rea review for dumais

8/8/2019 REA Review for Dumais

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Review of Draft REA Reports and Documents

Big Thunder Wind Park

Horizon Wind Inc.

Prepared by the NorWester Mountain Protection Committee.

August 30, 2010


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Table of ContentsForeword and Acknowledgements ................................................................................................... iii1. Introduction ................................................................................................................................ 12. Background ................................................................................................................................ 2

2.1 NorWester Mountain Escarpment Protection Committee ................................................ 22.2 Approval Requirements and Expectations ......................................................................... 3

2.3 EA process ......................................................................................................................... 32.4 REA process....................................................................................................................... 32.5 Transition Process .............................................................................................................. 5

3. Review of REA Reports............................................................................................................. 63.6 General ............................................................................................................................... 63.7 Environmental Study Report (ESR)................................................................................... 6

3.7.1 ESR Chapter 1 Project Summary ............................................................................... 63.7.2 ESR Chapter 2 Project Description ............................................................................ 73.7.3 ESR Chapter 3 Scope of the Assessment ................................................................... 83.7.4 ESR Chapter 4 Agency Consultation ......................................................................... 93.7.5 ESR Chapter 5 Public Consultation ........................................................................... 9

3.7.6 ESR Chapter 6 First Nations Consultation .............................................................. 113.7.7 ESR Chapter 7 Environmental Characteristics ........................................................ 113.7.8 ESR Chapter 8 Assessment of Environmental Effects, Mitigation Requirements,and Residual Effects ................................................................................................................ 143.7.9 ESR Chapter 9 Follow-up Measures........................................................................ 283.7.10 ESR Chapter 10 Summary of Mitigation, Effect Management and MonitoringCommitments ........................................................................................................................... 293.7.11 ESR Chapter 11 Project Advantages and Disadvantages ........................................ 293.7.12 ESR Chapter 12 Conclusion .................................................................................... 303.7.13 ESR Chapter 13 References ..................................................................................... 30

3.8 ESR Appendix A Agency Correspondence ..................................................................... 31

3.9 ESR Appendix B Technical Specifications ..................................................................... 313.10 ESR Appendix C Public Consultation ............................................................................. 323.11 ESR Appendix D First Nation Consultation .................................................................... 333.12 ESR Appendix E Avian Impact Assessment Report ....................................................... 333.13 ESR Appendix F Bat Monitoring Report......................................................................... 343.14 ESR Appendix G Archeological Impact Report .............................................................. 343.15 ESR Appendix H Rare Terrestrial Species ...................................................................... 353.16 ESR Appendix I Areas of Natural and Scientific Interest ............................................... 353.17 ESR Appendix J Radio Communication, Radar, and Seismoacoustic Impact Assessment

353.18 ESR Appendix K Shadow Flicker Analysis Results........................................................ 36

3.18.14 ESR Appendix K Incomplete report .................................................................... 373.18.15 ESR Appendix K Inconsistency with ESR Report .............................................. 373.18.16 ESR Appendix K Data Issues .............................................................................. 37

3.19 Project Description Report ............................................................................................... 383.20 Design and Operations Report ......................................................................................... 433.21 Construction Plan Report ................................................................................................. 453.22 Decommissioning Report................................................................................................. 463.23 Consultation Report ......................................................................................................... 48


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3.24 Natural Heritage Records Review Report........................................................................ 483.25 Natural Heritage Site Visit Report ................................................................................... 493.26 Environmental Noise Impact Report ............................................................................... 503.27 Visual Impact Assessment Report ................................................................................... 533.28 Maps ................................................................................................................................. 54

4. Summary of Comments ........................................................................................................... 56

5. Review Conclusions and Recommendations ........................................................................... 57

APPENDIX A Draft REA Initial Comments (as provided to Horizon August 24, 2010) Pages 1- 69

APPENDIX B Summary of Review Recommendations .................................................Pages 1 - 11

APPENDIX C LETTER OF January 4, 2010 from MNR - Peregrine Falcon....Page 1 - 3

List of Tables

Table 1 Environmental Study Report Initial Comments Summary ................................................... 6

Table 2 Consultation Initial Comments Summary........................................................................... 32Table 3 Inconsistencies between ESR and Appendix K .................................................................. 37Table 4 Project Description Report Initial Comments Summary .................................................... 38Table 5 Design and Operations Report Initial Comments Summary .............................................. 43Table 6 Construction Plan Report Initial Comments Summary ...................................................... 45Table 7 Decommissioning Plan Report Initial Comments Summary .............................................. 47Table 8 Natural Heritage Site Visit Initial Comments Summary .................................................... 49Table 9 Environmental Noise Impact Report Initial Comments Summary ..................................... 51Table 10 Visual Impact Assessment Initial Comments Summary................................................... 53Table 11 Maps Initial Comments Summary .................................................................................... 54

List of AcronymsANSI Area of Natural or Scientific InterestBTWP Big Thunder Wind ParkCanWEA Canadian Wind Energy AssociationEA Environmental AssessmentESR Environmental Study ReportFWFN Fort William First NationLP Limited PartnershipMOE Ministry of EnvironmentNavCan Navigation CanadaNMEPC NorWesterMountain Escarpment Protection Committee

OPA Ontario Power AuthorityPDR Project Description ReportPPS Provincial Policy StatementREA Renewable Energy ApprovalTB Technical BulletinWTG Wind Turbine Generator


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Foreword and AcknowledgementsThis review of the proposed Big Thunder Wind Park draft REA reports represents a significantaccomplishment for a grassroots community group, theNorWesterMountain EscarpmentProtection Committee, in two important ways; first, the group is all volunteers who found time tobecome involved and contribute to this review and, second, many members of the group only metfor the first time this year, yet were able to come together to work as a team.

The REA process is still being developed and implemented even at the time of this review. TheGreen Energy and Green Economy Act regulations passed just over a year ago have resulted in acascade of changes to policies, guidelines and programs in environmental and energy planning,and public consultation. The changes can be difficult to comprehend for project developers, whohave an entire government office to assist them (the Renewable Energy Facilitation Office), butalmost impossible for the average person.

The proponent (project developer) driven process that has been implemented, without direct MOEoversight or involvement during planning, relies on the project developer to interpret the adviceand guidance documents. For developers with significant and varied experience in power projectplanning, allowing interpretation provides the ability to tailor the process somewhat to the project,and still provide meaningful consultation and public involvement, and a fair and open process.Perhaps because of the changing regulatory and approvals processes, or perhaps because the newREA process was not strictly adhered to in this case, this project is seen by many in the communityas not providing meaningful public consultation, nor an open process.

This review provides comments and advice on the reports in an effort to improve them, and ensurethey meet the MOE technical bulletin guidance documents which the proponent committed tomeeting at the Aug 5th and 24th open houses. There are 412 comments from an initial assessment ofthe reports, which were provided to the proponent August 24

th. This review document appends

those comments, and provides further review based on additional assessment and considering theproponents statements and information at the August open houses. This review document used theinitial and further reviews to develop 139 specific recommendations.

This review is the result of dedicated efforts and community teamwork. It involves months ofvolunteer work by many people from the NMEPC. The contributions included formal review ofsections of various reports and appendices, working on the database of 412 initial comments(Appendix A), as well as many informal comments and discussions.

