EBR Tech. SR TOC

TABLE OF CONTENTS

Comments Regarding EBR Number 011-8756.........................................................................2

The Oak Ridges Moraine................................................................................................................. 2

Water................................................................................................................................................... 11

Natural Heritage Flora and Fauna.............................................................................................24

Cultural Heritage:........................................................................................................................... 47

Cultural Heritage Assessment.............................................................................................................47

Archaeological Assessment..................................................................................................................52

Construction and Geotechnical:.................................................................................................58

Health and Safety............................................................................................................................ 67

Noise Impact Assessment:.....................................................................................................................77

Effect on Children.......................................................................................................................................96

Flicker Shadow Effect............................................................................................................................103

Economic Impact.......................................................................................................................... 108

Public Consultation......................................................................................................................120

SUMAC RIDGE WIND PROJECT

EBR TECHNICAL SUBMISSIONS

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COMMENTS REGARDING EBR NUMBER 011-8756

The proponent wpd Canada Corporation is proposing to construct a wind power plant project called Sumac Ridge. This submission will demonstrate that the project site is unsuitable for a power plant and that the surveys and assessments produced by the proponent do not support the proponent’s contention that this industrial project will have minimal or negligible effects on the environmental, social, cultural and economic health of the area.

THE OAK RIDGES MORAINE

Biologist A. H. Richardson, wrote of the Oak Ridges Moraine in 1941, "A great part of the headwaters today is a barren waste. Its prosperous days of lumbering, settlement and substantial contribution to Canada's wealth are merely history, although history that is all too recent in terms of the exploitation and exhaustion of resources." – (from Richardson's study "A Report on the Ganaraska Watershed" which led to the creation of the Conservation Authority movement in Ontario).

According to the government of Ontario,

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“The Ontario government's vision for the Oak Ridges Moraine is that of "a continuous band of green rolling hills that provides form and structure to south-central Ontario, while protecting the ecological and hydrological features and functions that support the health and well-being of the region's residents and ecosystems". Also according to the

government under Plan Objectives: The Oak Ridges Moraine Conservation Act, 2001 establishes the following objectives for the Oak Ridges Moraine Conservation Plan:

(a) protecting the ecological and hydrological integrity of the Oak Ridges Moraine Area;

(b) ensuring that only land and resource uses that maintain, improve or restore the ecological and hydrological functions of the Oak Ridges Moraine Area are permitted

In March 2010, now Minister of the Environment, Jim Bradley with regard to the nomination of the Oak Ridges Moraine as a World Biosphere Region stated:

“ I am pleased to support the Oak Ridges Moraine Foundation’s bid for the designation of the Oak Ridges

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Moraine and adjacent Protected Countryside Areas of the Greenbelt, as a UNESCO World Biosphere Region.” http://www.mah.gov.on.ca/Page7211.aspx

According to page 98 of the Technical Guide for Renewal Energy Project Approvals: “ In addition to the specific requirements related to provincial plans in O.Reg.359/09, applicants should broadly consider the policy intent of the relevant plan when designing their project in a protected area.”

The construction of industrial wind power plants that require multiple access roads and excavations for huge permanent concrete bases will not serve to support the objectives or vision set out by the government for the Oak Ridges Moraine. If approved in its present state, the Sumac Ridge power plant project will set a precedent thus allowing many future large scale industrial power plants on this unique landform which plays an important role in the province’s water supply.

When the Oak Ridges Moraine Conservation Plan was drawn up in 2001, the future proliferation of industrial wind turbines was not anticipated.

The Board representing the advocacy group STORM (Save

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the Oak Ridges Moraine) in a letter to the Premier dated March 1st, 2012 did seek a moratorium on industrial wind power plants constructed on the Oak Ridges Moraine until full environmental assessments become mandatory.

Debbe Crandall has been involved with the Save the Oak Ridges Moraine Coalition (STORM) as a volunteer board member and Executive Director. Ms. Crandall has represented STORM on a number of provincial initiatives concerned with landscape-scale, conservation planning and regional growth management. Ms. Crandall was appointed to the Oak Ridges Moraine Advisory Panel, which developed the framework for the Oak Ridges Moraine legislation, as well as the Central Ontario Smart Growth Panel.

From: The Moraine – A Cloudy Forecast : “Another gap allows some infrastructure work to fall outside the rules of the moraine plan. In fact, provincial policies on green energy have meant projects such as a controversial proposal to build windmills near Pontypool are, in Crandall’s words, “fundamentally removed from environmental assessment and the Planning Act.”http://watershedmagazine.com/?p=1558

On May 17th 2012, the Board of the Ganaraska Region Conservation Authority passed a resolution seeking a moratorium on industrial wind developments on the Moraine until full environmental assessments are made a mandatory requirement as part of O. Reg 359/09. On September 27th, 2012, the board of the Kawartha Conservation Authority also

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adopted a motion with a special emphasis on industrial wind projects stating full environmental assessments must be made mandatory for renewable energy projects.

Two industrial wind turbines in the Sumac Ridge power plant will be constructed within vulnerable areas of the Moraine. When asked about building this project on the Oak Ridges Moraine, wpd Canada Corporation spokesperson Kevin Surette wrote,

“Legislation sets a clear policy framework for protection of the Moraine, and provides land use and resource management direction. The limited development that is allowed in the Moraine, must follow strict requirements. The Project will be developed in accordance with those requirements. Should the Ministry find that the turbines proposed within the Moraine do not meet those requirements, they will not be approved. Mr. Surette did not expand on what those

requirements might entail. WPD spokesperson Kevin

Surette also stated.... “Two turbines are proposed within the Moraine, and fall within a Countryside Area. Development in this type of area is restricted to items such as transportation, infrastructure, and utility uses, to name a few. As

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wind turbines generate electricity, they are included within the category of permitted development. However, should the MOE determine that these two turbines do not meet the requirements for development, they will not be approved.”

The ORMCP plan states allowable uses for sites designated ‘Countryside’ and include:

The following uses are permitted with respect to land in Countryside Areas, subject to Parts III and IV:

Transportation, infrastructure, and utilities as described in section 41.

41. (1) Transportation, infrastructure and utilities uses include,

(a) public highways;

(b) transit lines, railways and related facilities;

(c) gas and oil pipelines;

(d) sewage and water service systems and lines and stormwater management

facilities;

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(e) power transmission lines;

(f) telecommunications lines and facilities, including broadcasting towers

Power transmission lines are not the same thing as an energy generating power station which the Sumac Ridge project is. Nowhere is it stated in the ORMCP that power plants are allowed to be constructed on the Moraine.

wpd Canada Corporation did not advise the public that the Sumac Ridge power plant project is to be constructed on the Oak Ridges Moraine. There is no mention of the Moraine in any of the public notices issued by the proponent. The Sumac Ridge application is the first application for a power plant to be constructed on the Oak Ridges Moraine. There are two additional proposed projects adjacent to the Sumac Ridge project – Settlers Landing and Snowy Ridge. Both will also be built on the Oak Ridges Moraine. Allowing the construction of power generating plants on the ecologically sensitive Oak Ridges Moraine will set a dangerous precedent.

This submission will demonstrate that the reports prepared by wpd Canada Corporation have not provided sufficient information demonstrating that the construction of the Sumac Ridge project will protect “the ecological and hydrological integrity of the Moraine” as set out in the government’s vision or “ ensure that only land and resource uses that maintain, improve or restore the ecological and hydrological functions” . The project may result in serious

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and irreparable harm and thus should not be approved.

It has not been demonstrated that serious and irreparable harm will not befall the Oak Ridges Moraine by the proponent.

The boards of the Ganaraska Region Conservation Authority, STORM (Save the Oak Ridges Moraine) and the Kawartha Conservation Authority have passed and/or adopted resolutions stating that a Full Environmental Assessment must be a requirement for any industrial scale renewable energy project proposed to be constructed on the Oak Ridges Moraine.

The ORMCP states under Section 41 that utility development is restricted to transmission lines. A multiple wind turbine project is considered to be a utility generator. The ORMCP does not state that utility generators are allowed to be constructed on the Moraine. The two turbines to be erected on the Moraine,. #4 and #5 are both located in an ecologically and hydrologically sensitive area.

The Oak Ridges Moraine contains 1,171 plant species; 125 species of moss, 166 breeding bird species (and more through migratory seasons), 30 species of reptiles and amphibians, 51 mammal species, 73 fish species, 74 species of butterflies, 70 dragonflies and damselfly species. Eighty-eight species are provincial or national species at risk and 466 are moraine rare (Canada as a whole has 71,500

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species of plants and animals, with approximately 422 species at risk).

64 rivers or streams begin on the moraine and run either south directly into Lake Ontario, or north to Lakes Scugog, Simcoe or Georgian Bay (Lake Huron).

Because a full environmental assessment has not been conducted, the proponent has not demonstrated that the hydrologic functions of the Moraine will not be negatively affected. The proponent has not demonstrated that natural heritage features of the Moraine will not be seriously and irreparably harmed. When mature trees and heritage hedgerows are removed, when watercourses are altered, grassland areas removed and structures are erected that kill and maim wildlife, wildlife habitat is also removed. The claim on page 3 of the Ortech Water Report & Environmental Impact Study that the project will result in “Habitat Loss – None – No Habitat Loss is Planned’ is not accurate.

wpd Canada Corporation has indicated that if the Ministry of the Environment was to find that the Sumac Ridge project unsuitable for the Oak Ridges Moraine, the proponent will respect that decision. The biodiversity of the Oak Ridges Moraine needs the utmost protection. As well as its diverse wildlife population, hundreds of thousands of Ontario depend on the retention of the complex hydrologic cycles that are found throughout this unique landform. That water security needs to be ensured for the present and the future.

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“The moraine has been shaped by the forces of nature and the forces of human occupation. What happens in the future will depend on understanding the past and by acting now to find a course of continued sustainability.” - ORMF

WATER

“The Oak Ridges Moraine's most important function is sustaining the health of the many watersheds and the diversity of species that live within them. Permeable sands and gravels, deposited in random patterns by glacial melt-waters between two lobes of ice, now collect precipitation which slowly recharges the deep aquifers below the ground. These same sands and gravels filter and release this groundwater to over 65 watercourses flowing north and south into Georgian Bay, Lakes Simcoe, Scugog, Rice and Ontario.” – www.oakridgesmoraine.org

The Sumac Ridge project area drains into two watersheds – the Pigeon River watershed and the Fleetwood Creek watershed which are fed by “groundwater found within the Oak Ridges Moraine”. Construction of the large scale

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industrial Sumac Ridge development could result in serious interference and impact to two watersheds. The consultants acknowledge that there are numerous springs and seeps to be found just outside the project perimeter. There is no evidence that these complex water features which may be, and are likely connected, to water features in the project area were given due consideration.

There are many springs and bodies of water in the subject area. A few examples: Receptor R001 – Pit Road - this property contains an artesian well which constantly runs out of the side of the hill. Receptor R005 - 804 Hwy 7A contains a spring-fed pond. Receptor R060 on Gray Rd also has a pond as does Receptor R061 also on Gray Road. The property of Receptor R062 located on 999 Gray Road also contains spring-fed ponds.

Historically there is evidence that the hydrology of this area of the Moraine is in a state of flux. The creation of the settlement of Pontypool in the 1830s was based on the resources provided by the three distinct pools fed by nearby streams in the immediate vicinity. The nearby village of Pontypool was known from the 1920s to the 1950s as a summer resort for hundreds of vacationers from the Jewish community in Toronto. It was said that the waters of the 5 acre pond seemed to have a special healing effect. Cottages sprang up around the ‘Big Pond’. The ‘big’ pond is a fraction of its former size and the resort community has disappeared. In recent years however, the three ponds have overflowed on several occasions resulting in wide scale flooding of the

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village. Even homeowners in a subdivision built 100 feet higher than the village of Pontypool have had to deal with flooded basements.http://www.mykawartha.com/news/news/article/865888

The Sumac Ridge project is in close proximity to the Pigeon River Headwaters Conservation Area situated on the Pigeon River. Water collects in the high grounds of the Moraine and forms the headwaters of the Pigeon River. Headwaters are an essential part of the water cycle and critical to the residential, commercial and industrial water supply. Components of the Sumac Ridge project may interfere with the headwaters of the Pigeon River. There are 5 water features that fall within 120 m of components of the wpd Canada Corporation project - a seasonal fish habitat, a complex fish habitat, a large man-made pond, two artesian wells, and a spring. The spring will be in the direct path of the electrical line to be constructed along the length of the unassumed laneway Gray Road. The construction of the transmission line either above or below ground may interfere with two underground streams that conjoin and are located at the junction of Gray Road and Highway 35. Turbine # 5 located on the Moraine in a high infiltration area will be bordered on two sides by tributaries of Fleetwood Creek.

