wpd answers APPEC questions about White Pines Project

On March 11, wpd Canada received a list of 17 questions from a local group Alliance to Protect Prince Edward County ( APPEC) which is opposed to the development of industrial wind projects in Prince Edward County. The list was also forwarded to local media outlets by APPEC.
Kevin Surette, wpd manager of communications, shares the list of the 17 questions and wpd responses. The document, he notes, was made available to the public at the White Pines open house.

APPEC Question 1: To understand the benefits for the community, it is necessary to know the scale of project participation and the population size affected.
a. How many people are participating in the White Pines Wind Project?
b. How many project participants are resident within or adjacent to the project?
c. How many nonparticipants will be living 550 m from an industrial wind turbine (IWT)?
d. How many nonparticipants will be living within 1000 m?
e. How many nonparticipants within 1500 m?
f. How many nonparticipants within 2000 m?

wpd Response
The White Pines project is located in the ward of South Marysburgh and a small portion of Athol, and covers an area of approximately 105 square kilometres.
30 landowner families are participating in the project. The project will contribute an average of approximately $860,000 yearly to the local economy through lease arrangements. In addition, there will be municipal property taxes assessed – to be determined.
The Noise Assessment Report (required under regulation 359.09) will be available 60 days prior to the Final Public Open House and will list all dwellings* within 1.5 km of the turbines (participating and non-participating).
* For official definition of dwelling in reference to wind projects, please consult O.Reg 359/09

APPEC Question 2: Wind energy developers often claim to have broad community support.
a. Has WPD surveyed public opinion in South Marysburgh?
b. In Prince Edward County?
c. If there are no survey results, what does WPD believe is the percentage of community support?
d. What percentage of community opposition would be sufficient for WPD to abandon the White Pines project?

wpd Response
It is not a requirement of O.Reg 359.09 to conduct public opinion surveys, however, there are a number of ways for the public to express support or opposition to the project, voice concerns or to APPEC ask their questions about the White Pines project (see note at the bottom of this answer). A summary of all communication with the public will be part of the Renewable Energy Approval (REA) application.
The public is able to provide written comment to us via mail or email. In addition, we must hold two Open Houses prior to submitting our Renewable Energy Approval (REA) application, as well as post all the relevant documentation on our website. We are required to summarize feedback received during any of these stages, and include it in our application. Once the application is determined to be complete and is accepted by the Ministry of the Environment (MOE), it will be posted to the
Environmental Registry (EBR). Within 10 days, we will be notifying members of the community via local papers and the project website that the MOE has accepted our application. The community will then have at least 30 days to review and provide comment to the MOE on our application. If the project is approved, any member of the public can appeal the decision through the Environmental Review Tribunal within 15 calendar days of the decision being posted on the Environmental Registry
(EBR). (http://www.ert.gov.on.ca/english/home.html)
Ways for Members of the Public to Contact wpd
Phone: 1-888-712-2401, Ext 118
Email:WhitePinesProject@wpd-canada.ca
Canada Post or Courier: White Pines Project, 2233 Argentia Road, Suite 102, Mississauga, Ontario,
L5N 2X7
APPEC Question 3: According to the Ministry of Environment’s regulations, IWTs must be set back at least 50 m from roads and 550 m from residences.
a. When IWTs are operating under typical wind conditions, what is the predicted noise level along roads?
b. Which IWTs will be perceived as the noisiest?
c. By how many decibels will they exceed current ambient levels of sound?

wpd Response
The setback requirements put in place by the Ministry of the Environment (MOE) regarding sound for wind turbines apply to non-participating dwellings*. According to O.Reg 359/09, turbines must be placed a minimum distance of 550m, provided cumulative sound levels at non-participating dwellings*, does not exceed 40 dBA. wpd has utilized sound modelling software to aid in the design of the wind farm as proposed; however, a third party sound assessment firm will be retained to provide the Noise Assessment Report submission to the MOE. This report must show that predicted sound levels at non-participating dwellings* do not exceed 40dBA. Our turbine manufacturer, REpower has guaranteed to us the maximum sound produced by the turbines. This level has been used in calculations to ensure the sound level at non-participating dwellings* meets the
requirements of the regulations.
* For official definition of dwelling in reference to wind projects, please consult O.Reg 359/09

APPEC Question 4: Many rural Ontarians have expressed concern about the effects of IWT noise and
infrasound.
a. How will WPD monitor for adverse health effects?
b. How will WPD specifically monitor for infrasound and low frequency noise?

wpd Response
wpd will follow the highly prescriptive process put in place by the Ontario Government to apply for, develop and operate a wind project. Various Ministries will review our Renewable Energy Approval (REA) application to ensure we have met the requirements of this process. If any member of the public disagrees with an approval of our REA application, they can appeal the decision through the Environmental Review Tribunal within 15 calendar days of the decision being posted on the
Environmental Registry (EBR). (http://www.ert.gov.on.ca/english/home.html)

APPEC Question 5: Will WPD provide a written guarantee to every resident within 2000 m of a White Pines turbine that he or she will not suffer adverse health effects from these installations?

wpd Response
wpd can guarantee that it will meet the requirements put in place by the Ontario Government to apply for, develop and operate a wind energy project.