It is hoped that this review will be useful in the efforts to improve the REA report documents, theplanning and public consultation processes, and ultimately the project, should it proceed.

NorWesterMountain Escarpment Protection Committee


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NMEPC Review of draft REA reports for proposed Big Thunder Wind Park

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1. IntroductionThis document is a review of the draft REA reports issued by Horizon Wind in May 2010 as partof the REA approvals process. The draft REA reports include the ESR report, and appendices, theProject Description Report (PDR), and the Design and Operations Plan, Construction Plan andDecommissioning Plan Reports.

The review was carried out by various members of the NMEPC and the public over the periodfrom June to August 2010. There was no paid consultant or professional contribution to thisreview; it was entirely carried out by average people, members of the public who volunteeredsignificant time over the summer.

The review was comprised of two approaches. The initial approach was to document the issues andconcerns in a database noting the page, chapter and section number. This information is includedin Appendix A. The issues and concerns were identified by comparing the draft REA documentsagainst the MOE Technical Bulletins, as well as considering what a reasonable person wouldexpect. This approach was confirmed as reasonable by statements at the August 5th and 24th, 2010open houses in Thunder Bay and Neebing where a Horizon representative answered a question inopen public forum that the final reports would meet the MOE Technical Bulletins.

The second approach to the review was to critique the documents and note comments outside thedata base. This part of the review was more of a holistic approach, looking for issues and concernsfrom as wider context. These comments formulated much of the text in the body of the review.There may be overlap in the database comments and the comments in the body of the text.

The background section provides a brief overview of the NMEPC, and the various approvalsprocess. The transition provisions and the implications are also discussed

The draft REA report review is comprised firstly of the ESR review. The ESR review includesreview of the various chapters and appendices in varying levels of detail. Where volunteers had thetime and interest, there is more detailed review. The review of the REA reports follows the ESRreview. Each report is compared against its applicable Technical Bulletin. For each report (ESRand REA reports) there is a summary table provided which collates the database of REA commentsincluded as Appendix A. The comments are categorized, including missing information,misleading information and minor infractions, and a short description added. This is to assistothers in identifying what each comment relates to, and how it could be remedied.

In each section, recommendations as specific direction or advice to the proponent or MOE isprovided identified in bold and italics. These are based on the review, and are made to address

various deficiencies or issues. These recommendations are summarized after the review, andfurther, overall recommendations are provided.

Readers of the report should keep in mind limitations of this review. It was prepared by averagepeople, in their spare time, without the benefit of paid professionals. There were obvious resourceissues and the review was not able to cover all the various reports, appendices and manufacturers

data sheets in a level of detail which a regulator or paid professional might. Further review andinformation could be identified following submission of this report.


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2. Background

2.1 NorWesterMountain Escarpment Protection Committee

TheNorWesterMountain Escarpment Protection Committee (NMEPC) is a local grassroots groupof citizens. It was formed in the fall of 2009 when many area residents first learned about thisproject proposed on a mountain close to their homes. Although the proponent has identified thatdirect notice was sent to all area residents, many of those immediately adjacent had no knowledgeof the project until November 2009 when the NMEPC contacted them. On August 5, a Horizonrepresentative further stated that everyone within 120 m of the project, including electrical lines,had been directly notified.

Residents were shocked to learn of this project (especially since it was signed 3 years prior behindclosed doors without their knowledge on city owned land) as it was a threat to a previously well-protected watershed area containing protected peregrine falcons, rare to the area Sugar Mapletrees, a cold water Lake Trout lake, sensitive groundwater recharge area, and an area upon whichdevelopment was discouraged. Many residents hike the trails within the area and enjoy thebenefits of this pristine environment close up and from afar.

Industrial sized wind turbines have increased dramatically in height, and power and sound outputin recent years. They have been developed closer to people, and many documents and researchhave suggested adverse health and environmental effects due to their presence, especially whenlocated close to homes and in sensitive areas. There were significant concerns and questions raisedby the local community regarding this project, and its specific proposed sites.

From the fall of 2009 until summer 2010, there has been no significant public consultation by theproponent. What the local residents were provided with was a media campaign and public relationsprogram. Certainly the proponent and its local consultants (Firedog Communications and Mr S.

Wright) would have been aware of the many meetings, open houses, City Council deputations,demonstrations, newspaper articles, and editorials. These external consultants or Horizon itself hadample opportunity to directly engage the public to provide information and address concerns. Thepublic concern or activity is not reasonably reflected in the Renewable Energy Approvals (REA)reports. Questions regarding the proposed project and the specific studies were directed to theproponent. But still there was no reasonable public consultation.

MOE must review the project and consultation from September 2009 to August 2010 to

determine whether reasonable attempts were made to engage and consult with the public.

Should it be determined that there was a failure to consult appropriately, the proponent must berequired to develop and carry out a consultation program satisfactory to MOE before any REA

report is prepared.

MOE must review the direct notifications made in this project to determine if they satisfy therequirements. Failure to provide appropriate notification should be considered a significant

flaw in the process, for which the public should not suffer.


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MOE must require the proponent to include in its REA reports sufficient and detailed

description of the ongoing public and community concerns. Also, the proponent should identify

how it has addressed specific individual and community concern.

2.2 Approval Requirements and Expectations

The MOE identifies its requirements (needs) and expectations (wants) for studies and reports in

many forms. These can include needs identified in regulations or Directors orders, or wantsidentified in guidelines, bulletins, or direct correspondence with proponents. Sometimes theguidelines can become requirements, based on specific project or proponent considerations. Theapplication of the requirements is normally absolute. For expectations, there is considerableleeway in application. An experienced proponent with a good track record and no significantproject concerns may not have to satisfy all the expectations, while others may have to.

2.3 EA process

The Environmental Assessment process is a regulatory requirement that applied to industrial windpower projects until 2009. The EA process is one that includes identification of impacts, andmitigation. It examines impacts from an environmental, economic, and social perspective. Publicconsultation and involvement is an integral part of the process. The EA process was developedover the last 40 years, primarily as a response to problems with large scale developments andpublic concerns.

With the introduction of the Green Energy and Green Economy Act the EA process was no longerto be used for industrial wind power developments. A new process, called the REA process wasdeveloped and used.

2.4 REA process

The REA process, requirements, and guidelines are still in development. The REA process is in

some ways similar to the EA process, in that there are still investigations into environmentalimpacts, and mitigation. There is also a public consultation and regulatory approval process.