The staff of NRSI who prepared the Water Report are not

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qualified hydrologists or hydrogeologists, Despite many studies, (Natural Resources Canada website lists over 200), the complex surface and groundwater system of the Oak Ridges Moraine is still not fully understood. Over 250,000 people and countless numbers of wildlife rely on it for survival. It is essential therefore, that a full hydrogeological study be conducted by qualified hydrogeolgists familiar with the Oak Ridges Moraine before approval of this project is considered and/or construction is allowed to proceed.

The aquifer in the area of the Sumac Ridge project has been identified as being in an Area of High Vulnerability. Despite assurances from the proponent, it could become contaminated during the construction process or through post-construction maintenance. Turbines # 4 and 5 to be built on the Moraine will be constructed in a ‘high infiltration’ area. Each Repower MM92 turbine require 520 litres of synthetic oil as well as 12 litres of hydraulic

oil. “Typically, each wind turbine requires maintenance four times per year. Each maintenance visit takes one to five days per turbine to complete. Maintenance visits involve changing hydraulic and lubricating fluids” (REpower maintenance guide – M.K. Ince).

If a spill occurs, there is the very real possibility that the aquifer could become contaminated affecting not only area residents, agricultural and commercial operations but the population of two nearby schools. There are two schools

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located on the perimeter of the Sumac Ridge Project – Grandview Public School with an enrolment of 281 students from JK to Grade 6 and Rolling Hills Public School with an enrolment of 246 students covering Grades 1 to 8. There is also a daycare facility on site.

There is also the danger of contamination post-construction. Debris build up on the turbine blades resulting in a decrease in the energy generation. The solution to this problem is to clean the blades:

http://www.bladecleaning.com/problematica_EN.htm. http://proceedings.ewea.org/ewec2009/allfiles2/35_EWEC2009presentation.pdf

http://www.epaw.org/multimedia.php?lang=en&article=s1

High pressure water is used to clean the blades as in many cases are detergents. There is nothing in the construction report prepared for the Sumac Ridge project stating how much water will be used and where the water will be sourced from. There is nothing in the post-construction report stating how often cleaning will be required and if detergents will be used, what kind. Detergents entering an area of a high vulnerability aquifer poses contamination risks to an important Moraine water source.

The Construction Report, and Design and Operations Report

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indicate that de-icing materials and salt will applied to access roads during the winter months. Road salt is NOT applied to secondary roads in the Manvers area of the City of Kawartha Lakes... one of the reasons being, that residents rely on wells for their drinking water. In nearby Welcome, application of salt contaminated an aquifer in the early 1980s.... it is still contaminated. http://www.northumberlandnews.com/community/health/article/1570091--fresh-water-would-be-welcomed-in-welcome Considering the many springs, seeps, tributaries as well as high aquifer vulnerability in the project area, there is a possibility that post maintenance activities might compromise the drinking water used to sustain many residents as well as supplying the needs of livestock.

The switching station according to the Ortech Environmental Construction Report illustration Figure 2, page 11, will be located in the proximity of Gray Road and Highway 35 and is also in very close proximity to a watercourse. A number of electrical apparatus installed in substations are filled with oil that provides the necessary insulation characteristics and assures their required performance. “Oil-filled reactors, large regulators, and circuit breakers are the greatest potential source of major oil spills in substations, since they typically contain the largest quantity of oil. Power transformers, reactors, and regulators may contain anywhere from a few hundred to 100,000 l or more of oil (500 to approximately 30,000 gal), with 7500–38,000 l (approximately 2000–10,000 gal) being

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typical.”.. http://electrical-engineering-portal.com/oil-filled-equipment-in-substation. There are few details in the wpd Canada Corporation about the switching station. The report is lacking any information on emergency response protocol that will be followed in the case of an oil spill or mitigation measures regarding containment of drainage from the operating areas of the facility to prevent oil spills and contaminated runoff from reaching the storm drains along Highway 35 and the streams.

A proposed project that would interfere with one body of water on the Moraine would not be looked on favourably by municipal authorities or conservation authorities – yet there are 5 bodies of water within 120 m of project components that will be impacted by construction of the Sumac Ridge project. A large pond was not assessed even though the Water Report acknowledges that it is possibly sourced within the Moraine and is connected to a tributary that supplies the headwaters of Pigeon River.. Three tributaries of Pigeon River are within 120 metres of the proposed access roads, transmission lines and/or turbines.

There are two artesian wells in close proximity to the project site. The unevaluated pond is connected to one of the artesian wells. The project area is dotted with many underground seeps and springs. There are indications in the Water Report that underground streams in the project area may be supporting waters elsewhere that support sensitive trout habitat. There is no guarantee that an artesian spring will not be struck during construction of the access roads or the concrete bases. This could result in substantial

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dewatering and interference with the complex Oak Ridges Moraine water system. The Water Report identifies a spring along Gray Road that will be in the direct pathway of the transmission lines but there is no information as to its rate of flow or a clear understanding of its connection to area surface and ground water systems.

The Water Report prepared for wpd Canada Corporation indicates that it will not be possible to mitigate damage caused by interference with the seep (spring) along Gray Road “It will not be feasible to mitigate sediment entrainment into the seep using standard methods.”.... The mitigation strategy is “to complete work as quickly as possible”. What happens if there is delay – weather conditions, labour problems, contract problems, illness etc. etc:? In a different section of the Water Report it states that since the seep along Gray Road will be directly impacted that work be done when the ground is ‘frozen’. Conflicting mitigation strategies indicate an incomplete and unresolved construction plan.

Further confusion is created in the Water Report which also recommends as a mitigation strategy that work around watercourses take place when they have dried up - presumably late summer. However, the Water Report notes that the permanency of at least one watercourse is unknown since it was not evaluated in the summer. From page 21 of the Water Report: “The tributary was assessed on April 4, 2011 .... the permanency of the feature is unknown, as it was not assessed in the summer”. There were 4 brief water surveys conducted. No water surveys were conducted in the

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fall or winter or during spring run-off.

Two of the water surveys on April 4th, 2011 and March 26th 2012 were conducted at the same time that NRSI indicates vegetation mapping, floral inventories and wildlife identification surveys including the requisite Evaluation of Significance were being conducted (p. 14 Site Investigation report). NRSI indicates in the application for approval that a small staff of 6 were responsible for all natural heritage and environmental assessments; one operating in the capacity as a GIS mapping technician. To conduct all of the natural heritage surveys as well as water surveys on these two dates by a very small staff in a thorough manner would be a herculean if not impossible feat. Accurate and detailed studies are of paramount importance considering this is a large scale industrial power plant project.

According to the studies prepared for WPD, an expert source is quoted as saying: “In general, this upland is to be regarded as the source area for many streams which drain the till plains on either side of it. The water drains vertically through the sand and gravel moving laterally only when it reaches less pervious beds and reappearing as springs along the slopes of the Moraine (Chapman & Hall 1984). The report states that Pigeon River tributary # 3 will see a decrease in water infiltration by the construction of turbine # 1.

The project will result in 6 hectares of impervious cover which means it will not allow the infiltration of surface water in two drainage areas which equals “8% of the drainage area” . The Stanfield & Kilgour 2006 study (pg 31) notes that

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the threshold for degradation within a drainage area occurs at 10% of impervious cover. Existing impervious cover of residential and outbuildings foundations plus existing roads were not taken into account and may push the total of impervious cover to 10% or greater which, along with the wind project will exceed the defined threshold for degradation.

The ORMCP regulations of 2001 state that,

1) Except with respect to land in Settlement Areas, all development and site alteration with respect to land in a subwatershed are prohibited if they would cause the total percentage of the area of the subwatershed that has impervious surfaces to exceed,

(a) 10 per cent

The prevention of water from entering the substrata creates surface runoff. This runoff results in dramatic increases in wet weather flows of the headwater streams on the Moraine in turn causing erosion and degradation of fragile systems. The soils in the project area known as Pontypool sands create a high infiltration area vital to the hydrologic cycle of the watersheds contained within the Oak Ridges Moraine. Each turbine base will be a minimum of 18 m or 60 feet in diameter and each base will also be accompanied by concrete laydown pads each measuring 50 m by 100 m.

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Water infiltration will be affected. The proponent has not revealed the calculated annual amount of water that historically infiltrated the turbine locations or demonstrated the cumulative effect infiltration prevention will have on the hydrologic cycle of the watershed. Water infiltration and recharge rates will be permanently affected.

wpd Canada Corporation’s own reports states that the two turbines to be constructed on the Moraine may prevent recharge of the aquifer. Construction of the Sumac Ridge project may also exceed the 10% degradation threshold set by Stanfield and Kilgour in 2006 which will “eliminate the potential for habitat to sustain salmonids” (trout). Good water infiltration is vital in maintaining groundwater discharge to Fleetwood Creek which is noted for its brook trout population. According to experts such as Jack Imhof and Les Stanfield brook trout are quickly disappearing and may soon become a species at risk.

According to the Official Plan for the City of Kawartha Lakes,

“Any development and site alteration must demonstrate that the existing hydrologic function of surface and ground water features and any relationship to natural heritage features and areas will be maintained or enhanced. (page 18)”

The proponent has not demonstrated that the existing hydrologic function and ground water will be retained in the

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Sumac Ridge project; rather, the Water Report contains vague, contradictory, and incomplete information.

The well supplying the two nearby schools is located 124.7 m deep through fine sand and gravel http://www.downloads.ene.gov.on.ca/files/wells/EN/E4/D9/wellrecord10071349.html

However, the residential unit located next to the schools is dependent on a well only 16.5 m deep through white clay and brown gravel. http://www.downloads.ene.gov.on.ca/files/wells/EN/E8/D2/wellrecord10446982.html

According to records on file at the Ontario Ministry of the Environment, wells in the Sumac Ridge project area well records range widely. One residence might require a well 150 m deep, but the next door neighbour may rely on a well only a few metres deep. The well records along the short stretch of Ballyduff Road which will be used as a construction route for the Sumac Ridge project include varying depths of 29.9 m, 57.6 m, 30.5m, 152 m, 18.3 m, 83.2 m, 11.6 m, 85.7 m and 104.2 m. Well depths along this section of Ballyduff Road demonstrates the variances in groundwater flow and groundwater access in this area.

The nearby village of Pontypool has experienced periodic flooding in recent years because the water table is rising. http://www.thepost.ca/2010/07/29/flooding-costly-pontypool-residents ; http://

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www.thepeterboroughexaminer.com/2010/07/30/water-table-troubles-pontypool Ironically, dry hot summers have seen the issuance of water restrictions and bans such as this one issued in 2006. http://webcache.googleusercontent.com/search?q=cache:ALg9JA0trMkJ:sis.agr.gc.ca/cansis/publications/surveys/on/on42/on42_report.pdf+pontypool+ontario+municipal+water+restrictions&cd=28&hl=en&ct=clnk&gl=ca#36

Most residents of Pontypool are dependent on individual wells. A municipal well supplies the new Pinewood subdivision just north of Pontypool. This subdivision, despite its high elevation (100 feet higher than the village of Pontypool) has experienced flooding due to the rising water table. There is no evidence in the Water Report prepared on the Sumac Ridge project that water sources providing Pontypool and area will not be affected by the construction of the power plant.

The vast range of wells depths combined with a changing water table demonstrates the variability and unpredictability of water resources on the Oak Ridges Moraine. Five water features will be within 120 m of the planned access roads, transmission lines, crane pads and the turbine foundations. The area aquifer is designated as being ‘highly vulnerable’ and the Pontypool sands geology makes the area one of high water infiltration. The Water Report does not adequately address the impact this project will have on Moraine and the two watersheds. Proposed mitigation strategies have not been made by qualified hydrogeologists or hydrologic engineers.

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A thorough hydrogeological study needs to be undertaken on the project site as well as studies that extend well beyond the boundaries of the project area. According to the provincial government and posted on the Ministry of Municipal Affairs and Housing website, the hydrological function and integrity of the Moraine must be maintained.

