The Ministry of the Environment and Climate Change has responded to numerous questions about wind energy, specially questions raised about the proposed Otter Creek project planned for north of Wallaceburg.
Gary Wheeler, a spokesperson for the ministry, told the Sydenham Current the Ministry of the Environment and Climate Change takes all concerns about wind turbines and wind farms very seriously.
“That’s why Ontario’s Renewable Energy Approval process ensures that the environment and human health are protected and that developers conduct extensive municipal, Indigenous and public consultation,” Wheeler said in an email to the Sydenham Current.
“We have taken a cautious, science-based approach when setting standards for renewable energy projects to protect the people of Ontario.”
Wheeler said Otter Creek’s REA application was posted on the Environmental Bill of Rights (EBR) Registry for a 45-day public review/comment period in July.
“The ministry is currently undertaking a technical review of the REA application for Otter Creek Wind Project,” he said.
“As part of the technical review, all comments received during the 45-day comment period will be reviewed and considered by the ministry. The ministry will carefully review any correspondence when we receive it.”
The Sydenham Current posed a number of questions (in bold below) to the Ministry, and their answers are listed below (in italics):
What does the Ministry do to measure the risk of noise impacts for wind turbine projects, specifically ‘infrasound’?
The 2010 expert report on low frequency sound from wind turbines found there is no direct health risk from wind turbine sound at the province’s regulated sound level criteria of 40 dBA and the minimum setback distance of 550 metres.
Does the Ministry consider ‘infrasound’ a potential concern for the proposed Otter Creek project? Are there regulations to measure it?
We have the capability to measure various types of wind turbine noise, including low frequency noise, using internationally-recognized procedures, in the frequency range of 20 Hertz to 20,000 Hertz. The MOECC sought external advice in developing a measurement protocol from noise from wind turbines in the frequency range of 20 Hertz to 20,000 Hertz. Based on the report prepared by the external experts, the MOECC developed a measurement protocol specific to wind facilities known as the Compliance Protocol for Wind Turbine Noise. The document can be found at: https://www.ontario.ca/document/compliance-protocol-wind-turbine-noise
Is the Otter Creek project a forgone conclusion to be approved and proceed?
The ministry’s review team, with input from key ministries and agencies, ensures that: the application satisfies all regulatory requirements; reviews all submitted reports, including the Consultation Report; and, considers all comments submitted to the ministry prior to making a decision on the application. A significant part of the REA review process is the consideration of how the proponent addressed community concerns raised during the consultation process.
What would some reasons be for a project to be stopped at this point in the process?
The project is still under review and the ministry has not rendered a decision, so at this point it would be premature to speculate.
Does the Ministry have any concerns about the proximity of this project to the majority of the population of the town of Wallaceburg?
Our minimum noise setback distance of 550 metres was determined based on conservative modeling. The modeling considered a number of variables including the number of wind turbine units as well as the sound power level of the turbine. Ontario has one of the strictest sound criteria in North America. The setback and noise limits are consistent with limits set in 2009 by the World Health Organization (WHO).
What are the Ministry’s thoughts about the proposed Enercon E-141 turbines, pro’s/con’s? (Min of Energy?)
As part of our technical review of the application, the ministry will ensure that the proposed project can meet our stringent noise and setback requirements. Through the technical review of the REA application, the ministry will ensure that noise generated from the proposed turbines meet the ministry’s stringent noise requirements
Would these turbines be the largest in Canada?
Until the REA application process is complete it would be premature to discuss the specifics of the project.
Is there a threat of water wells being damaged with contaminants, such as Black Shale, with the proposed construction of the Otter Creek project?
Regarding North Kent and water quality, the ministry is aware that the shale of the Kettle Point Formation underlies the area. The groundwater has historically flowed through an aquifer made up, in part, of Kettle Point shale granules and private wells in the area rests on this bedrock. Well water quality testing prior to wind turbine construction showed that turbidity in the wells could be associated with naturally occurring groundwater conditions.
The ministry is using turbidity analysis to assess whether vibrations associated with wind turbine construction are related to the amount of particles in the groundwater. Particles do not dissolve with vibration.
According to the Chatham-Kent Medical Officer of Health, there is no health hazard from particulates in the water. Historical information on the groundwater aquifer has not identified any issues with metals in the water column.
The primary purpose of the ministry’s sampling is to provide an independent confirmation of the analytical results reported by the proponent and their consultant. The ministry’s sampling aligns with the parameters set out in the Renewable Energy Approval (REA).
How much feedback, what type of feedback and did any concerns arise from the recent 47-day public feedback period for the Otter Creek project?
As part of the technical review, all comments received during the comment period will be reviewed and considered by the ministry. As such, we are not able to disclose the comments at this time.
What is the Ministry’s thoughts about the emergence of the Wallaceburg Area Wind concerns group and the possibility of being brought to a tribunal about the Otter Creek project?
REAs issued for wind projects are commonly appealed. Anyone in Ontario can appeal the REA of a renewable energy project to the Environmental Review Tribunal (ERT) within 15 days.
There are two grounds for appeal to the ERT:
– Engaging in the project will cause serious harm to human health; or
– Engaging in the project will cause serious and irreversible harm to plant life, animal life or the natural environment
ERT decisions may only be appealed in court on questions of law or to the Minister of the Environment and Climate Change on questions of fact. ERT appeal decisions can be further appealed to the Divisional Court and/or the Minister of the Environment and Climate Change
Does the Ministry feel the findings from the ‘Golder Report’, used in the North Kent project, apply to the Otter Creek project, and would these findings be considered scientific evidence?
As part of their REA application, the applicant retained consultant GHD to conduct a peer review of the Golder Report.
As part of this peer review, GHD compared the geological conditions at the Otter Creek site in order to assess whether the conclusions in the Golder Report for the North Kent site could be reasonably considered to apply to the Otter Creek site.
Both the results of the GHD peer review and the Golder Report were submitted with the REA application. Both reports are being reviewed by the ministry as part of the technical review of the application.