Generally the REA process as we understand it is as follows,

Site investigation and notice of project.o Proponent identifies a site that looks promising for developmento Proponent issues a notice in the newspaper etc to identify it is considering

developing a project in a specific areao Basic information is gathered to identify whether the project is feasible and what

the potential impacts might beo Proponent could begin engaging local stakeholders to exchange information

Development of Project Description Reporto Basic background information gatheredo Identification of environmental, social and technical issues and informationo Identification of project technical components (tower and turbine types, heights etc)o Identification of alternatives or a proposed project layouto Issue of Project Description Report

Project Description Report Open Houseso First opportunity for public to see project and potential impacts


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o Opportunity for public to provide missing information (correct errors / omissions)o Chance for proponent to identify further opportunities or issues regarding projecto Important step to ensure project reasonably considers public input

Development of Draft REA reports (Operation, Construction, Decommissioning etc)o More detailed information gatheredo Detailed assessments of impacts developed

o Issue of Draft REA reportso MOE does not normally review these reports

Draft REA Open Houseso Opportunity for public to see project in detail, after input from PDRo Opportunity for public to identify issues, missing information etco Opportunity for proponent to identify further opportunities and issues regarding the

specific project proposal and details

Development of Final REA reportso Proponent takes input from draft REA open houses and revises project and reports

as necessaryo If significant changes to project or reports are made, new draft REA reports could

be developed with open housesIssue of Final REA reports to MOE

o MOE reviews against regulations and technical bulletins

MOE Decisiono MOE can approve, deny, or approve with conditions, the projecto Decision can be appealed

Appeals Processo There is a short appeals process (15 or 30 days)o There is limited grounds on which to appeal , essentially unless permanent harm

will be caused and can be proven there is little ability to successfully appealo Once appeals process, or time limit has expired, the final REA approvals is

providedREA approvals

o After appeals process expired, and assuming decision was approve, or approve withconditions

o REA approvals provides for most provincial approvals, but not federal if requiredo Specific local approvals ie water crossings may still be required

But the REA process is an approvals process not an assessment process. Its goal is to speed up andstreamline the approvals. Minimum setbacks are included in the process, to provide (in theory)separation from sensitive features, such as water course and people. The use of setbacks relievesthe proponent from investigating potential impacts for some concerns. There is no requirement to

identify alternatives. There is no requirement to mitigate impacts (use of setbacks is enough).

A positive feature of the REA process is the Technical Bulletins. These are guidance documentswhich the MOE has issued (in draft March 2010) to provide detailed and specific direction toproponents. The bulletins clearly identify information requirements and expectations. Should thesebulletins be adhered to in a meaningful way, project information will be collected, collated andcommunicated clearly to the public and regulators.


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At the open house Aug 5, 2010 in Thunder Bay, a representative of BTWP project clearly statedthat they would meet the MOE technical bulletin requirements. (This can be confirmed byreviewing the videotape of the proceedings made by Horizon)

The proponent must be required to satisfy its public commitment of August 5th and 24th, 2010

and fully meet the requirements of the MOE Technical Bulletins for all the REA reports.

2.5 Transition Process

Because the project was already started before the REA process was developed, it was termed atransition project and special provisions apply. This was to provide projects in various stages ofdevelopment some credit for work and consultation already completed. It was not intended toreduce the opportunities for real involvement of the public

Apparently, the MOE decision to provide this special provision to the BTWP was made in the fallof 2009. The decision was made based on information provided by Horizon Wind to MOE. At thattime MOE was apparently not aware of the growing public concern regarding this project, and

made a decision that previous open houses in 2008 and 2009 for BTWP sufficiently satisfied theProject Description Report open house requirements.

Since the decision to provide the transition project special provision (no first open house) therehave been a number of issues that would indicate the special provisions be revoked. These include,

Initial open houses (2008 and 2009) did not provide specific information as normallyprovided with a PDR open house (turbine types, sizes, manufacturer)

Previous open houses did not indicate electrical connections, roads, or site information

Project changed significantly since fall of 2009 (turbine locations moved twice, and projectnow includes electrical connections)

Significant public concern and requests for information and consultation since fall 2009

Public was not informed of special provisions by proponent or regulator until spring 2010

The proponent must identify to the public in the draft REA documents what special provisions

apply outside the normal process. This is specifically the transition project provisions.

The August 4, 5, 23, 24 open houses must be considered as the PDR (first) open houses. The

information presented at prior open houses was general and non specific. The changes in the

project and lack of consultation since 2009 are significant. The proponent must update and

revise the draft REA reports, reissue draft REA reports based on the first real public input. Afterreissuing the draft REA documents the proponent must then have draft REA open houses.


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3. Review of REA Reports

3.6 General

The reports were reviewed by a number of people and comments assembled into this report. Manyof the specific comments are in the attached Appendix A. These comments are included as thereviewers input, without editing. There are obvious grammatical and spelling issues, but thecomments should provide sufficient detail to indicate what the issue is. If additional information isneeded, it is suggested to go to the report section and read the relevant part of the report, at whichtime the issue often becomes apparent to the reader even without the REA review comment. Iffurther clarification is required, it is suggested to contact the NMEPC who will have the originalreviewer clarify.

Overall, the review found that there was significant duplication between the various REA reports,and that there was significant missing information. There were many instances where thereviewers were expecting more detailed information, but it was not provided. This was mostapparent for identifying the rationale for why decisions were made to located project components,or why turbines were relocated multiple times.

3.7 Environmental Study Report (ESR)

In general the environmental study had a number of issues. The information in Appendix Aprovides specific location and description of some issues. The total number of comments providedin Appendix A is 412, and these comments were provided t oHorizon Wind Inc on August 24,2010. Table 1 Environmental Study Report Initial Comments Summary below summarizes theissues found related to the ESR report. For the ESR report there were 130 issues, of which almosthalf were identified as missing information. This is significant as the ESR should provide clear andcomplete information regarding the environmental features, effects, mitigation and remaining

effects.

Report Type of issue Number of issues (Total=130)

General ESR Minor infractions 17

Missing information 64

Misleading information 17

False information 7

REA conflicts 5

Process inadequacies 19

Credibility 1

Table 1 Environmental Study Report Initial Comments Summary

3.7.1 ESR Chapter 1 Project Summary

This section indicates that the project is 27 MW, but fails to identify that a total of 79.5 MW hasbeen applied for from the OPA for power supply contracts. This should be identified in the project,as it is the same proponent, with the same name for the projects (Big Thunder Wind Park Alphathrough Gamma). This is further neglected at the Project Titles section, where the specific projectnames (as named on applications to OPA) should be included


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The regulatory regime is described, but it neglects to identify the special transition provisions, norhow they affect public involvement and opportunities for input

The proponent information is identified, although Ms. Nguyen position and authority within thecompany is not provided. It is likely that Ms Nguyen does not have the authority to bind thecompany, and a more senior employee/ officer should be identified

The authors of the screening report are identified, although many of the REA reports and portionsof the ESR include limitations and qualifications. It is difficult to understand how the authors ofsome of the reports can be listed with a primary role, and then limit the reliance on their reports.Further, there are others involved in the project, whose roles should be clearly communicated, suchas Foghorn Renewable Energy, Big Thunder Wind Park Limited partnerships, and Horizon EnergyLegacy Group.

The proponent must address the 10 comments as included in Appendix A related to the ESR

chapter 1.

The proponent must clarify the project relationship and names relative to the large number ofprojects known as Big Thunder Wind Park.

The proponent must clarify the nature and relationship of all parties involved in development ofthe project.

The proponent must clearly communicate the special transition provisions and how that impacts

public opportunities for involvement.

3.7.2 ESR Chapter 2 Project Description

The project description identifies the proponent as Horizon Wind Inc., but the nature of therelationship of other parties (as noted in chapter 1 review above) should be clearly identified andcommunicated.

The use of only selected parts of the Provincial Policy Statement (PPS) should not occur. The PPSshould not be used piecemeal, and ignoring other relevant policies is not appropriate

The purpose of the project is also to provide the proponent with a business opportunity. The truenature of the project purpose was apparent during open house questions when the proponentadvised that it could not move turbines away from people because it would make the projectuneconomic.