NATURAL HERITAGE FLORA AND FAUNA

The Official Plan for the City of Kawartha Lakes stipulates: “3.5.18. Development and site alteration in or within 120 metres of a significant woodland area may be permitted if it is demonstrated that there will be no negative impacts on the natural features or on the ecological functions for which the area is identified.”

The construction of the Sumac Ridge project will impose negative impacts on the natural features and ecological functions of the Oak Ridges Moraine and surrounding area.

There are 10 woodlands in the project area. Nine woodlands are within 120 m of access roads, transmission lines, crane pads and/or turbine pads sites. Four woodlands range in distance from the construction zone from 4 to 7 metres; one at 58 meters, one at 100 metres and one at 104 metres. Two

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of the woodlands will actually overlap components of the turbine project construction which means significant tree removal. Five of the woodlots are considered as being ‘Significant’ as defined by government protocol. In total, the woodlands cover an area over 2000 hectares; one surrounds a wetland. Project components for Turbine # 5 located on the Oak Ridges Moraine will overlap part of a 1068 ha woodland that connects to the Fleetwood Creek Earth Science and Life Science ANSI also located on the Moraine. Species at risk butternut trees have been identified in the construction area of Turbine # 5.

Many trees and much vegetation will be removed in a sensitive ecosystem. According to the reports prepared by the proponent, at least 310 cubic metres of wood waste will be created, enough to cover an acre of land. The widening of Wild Turkey Road on the Oak Ridges Moraine will require the removal of vegetation on either side of the road for a distance of 1300 metres. Wild Turkey Road is an old pioneer unassumed roadway that sees very little vehicular traffic, and thus little disturbance to area wildlife. Wild turkey were introduced to this area. Wild turkeys love to roost in hedgerows. Removal of the vegetation along Wild Turkey Road will remove valuable wild turkey habitat. Local birdwatchers have recorded the rarely seen clay-colored sparrow using the ground and/or the dense shrub along Wild Turkey Road as breeding habitat; nests have been recorded over several years. There are also mature trees estimated as being between 80 and 100 years of age that will have to

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be removed along the hedgerow. The hedgerows are in close proximity to grassland habitats and significant woodlands. Hedgerow removal will negatively affect the complex interconnected ecosystem found in this area.

About 77% of all forest plant species (including some endangered taxa) occurring in the neighbouring forests are also found in the adjacent hedgerows. (Biological Conservation Volume 142, Issue 11, November 2009, Pages 2522–

2530) Environment Canada has conducted many studies on hedgerows…and concludes: “Biodiversity was always highly significant between hedgerows and fields at all trophic levels” as well as: “Habitats are important to wildlife in agroecosystems”. The removal of hedgerows will remove habitat that will affect many generations of avifauna. Furthermore, Wild Turkey Road as is Gray Road are pioneer roadways identified on the Tremaine map of 1861. The Ministry of Culture identifies that existing hedgerows to be of historical cultural importance and to be retained as part of the cultural heritage of Ontario. http://www.mtc.gov.on.ca/en/publications/Strength_Heritage.pdf

Trees and vegetation along a section of 1.9 km of Gray Road will have to be removed either to accommodate construction vehicles, road widening or erection of the transmission line. Gray Road is little more than a rutted laneway used primarily by recreational users. It is a pioneer trail dating back to the 1800s. The removal of an acre - .4

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hectares of mature forest that connects and crosses Gray Road will fragment this mature forest. This forest also supports a wetland. The reports prepared for WPD do not indicate the total number of trees to be removed or the species. Removal of a section of woodland will affect wildlife habitat, corridor movement, and breeding grounds on the Moraine and surrounding area. The proponent has stated that a biologist will be present if vegetation is to be removed between bird breeding season from May 1st to July 31st.. However, avian surveys were not conducted throughout the May 1st to July 31st time period on the hedgerows or woodlands to be removed so it is unknown how many bird species will be affected; not to mention other species of wildlife dependent on hedgerows and forests. The Migratory Birds Convention Act prohibits the disruption of birds and their nests.

The construction of access roads, transmission lines, crane pads, as well as the turbine bases and turbines will fragment natural heritage corridors thus restricting and interfering with the movement of wildlife. The project area is adjacent to the Fleetwood Creek Natural area - a 380 hectare (900 acre) property within the Oak Ridges Moraine that hosts over 44 types of birds as well as a plethora of wildlife and over 250 kinds of plants. Large sections of this protected area are designated as being a Provincially Significant Earth and Life Science Area of Natural and Scientific Interest. This area supports not only sensitive brook trout and minnow species such as creek chub but also hosts white tailed deer, mink,

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muskrat and beaver to name a few. Local sightings include the elusive gray wolf, bears and even the occasional cougar. Various wildlife species found within the Fleetwood Natural Area are likely to use the natural heritage corridors established between the 10 woodlands in the project area as well as established interconnecting trails. There is no evidence that established wildlife trails were recorded or monitored. There are indications that sections of the project will be fenced which will prove a further movement impediment especially to the movement of deer populations. The vast sprawling Sumac Ridge project will, by its close proximity to 10 woodlands, interfere with natural heritage movement corridors and create the potential for loss of species and thus a loss of biodiversity. Loss of biodiversity leads to extinction of species. According to a recent special report on biodiversity prepared by Gord Miller, the Environmental Commissioner of Ontario, "A Nation’s Commitment, an Obligation for Ontario," as well as other studies, biodiversity on the Moraine – the collection of plants, animals and ecosystems –is in a state of serious decline.

Turbine # 5 located on the Oak Ridges Moraine according to the Site Investigation Summary Table 8, is also located in a mineral savannah ecosite – a dry-fresh mixed savannah. According to the Oak Ridges Moraine Conservation Plan Under Section 22, key features include sand barrens, savannahs and tallgrass prairies. According to the ORMC Plan “All development and site alteration with respect to land within a key natural heritage feature

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or the related minimum vegetation protection zone is prohibited with the exceptions such as utilities as described in section 41, but only if the need for the project has been demonstrated and there is no reasonable alternative. Section 41 of the ORMCP makes reference to power transmission lines, not power generating plants. The proponent has not demonstrated the need for Turbine # 5 and has not presented a reasonable alternative.

It is also acknowledged in the reports prepared for the proponent that the components of the Sumac Ridge project will cover a great swathe of open fields - 76 hectares. These fields, not used for agricultural purposes, provide breeding grounds and habitat for many bird species. The greatest threat to grassland birds, which are declining at an alarming rate, is loss of habitat. “Grassland birds in the southern Ontario have declined by over 70% in the past 40 years”. (source: Nature Canada). Open country breeding grounds must be preserved. The project summary report prepared by Ortech states that the components of the project will overlap Eastern meadowlark habitat. The reports also acknowledge that the project will overlap a raptor wintering area. The 7 minute raptor surveys conducted for WPD are not sufficient to determine an accurate winter raptor population. Even these extremely short minute surveys identified two species of raptors - red-tailed hawk and rough-legged hawk in the project area. The natural heritage assessment reports do not state how injury and death of these raptors will be avoided. A longer study would probably have identified several more raptors. Kawartha Conservation

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Authority species breeding monitoring lists include Osprey, Bald Eagle, Northern Harrier, Sharp-shinned Hawk, Cooper’s Hawk, Red-shouldered Hawk, Northern Goshawk, Broad-Winged Hawk, Merlin and Peregrine Falcon in the area.

Noted raptor expert Tim Dyson has indicated that it takes days and weeks of constant monitoring to truly know what raptors species inhabit an area including nest searches. There is no evidence in the Natural Heritage Assessment Report that indicates a survey of raptor nests was conducted in early spring. The KCA breeding monitoring list includes Great Horned Owl, Barred Owl, Long-Eared Owl, Northern and Saw-whet Owl. Short-Eared Owl (which is of special concern) is believed to be in the project area. Owls are most active at night. No raptor surveys were conducted at night.

The prevalence of mature trees, combined with open fields and water sources make the Sumac Ridge project area an ideal breeding habitat for species of raptors. Bald eagles have been recorded in Fleetwood Conservation area by birders and area naturalists. http://www.kawarthafieldnaturalists.org/70.pdf

According to the newest edition of the Ontario Breeding Bird Atlas, the Sumac Ridge Wind Power Plant is located in section 17PJ99. The UTM coordinates place this section at the juncture of Ballyduff and Wild Turkey Roads. According to the atlas, there are 118 breeding entries in this section.

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Confirmed bird breeding evidence, none which the consulting firm could find include the following species; several are species at risk: Canada goose, wood duck, mallard duck. green winged teal, ruffed grouse, wild turkey, Northern goshawk, red-shouldered hawk, American kestrel, killdeer, rock pigeon, spotted sandpiper, mourning dove, barred owl, chimney swift, ruby-throated hummingbird, belted kingfisher, yellow-bellied sapsucker, downy woodpecker, hairy woodpecker, northern flicker, Eastern kingbird, blue jay, American crow, tree swallow, back-capped chickadee, red-breasted nuthatch, white-breasted nuthatch, house wren, Eastern bluebird, American robin, brown thrasher, European starling, yellow warbler, Northern water thrush, mourning warbler, common yellowthroat, chipping sparrow, savannah sparrow, song sparrow, scarlet tanager, indigo bunting, red-winged blackbird, common grackle, Baltimore oriole, house finch and house sparrow. The construction of the Sumac Ridge project places all these breeding sites at risk.

As well, probable and possible evidence of breeding birds in this same area as evidenced in past editions of the atlas and some confirmed by local residents include the following species; again several are species at risk : least bittern, green heron, Northern harrier, turkey vulture, merlin, Virginia rail, sora, upland sandpiper, American woodcock, common snipe, black-billed cuckoo, yellow-billed cuckoo, Eastern screech owl, saw whet owl, great horned owl, whip-poor-will, nighthawk, pileated woodpecker, Eastern wood peewee,

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least flycatcher, alder flycatcher, willow flycatcher, Eastern phoebe, great crested flycatcher, blue-headed vireo, red-eyed vireo (several nests confirmed by local birders), horned lark, cliff sparrow, bank swallow, brown creeper, veery, hermit thrush, wood thrush, gray catbird, cedar waxwing, blue-winged warbler, golden-winged warbler (breeding sites confirmed by local birders near turbine sites), Brewster’s warbler, Nashville warbler, Blackburian warbler, black and white warbler, American redstart, Eastern towhee, field sparrow, vesper sparrow, white-throated sparrow, cardinal, bobolink, Eastern meadowlark, brown-headed cowbird and American goldfinch.

An Osprey nest has been identified on Telecom Road, just southwest of the Sumac Ridge project. Osprey will use the same nest for many years. Ospreys will travel up to 6 – 10 miles to find food(Clark 1995, USEPA 1993 as cited by Rattner et al. 2001). Osprey are exclusively fish eaters and prefer hunting in shallow bodies of water. The nearest shallow bodies of water that contain fish are located in Fleetwood Conservation area. The two turbines to be located on the Moraine in close proximity the Fleetwood Conservation Area could pose a serious threat to the local osprey population. According to field notes filed for the adjacent ZEP Snowy Ridge project located just north the Sumac Ridge project, three osprey were sighted perched on the two communication towers located on Beers Road. The Sumac Ridge turbines will be located in the flight path used

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by the ospreys.

The reports prepared for wpd Canada Corporation indicate that there were no studies conducted on migratory birds. The project area is part of the Atlantic Flyway migration route and migratory birds take advantage of the diverse terrain in the Sumac Ridge area during their travels. Migratory birds may use this region as a flyway to the Carden Plain which is rated among the top five birding locations in Ontario and among the top 200 in the world. Fleetwood Creek Conservation area which borders the Sumac Ridge project area is also noted as one of the top 10 local birding sites. Kawartha Conservation Authority has a monitoring program dedicated to assessing species and biodiversity within its venue and watershed. http://www.kawarthaconservation.com/projects_services/watershed_monitoring/natural_heritage/species.html

Species being monitored include vulnerable avian populations including least bittern, Henslow’s sparrow, bald eagle, red-shouldered hawk, peregrine falcon, King rail, Caspian and black tern, short-eared owl, red-headed woodpecker, olive-side flycatcher, prairie, hooded and cerulean warbler and Louisiana water thrush. The avian studies completed for the Sumac Ridge project lasted 7 minutes to one half hour. The sole longer study conducted over a period of two hours on July 2nd, 2010, two years ago, revealed 41 species of birds including species at risk.