APPEC Question 6: Other wind developers in Western Ontario have bought out homeowners, at preturbine market values, that were suffering negative health effects from IWTs. Will WPD undertake to do the same in Prince Edward County?

wpd Response
We are not privy to this information nor would we be privy to the circumstances or reasoning behind the decisions of other wind developers. We will follow the requirements put in place by the Ontario Government to apply for, develop and operate a wind project.

APPEC Question 7: What guarantees will WPD put in place to ensure that homeowners within 2000 m of any IWT will not suffer diminished property values?

wpd Response
The RE/MAX Market Trends Report – Farm Edition 2011, released September 12th, 2011 found that agricultural property value has increased throughout Ontario, including areas such as Chatham-Kent where wind turbines have been installed for some time. This report reflects the conclusions of three significant reports. (1. The Impact of Wind Power Projects on Residential Property Values in the United States: A Multi-Site Hedonic Analysis; Ernest Orlando Lawrence Berkeley National Laboratory; December, 2009. 2. Wind Farm Proximity and Property Values: A Pooled Hedonic Regression Analysis of Property Values in Central Illinois; Jennifer L. Hinman; May, 2010. 3. Wind Energy Study – Effect on Real Estate Values in the Municipality of Chatham-Kent, Ontario; George Canning and John L. Simmons; February, 2010). These studies were conducted to measure the
effect of wind projects on property values. The reports looked at past housing sales and concluded that, within the study areas, there was no evidence to suggest the presence of a wind facility negatively affected property values or cumulative home sales.

APPEC Question 8: Many buildings in the study area are designated as heritage.
a. Has WPD established special setbacks?
b. Will WPD guarantee there will be no loss to the heritage value of South
Marysburgh?

wpd Response
As part of the Renewable Energy Approval (REA) application, wpd is required to prepare a Heritage Assessment Report and Protected Property Assessment Report. This report is then reviewed by the Ministry of Tourism, Culture and Sport. As part of the consultation process, wpd will seek input from the municipality regarding the identification of heritage and/or protected properties within the municipality. The Heritage Assessment Report will be made available to the public at least 60 days prior to our Final Open House for the project.

APPEC Question 9: In the latest site plan for the White Pines project the electrical substation has been relocated.
a. Why?
b. How close is it to the home of the nearest nonparticipant?
c. What guarantees will WPD provide that this substation will not affect neighbouring
properties?

wpd Response
In order to transport the output from the project to the connection point on the grid, it is necessary to step up the voltage of the power collected from the turbines through the use of a transformer substation. Two potential locations are being considered, near turbines #3 and #7, with the substation located near turbine #7 being the preferred location. However, negotiations are still underway with Hydro One regarding the interconnection line, which could result in the substation being located near turbine #3. An additional transformer substation will be required at the project’s connection point to the grid, near the Picton transformer station. The electrical substation located near turbine #7 is approximately 691m from the nearest  non-participating dwelling*. According to O.Reg 359/09, this substation is subject to the same maximum sound and minimum distance requirements as the turbines.
* For official definition of dwelling in reference to wind projects, please consult O.Reg 359/09

APPEC Question 10: What is the total acreage required for turbine bases, access roads, and
substations?

wpd Response
The 29 turbine bases, the access roads and substations use approximately 37 acres.

APPEC Question 11: How many trees will be cut down for the installation of IWTs, access roads and transmission lines?

wpd Response
Any clearing of shrubs and removal of trees for turbines and access roads will occur on private lands with the owner’s permission. If collector lines are to follow municipal right-of-ways, we will work with the municipality. We will remove the minimal amount necessary for proper access and placement.

APPEC Question 12: What is the proposed route for the transmission line? If it is Mapul Llayn, how does WPD justify cutting down heritage maple trees?

wpd Response
There are two aspects to the transmission system for the White Pines Project: collecting the power produced by the turbines (via collector lines), and supplying the power to the grid (interconnection line). Collector lines will either be on participating landowners’ property or follow municipal or Hydro One right-of-ways. We will work with the municipality and Hydro One to determine these details. For the interconnection line, we are relying on Hydro One to ensure our power output is transmitted to the Picton transformer station. This would involve using Hydro One’s infrastructure, or potentially using infrastructure developed in conjunction with the Gilead project. We are still working with Hydro One on this as well, however it is more related to process and cost than to routing.