Current land use description ignores the land use associated with the electrical lines. The lines arepart of the project undertaking.

The description of the wind turbine fails to disclose that the manufacturer data sheet sound power(and perhaps other information) is estimates, and that no actual turbines of this type have beenconstructed. This is an important piece of information which has is missing from the projectdescription.


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Electrical tap lines are discussed, but the existing capacity as per Thunder Bay Hydro is only 3 to 4MW as per Thunder Bay Hydro website. Which turbines will be connected initially, and how theothers will be connected is unclear. Given that there is only an OPA contract for 16.5 MW, it isunclear how various parts so the project will connect, where, and in what stages.

The nature and status of the FWFN land claim is vague. The land proposed for the developmentwas part of the historical claim, but this is ignored.

Much of Section 2.6 is from the Construction and operations reports. Including them here isirrelevant and only increases the size of the report


chapter 2

The proponent must identify and clarify the nature and involvement of all parties involved in

project development.

The proponent must include in the purpose that its objective is to make money. If not, the

proponent should not identify economics as rationale for turbine location, or rationale for not

implementing certain mitigation.

The proponent must clearly disclose that the tower and turbine information is estimated and that

no tower and turbine of this type has been constructed.

The proponent must clearly identify the electrical connections, land uses associated, the turbines

and schedule for various stages, and how potential stages of the project will be incorporated, for

3 MW, 16.5 MW, 27 MW and other stages to 79.5 MW.

The proponent must clearly identify how the First Nations and Mtis have been consulted, and

how their land claims and use of lands could be impacted.

3.7.3 ESR Chapter 3 Scope of the Assessment

This chapter reveals a significant issue with this project. The project identifies that issues werescoped through consultation. It also identifies that local residents were consulted and that theprofessional judgment of the assessment team was used. Unfortunately, the results of that processto scope issues, and identify the importance of issues, and why some are not addressed is not partof the report. This leaves readers and the public wondering why and how some issues are

addressed and others not. Specifically the significant concerns of the local residents regardingnoise, health issues, flicker, property value impacts and visual impacts have been discounted andnot addressed. The results of scoping should be clearly provided, perhaps with maps and figures toidentify preferred area, and exclusion zones. The entire process of moving from a large study areato specific sites should be clear, with the rationale and decision making provided.

The provincial screening criteria identified as table 3-1 is suggested as part of the screeningcriteria. These are criteria used for projects as part of the environmental assessment process, to


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screen out those projects with minimal anticipated impacts. Use of these criteria for this projectdoes not seem appropriate. This screening process does not address the specific issues raised bythe community. How these screening criteria are used in the scoping process is not adequatelyidentified.

The study area is identified as determined through a combination of professional judgment and

experience with predictable effects. This is completely deficient in details that would be expectedto be known and communicated to the public. This is the very heart of decision process regardinglocating of turbines. If the proponent cannot identify how the study area and turbines are located,or based all its decisions on professional judgment and experience, then this entire study andproject should be denied.


chapter 3

The proponent must clearly identify how it scoped issues, and how consultation and professional

judgment were used in the scoping and turbine locating process.

The proponent must clearly communicate the process it used to determine the study area, and

turbine locations. The rationale for identify locations must be known, and without this

information any evaluation and comments by the public or regulators is irrelevant.

3.7.4 ESR Chapter 4 Agency Consultation

The agency consultation identifies that a transition process was to apply to this project.Unfortunately, the specific transition provisions are not identified, nor are the impacts on agencyand public consultation.

Appendix A includes agency correspondence. Unfortunately determining the consultation processand status is difficult without some collation and tabulation of consultation and status.


chapter 4

The proponent must identify the specific transition provisions and how agency consultation has

been impacted.

The proponent must clearly identify the dates, nature, and status of agency consultations. Thisshould be summarized in tabular format.

3.7.5 ESR Chapter 5 Public Consultation

Similar to comments on agency consultation, the impact of transitional project status is notidentified, and the impacts on opportunities for public involvement are not identified.

The public consultation identifies that area landowners and residents must be involved.Unfortunately for this entire project this has not occurred. More specifically since late 2009 the


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proponent has avoided contact with area residents. During Thunder Bay City Council deputations,Horizon representatives left early, and refused to stay even when requested by a member of thepublic. This could be interpreted as indicating a lack of concern for residents issues and no desirefor involvement. The entire first paragraph indicates what should happen for public consultation;unfortunately this did not occur. What is later described as consultation are actually the minimumnotification requirements as required by regulation, not true consultation.

The methodology section indicates that public consultation was comprised of 2 public meetingsand responses to inquiries. There is no mention or acknowledgement of the significant publicconcerns since the fall of 2009, and that there has been no specific measures taken to consult inresponse. In fact, the proponent has avoided contact and consultation, preferring to use publicrelations and a media campaign to try to sway public opinion.

The sections on activities is missing a number of activities including Horizon presentations andletters to City Council in 2009 and 2010, as well as the significant number of publicdemonstrations, deputations to councils, editorials, news articles, and letters to the editor. Themajority of the news media and letters to the editor were opposed in some form to the project or

specific turbine locating. The existence and activities of theNorWesterMountain ProtectionCommittee was totally ignored.

The open house descriptions identify that there was no specific information or maps related toturbine locating, or locating decisions provided at the open houses. This was also the case for theAugust 2010 open houses, where no project area maps of sufficient size (ie table size) wereavailable. This is significant relative to the REA consultation process and the first (projectdescription report) open houses. Under the REA process the first open house must have the sitespecific and generator information. The response to questionnaires fails to acknowledge that as theproject proceeded, the support for the project declined.

The response to correspondence is lacking in detail and information. There should be a table ofquestions and answers provided; with the names of the questioner removed (these can be replacedwith generic descriptions such as resident).

The table 5-3 is has little value. To identify that issues were addressed in specific sections does notclearly identify to the public how there issues were addressed. It merely sends the reader on asearch through various reports. A clear communication of issue, and resolution, preferably in atable format, would make it clear to all how issues were addressed.

Overall, this section of the report provides little detail upon which the public or a regulator couldassess the public consultation. It lacks detail, and totally ignores the significant community based

activities which occurred since the fall of 2009. The appendix that supports this section is alsoinsufficient; refer to review of ESR Appendix A.


chapter 5

The proponent must identify the specific transition provisions and how public consultation is

impacted.


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The proponent must acknowledge that since public concerns became apparent last fall (2009) it

has not engaged in any real public consultation.

The proponent must halt its process, engage the public meaningfully, and address the concerns.

Suggested methods would be standard consultative tools such as working groups, stakeholder

focus sessions, and meeting directly with potentially impacted residents. This could beginimmediately.

The proponent must acknowledge and describe the significant public and media concerns andevents, especially since fall of 2009.Also, the proponent should explain its response to theconcerns.

The first open houses did not have specific turbine locating information. The proponent shouldnot be provided the free pass on the first (PDR) open houses. The proponent must hold open

houses further to its first real set of open houses in August

The proponent must provide more information, preferably in a tabular form, identifying howwritten, email, and phone questions were responded to.

The proponent must identify how issues raised were addressed, and not merely provide reportsection to refer to. Provided in a tabular form this would communicated clearly how issues were

addressed.

3.7.6 ESR Chapter 6 First Nations Consultation

This section is less than one half page in length. Given the significant and historical ties to thelands on which this project is located, this is surprising.