Of special note is monitoring of the critically endangered

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loggerhead shrike. Only 22 pairs of loggerhead shrikes were recorded in 2010 and 2011; 21 in 2012. The MNR comment sheets for the adjacent Settlers Landing and Sumac Ridge wind projects advise proponents of the possible presence of loggerhead shrikes in the project area. According to information received from Wildlife Preservation Canada, the agency involved in the loggerhead shrike recovery program, the exact migration route of the loggerhead shrike is unclear, but the wpd Canada Sumac Ridge project appears to be in the Carden core area. Local avian experts acknowledge that the area encompassing the proposed sites for the Sumac Ridge, Settlers Landing and Snowy Ridge projects has been known to be a loggerhead migration route for at least twenty years. To lose even ONE loggerhead shrike could mean extirpation of the species from Ontario and aid in their extinction.

The cumulative effect of industrial wind farms on migrating birds has not been researched or assessed. The Stantec Natural Heritage report on the Ostrander wind power plant states: "No information exists regarding the effects on migrating passerines of disturbance and habitat fragmentation due to wind turbines."

Considering the number of vulnerable bird species including the critically endangered loggerhead shrike that are being monitored in the watershed where the Sumac Ridge project

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is planned, brief, intermittent bird surveys are not sufficient.

Migratory birds studies must be completed on the unique landscape to be found in the Sumac Ridge project area.

The reports prepared for wpd Canada Corporation indicate the project will also overlap a bat maternity colony site. The bat maternity colony site is located in the woodland on the Oak Ridges Moraine – a woodland as indicated overlaps the location of Turbine # 5. There is no indication that searches for bat maternity sites were conducted in the region of the large pond along Gray Road and/or adjacent Woodland # 7 where it is planned that an acre of woodland will be removed. “ Little brown bats play an important role as predators of night flying insects. “They are very efficient hunters capable of catching over 1000 insects in just one hour. Little brown bats concentrate on insects that have an aquatic larval stage, such as mosquitoes, midges, and mayflies. Consequently, they prefer roosts in the vicinity of water. ” http://www.cwf-fcf.org/en/conservation/wildlife/featured-species/fauna/mammals/little-brown-bat.html

“Several consistent patterns have emerged from the fatality data on bats at wind turbines (Cryan and Barclay 2009, Arnett et al. 2008, Barclay et al. 2007, Cryan and Brown 2007, Horn et al. 2008, Baerwald et al. 2009). Tree roosting species are most affected, most fatalities occur in late summer through autumn. Fatalities are not concentrated at

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individual turbines and are highest at low wind speeds. Interactions with bats and wind turbines do not appear to be random, thus several plausible hypotheses have arisen that involve attraction to turbines. The most plausible and testable of these hypotheses include attraction to: aviation lights; sight sound or movement; turbines as potential mating sites; and electromagnetic fields generated. Other factors potentially contributing to attractiveness include turbine height, weather patterns and insect abundance.

Horn et al. (2008) concurs with these hypotheses, but further adds that forest edges created by the construction of access roads may create favorable foraging grounds where bats can more easily capture aerial insect prey, creating hotspots of bat activity (Barclay 1985, Kunz et al. 2007b). Use of these habitats is likely driven by prey density and availability. Thus, bat activity, and the likelihood of bats being struck by rotating turbine blades, may be predicted by seasonal weather patterns and the temporal phenology of insects. ”Interestingly, the highest bat fatalities occur on nights when wind speed is low (< 6 m s–1), which is when aerial insects are most active” (Arnett 2005). (Brenda Huber BSC)

Bats are facing possible extinction. There is no evidence that bats were monitored or counted during migratory periods. What is occurring in Europe may be a harbinger of what may happen to the bat population in Ontario.

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Troubling study indicates wind turbines may cause harm to bat populations

Source credit: by Chris Clarke | Rewire | www.kcet.org 19 September 2012 ~~

A study published in a German scientific journal this summer indicates that wind turbines in one area may pose a serious risk to populations of bats over the better part of a continent. The study performed by researchers from the Leibniz Institute for Zoo and Wildlife Research (IZW), showed that pipistrelle bats killed at German wind turbines likely originated from countries as distant as Scandinavia, Poland, the Baltic countries, and Russia. An estimated 200,000 bats are killed each year at German wind turbines, raising the possibility that Germany will become a sink for European bat populations — and raising troubling implications about the effect of wind turbines on California bats....

....As bats killed at German wind facilities may have come from places 1,000 miles or more away, and as bats have very slow reproduction rates of only 1 or 2 offspring a year, the study suggests that wind turbines in Germany may well be depressing bat populations across the entire northeastern portion of Europe, in an

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area perhaps a million square miles in extent.

The bats most vulnerable to wind turbine injuries — which seem to stem mainly from lung trauma from steep gradients in air pressure rather than from collisions — are migratory species that live in trees. ....

A 2011 paper by Paul Cryan of the USGS Fort Collins Science Center in Colorado reports that bat deaths have skyrocketed with the advent of wind turbine installations:

Since 2004, unprecedented rates of bat fatalities have been documented at multiple wind energy sites across the United States and Canada, as well as in several European countries. In the United States, bat fatality rates at turbines are variable across sites and regions. Despite standardized and well validated methods for measuring and comparing fatality rates across sites rarely being employed, estimates to date for individual wind energy sites range from just below one bat per installed megawatt per year (bats/MW/yr) to as high as 70 bats/MW/yr. These fatality rates for bats generally exceed the fatality rates of migratory songbirds at wind turbines, and far exceed any documented natural or human-caused sources of mortality in the

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affected species of bats. Some large wind energy facilities (e.g., 100-300 MW) are estimated to have fatality rates of 10-20 bats/MW/yr, which means that single wind energy facilities are causing the deaths of thousands of bats per year. With approximately 40,000 MW of turbines currently installed in the United States and Canada, and an average published bat fatality rate of 11.6 bats/MW/yr, more than 450,000 bats may already perish at turbines each year in North America. This number might even be an underestimate due to problems with earlier fatality estimation equations and because bat fatality rates appear to be increasing with deployment of larger turbines.

If U.S. wind turbines truly do pose more of a threat to some American bats than the dreaded White Nose Syndrome now devastating eastern Bat populations, then the German study is sobering indeed. It may be that even a few isolated wind installations may harm bat populations across a broad landscape.

As Cryan says, distressingly,

“In some parts of the country, bat researchers who only rarely catch hoary bats in the wild can now walk beneath turbines at certain wind energy facilities

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during autumn and find more dead hoary bats on the ground in a few weeks than they have caught during their entire careers.”

http://www.kcet.org/news/rewire/wildlife/troubling-study-indicates-wind-turbines-may-cause-large-scale-harm-to-bat-populations.html

Monarch butterfly populations are in decline, so much so that they are fast becoming an endangered species. http://monarch-butterfly.info/Endangered.html

A local resident documented in September 2012, the congregation of 1000s of monarch butterflies in trees just at the southwest perimeter of the Sumac Ridge project. This huge amassing of monarchs demonstrates that monarch butterflies use the Sumac Ridge project site as a migratory route. The proponent has not demonstrated that monarch butterfly populations will not be negatively affected by the construction of the wind power generation plant.

The consultants who prepared the Natural Heritage Assessment reports visited the Sumac Ridge project area briefly on June 14, 2010, June 15, 2010, July 2, 2010, November 11, 2010, April 4, 2011, January 16, 2012,

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January 24, 2012 and March 26, 2012. The purpose of these visits was to conduct Wildlife Habitat Identification, Floral Inventories and Vegetation Mapping surveys (page 14 Site Investigation). Four of the eight surveys were conducted in the winter season – not an optimum time to conduct comprehensive wildlife habitat or vegetation surveys. There were only two brief summer site visits in June and July in 2010 and only one spring visit in April of 2011. Considering this project is to be constructed on the Oak Ridges Moraine and near the Fleetwood Kames and Fleetwood Conservation Area, numerous, comprehensive and exhaustive year-long studies need to be conducted.

Although the Natural Heritage report indicates that a detailed ongoing floral inventory will be undertaken, there is no evidence of this in the reports. The handwritten survey notes often speak in generalities with flora identification marked in simple terms such as grasses, shrubs, meadows, small trees etc. The Sumac Ridge project area is rich in a variety of flora including a tall grass prairie restoration project. A complete and thorough inventory of the area’s vegetation needs to be compiled.

Although consultants conducted only brief and limited natural heritage surveys, even these reveal species at risk to be in the project area – bobolinks, Eastern meadowlarks, barn swallows and butternut trees. These species at risk are not noted in the environmental impact section of the reports.

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Local residents have been monitoring another species at risk, the Golden Winged Warbler, for several years. Not only does the proponent make no mention of these birds, the breeding grounds have been identified to be within 120 m of the location of Turbine # 2. The reports prepared by NRSI also state that it is unlikely that the snapping turtle, another species at risk, is in the project area. On page 50 of the Site Investigation report it states: “has not considered this pond as a candidate for the common snapping turtle”. Yet two of the maps prepared for wpd Canada Corporation clearly identify a large area including the pond as Snapping Turtle Habitat. Moreover, in the project summary it states “Silt fencing will be placed accordingly in order to reduce the likelihood of turtles entering active construction zones.” In the Ortech project description summary it states that a turtle wintering area is located within 41 m of components of the project and that nesting habitat is located 11 m away. This counters the report that snapping turtles, a species at risk, are unlikely to be found in the area.

In addition, local residents have seen the remains of snapping turtle nests along gravel stretches of Gray Road. Snapping turtles are fond of using gravel roads as egg laying sites in May or June. According to the Significant Wildlife Habitat Technical Guide which was presented to wind developers in early 2011 over-wintering areas for snapping turtles are to be “identified by searching for congregations (Basking Areas) of turtles on warm, sunny days during the fall (Sept. – Oct.) or spring (Mar. – May)”.

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There is no evidence that this was done for the Sumac Ridge project.

The Sumac Ridge project is located in Ecoregion 6E-8. Under the SWHTG the following are to be designated as Significant Wildlife Habitat:“Any wetland with 20 or more frogs or tadpoles, a single snapping turtle nest, movement corridors where toads, salamanders, frogs or deer move from location to location, and any spring or "seep" where groundwater comes to the surface. These elements are all present in the Sumac Ridge project.”

The large multi-acre man-made pond connected to a water source in the Moraine as well as supplying a tributary of Pigeon River connects to a wetland located on the north side of Gray Road The two water bodies create a natural habitat suitable for all manner of herpetofauna. It is also probable that species of amphibians traverse Gray Road at certain periods of the year for breeding purposes. There is no evidence of early spring surveys on salamander and frog movements between the pond and the wetland which would involve crossing Gray Road. Green frogs have been observed in puddles along Gray Road during the dry summer season of 2012 and as late as September. Existing records indicate that the species at risk Western Chorus frog inhabit the project site. Since plans by the proponent are that Gray Road will undergo a significant alteration, a spring breeding survey of amphibians needs to be conducted. There are no studies on snake populations in the project site area to be found. The monitoring records for nearby

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Fleetwood Conservation area indicate that Eastern hognose, milk, ringneck, northern water, brown, northern ribbon and smooth green snakes may be present in the project area. Not only should comprehensive studies on amphibians and snakes be conducted, specific studies on the number of snapping turtles and location of their breeding territories along Gray Road must be completed before the Sumac Ridge project can proceed.

It has been reported by long-time local residents that the endangered Eastern hog nosed snake is to be found on the quarry property adjacent to the location of access roads and the site of Turbine # 2. There are NO indications in any of the Natural Heritage Assessment studies that a concerted effort was made to look for Eastern hog nosed snakes. According to the MNR Hog Nosed Snake Recovery

Program: “Eastern Hog-nosed Snakes have been observed using the same general area for hibernation and oviposition (i.e., the same stretch of dune or beach, or area of sandy soil) for multiple years.”

The eastern hog-nosed snake hibernates singly and buries itself under sandy soils below the frostline. The construction of access roads and other components of Turbine # 2 may compromise or threaten this endangered species.

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In a letter in the minutes recorded from the MNR meetings it states that an aquatic survey was to be completed on site in July 2010. There are no detailed fish surveys to be found in the Water Report or evidence of fish catchment studies at any other times of the year. The report states for one of the tributaries that ‘fish sampling (brook trout) would be difficult due to the very dense vegetation’ yet acknowledges that ‘brook stickleback could spawn in the dense vegetation”. Both the MNR and the Kawartha Conservation Authority acknowledge ‘that little fish and fish habitat data is available for the watercourses present in the project area” (p. 24 Water Report NRSI). Unless thorough survey and studies are completed, fragile fish populations could be severely affected by the construction of the Sumac Ridge project.

