IS MOE changing REA rules on the fly?

Doris Dumais
Director – Approvals Program
Environmental Assessment and Approvals Branch
Ontario Ministry of Environment
Dear Ms. Dumais:
Your letter of June 5, 2011 acknowledged my continuing concern that the public has not yet been either informed or consulted about project plans for the routing of either the power transmission lines or the component transportation, for the Ostrander Point Wind Energy Project proposed by Gilead.  You suggested that I contact Hydro One and the Municipality of Prince Edward County concerning these issues.  But I submit that such consultations are Gilead’s responsibility, not mine.
Your suggestions only support my increasing suspicion that MOE’s public consultation process for this REA is a SHAM.  I am coming to that conclusion for the following reasons:
1.When this project was introduced to the public, Gilead obviously believed that transmission lines were within the scope of the project.  Indeed, in its initial plans Gilead showed its intended routing of power transmission lines to be along Maypul Layne Road.  Then, following negative public reaction to this proposed routing, your ministry advised that such routing is not within the scope of Gilead’s project responsibility, and therefore not subject to the REA consultation process. You have suggested that I engage Hydro One regarding my concerns about the transmission lines.  One of my colleagues, Duncan Fischer, has already attempted to do so without success.  It appears to me that MOE is changing the REA rules “on-the-fly”, to deny local residents an opportunity for open consultation while also absolving the project proponent of responsibility to consult with them concerning the significant impact that transmission lines may have on our neighbourhoods.  This renders the consultation process a SHAM.
2.When the project developed further, Gilead proposed that the routing for the supply of project components, including giant turbine blades, would be through the centre of the hamlet of Milford, right past this Ward’s only General Store, Restaurant, Post Office, Gas Pumps and Public Library.  Gilead then attempted to minimize perceived public impact by observing in its draft transportation plan that traffic at this intersection was “minimal”!  Following strong adverse public reaction to this proposed routing, Gilead then announced that it was seeking other routing, and subsequently entered into negotiations with municipal engineers.  You are now suggesting that I engage with my local municipal officials and with the proponent directly regarding this matter.  It appears to me that MOE is again changing the rules on the fly, to
complicate for local residents their MOE-mandated rights for open proponent-driven consultation, while also absolving the project proponent of responsibility to proactively consult with local residents prior to seeking project approval.  This further renders the consultation process a SHAM.  I have repeatedly engaged the project proponent on this issue, and I have copied both Gilead (Stantec) and the Mayor of the municipality on my earlier letters to you.
The routing of both the transmission lines and the supply of components were considered by both Gilead and local residents to be an integral part of the project at the beginning of this project’s planning and consultation process.  Informing and consulting members of the affected public about potential impacts of Wind Energy projects should be the responsibility of the proponent, not left to the initiative of individual members of the public as you suggest in your letter.  Both of these routing issues need to be resolved and reported upon by Gilead to the public and to MOE, prior to MOE’s determination of whether or not Gilead’s REA application is deemed to be complete.

We trust that MOE will take whatever steps may be necessary to protect the integrity of its proponent-driven public consultation process.  As you have suggested, I am sending a copy of this letter to Shannon McNeill, Senior Project Evaluator, hoping that steps will be taken to strengthen the REA process to correct the deficiencies identified in my correspondence with you.

Yours sincerely
Jim McPherson
South Marysburgh Resident