The section identifies that the details will be provided in the final REA applications. This isunacceptable with respect to providing appropriate comment and consultation on the draft REAreports. The review for the final documents is short and there is not sufficient opportunity toreview entire new reports. The activities to date should be presented to provide the public and FirstNations and Mtis people the opportunity to review and evaluate the activities to date.

The First Nations Consultation section and the corresponding Consultation Report are missing

from the draft REA report. The proponent must issue the missing section and Consultation

Report, as part of the draft REA, with 60 days notice and open house to follow. Not includingthis information was the choice of the proponent, but the public and First Nations deserve to

have this information at the draft report stage.

3.7.7 ESR Chapter 7 Environmental Characteristics

This entire chapter is an interesting combination of significant amounts of general information, andsmall amounts of site specific information. The site specific importance, location, and distributionof environmental characteristics are important, as well as the relevance to this project. They shouldbe adequately and clearly addressed and communicated.


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Turbine locating decisions would obviously require that environmental concerns be identifiedgeographically but none of this information is included. Site maps identifying where the areas ofconcern are located would assist the public and regulators in understanding the process, but theseare not included. This brings into question the entire process, and evaluation of impacts andmitigation, because the project should attempt to minimize overall impact on the environment.

The hydrogeology section fails to identify that the area is a high groundwater recharge area, and asensitive aquifer. This combined with fractured rock groundwater is not addressed as it relates tothis project. At the August 23, 2010 open houses the Horizon Wind Inc., Vice President, identifiedthat there would be a lot of blasting, sufficient to provide almost enough gravel for the entireprojects roads and pads. The potential for impacts on the rock (unknown fragility orcharacteristics) and groundwater networks is not addressed or acknowledged.

Climate and wind information presented is general and of little value. Climate normal monthliesare far too general, and obviously the minimum night time winter temperatures would be importantto mechanical equipment operation. Whether these turbines will function is the extreme low

temperatures in the area are a concern. The preferred wind over the area close to the only wind testtower has been identified as a reason to locate the turbines close to the cliff edge. There is no datasupplied to support this assertion, and it is difficult to understand how wind at 140 meter heights,on top of 200 meter cliffs would vary so drastically in the a space of a few hundred meterslaterally. There is no indication of how the wind patterns over the area were determined, and theonly information provided is an average wind speed and direction.

Socioeconomic conditions information is general and does not provide sufficient detail regardingthe area in the vicinity of the project. Data regarding the number of people in Ontario is irrelevant.The current land use ignores the significance of the land uses adjacent to the project as desirablerural and estate residential areas. The reason they are desirable is the natural beauty and quiet area.

The proximity to residential areas is downplayed and the proximity of significant estate residentialareas of Broad Oaks and Mount Forest are ignored.

The tourism section is missing information and evaluation regarding the role the natural state oftheNorWesterMountains plays in the important tourism industry. TheNorWesterhotel relies onuse of its facility with the natural scenic backdrop for weddings and graduationsloss of whichwill occur with the present development - this is not acknowledged. The general informationprovided does not sufficiently address the local importance of the visual and quiet aspects of theNorWesters. The information provided includes irrelevant generic information about Thunder Baytheater and golf, yet ignores the Fort William Golf and Country Club which is in closer proximity.This tourism section appears to be sourced from local tourist brochures, rather than relevant site

and project specific information.

Existing noise levels in the area are described, but the impacts of the proposed project are ignored.

Archeological assessments area described, with a stage 2 assessment proposed before construction.The recommendation of the Ministry of Culture is identified in the report as prior to construction.Actually, the Ministry of Culture identified that a stage 2 assessment should be completed farenough in advance to account for delays. There is a significant difference between the statement in


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the REA draft ESR 7.9.4 and the letter from Ministry of Culture. The proponent should beundertaking surveys far enough in advance to account for delays. Perhaps the surveys should befar enough in advance to allow for alteration of road or turbine locations should information orartifacts be found..

Recreation areas do not adequately describe the existing use of the areas as trails and hiking, the

potential uses with various tourism and recreation developments. The existing Loch Lomond skifacility, and the presently closed Big Thunder Sports Park (reopening has been subject of call froproposals in 2010) should be clearing and adequately described. The impacts on these uses are notaddressed.

Safety issues fail to address the significant and important tissue of ice throw. The proximity of thelocal ski area and the locating of turbines immediately (180 metres) above residences increase thelikelihood of ice throw. The proximity of snowmaking equipment is not acknowledged. Thesection identifies that the roads will be gated to prevent unauthorized entry, but other parts of thereport indicate public will have access. This should be clearly communicated in the report as theaccess roads will cross and be located on ski trails and hiking trails.

The Visual Landscape section has 3 lines of text. This is inadequate based on the importance thatthe local community, residents and business place on the unadulterated natural landscape. Theproposed project would drastically alter the visual landscape and this is ignored entirely. The localcommunity has identified these concerns.

The proponent must provide clear information, on legible maps to show the location of all

environmental characteristics and information used in locating turbines and roads.

The proponent must acknowledge the groundwater significance of the area, and provide more

detailed information regarding potential impacts of its construction and operation activities on

the rock stability, groundwater network, and aquifer.

The proponent must indicate the distribution of wind over the area, and how this wasdetermined. Because the proponent is using the wind distribution as rationale for turbine

location this information is required.

The proponent must acknowledge that the area in the vicinity of the proposed project is a

residential area, valued for its proximity to the natural beauty of theNorWesters and the quiet

of the area.

The proponent must revise its tourism section to acknowledge and describe the local tourism

and the significance of the local vista and the quiet nature of the area on local tourism.

The proponent must include a description of how the proposed facility will impact noise levels.The sound power levels and the impacts on people, and properties must be clearly

communicated.

The proponent must acknowledge that the Ministry of Culture recommends a stage 2

archeological assessment far enough in advance to account for delay. It would be prudent to


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conduct the stage 2 assessment as early as possible to allow for relocation of turbines, roads and

electrical lines as necessary.

The proponent must acknowledge and describe the existing and potential recreation uses inmore detail, and describe the impacts of the proposed facilities on those uses.

The proponent must describe the potential safety issues related to ice formation and throwrelative to the ski facility, and residences especially immediately below and adjacent to the

proposed turbines.

The proponent must acknowledge and describe fully the visual landscape and its importance to

the community. This is perhaps one of the most common issues raised, and relates to property

values, enjoyment of property, the local economy, and tourism.

3.7.8 ESR Chapter 8 Assessment of Environmental Effects, MitigationRequirements, and Residual Effects

This chapter was reviewed in detail, as the identification of effects and mitigation is critical. Thereview identifies the relevant section of the report, so that it is easier to identify the source of thecomments.

ESR 8.1 Level of impact after mitigation measuresCriteria used to assess level of effect after mitigation appears to be based on a resource model.This model may be appropriate for some effects, but for many of the effects identified in thischapter it seems inappropriate. This model does not adequately address the distribution of impacts,as some residents are impacted severely, while on a broader scale the impact is much less severe.

ESR 8.1 The proponent should provide a more detailed and descriptive identification of level of

effect. The effect before and after mitigation should be quantified wherever possible.

ESR 8.2 .1 General Construction ActivitiesEnvironmentalThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.