A Conservation Land Easement with Kawartha Heritage Conservancy was finalized in December 2011 regarding the 250 acre property where Turbine # 5 is to be located. The property lies on the Oak Ridges Moraine, with the eastern portion found in the Core Area, and the western portion found in the Countryside Area of the Oak Ridges Moraine Conservation Plan.

Reports prepared for the proponent do not mention the easement.

According to a media release issued by KHC

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“The property contains springs and coldwater streams at the headwaters of Fleetwood Creek, which flows north from the Moraine into Pigeon Creek and then into Pigeon Lake. The property is recognized as being part of a significant groundwater recharge area and as having high aquifer vulnerability under mapping for the Oak Ridges Moraine Conservation Plan and for the Trent Conservation Coalition Source Protection Region Assessment Report. KHC will monitor the property and work with the landowners toward continued rehabilitation of the natural values and long-term stewardship.”

An industrial energy development is the antithesis to “ continued rehabilitation of the natural values and long-term stewardship” on these lands.

The statement “Habitat Loss – None – No habitat loss is planned” found on page 3 on the Water Report and Environmental Impact Study prepared by Ortech is inaccurate. The planned removal of trees and other vegetation and interference with watercourses means that habitat loss is planned.

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CULTURAL HERITAGE:

CULTURAL HERITAGE ASSESSMENT

Stantec, the consulting company which prepared the cultural heritage assessment reports for the adjacent ZEP Snowy Ridge and Settlers Landing included all possible features within the study area. It appears that Ortech did not do this and restricted its cultural heritage assessment to a very small area surrounding in and around the turbines. In the map included for the cultural assessment report dated September 13, 2011

http://canada.wpd.de/fileadmin/pdfs/Sumac%20Ridge/12%20-%20Draft%20Cultural%20Heritage%20Assessment%20October%207%202011.pdf

an outline appears not listed in the map legend. It is assumed this must be the study area. There is no rational explanation as to how the revised study area outline was determined. Other project components such as the transmission lines and the switching station are not included

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in the cultural assessment study area marked on this map. Neither are sections of Wild Turkey Road or Ballyduff Road. This study area is quite different from the defined ‘project site’ area in other maps in the wpd Canada Sumac Ridge application.

The original study area map produced by Ortech for the project in July of 2010, and which is included in the map entitled Ballyduff Wind farm as an Appendix One in the Natural Heritage Assessment and Water Report, http://canada.wpd.de/fileadmin/pdfs/Sumac%20Ridge/10%20-%20Sumac%20Ridge%20DRAFT%20Water%20Report.pdf defines the project study the area to be bounded by Waite Road extending into Solanum Way to the south, the eastern boundary extends midpoint between Porter Road and Pitt Road, the northern boundary follows Twigg Road west to Hwy 7A to the west side of Hwy 35 and the western boundary extends south of Hwy 7A midway between Hwy 35 and Century Farm Road.

In the screening section of the Cultural Heritage Assessment prepared by Ortech, it is indicated that no accessible documentation was available to indicate heritage or cultural points of interest in the project area. It is also indicated that there are no historic roads in the project area or planned recreational areas. No indication was made in section 6.1 of the self-screening process as to whether or not a cemetery abuts the project location.

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According to Ortech Consulting,

“There are no residential structures, farm buildings, industrial, commercial or institutional buildings, engineering works, monuments or landmark features at the project location. Project location is defined by O.Reg 359/09 as “when used in relation to a renewable energy project, a part of land and all or part of any building or structure in, on or over which a person is engaging in or proposes to engage in the project and any air space in which a person is engaging in or proposes to engage in the project”... page 17.

In the cultural assessment reports prepared by the consulting company Stantec for the adjacent Snowy Ridge and Settlers Landing projects which share sections of a common area within the original study area for the Sumac Ridge project, several heritage properties are listed that are also common to the wpd Canada Sumac Ridge project. They include the addresses 697, 785, 754, 804, 832, 823, and 990 along Highway 7A, 103 Pitt Road, 905 and 902 Gray Road. It also includes 569 Highway 35 which is in close proximity to the proposed switching station site. As well, there are several heritage properties along Ballyduff Road including Nos. 619, 623, 745, and 759 to name a few. None

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of these properties along Ballyduff Road including the historic Presbyterian Church and pioneer schoolhouse have been assessed by Ortech as to the visual impact that may be caused by direct or indirect obstruction of significant views or general impact on the cultural heritage of the area by project components.

The Stantec cultural heritage assessment prepared for the adjacent Snowy Ridge project indicates that construction methods might damage the structural integrity of at least one heritage building. There is the possibility that construction techniques employed by wpd Canada may also cause damage to heritage buildings. This possibility has not been considered in the Ortech report.

Of additional concern is the property located at 804 Highway 7A. This property is identified in the Stantec Snowy Ridge cultural assessment report (p.27) as meeting the ‘criteria of design value as outlined under O. Reg. 9/06’. While this extraordinary farmhouse, mill and covered bridge with architectural elements dating to the 1860s and 1870s is estimated to be approximately 1000 m south of the nearest turbine in the Snowy Ridge project, it is designated as Receptor # 5 for the wpd Canada Sumac Ridge project and is located only 595 metres north of Turbine # 1 and approximately 1000m north of Turbine # 3. The residential property is located at an elevation lower by 10 metres than the location of Turbines Nos. 1 and 3. The visual impact of

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the two Sumac Ridge turbines Nos. 1 and 3 on this heritage estate has not been taken into consideration. According to the Flicker Shadow report which was not made available on the project website, but provided to City of Kawartha Lakes municipal staff in January 2013, months after the application for approval was turned into the MOE (June 29th, 2012) this heritage property will also be subjected to at least 9 hours of flicker effect per annum; likely more considering the adjacent ZEP Snowy Ridge turbines will also cast flicker shadow upon the designated heritage estate.

The Ortech report did not state in the self-screening section either way whether a cemetery is present in the Sumac Ridge project area. There is a 19th century cemetery connected to the Presbyterian Church on Ballyduff Road located on Lot. 11. There is also speculation that another unmarked cemetery may be present on the property of 745 Ballyduff Road. While the Ortech self-screening diagnosis indicates there are no historic roads in the project area, Ballyduff Road is a historic road that dates back to the 1820s. Wild Turkey Road also dates to the early 1800s. As well, in the self-screening process Ortech indicates that there are no planned recreational areas that will abut the project area. Fleetwood Conservation area is a 900 acre property managed by Kawartha Conservation for the Ontario Heritage Foundation. It abuts the location of Turbine No. 5. This unique conservation authority which is a draw for nature lovers from many points across the province is located at an elevation of 270

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metres. http://www.canmaps.com/topo/places/f/fbehi.htm which is a much lower elevation than all five turbines including Turbine No. 5.

There is a stark marked difference between the in-depth Stantec report prepared for the ZEP Snowy Ridge and Settlers Landing projects and the sparse and arguably incomplete assessment conducted by Ortech for the wpd Canada Sumac Ridge project. Since the landscape and the cultural heritage of the area will be transformed by the proposed gigantic power plants, an in-depth assessment is also warranted and must be undertaken for the wpd Canada Sumac Ridge project

ARCHAEOLOGICAL ASSESSMENT

According to local lore, the Sumac Ridge project area was once the site of an ancient Aboriginal battleground. The local expert on ancient aboriginal inhabitants and archaeological evidence in the region did approach wpd Canada Corporation to offer her services and information, but it appears her expertise was not employed by the proponent. According to the provincial data base there are 5 registered archaeological sites within 2 kms of the project area. The precise locations are considered confidential information.

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Sites include: The Strong site (BaGp-1), is located west of Ballyduff on Concession 5 and is classified as an Iroquoian campsite; the Fleetwood 2 site (BaGp-36) was discovered during an archaeological survey conducted in 1987 by Mayer, Pihl, Poulton & Associates (MTC n.d.). This site is located just east of the study area and consists of an early to mid 16th century Huron village and a mid-nineteenth century Euro-Canadian component; and the Fleetwood Creek 1 site (BaGp-35), located southeast of the study area, consists of a single Late Woodland ceramic shard found during the 1987 archaeological survey conducted by Mayer, Pihl, Poulton & Associates.

One highly significant site is located just beyond a two kilometre radius from the project property. This is the Spearing Ossuary (BbGp-1), a large burial pit that has been extensively looted over the years. A second ossuary is reputed to be located in the area.

“Virtually all of the land within the subject property has high potential for the recovery of precontact aboriginal sites. This is due primarily to the presence and proximity of Fleetwood Creek and Pigeon River tributaries along the eastern and northern edges of the study area.”, according to the archaeological reports prepared for WPD.

http://canada.wpd.de/fileadmin/pdfs/Sumac%20Ridge/11-1%20Sumac%20Ridge%20St%201%20Final.pdf

According to the Ontario Ministry of Tourism and Culture…

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Aboriginal archaeology in Ontario

In Ontario, 80 per cent of all archaeological sites are Aboriginal. This includes First Nations villages, longhouses, hunting camps, portage areas, burial grounds and ossuaries. Artifacts that have been uncovered include pottery shards, arrow and spear points, and everyday materials used by First Nations and Métis people. Some artifacts, such as sacred bundles, funerary objects and human remains are sensitive, and one must treat them with utmost respect and dignity.

Role of communities

This ministry has taken active steps to include First Nations and Métis in archaeological assessment through new Standards and Guidelines for Consultant Archaeologists, which require licensed archaeologists to engage communities on Aboriginal sites.

The draft technical bulletin, Engaging Aboriginal Communities in Archaeology,is a living document that helps consultant archaeologists plan engagement. It encourages best practices, such as using on-site monitors from communities.

“Engaging Aboriginal communities at the following additional stages constitutes wise practice, which you are encouraged to follow. You should engage Aboriginal communities:

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In Stage 1, when conducting the Background Study, in order to identify information sources in local Aboriginal communities (e.g., for information on traditional use areas, sacred sites, and other sites) when available and relevant to the property). [Standards and Guidelines for Consultant Archaeologists Section 1.1]

In Stage 1, when evaluating archaeological potential and making recommendations to exempt areas meeting the criteria for low archaeological potential from further assessment, in order to ensure there are no unaddressed Aboriginal cultural heritage interests. [Section 1.4]

In Stage 2, when assessing a property and determining archaeological sites that require Stage 3 fieldwork, in order to determine interest (general and site-specific) in the Aboriginal archaeological sites and ensure that there are no unaddressed Aboriginal archaeological interests connected with the land surveyed or sites identified.”

Nowhere in the archaeological reports is it stated that aboriginal communities were consulted. Local legend indicates that the Sumac Ridge project site was home to a significant ancient battle and the reports indicate that the Sumac Ridge project location may be rich in aboriginal

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artifacts. There is the possibility that the project site may contain the second yet to be discovered ancient burial ground. Considering that Sumac Ridge project area is so rich in ancient cultural heritage, the invitation to First Nation people to participate in this process should have been extended by the proponent as indicated under ‘best practices’. There is no evidence that First Nation representatives were actively involved in the archaeological assessment. Moreover, representatives of aboriginal communities should be involved in all aspects of decision-making in regard to the construction process to ensure that their ancient cultural heritage is not destroyed.

The wpd Canada report "Stage 2 Archaeological Assessment Addendum Report Sumac Ridge Wind Farm dated "November 2011 describes an extension of the area around the proposed switching station being examined as "a new impact area" (p. iv). However, the area, identified at Figure 2, page 3 and at Figure 3, page 7, is immediately adjacent to Gray Road. More significantly, the switching station is still shown in Figure 2 as next to the north-south boundary line for Highway 35 (even closer to the boundary than the ploughed field area) and not in its new location. A new minor error also appears in the Addendum at p.5, where the report states: "As such, a roughly 700 metre (east-west) by 30 metre (north-south) area fronting Grey Road was assessed” - the area shown in Figures 2 and 3, is 70m by 30m and not 700m? Note: Gray Road is continually referred to as Grey Road in several reports which is inaccurate.

