? I could find no habitat analyses or maps of habitat types that would be essential for selecting turbine sites to minimize impacts on critical habitats should they exist.
What is the total meadow and cropland acreage estimated to be included in crane maneuvering and transit between turbine sites (as described in the ERR)? The ERR reports the acreage of agricultural land lost due to the concrete foundation footprints but a much larger area of additional habitat will be compacted or destroyed for wildlife use as the pairs of huge cranes move on their steel treds while lifting the turbines into place as well as “walking” to the next turbine erection site. Changes in terrestrial habitat can be anticipated from soil and plant compaction with potentially significant degradation for species of concern like bobolinks, for example.
How many total vehicle trips and kilometers driven will the proposed Project total on new and established roads and tracks? Just to deliver the wet concrete from the batch site to the turbine foundations will involve 225 trips per site (ERR). There are 7 species of turtles and at least 3 species of snakes on Wolfe Island, some of which are at risk of being crushed by vehicles when these animals migrate to build nests, go to den-sites, bask in sunlit open areas or just move about hunting prey. Northern snapping turtles are especially vulnerable to vehicle mortality because of the long distances that they walk overland to find suitable soil for egg laying. Rather than presenting quantitative data on areas affected the ERR provides vague, qualitative generalities about potential “net effects” under the heading Construction (page 236): “Though the net effects are expected to be minimal, there is some potential for disturbance of natural features, habitats and mammals and herpetiles (sic) during construction of the project as a result of the limited removal of vegetation and increased human activity. However these effects are expected to be short-term in duration and spatially limited to the work areas and immediate adjacent areas.” How the effects of access roads and monster crawler crane movements for a 5-year construction period can be considered “short term” and “spatially limited” is unclear. This contradiction in the draft ERR needs to be resolved and the potential effects presented accurately and quantitatively.
What animal species are present or absent in the areas of proposed Project structures and associated activities? Best practices for all EAs in Canada and the USA would include, at the very least, reliable, statistically based sampling of the areas potentially impacted by the proposed activity or structures. Established methods for field sampling on site are well developed and widely available. Systematic sampling for collection of quantitative data collected on temporal and spatial protocols is standard practice. There appears to be none of this level of monitoring and analysis accomplished. Without it there can be no science-based understanding of anticipated environment impacts nor the kinds of adjustments to the Project that need to be made to avoid or minimize those effects. Furthermore without this kind of baseline data there can be no scientifically reliable evaluation of changes should a study be warranted after completion of the proposed Project. Until these studies are completed and evaluated decisions to proceed with the Project would appear to contravene established provincial and federal guidelines for assessing impacts of wind power utilities (cf “Guidelines to Assist MNR staff in the Review of Wind Power Proposals: Potential Impacts to Birds and Bird Habitats, EBR Registry No. PBO07E6036. January 09, 2007).
What are the baseline patterns, both daily and seasonal, of the very large population of waterfowl, for example? Many species of waterfowl including Tundra swans, wood ducks, greater scaup, etc., use Wolfe Island marshes and other wetlands during stopover and staging during spring and fall migration and nesting. The region is part of an internationally recognized Flyway (a major North American flight corridor for ducks, geese and swans). While these birds are active in moving between wetland habitats across Wolfe Island there would appear to be a high level of risk of collision with towers and rotor blades. To avoid or lessen the probability of these birds strikes it would seem imperative identify local flight corridors based in well-designed field sampling both day and night during the activity period for these birds. The ERR fails completely to present information that provides guidance for this goal. Furthermore the intensive fall hunt (both from shore blind and field-hunting of Canada geese) causes waterfowl to move more frequently than they otherwise would. The implication of this displacement for collision mortality rates needs to be assessed.
What are the winter population estimates and distribution of resident and migratory raptors (hawks, eagles, owls, etc.) in the region of WI of the Wind Project? Raptors such as the short-eared owl occur in high densities in irruption years of the Meadow Vole (Microtus pennsylvanicus). The peak densities of these rodents can be 10,000 times the densities measured in low years of the population cycle. Accurate estimates of raptor mortality will require field monitoring and assessment of raptor numbers over the rodent cycle. No quantitative data on numbers and behaviour of ecologically significant species has been presented in the ERR.
Where is information about the effects of towers on bird mortality in Ontario presented? The scientific literature contains collision rates of migrating birds from studies done on radio towers, high buildings in places like Toronto, including radar visualization of populations of birds during dark and inclement weather (e.g. fog). The ERR has not adequately accessed and reported on this information in order to make the most reliable estimates of annual losses of birds that might reasonably be expected. I consider the ERR estimate of 2 birds deaths per turbine per year invalid as it extrapolates that rate, one of the lowest reported, from a region that does not have the high resident and migratory populations that are documented for Wolfe Island.
What alternative areas or energy generation types (e.g. run-of-the-river) have been explored? The ERR has not explained why it is logical or necessary to site a major wind energy industry over a landscape that is assigned a “Very High” sensitivity status. The Wolfe Island Wind Project area ranks as a category 4, the “highest level of concern possible”. Given the international recognition of Wolfe Island for sport hunting and birding a thorough explanation for degrading this natural resource would be expected, even required. As settlement and urban 4sprawl spreads across the St. Lawrence/Lake Ontario region the conservation biology needs increase for landscape corridors and connectedness, such as Wolfe Island in the Adirondacks to Algonquin Park Corridor (A2A Wildlands Project).
Has the planning process of turbine site selection and ERR analysis violated provincial guidelines for protecting habitats? Ontario’s MNR has presented a policy proposal to the public entitled: “Guidelines to Assist MNR staff in the Review of Wind Power Proposals: Potential Impacts to Birds and Bird Habitats, EBR Registry No. PBO07E6036. January 09, 2007) 1. It states, in part,
“…. concerns have been raised about possible impact of wind turbines on bird populations. Scientific research has identified two main types of potential effects wind turbines can have on birds: collisions impacts and disturbance effects. Appropriate site selection appears to be the key factor in preventing these potential effects on birds.” {Emphasis added}.
To the extent that site selection preceded the completion of the draft ERR it would appear that there was no specific information available on bird habitats or activities to guide planning for appropriate site selection. If so this is so serious flaw in the whole procedure for minimizing impacts on birds and their habitat that the environmental analysis could be considered invalid. On the basis of concern for serious imp[acts on natural resources I believe this Project contravenes provincial and federal laws and should be rejected for Wolfe Island.
Sincerely yours
Barrie Gilbert, Ph.D.
Sawmill Creek 97A
Box 252
Wolfe Island, Ont.
Canada K0H 2Y0
(613) 385-2289
email: barrie_gilbert@hughes.net