APPEC Question 13: Every wind project has environmental impacts specific to each IWT.
a. Which natural features (e.g. woodlands, wetlands) will be affected by each IWT?
b. Which endangered or threatened species?

wpd Response
Natural heritage features were inventoried and assessed, and potential impacts from the project to natural features are being identified within the Natural Heritage Assessment and Environmental Assessment Report. Provincially accepted protocols and guidance were applied to determine the existence and boundaries of all natural features found within 120 m of the Project Location. The NHA Report will be available to the public at least 60 days prior to the Final Public Open House.
Provincially endangered and threatened species are being addressed under the requirements of the Endangered Species Act (ESA 2007). Information required to address these species is being submitted to MNR directly. Where this information indicates that approvals or permits are required, these will be addressed through the ESA permitting process.

APPEC Question 14: What is the predicted bird collision mortality for the 12 IWTs installed inside the South Shore Important Bird Area versus those outside?

wpd Response
Bird mortality at existing Ontario wind farms has been low to date and experts agree that this level of mortality is not concerning at the population level. The Ministry of Natural Resources (MNR) has produced detailed and prescriptive guidelines for post-construction monitoring of bird mortality, and monitoring will occur for a minimum of three years in accordance with these guidelines. Annual post-construction monitoring reports will be submitted to MNR (through the Ministry of the
Environment) and results will be reviewed annually by MNR and wpd. Please note that the number of birds killed by wind turbines is substantially lower than that from other human sources of mortality, such as collisions with windows, buildings, and communication towers; cats; farming and pesticides; and vehicles.

APPEC Question 15: Every wind developer prepares a plan for decommissioning a project, but without financial commitments.
a. Will WPD be depositing cash, a bond or a letter of credit to guarantee demolition of all turbines and related infrastructure and the complete restoration of the natural environment?
b. If so, for how much?

wpd Response
A developer is required to decommission the wind turbine at their own expense at the end of a typical 20 year Power Purchase Agreement contract with the Ontario Power Authority. As part of the Renewable Energy Approval (REA) process, wpd is required to submit a decommissioning plan to the Ministry of Environment (MOE) detailing how this will be achieved. The Renewable Energy Approval (REA) application must be approved before wpd can start construction. wpd Canada, as
part of our standard leasing agreement, provides an escrow account covering the estimated cost of dismantling the facility. Monies are set aside and controlled by a third party.

APPEC Question 16: The proposed layout extends over a large geographic area. Does the layout design facilitate project expansion? That is, does it permit the infilling of IWTs?

wpd Response
wpd’s contract with the Ontario Power Authority (OPA) is limited to a maximum 60MW of nameplate output. Our project, as proposed, is at a nameplate value of 59.45MW. In addition, the presence of the Department of National Defence (DND) facilities in Trenton and Mountain View will limit the areas within Prince Edward County where turbines could be placed. In order to place additional turbines, capacity would have to exist on the grid, we would have to apply for a contract from the OPA and DND would have to have no objections.

APPEC Question 17: The original White Pines project was announced as 75 IWTs. If not within the current proposed project, where will project expansion occur?

wpd Response
The original project was conceived and begun prior to the new, more restrictive requirements for wind projects under the Green Energy Act. As a result of the new setback requirements, we were obliged to limit our project to 29 turbines. Also, we believe the presence of the Department of National Defense (DND) facilities in Trenton and Mountain View virtually eliminates 80 % of Prince Edward County from hosting wind turbines without DND objection, only leaving the southeast corner available for wind energy development.
In addition to the 17 questions, APPEC’s Chair wrote a letter to wpd requesting that wpd provide specific items of documentation to the public regarding wind turbines that were referred to in a letter from its counsel, Mr. Eric Gillespie. The foundation of this letter was drawn in large part from testimony given at the Environmental Review Tribunal (ERT) proceedings for the Kent Breeze wind project (Erickson vs. Director, Ministry of the Environment, Case No. 10-121/10-122). Rather than providing any particular individual’s opinion on the findings of the Environmental Review Tribunal, wpd recommends that the
public read the decision in its original unaltered form. This will allow readers to draw their own conclusions from the original content and remove any unnecessary bias.
The text in its original form can be found by visiting the Environmental Review Tribunal Decisions and Orders Website (http://www.ert.gov.on.ca/english/decisions/index.htm ) and, using the search function near the top right, type in ‘Case no.10-121’.
For the convenience of the public, while at the Public Open house, wpd has made available a portion of text of the decision that addresses the overview, overall conclusion and final decision of the Tribunal. In spite of the provided pages, wpd would still strongly encourage all members of the public who are interested to review the decision of Environmental Review Tribunal in its entirety.