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Given that wpd Canada’s construction report sites the switching station very roughly about 25 metres further west than the Addendum ( p.10, Figure 2) the question becomes was the "new impact area" examined in the previous archaeological assessment report. The first Stage 2 report shows that the area examined is identified as the old position. As indicated on p.17, there is no report of the measurement of the terrain covered by the ploughing and subsequent search. Here the Stage 2 report identifies the 100m by 50m site "at the south-east corner of grey [sic] road and Highway 35" and says it was ploughed and later searched.

Given the new site for the switching station in the April, 2012 Construction Report, the new section of the 100m by 50m site was not subject to a Stage 2 search. The exception is the northernmost section towards Gray Road where a 30 m band along Grey Road was searched as reported in the Addendum. From the Addendum aerial maps (Figures 2 & 3 again) the overlap to the south with the new placement of the switching station is about 20m. That leaves a new impact area of roughly 80m by 25m to be searched.

In the Addendum, Timmins Martelle states:

"If construction plans change to incorporate new areas that were not subject to Stage 2 field survey, these areas must

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be assessed prior to the initiation of construction. The Ministry of Tourism and Culture must review the new fieldwork and agree that methods and recommendations are in keeping with applicable standards and guidelines (MCTR 1993)." Ministry of Culture and Tourism letter to consulting agency Ortech dated August 31, 2011. (Doc. 11-4 in the wpd online files)

CONSTRUCTION AND GEOTECHNICAL:

On page 11 of the Water Report it makes reference to the Chapman & Putnam study of 1984: “The project area is located in the Pontypool series of the Oak Ridges Moraine and the hilly soils are particularly prone to deflation and water erosion, and are generally not stable under cultivation or pasture” Unstable soils will not be able to support 18 m or 60 foot diameter concrete foundations. According to the Terraprobe Geotechnical Report the soils will not provide adequate bearing support for at least two turbines. One of those turbines, Turbine # 5, is located on the Oak Ridge Moraine. To create a soil base that will support this turbine will mean an alteration of the composition of the soil, possibly by trucked in fill, and thus

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altering the geology of the Moraine. The geotechnical report also indicates that the soils will be difficult to handle and will become even more so due to inclement weather or water seepage. The bases may have to be excavated far deeper than the first estimated 3 metres which also may compromise water resources. The geotechnical report also states that ground water seepage might occur which would mean continuous pumping out of water. This dewatering could impact the hydrological integrity of the Moraine. The geotechnical report also admits that site excavation might reveal previously unknown conditions in regard to groundwater. Protection of the aquifer, and complex system of above and underground steams and seeps must take precedent.

The Construction Report prepared by Ortech states on page 6 that it will not be necessary to upgrade Ballyduff Road (Ballyduff Road – “At this time no upgrades are required for this roadway”), yet a few pages later on page 13, the same report states that an upgrade of Ballyduff Road will be necessary (“The Roads which will be upgraded as a component for this project are: Wild Turkey Road and Ballyduff Road”). Aside from the conflicting construction plans, the proponent plans to alter municipal roads but there is no evidence that the proponent has the permission of the City of Kawartha Lakes to do so.

In the Ortech report Section 2.1.2. Roadway Upgrades it is

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indicated the roadways must be able to accommodate a minimum of a 12.5 tonne load. The roads involved in this project have a maximum load of 5 tonnes. In order to accommodate a minimum load of 12.5 tonnes, major construction along Ballyduff Road would have to be undertaken. The proponent has not received permission from the City of Kawartha Lakes to undertake such a venture. Furthermore, construction might cause structural damage to two heritage buildings located along Ballyduff Road. The consulting company Stantec has indicated that road construction to be undertaken on the adjacent project Snowy Ridge might cause structural damage to a heritage building located on this project site. The Stantec report indicates that an engineering study and monitoring needs to be undertaken pre-construction, during construction and post construction. Two properties along Ballyduff Road were not included in the Cultural Heritage studies for the Sumac Ridge project. Their inclusion is important since road construction along Ballyduff Road might cause structural damage to these properties. Aside from construction upgrades to Ballyduff Road, it is expected that at least 120 truckloads of gravel and 70 truckloads of concrete will travel this minor roadway. There are fragile foundations of at least two of the four heritage buildings on north side of Ballyduff Road, # 619 (NW corner of Ballyduff Road and Hwy 35), # 637 Church, #645 School and #745 residence. The property located at 745 Ballyduff Road consists of a residence originally built in 1867. It has a fieldstone foundation. The other building is the Ballyduff Church. It was constructed in 1858. http://www.heritagetrust.on.ca/Ontario-s-Places-of-

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Worship/Inventory/Search-results-details.aspx?ItemID=3306. A second church was built in 1862. Destroyed by fire in 1896, it was rebuilt in 1897 and still stands today. (p. 93 Rolling Hills Edited Ross Carr – pub. 1967) Construction vibrations effect structures in two major ways - vibrations may produce direct damage to structures and create damage due to vibration-induced settlement. http://www.vulcanhammer.net/svinkin/vibration.php

According to the wpd Canada Sumac Ridge Draft Construction Report (p.8), the area required for the crane laydown pad for Turbine # 5 will be 120 m by 6 m (393 by 20 ft). It will extend from a private property, across a municipally owned unassumed roadway and will extend into another privately owned property of a different landowner.

This laydown area will be “cleared of surface material which is stripped and stockpiled and applied with a gravel or stone base. The ground is covered in sheet metal in order to maintain a flat, obstacle free area” .

This construction will alter the configuration of Wild Turkey Road completely and obliterate its use as a roadway. It will restrict and prevent its historic usage and purpose. It will interfere and prevent roadside drainage on both sides which could prove to be hazardous during periods of inclement

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weather. The construction of the crane laydown pad will be obstructing a roadway. Blocking usage of the roadway could result in personal injury and/or death. This large construction project involving steel sheets and a crane laid across a roadway presents questions of liability for the landowners, wpd Canada and the City of Kawartha Lakes if an accident should occur.

The City of Kawartha Lakes has no building permit on file that might address this unusual situation. Therefore, it is recommended that the crane laydown pad be constructed solely on private property where Turbine # 5 is located. The site map indicates the participating landowner has suitable acreage available to accommodate construction of the crane laydown pad.

The construction plan states that a “detailed vegetation inventory of species and abundance to be removed” will be taken. A “Tree Preservation Plan detailing trees to be removed and retained within 10 m of construction activities will be detailed before construction” is also stated in the Draft Construction Report . There is no indication when this detailed inventory will be completed and no indication who will be allowed to review and/or enforce or monitor the inventory and preservation plan. The Draft Construction Project Report does anticipate hundreds upon hundreds of cubic metres of wood waste will be produced by removal of vegetation. It is calculated that 310 cubic metres of wood

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waste, enough to cover an acre of land will be created.Page 36 of the Natural Heritage Report states that site ‘fencing may be required at the discretion of the inspector”. What type of fencing – what size perimeter – what height? There are no specifics. What credentials does this inspector possess? Role & duties? The Construction Report suggests that environmental impacts will be dealt with on an ad hoc basis and will be self-supervised. It is stated several times that as a mitigation strategy, denuded areas will be replanted with native plants.. Native plant restoration is a complex and long term activity. No detailed plan is revealed by the proponent, nor is there any indication that the City of Kawartha Lakes, the owners of the properties where much of the vegetation removal is to occur, was contacted about this proposal or that consent was given to this proposed mitigation strategy.

According to the government of Ontario regulations, a Class EA must be conducted on proposed minor transmission lines. http://www.hydroone.com/Projects/Documents/class_ea.pdf. There is no indication in the application by the proponent that Hydro One has been contacted about a Class EA on the transmission line to be constructed along Gray Road. The transmission line will interfere with identified bodies of water and may cause interference with a complex hydrological system. Its construction will call for the removal an acre of mature trees as well as hedgerow vegetation.

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Ortech Environmental Service prepared the Construction Report, but this consulting service has been replaced by the company Stantec. At the June 19th final public meeting, it became clear that the Stantec representative could not answer questions with regard to the construction report. If the Ortech report is found to be flawed, who will be held responsible?

As indicated in the Cultural Heritage section, the position of the switching station has been moved more than once. There are plans to widen Hwy 35 in the area turning the two lane provincial highway into a 4 or 5 lane transportation corridor. This plan has been in the works since 2007. There is no indication in the Draft Site Plan or Construction Reports that wpd Canada took this major road project into account when planning the Sumac Ridge wind power plant. Various components of the project including the switching station will be affected by the highway lane widening.

“As part of the broader Highway 35 Four-Lane Planning and Preliminary Design Study, the Project Team has also undertaken a sub study (the Highway 35/Highway 7A Connection Study) to examine alternatives for the connection between Highway 35 and Highway 7A within a Study Area that is bounded by 10th Line/Lifford Road to the north, 7th Line/Gray Road to the south, and extending 2.7 km west, and 4.2 km east of the Highway 35/Highway 7A north and south

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junctions. “http://web.archive.org/web/20070929110210/http://highway35.planningstudy.on.ca/

“Highway 35 from Highway 7 southerly 2.2 km Two to four and four to five lane widening planned/expected start: 2010, planned/expected completion: 2012”

http://www.mto.gov.on.ca/english/pubs/highway-construction/southern-highway-2008/partH.shtml#N30

Map:

http://www.mto.gov.on.ca/english/pubs/highway-construction/southern-highway-2007/future.shtml

No visual model of the Sumac Ridge project was presented to area residents. Other proponents have done so. Residents deserve to see what a project of this monumental scale will look like once completed.

According to the proponent, the wind turbine model to be used will be the: REpower MM92. According to a REpower MM92 sales brochure:

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“The reliable gearbox and generator technology of the MM82 is also the basis for the MM92 wind power plants. With a diameter of 92.5 meters its rotor is significantly wider than that of its precursor, enabling the wind turbine to deliver a nominal power of 2.05 megawatts even at a wind speed of only 12.5 m/s. This makes the MM92 ideal for locations with medium or weak winds (IEC IIA to IEC IIIA) and helps to reduce the cost of wind power generation.”

http://www.repower.de/wind-power-solutions/wind-turbines/mm92/

The REpower MM92 brochure lists the following statistics about this industrial wind turbine model:

REpower MM92 brochure

Cut in 3.0 m/s

Rated output wind 10.5 to 11 m/s

Cut out 22 m/s

http://www.repower.de/fileadmin/download/produkte/PP_MM100_uk.pdf

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According to the Government of Canada’s wind atlas database, http://www.windatlas.ca/en/nav.php?field=E1&height=80&season=ANU&no=24&roads=1&cities=1 , the mean wind speeds for the Sumac Ridge project are, as follows: Winter 7.50 m/s ; Spring 6.57 m/s ; Summer 5.26 m/s ; Fall 6.55 m/s. The Annual wind speed is rated at 6.48 m/s. The rated mean wind speeds indicate that the winds in the Sumac Ridge project area will not allow the project to produce energy at its rated output. The wind atlas measures winds at a 80 m hub height. The hub height for the REpower MM92 is 100 m and it is unknown if the optimum required wind speed of 12 m/s will be achieved.

Furthermore, the Wind Atlas of Ontario map indicates wind speeds in the Sumac Ridge project area average at 6.0 m/s. According to the Wind Atlas of Ontario scale this median wind speed is rated below Acceptable.

http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@renewable/documents/document/198060.pdf

http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@renewable/documents/document/197242.pdf

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HEALTH AND SAFETY

Turbine fires can be caused by technical defects or mechanical/electrical malfunctions – usually gearbox failures. In many incidents, lightning has been the source of the fire.

According to the Environment Canada Weather and Meteorology website the region where the Sumac Ridge project is to be located is listed as one of Canada’s lightning “hot spots”.

http://www.ec.gc.ca/foudre-lightning/default.asp?lang=En&n=42ADA306-1

The Sumac Ridge project will be constructed within 10 woodlands. The ANSI designated Fleetwood Kames and Fleetwood Conservation area are just to the west of the project area. Worldwide, there are scores of documented cases of industrial wind turbines catching fire. http://www.caithnesswindfarms.co.uk/fullaccidents.pdf

Industrial wind turbines require highly flammable lubricating agents.