The activities should describe the specific construction activities in sufficient detail tounderstand what the impacts are.

The environmental components would also include dust and air quality

Potential effects should include runoff and siltation, impacts of large equipment etc.

Mitigation measures refer to other reports for details of various activities. Thatinformation should be included here. Mitigation is provided in general terms, such asdefensive driving practices, where specific mitigation for specific issues would be ofvalue.


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Residual effects are identified as localized and short lived. Who and how long they areaffected would be important and should be identified.

Importance of effects is noted as minimal. How this was determined, and on what basisthis decision was made is important. The importance of effects to nearby residents orbusiness may be important.

The proponent must rewrite section ESR 8.2.1 to fully address the missing activities,environmental components, potential effects, mitigation measures and residual effects.

ESR 8.2.2 General Construction ActivitiesSocial EconomicThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.

The activities should describe the specific construction activities in sufficient detail to understandwhat the impacts are. How these activities are relevant to socio economic is not understood

The environmental components only identify socio economic issues that may be interpreted asonly positive. There must be more detail here to more clearly understand what the environmentalcomponent considered actually is.

Potential effects are only identified as positive. The positive spin put on this issue borders on theabsurd, with more than a half page listing of trades possibly employed in wind farm construction,operation and decommissioning (although this sections is only construction). This is misleadingand incorrect. There must be potential negative effects, such as loss of business due to traffic,noise, visual disruption.

Mitigation measure identifies none. This totally ignores that there might be negative effects.

Residual effects are identified as positive. Again, by ignoring possible negative effects, the publicis not properly informed.

The proponent must rewrite section ESR 8.2.2 to fully address the missing activities,

environmental components, potential effects, mitigation measures and residual effects.

Specifically the proponent must clearly identify potential negative effects which have been

totally ignored.

ESR 8.2.3 Surveying and SitingThis section is reasonably developed and there are no comments at this time.

ESR 8.2.4 Land ClearingThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects. In many respects this deficiency is related to theproject activities and effects from electrical lines of theproponents site, and along the upgradedelectrical lines into Fort William.


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The activities should describe the specific construction activities in sufficient detail to understandwhat the impacts are. Additional information related to upgraded electrical lines into Fort Williamshould be added. Maps and diagrams would clarify what and where the activities would occur.

The environmental components should include runoff and siltation.

Potential effects are identified as destruction and alteration of habitat. That is too general and thepotential effects should be linked to the environmental component. New access is identified as apositive effect, although that may not be accurate. There is no mention of loss of use of ski/hiketrails.

Mitigation measure identifies natural revegetation and replanting. That is post construction.Mitigation for the specific effects, by component should be identified. The limitation of publicaccess is contrary to the benefit of increased accessit cant be both increased and prevented atthe same time

Residual effects are identified as some reduction and alteration of wildlife habitat with no details,

or project life. Unfortunately this is a vague and general statement that provides no realinformation regarding the scope or duration of effects. The project will last 25 to 45 years, theduration of the Horizon/City contract.



Specifically the proponent must clearly identify the residual effects in more detail and that they

will last 25 to 45 years.

ESR 8.2.5 Road Construction/ ModificationThere should be maps and profiles of roads, including cut and fill areas and location of trails.

There should be identification of the visual impacts and scarring of the mountainside to build andmaintain roads in this rugged and steep terrain.This section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects. There are no existing roads, only ski trails

The activities should describe the specific road construction activities in sufficient detail tounderstand what the impacts are.

The environmental components do not address loss of trails or visual impacts

Potential effects are only identified related to some environmental components. The effects on the

ski trails will be devastating. There will be permanent loss of use and destruction of trails. Theimpact of the wide roads and clearing up the side of the mountain is ignored.

Mitigation measures fail to identify whether or how roads or turbines will be relocated shouldarcheological finds be made. Mitigation for loss of trials and visual impacts is not addressed.

Residual effects are identified as localized and short lived. This is not accurate for the trail systemand visual impacts- these are long lived and essentially permanent.


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Specifically the proponent must clearly identify environmental components and potentialnegative effects related to the Big Thunder ski and hiking trails destruction, and the significant

visual impacts.

ESR 8.2.6 Water CrossingsAddition of maps and diagrams to this section would assist with understanding the nature andextent of water crossings.

This section ignores the water crossing associated with the upgraded transmission/ electrical linesto Fort William.

The proponent must rewrite section ESR 8.2.6 to include the water crossing into Fort William.

Specific information and description should be included.

ESR 8.2.7 Delivery of EquipmentThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.

The activities should describe the specific equipment delivered and the size of truck. There aremany varied sizes and weights, many of which are over size or over eight. Without thisinformation it is not possible to understand the potential impacts.

The environmental components should also identify socio economic issues, as the additional trucktraffic, and road closures will impact local businesses.

Potential effects are only identified in general terms. The nature of road closures, how often, andfor how long should be identified.

Mitigation measure identifies defensive driving practices, and delivery times. More detail andinformation about how mitigation would reduce impacts would be useful.

Residual effects are identified as localized and short lived. The specific impacts, and affectedbusiness and residents would be useful.

The proponent must rewrite section ESR 8.2.7 to fully address the missing activities,environmental components, potential effects, mitigation measures and residual effects.

Specifically the proponent must clearly identify the types and sizes of vehicles and impacts onroads and local residents and businesses.

ESR 8.2.8 Foundation ConstructionThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.


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The activities should describe the specific foundation construction activities in sufficient detail tounderstand what the impacts are. The depth and diameter of foundations, and how rock will beexcavated is important missing information.

The list of environmental components is missing the identification and description ofgroundwater and safety of residents who live below the cliffs. This area is a sensitive

groundwater area, and the locating of turbines in proximity to the cliff edges on fragile rock shouldensure the potential impacts are adequately addressed.

Potential effects are missing what might happen to groundwater or the mountain rock structure.With the indication from August 23rd open house where a Horizon representative indicated thatmost of the site rock will come from foundation excavation, it is expected that there will be a lot ofblasting and rock excavation.

Mitigation measures ignore mitigation for groundwater impacts, or for prevention of rock slidesand failures

Residual effects could be devastating and long term. Groundwater impacts would be extremelydifficult to mitigate, and any loss of integrity of the rock structure would result in significantimpacts to local residents and businesses.


environmental components, potential effects, mitigation measures and residual effects, and to

account for the possible impacts to groundwater and to the integrity of the mountain rock

structure.

ESR 8.2.9 Tower and Turbine Assembly and InstallationThis section is deficient in identification of activities, environmental components affected,

potential effects, mitigation, and residual effects.

The activities should describe the specific activities in sufficient detail to understand what theimpacts are. How these activities are carried out, and with what equipment and what impacts is notwell described.

The environmental components should include birds as these cranes and turbine parts are largeand tall. Impacts on birds in this context should be addressed.

Potential effects are only identified in general terms as disruptive. The specific effects and on whatcomponent should be identified.

Mitigation measure identifies that area will be returned as close as possible to original condition.This statement is unclear. Will the areas be top soiled, and trees planted?

Residual effects are identified as none anticipated. This does not correspond to mitigating back tooriginal condition.