Lubricants and Oils used in a single REpower MM92 industrial wind turbine – model to be used in the Sumac

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Ridge project

Fluid Type Quantity

Gearbox - synthetic oil 500 l

Azimuth gears – synthetic oil 20 l

Hydraulic system – hydraulic oil 12 l

Main bearing – grease 15 kg

Generator bearing - grease 1 kg

Azimuth bearing – grease 9 kg

Azimuth toothing – grease 1.4 kg

Blade bearing – grease 12 kg

Blade bearing toothing – grease 1 kg

Pitch gear – synthetic oil 3×5.5 kg

Pitch gear seal – grease Small amount

Rotor locking, door hinges, etc - grease Small amount

Since the 1990s, parts of Ontario including the Sumac Ridge project area are experiencing lesser amounts of annual rainfall. This year has proven to be extremely dry. Westerly winds predominate in project area. If a fire were to occur, such winds would blow fiery debris into the Fleetwood Conservation Area and Fleetwood Kames. There is one pumper truck at the Pontypool fire station, but the volunteer fire crew will not be able to extinguish the turbine fire; it must

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be left to burn out. The fire fighter’s primary concern is extinguishing secondary fires caused by burning debris especially during windy conditions, storms or when the burning blades cannot be shut down and continue to spin uncontrollably at high speeds. Debris from shattered blades thrown up to several hundred meters have triggered fires on neighbouring properties and in some cases have spread to nearby fields or forested areas causing hundreds of acres of land to burn. In 2007, within a very short period of time, 125 acres of pasture and forest were burned along Ballyduff Road. This grass fire required fire crews from Ops, Lindsay, Omemee, Oakwood, Emily as well as from the nearby township of Cavan Monaghan to extinguish the wildfire. http://www.mykawartha.com/print/125116

Fire sweeping throughout the beautiful and ecologically important Fleetwood Creek and Pigeon River watershed would be devastating. There is a potential for great loss of residential, agricultural and commercial structures. A devastating wildfire on the Moraine will affect the complex hydrologic system.

Wildfire is a natural disturbance with epic potential to drastically alter watershed hydrologic condition. Basins with high-burn severity, especially those with steep previously forested terrain, have flashier hydrographs and can produce peak-flows orders of

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magnitude greater than pre-fire conditions. This is due to fundamental changes in the hydrology of burnt watersheds, especially in the short term (1-3 years). Consumption of the canopy and forest-floor organic horizon that formerly intercepted precipitation, moderated infiltration, and protected mineral soil, results in decreased evapotranspiration and infiltration, and increased runoff. Further, newly exposed soil surfaces are subject to rain-drop erosion, which may be exacerbated by fire induced soil-water repellency. Though the hydrologic impacts of high-severity wildfire have been well documented in the scientific literature, the socio-political ramifications of a latent, continuous, and highly unpredictable disturbance regime (i.e. post-fire flooding and sedimentation) has not been addressed. Fires are increasing in size, frequency, and severity. Simultaneously, development continues in the wildland-urban interface and the number of people living in or visiting forest areas is growing. Understanding the post-fire hydrologic response of watersheds is paramount for effective risk management and mitigation of post-fire hydrologic and geomorphic hazards. Equally important is educating communities that are at high-risk for post-

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fire flooding and sedimentation hazards. This presentation encompasses research on hydrologic and geomorphic impacts of past fires, a real-time perspective on recent post-fire hazards and mitigation (including the 2010 Schultz Fire and others). It identifies some high-risk areas where opportunity exists to educate and prepare the public for post-fire hazards after wildfires. (Daniel G. Nearya, Karen A. Koestnera, Ann Youbergb

Abstract - Hydrologic Impacts of High Severity Wildfire: USDA Forest Service, Arizona Geological Survey, 416 Congress Street, Suite 100, Tucson, Arizona 85701) http://www.fs.fed.us/rm/pubs_other/rmrs_2011_neary_d003.pdf

The proponent has not indicated what, if any, responsibility will be borne in the case of a fire event.

According to the Property Line Impact Assessment prepared for wpd Canada Corporation, it is stated that there is the possibility that the turbine might collapse. Structural failure is the failure of major components under conditions which

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components should be designed to withstand. This mainly concerns storm damage to turbines and tower collapse. However, poor quality control, lack of maintenance and component failure can also be responsible. In the geotechnical report, it is indicated that the soils in the Sumac Ridge project area will not support two turbines. Furthermore, existing water studies indicate that the soils in the area are prone to erosion and are considered to be unstable. Turbine collapse could result in personal injury or loss of life. The setback report prepared for the proponent indicates that two turbines overlap properties of non-participants as well as Wild Turkey Road.

In 2011 a conference was held in Sweden to address specifically the problems of industrial wind turbines in cold weather climates including REpower MM92 turbine models that will be used in the Sumac Ridge project:http://www.winterwind.se/2011/programme.html Blade icing and blade throw continue to present serious problems. “...rotating turbine blades may propel ice fragments some distance from the turbine— up to several hundred meters if conditions are right. Falling ice may cause damage to structures and vehicles, and injury to site personnel and the general public..” (GE turbine manual)

The turbines will be controlled from a remote destination. There is no evidence in the Sumac Ridge reports of a

detailed workable protocol if ice throw occurs. “The CWIF report details incidents where people have had to

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take cover as shards of ice as large as two feet long have been thrown onto homes, vehicles and roads causing damage. In two incidents turbines were reported to have thrown sharp pieces of ice into the ground despite being fitted with ice sensors.” http://www.caithnesswindfarms.co.uk/

Most of the accidents that occur at wind power plants will require the services of emergency teams. Local fire fighting, police and paramedic resources may be stretched or unavailable as they respond to accidents involving fatalities, injuries, worker rescues, fires, explosions, ice throws, blade and structural failures.

According to the Construction Report prepared by the proponent:

“The Emergency Response Plan will include a plan for the proper handling of material spills and associated procedures to be undertaken during a spill event. The plan will also specify containment and clean-up materials and their storage locations. The plan will include general procedures for personnel training. As

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appropriate, the plan may cover response actions to high winds, fire preparedness, evacuation procedures, high angle rescue, and medical emergencies. Developing this plan with local emergency services personnel will allow wpd to determine the extent of emergency response resources and response actions of those involved.”

In July of 2012, a report was filed with the County of Peterborough seeking that a permanent air ambulance base of operations be set up at the Peterborough Airport. As indicated in the chart below, the most calls, calls that eclipsed all areas including large urban centres for the services of ORNGE services originated in Peterborough and in the City of Kawartha Lakes region. Area residents indicate that ORNGE helicopters fly directly over the site of the proposed Sumac Ridge power plant. There is no evidence in the reports posted for public review that the proponent

contacted ORNGE services to confirm travel routes.

https://peterboroughcounty.civicweb.net/FileStorage/6123F10E4F604433A51544862E13F625-EMS%20Departmental%20Report%20-%20Permanent%20Air%20Ambulance%20.pdf

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It has been confirmed by City of Kawartha Lakes staff, that to date, wpd Canada Corporation has not contacted the municipality about the creation of an emergency response protocol. Since the proponent has not contacted the municipality with regard to responding to potentially serious mishaps, it is not known if the municipality has the equipment or supplies to deal with emergency situations. It is not known if there will be enough personnel to deal with hazardous situations. It is not known whether WPD will bear the financial responsibility of covering costs for supplies, equipment or personnel. An emergency response protocol needs to be established prior to project approval.

Moreover, Wild Turkey Road is not maintained by the City of Kawartha Lakes in the winter months. Public notices stating this are posted at each entrance of Wild Turkey Road; something wpd Canada should have been aware of. Wild Turkey Road is the roadway designated by wpd Canada for construction and maintenance access to Turbines Nos. 4 and 5. wpd Canada will NOT be able to access these turbine sites during the winter months. These turbines will be inaccessible for several months of the year preventing post construction maintenance or emergency repairs. Rural residents will be placed in harm’s way in the case of an emergency. Gray Road which is slated to host the distribution line is also inaccessible to vehicular traffic during the winter months.

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For the City of Kawartha Lakes to assume Wild Turkey Road as well as Gray Road, an application must be submitted that is supported by 100% of the abutting landowners. This is unlikely to happen.

http://www.city.kawarthalakes.on.ca/residents/public-works/general-operations/unassumed-roads-and-private-roads

NOISE IMPACT ASSESSMENT:

116 noise receptors have been identified in the Sumac Ridge project area. However, the accuracy of the mapping of these ‘receptors’ must be called into question. There are several notable errors contained within the noise assessment map. There are several missing or misplaced ‘receptor locations. The following receptors/addresses have been omitted from the map - Fire/911 assigned numbers 760 and 514 Ballyduff Road, 692 and 966 Hwy 35, 601 Gray Road, as well as 697 and 840, and 1115 Hwy 7A. Three receptors are marked on the noise impact map along Waite Road, but four others are missing including fire sign numbers 657, 663, 693 and 697. 1037 Gray Road has been missed as being designated a receptor even though there are 35 residential units at a greater distance which are marked as receptors including R060, R061 and R062.

As well, the receptor locations for R015 and R017 are in the

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wrong location on the property. Furthermore, the map lists 4 receptors for buildings/vacant lots that do not exist - receptors 105, 106, 107, and 110. They are located on the map in a wilderness area that connects to Fleetwood Conservation Area. There are no buildings or vacant lots in this area. Receptors 060, 109, 115,55, and 51 do NOT correspond to any existing marked address. There are no fire sign/911 number for these receptors.

Inaccurate mapping means that the Noise Impact Assessment is also inaccurate. The HGC report is based on an erroneous information and must be considered to be faulty.

HCG working from inaccurate information, visited the project site on the afternoon of July 22, 2011 to establish an ambient noise level. There is no indication where the monitor was set up or how long the session lasted. Turbines numbers. 2 ,4, and 5 are located at an elevation of 280 m. The area north of this site falls 18 m into a depression which rises to an elevation of 290 m where turbines numbers 1 and 3 are to be located. This is a 10 metre height difference between turbine locations. http://atlas.nrcan.gc.ca/site/english/maps/topo/map/ Changes in elevation will result in changes in ambient noise levels. The noise report does not state how long the ambient noise monitoring was conducted or what the weather conditions were. According to the Environment

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Canada weather office archives on the afternoon of July 22, 2011, relative humidity ranged from 74 to 80%, it was cloudy and showers in the region occurred around 4 pm... all factors that would be important in establishing an ambient sound base. Condensed water, in the form of rain, is a strong absorber of microwaves and contributes a significant amount of noise, whose level changes with time.

According to the EPA, “Ideally, measurements should be taken in ‘neutral’ weather conditions. This means in the absence of wind and precipitation, and ideally in conditions of standard temperature and pressure… The prevailing weather conditions at the time of measurement should be noted and recorded in the survey report…. In general, noise attributable to wind and or rain should be at least 10 dB below the noise source being measured; otherwise the measurements may be invalid….. http://webcache.googleusercontent.com/search?q=cache:Tprjbl8T_ZQJ:www.alcatel-lucent.com/bstj/vol40-1961/articles/bstj40-5-1331.pdf+&cd=15&hl=en&ct=clnk&gl=ca

There are 10 woodlands in close proximity to the 5 wind turbines proposed for the Sumac Ridge project. There is no indication of measurements or expected wind shear interference on performance in the WPD application.

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According to a best practices guide http://www.planningni.gov.uk/index/policy/policy_publications/planning_statements/planning_policy_statement_18__renewable_energy__best_practice_guidance.pdf

“The degree of wind shear (the rate at which the wind speed increases when moving vertically away from the ground) is dependent on the surrounding ground conditions; the higher the surrounding obstructions (e.g. vegetation or buildings) the greater the wind shear produced.

As well as affecting the wind shear, surrounding obstacles such as woodlands and buildings will increase the turbulence in the wind. Higher turbulence levels in the wind adversely affect wind turbine performance and life expectancy and, as such, developers will look to position turbines as far away from obstacles as is practicable. “

It can be argued that mid-summer is the noisiest time of the year. Even at this time of heightened noise levels, the ambient noise levels on the project site were recorded at 26 dBA to 36 dBA, well below the exclusionary limit of 40 dBA. Every 10 dBA increase is perceived by human ears as a doubling to tripling of the sound level. This means, the 116

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‘noise receptors’ aka homeowners within the Sumac Ridge project area will experience a doubling or tripling of sound levels… an increase that may be very hard to adjust to.