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environmental components, potential effects, mitigation measures and residual effect, and to

identify the specific mitigation required to return sites to original condition

ESR 8.2.10 InterconnectionsThis section is deficient in identification of activities, environmental components affected,


The activities should describe the specific construction activities in sufficient detail to understandwhat the impacts are. The stringing of lines and connections should be included

The environmental components should include impacts on birds, bats, and wildlife and noiseimpacts.

Potential effects are only identified as related to archeology. There must be potential negativeeffects, such as impacts on birds, bats and wildlife.

Mitigation measure identifies only mitigation for archeology. The impacts to wildlife etc could bebased on time of year and construction methods.

Residual effects are identified as none anticipated. This should include potential loss of habitatsand disruption to habitats.


environmental components, potential effects, mitigation measures and residual effects.Specifically the proponent must clearly identify potential negative effects on wildlife.

ESR 8.2.11 Water CrossingsElectrical Tap Lines

This section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.

The activities should describe the specific construction activities in sufficient detail to understandwhat the impacts are. This section refers to the water assessment report, but should discussactivities here also

The environmental components should be more specific. The Kaministiquia River is home to awalleye fishery and Lake Sturgeon

Potential effects should include disruption to fish spawning or migrations.

Mitigation measures should include timing the construction activities to avoid sensitive timeperiods.

Residual effects are identified as localized and short lived. Depending on impacts to fisheries thisshould be reviewed.


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environmental components, potential effects, mitigation measures and residual effects, and to

incorporate the fisheries concerns in the Kaministiquia River

ESR 8.2.12 Switching Station ConstructionThis section is deficient in identification of activities, environmental components affected,


The activities should describe the specific construction activities in sufficient detail to understandwhat the impacts are. The size of excavations and equipment necessary should be identified.

The environmental components should include groundwater and wildlife, birds, etc.

Potential effects should include potential to disrupt groundwater or rock integrity, as well aswildlife habitat.

Mitigation measures should include time of construction to reduce impacts on wildlife, how

groundwater will be protected, and any special considerations for rock structures.

Residual effects could be long term if groundwater impacted. The impacts on wildlife and birdswould likely be short lived



Specifically the proponent must clearly identify additional environmental components andpotential negative effects.

ESR 8.3.1 Wildlife Disturbance (birds)

Impacts on birds will likely be significant. The area is known as an area for peregrine falcons andbirds of prey. Local residents attest to significant numbers of waterfowl migrating in the area.

The wind turbines proposed in this area are very large with significant blade lengths. In fact theseturbine models have not yet been constructed anywhere. The interaction between birds, especiallybirds or prey and wind turbines is often lethal to the bird. Numerous articles and information isavailable in this regard, including Globe and Mail, June 10, 2010 Wind farm turbines provingdeadly for birds, bats.

The proponent has a project site 17,000 acres in size. Surely there are reasonable areas withinthose 17,000 acres to locate turbines away from cliffs where falcons nest and hunt.

The proponent must identify in section ESR 8.31 why they cannot relocate turbines away from

cliff face, within the 17,000 acre study area. Movement of turbines away from area would bebest mitigation for potential effects. The precautionary principle should be applied and turbines

moved as far as possible from peregrine falcon potential nest areas, given the project life of 25

to 45 years.


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ESR 8.3.2 Wildlife disturbance (bats)The only comment provided at this time is that there are impacts on bats and potential impactsshould be clearly identified with mitigation. Numerous articles and information is available in thisregard, including Globe and Mail, June 10, 2010 Wind farm turbines proving deadly for birds,

bats.

ESR 8.3.3 Noise effectsIdentifies all points of reception used are residences. Vacant properties should have been modeledwith potential residences. This missing information was identified to proponent and should havebeen corrected

Does not identify that the manufacturer specification includes tonal effect, and no tonal effectassumed for study

Does not identify that sound predicted is just below 40 dB, and there could be more or less noise inreality. Should have identified mitigation and proposed action should noise be higher

A significant issue is that with noise impacts, is that there is a night time operation identified bythe manufacturer to reduce noise. This mitigation measure was not identified (or acknowledged).

Mitigation measure identified was that turbines were relocated south away from residences. This ispartially true, but turbines have been relocated multiple times in the since fall 2009, both towardsand way from homes.

Mitigation measures should have identified possible reduced noise operation, or locating turbinesfarther away.

This section of the report is deficient. For identification of mitigation, it fails to identify that thereare a limited number of turbines (4 to 6) that are the source of most of the noise to residences,mitigation regarding manufacturers reduced noise operation is ignored, and other possibleoperational modes are not identified. The data used to identify the noise impacts is questionable,noise receptors (vacant lots) are missing, the use of estimated manufacturer data, and ignoringother manufacturer data (tonality K of 2 dB)

The proponent must rewrite section ESR 8.3.3 of the report to fully address the potentialmitigation and uncertainty regarding estimatedmanufacturers data.

The proponent must rewrite ESR 8.3.3 of the report to fully describe the mitigation measures

available including manufacturers reduced noise night time operation mode, as well as therationale for the mitigation to be used (and not used ) in this project (i.e. turbine location, blade

size, turbine height etc).Reference the Environmental Noise Study Appendix K for morespecific recommendations regarding the noise study

ESR 8.3.4 Land Use and the Local EconomyThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.


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The activities identifies only wind turbine operation this is too general and the specific activities

of the project related to operation should be identified.

Environmental components affected ignores potential use of the land as ski and hiking trails, theuse of the vistas in the local tourist and hotel economy, the vistas importance as part of the

gateway to Thunder Bay, impacts on the local ski hill, use of Loch Lomond (coldwater fishery),use of area as hunting area for First Nations or Mtis, or any specific employment components.

Potential effects only identifies positive effects in general terms, 3 new jobs, tax base and leasepayments. There should be more information available and provided.

Potential effects not identified are costs to Thunder bay Hydro to connect the project, road upgradecosts for the City of Thunder bay or MTO, loss of jobs from ski hill or hotel closures/reduced use,loss of use of millions of dollars of XC ski trails, impact of no trespassing zones in area, or impactson local homeowners property values. The lack of any negative impacts identified is a concern.

A project that has been marketed as having 75 million $ of benefits to the community should havemore specific information identified. General information on benefits, while tending to downplaythe negative impacts does not provide the public with an accurate assessment of land use and localeconomy.

Mitigation measures identifies that no mitigation is required. Based on the report only providinglimited and positive impacts this is not surprising, but certainly there will some actual or potentialnegative impacts. Mitigation for impacts should include specific and detailed mitigation to reducepotential effects as identified above. These include proponent paying for all or part of the electricalconnection and off site road upgrade costs, rerouting construction roads to stay away from skitrails, relocating turbines away from ski and trail areas, allowing access across roads and project

site, and relocating turbines to reduce property value devaluation.

Residual effects are noted as providing a positive effect on the community. There is no evaluationof the quantity of that effect ort how it would be determined. The residual effect for the abovenoted negative potential effects should be included


environmental components, potential effects, mitigation measures and residual effects. There

must be more detail and negative effects must be identified and considered.

ESR 8.3.5 Landscape




Environmental Component affected only identifies landscape. The visual impact of the turbineswill affect the social portion of the environment. The impact of the turbines on the landscape will


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impact the local community and the City of Thunder Bay who place high value on the naturalbeauty of the area. The environmental component should be expanded to include the broaderdefinition of environment including the social impacts. The development of the project itself hasalready caused significant environmental effects on the community with the formation of a localcitizens group opposed to the project proposed. This section should be revised to include theimpacts of the turbines on the local community, and the City.

The mitigation measures identify that turbines were moved further away from nearest residences asa result of input from the public. Actually the turbines had been moved multiple times, some awayfrom and some towards residences. The actual reasons for moving turbines from one location toanother have not been clearly identified, and statements identifying why turbines were movedshould be supported by information in the ESR to detail rationale for turbine locating, andrelocation.

Further mitigation regarding paint color and lighting is of little use. Turbine manufacturers paintturbines in standard colors, and lighting is required as per regulations. This is not mitigation.Turbine colors and lighting are not identified, and should be to properly assess the supposed

mitigation.

The mitigation of moving turbines back further is totally ignored. This is an important mitigationmeasure, as the available property to the proponent is 17,000 acres, yet it has sited its turbines atthe closest location to existing built up areas. Mitigation regarding smaller turbines has been totallyignored. Smaller turbines would obviously reduce the visual impacts.

Residual effects are noted that turbines will remain visible to residents. There should be somemeasure of how visible and to how many residences. The purported mitigation from movingturbines should be identified. There should be clear and more detailed information regarding thespecific residual effects.

Importance of effects is noted as low. This completely ignores the obvious concerns which remainin the community. Numerous deputations and public concerns have been made to Horizon and theCity in this regard. It is not appropriate for the proponent to identify this as a low importanceeffect.

The proponent must rewrite Section ESR 8.3.5 Landscape to fully address the missing activities,

environmental components, potential effects, mitigation measures and residual effects. There

must be more detail, and mitigation measures must be identified and considered.

ESR 8.3.6 Tourism




The environmental component is identified solely as recreation. There should be more detail

about what specific environmental component is being discussed. For instance there is hiking,


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cross county skiing, and snowmobiling in the area. There may be hunting and fishing. There isdownhill skiing. There is significant potential for that area if left as a natural area for future use asa recreational area.

Potential effects are limited to visibility and road construction. Obviously the project will havesignificant other effects including noise from turbines and construction, cut and fill from

construction, limited access during and after construction, possible ice throws on area users, and notrespassing zones.

Mitigation measures are related to painting and lighting (see section ESR 8.3.6 for comments) andmodifying roads to maintain ski trail high and low points. There is no discussion regardinglocating of access roads to reduce impacts on trails, or how roads will not be compatible with skitrails. This section ignores the potential mitigation of relocating turbines and roads to eliminate orminimize impacts on recreational users.

Residual effects are noted as turbines remaining visible and that ski trails will remain accessibleand topography preserved. The proposed project appears t o actually utilize the present trail system

for its access roads, and the trail network will be useless once severed by roads maintained yearround.

The importance of the effects is identified as low. This statement does not correspond to the highimportance that the people of Northwestern Ontario, Thunder Bay, and South Neebing place onoutdoor recreational activities.

The proponent must rewrite Section ESR 8.3.5 Recreation to fully address the missing activities,environmental components, potential effects, mitigation measures and residual effects. There

must be more detail and mitigation measures must be identified and considered. There must be

recognition of the residual effects of the roads, noise and visual impacts on recreational uses in

the area.

ESR 8.3.8 Property valuesThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.

The activities identifies only wind turbine operation this is too general and the specific activitiesof the project related to operation should be identified. For instance, property value and time onmarket has already been impacted by the proposal and planning activities of a wind farm.

The environmental component is identified as property values. There should be a more clear

identification that this is a social environment component.

Potential effects identify that often residents surrounding a wind farm express concerns regardinglocal property values, and then provides a full page of various studies seemingly proving thatproperty values are not impacted. There is no identification of the significant concerns raised forthis specific project, by local residents, or how this specific area would or would not be impacted.This area is one that has significant natural beauty, and is the primary reason local residentsidentify as affecting the decision to locate there. The area is away from the City downtown, and


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removal of the natural and unadulterated aspect of the mountains will certainly impact decisions tolocate there, and thus property values.

No mitigation measures are identified. There are mitigation measures.The obvious mitigation measure would be compensation direct to property owners from theproponent or the City (landowner). Other mitigation includes relocating turbines to reduce the

property value impacts, reducing the size and noise levels of the turbines, or not building turbinesat all.

Residual effects are identified as not expected to have significant impact on property values. Wedo not know what is significant to the proponent, as the proponent will not be bearing the cost ofproperty value decline. This section should clearly identify what anticipated property value losseswould be, and on what basis. Without this it is merely speculation and conjecture, upon which noone should rely.

Importance of effects is noted as minimal. Of course to the proponent the importance is minimal asthey will not suffer. For local residents, who will solely bear any possible property value loss, it

will be important.

The proponent must rewrite Section ESR 8.3.8 Property values to fully address the missing

activities, environmental components, potential effects, mitigation measures and residual effects.There must be some discussion of this specific area, and potential for property value loss as the

areasmain attraction to buyers is the natural beauty and the lack of noise.

ESR 8.3.9 Public SafetyThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.

The activities identifies only wind turbine operation this is too general and the specific activitiesof the project related to operation should be identified.

Environmental component affected identifies only safety. The nature of this section is that it reallyonly deals with ice throws, so perhaps a more accurate description and component should beidentified.

Potential effects concentrate solely on ice throws. There are obviously other aspects of publicsafety associated with the project, such as electrical contact, climbing/ fall from heights, fire, bladethrow and a turbine failing or falling. These other potential effects and how they relate to thevarious stages of construction should be identified. For ice throws, the information presented is

primarily general in nature and does deal sufficiently with the specific project. For instance theproximity of snowmaking equipment and a ski facility is not addressed. The wind direction, speedand risk to turbines should be identified and discussed. The risk of ice throws is downplayed, andthe concern from local residents who live 600 feet below the mountain the turbines are locatedregarding farther ice throws is not addressed. The risk associated from multiple turbines (ie the sitespecific risk based on 18 turbines) is not addressed. There should be site specific information andevaluation of the potential for ice accretion.


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Mitigation measures are identified as sensors to detect ice buildup. The manufacturer data sheetsdo identify ways to try to identify ice buildup including imbalance and power loss measurements.These methods rely on ice building up and a period of imbalance and power loss before blades arestopped. There will still be ice buildup, and potential for ice throw.

Mitigation is also identified as posting signs. This will mitigate neither ice throws nor public safety

(the risk will be the same, people will just be more aware).

Mitigation not discussed includes moving turbines away from human activities and residences ,using a more sophisticated system of observation, data collection and sensing to detect conditionswhich ice forms in and shutting down at those times, having exclusion zones which the publiccannot enter,

The proponent must rewrite Section ESR 8.3.9 Public Safety to fully address the missingactivities, environmental components, potential effects, mitigation measures and residual effects.

There must be some discussion of the various public safety risks and mitigation. Mitigation

measures including moving turbines away from homes should be considered given the

potentially disastrous impacts of ice throw, blade throw, or turbine failing.

ESR 8.3.10 Aeronautical ObstructionThis section is deficient in identification of activities, environmental components affected,potential effects, mitigation, and residual effects.

The activities section identifies only wind turbine operation this is too general and the specificactivities of the project related to operation should be identified.. For instance, risk to airplaneduring construction from cranes would be different than during operation when th