HGC Engineering, the company that conducted the computer noise modelling for the WPD Sumac Ridge project in Manvers states in their report:

“It is not realistic to expect that in practice a single repeatable sound level can or will be measured for a given wind speed at a given setback distance; a simple comparison of single numbers is not sufficient or possible.” (p.8)

The HGC report states on pages 3 and 4 that the wind power level (dBA) at a wind speed of 10 m/s for the REpower MM92 turbine model is 104.2 dBA (95% rated capacity) at a hub height of 100 m. This sound level at a rated 95% capacity is confirmed on page 8 of Appendix C which lists the manufacturer’s specifications. According to the Technical Guide, a supplement to O. Reg. 359/09, the setback from receptors of turbines that have an overall weighted sound power level (at 95% rated capacity) between 103-104 dBA are required to respect a setback of 600 m - not 550 m which the proponent has employed to site the wind turbines.http://www.ene.gov.on.ca/stdprodconsume/groups/lr/@ene/@resources/documents/resource/stdprod_088422.pdf

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The HGC report states “stands of foliage were not modelled” (p.7). There are 10 large woodlands in the project site, all except one contain a majority of deciduous trees. The foliage in summer will act as a noise muffler; in winter noise levels will be enhanced. In order to provide an accurate ambient noise level, the ambient noise levels need to be conducted over several seasons. Foliage can also contribute to an inaccurate ambient noise level measurement.

“The most likely sources of wind-generated noise are interactions between wind and vegetation. A number of factors affect the noise generated by wind flowing over vegetation. For example, the total magnitude of wind-generated noise depends more on the size of the windward surface off the vegetation than the foliage density or volume (Fégeant, 1999). The noise level and frequency content of wind generated noise also depends on the type of vegetation. For example, noise from deciduous trees tends to be slightly lower and more broadband than that from conifers, which generate more noise at specific frequencies.

http://www.windcows.com/files/WindTurbineNoiseIssues.pdf

Natural ambient sounds vary by vegetation community and terrain features. Different vegetation communities

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attract different birds, insects, and other wildlife, which have different sounds associated with them. They also respond to physical processes such as wind, snow, and rain with different natural sounds.

..... Temporal Sampling

Natural sounds vary by time of day, season, weather, and other variables. Collection of long term data is necessary to capture the variability of natural sounds. Since a change of 3 dBA is noticeable by a person of normal hearing engaged in an activity other than attentive listening (Brüel & Kjær 2000). Analysis of several year-long datasets (2005) show that summer and winter natural ambient sounds are significantly different from each other, and that a minimum sampling period of 25 days in each of those two seasons are required.

http://www.faa.gov/about/office_org/headquarters_offices/arc/programs/grand_canyon_overflights/documentation/GCNPNaturalAmbientSiteSelectionAugust2005.pdf

Using a ground attenuation factor (GAF) of 0.7 a temperature of 10C and Relative Humidity of 70%, are not appropriate for winter months, and under predicts the sound at distances of 1000 to 1500 m by some 3 dBA compared to a more typical winter value of a GAF of 0.2, a temperature of minus 10C and a Relative Humidity of 90% in the winter.

Employing the winter GAF of 0.2 may be too high as

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suggested by Ken Kaliski & Duncan (Maine study) who suggest 0.0 as a more appropriate value as the sound can travel from the source to the receptor in a straight line unimpeded or unaffected by the ground.

One mid afternoon sampling is not a true indicator of the ambient noise level in the project area.

According to the HCG noise study on page 7 it states:

“For each receptor the predictions include the sound emissions of known wind turbines within a 5 km radius as stipulated in the 2008 MOE Interpretation. There are two other proposed wind farms within 5 km, Snowy Ridge and Settlers landing, although at the time of this report there are no publicly available wind turbine coordinates”. (March 21,2012)

HCG argue that they did not have access to EFO/ZEP’s site plans so their predictions might not be accurate. There are two projects, Snowy Ridge and Settlers Landing, that will be just to the north and south of the Sumac Ridge project.

All three projects share a common project area first designated by Energy Farming Ontario in 2009. (Original study area map can be viewed on page 4 http://www.scugog.ca/uploads/1252613853-2009-09-14%20Corr%20Part%206.pdf ) The original study area map

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produced by Ortech for the project in July of 2010, and which is included in the map entitled Ballyduff Wind farm as an Appendix One in the Natural Heritage Assessment and Water Report labelled Project Area and Natural Features – Aquatic Stations, http://canada.wpd.de/fileadmin/pdfs/Sumac%20Ridge/10%20-%20Sumac%20Ridge%20DRAFT%20Water%20Report.pdf defines the project study the area to be bounded by Waite Road extending into Solanum Way to the south, the eastern boundary extends midpoint between Porter Road and Pitt Road, the northern boundary follows Twigg Road west to Hwy 7A to the west side of Hwy 35 and the western boundary extends south of Hwy 7A midway between Hwy 35 and Century Farm Road. The adjacent Snowy Ridge project area includes and shares the same study area as the Sumac Ridge project along Twigg Road, Pitt Road, Beer Road, Galloway Road, Hwy 7A and Hwy 35. The Settlers Landing study area includes a shared study area of Waite Road, Hwy 35 and Hwy 7A.

Since the three wind energy projects, Settlers Landing, Snowy Ridge and Sumac Ridge all share the same study area, they must be counted as one project. According to the Technical Guide to Renewal Energy Approvals, http://www.ene.gov.on.ca/stdprodconsume/groups/lr/@ene/

@resources/documents/resource/stdprod_088422.pdf projects with a cumulative number of 15 industrial wind turbines and a sound power level of 104.2 dba (EFO -now ZEP is also using REpower MM92 model wind turbines) must respect a

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minimum noise setback distance of between 700 and 850 m. Non-participating receptors numbers 2, 5 and 13 listed in the Sumac Ridge noise study are within 700 m of a turbine. Non participating receptors numbers 12 and 16 are within 850 m of a turbine.

It would have been a simple matter for the proponent, wpd Canada Corporation, to contact the developer of the Snowy Ridge and Settlers Landing projects to find out where turbines for these projects are to be located. On September 27th, 2012, Zero Emission People (formerly Energy Farming Ontario) issued public notices including maps with the turbine locations for both projects. The turbines are located within 5 kms of the Sumac Ridge project. The site location mapping plus the list of noise receptors issued for the Sumac Ridge and Settlers Landing project indicate that the location of the turbines have been known for a period of time; definitely previous to the time of wpd’s submitted application to the MOE on June 29th for construction of the Sumac Ridge project. Additional studies on sound emissions that include Snowy Ridge and Settlers Landing turbines need to be conducted.

The Technical Guide also states “If there are more than 5 turbines within 3 km of a noise receptor or if any turbines have a Sound Power Level greater than 102 dBA, greater setback distances must be met and/or noise studies must be completed..” According to the City

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of Kawartha Lakes staff report dated February 5th,

2013, “Between the Sumac Ridge and Snowy Ridge Project, 10 turbines are proposed within a radius of approximately 4.6 km.” http://www.city.kawarthalakes.on.ca/city-hall/agendas-and-minutes/council-meetings/SCA_Agenda_2013_02_05.pdf

The Ontario Environmental Review Tribunal Decision, July 18, 2011 states:

“This case has successfully shown that the debate should not be simplified to one about whether wind turbines can cause harm to humans. The evidence presented to the Tribunal demonstrates that they can, if facilities are placed too close to residents. The debate has now evolved to one of degree.”

A December 2010 report commissioned by the Ontario Ministry of Environment released December 2011 by the Ministry notes:

“The audible sound from wind turbines, at the levels experienced at typical receptor distances in Ontario, is nonetheless expected to result in a non-trivial percentage of persons being highly annoyed. As with sounds from many sources, research has shown that annoyance associated with sound from wind turbines

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can be expected to contribute to stress related health impacts in some persons.”

This report also states

“Stress symptoms associated with noise annoyance, and in particular low frequency annoyance, include sleep interference, headaches, poor concentration, mood swings…”

Although the province’s environmental review tribunal came to the conclusion that it could find no conclusive evidence that wind farms being developed under current regulations cause direct or indirect harm to human health, the tribunal also stated: "The evidence presented to the tribunal demonstrates that they can, if facilities are placed too close to residents".

While the proponent denies that the wind power plant project might cause physical distress to area residents, wpd is being held accountable for auditory distress imposed on residents in Germany:

Krank durch Windkraft?

Credit: 21.03.2012 ndr.de ~~

Sick from wind turbines? — Breathing problems, heart

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palpitations: Bertram Tauerschmidt is currently not very well. And he believes he knows why. Tauerschmidt lives in Wilstedt in the district of Rotenburg. There are nine wind turbines. Since the wind farm was put into operation in 2010, it went downhill with Tauerschmidt's well-being. A study will now determine whether wind turbines can be the cause of disease. The University of Halle, the German Wind Energy Institute, and the operator of wind farms, the company WPD, have launched the study. It is loud in his house, says Tauerschmidt - even with the windows closed, the noise level is very high. And he is not the only resident who has complained of discomfort. However, noise measurements in the area were all acceptable. Now the Wilstedters will be questioned individually. The results of the study will be available in 2013. WPD has already pledged to try to respond to suggestions from the study in order to reduce any possible stress.]...The original article in German can be found in the following link: http://www.ndr.de:80/regional/niedersachsen/oldenburg/windparkstudie101.html

“American and Canadian Wind Energy Associations (ACANWEA) have recently commissioned a review of the literature on wind turbine noise and health effects (Colby et al., 2009). The panel concluded that: “• There

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is no evidence that the audible or sub-audible sounds emitted by wind turbines have any direct adverse physiological effects. • The ground-borne vibrations from wind turbines are too weak to be detected by, or to affect, humans

The quality and authority of this review and its conclusions are open to considerable doubt. The medical members of the panel comprised a microbiologist, an otolaryngologist and an occupational health physician specialising in respiratory disease. From their biographies, none seems to have any expertise in sleep medicine or in psychology. The reference list shows that the literature review was far from complete. The panel admits that wind turbine noise causes annoyance which can lead to sleep disturbance but dismisses these findings. It is clear that they did not understand the significance of “annoyance” in a health context and neither did they comprehend the importance of sleep disturbance in causing ill health.

WIND TURBINE NOISE, SLEEP AND HEALTH Dr Christopher Hanning. BSc, MB, BS, MRCS, LRCP, FRCA, MD

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November 2010 – FULL REPORT can be found in this link:

http://www.acousticecology.org/wind/winddocs/health/Hanning%202010_Wind%20turbine%20noise%20sleep%20and%20health%20November%202010.pdf

“Sound movement through the atmosphere is affected by wind shear, which can bend the wave front, causing sounds to be heard where they normally would not, or vice versa. Wind turbines are affected by wind shear. Vertical wind-speed profiles result in different wind speeds at the blades nearest to the ground level compared to those at the top of blade travel, and this in turn affects the turbine operation.” Heier, Siegfried (2005). Grid Integration of Wind Energy Conversion Systems. Chichester: John Wiley & Sons. pp. 45.

High levels of wind shear at intermediate wind speeds significantly increase noise intrusion particularly during the night.

“Wind shear can have a pronounced effect upon sound propagation in the lower atmosphere, where waves can be "bent" by refraction phenomenon. The audibility of sounds from distant sources, such as thunder or gunshots, is very dependent on the amount of shear. The result of these differing sound levels is key in noise

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pollution considerations, for example from roadway noise and aircraft noise, and must be considered in the design of noise barriers. This phenomenon was first applied to the field of noise pollution study in the 1960s, contributing to the design of urban highways as well as noise barriers. C. Michael Hogan,Analysis of highway noise, Journal of Water, Air, & Soil Pollution, Volume 2, Number 3, Biomedical and Life Sciences and Earth and Environmental Science Issue, Pages 387-392, September, 1973, Springer Verlag, Netherlands ISSN 0049-

6979. http://www.springerlink.com/content/x1707075n815g604/.]

Recently, a peer-reviewed article entitled “Effects of industrial wind turbine noise on sleep and health”September-October 2012, Volume 14:60, 237-43

Authors: Nissenbaum, Michael; Aramini, Jeffery; and Hanning, Christopher

AbstractIndustrial wind turbines (IWTs) are a new source of noise in previously quiet rural environments. Environmental noise is a public health concern, of which sleep disruption is a major factor. To compare sleep and general health outcomes between participants living close to IWTs and those living further away from them, participants living between 375 and 1400 m (n = 38) and 3.3 and 6.6 km (n = 41) from IWTs were enrolled in a stratified

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cross-sectional study involving two rural sites. Validated questionnaires were used to collect information on sleep quality (Pittsburgh Sleep Quality Index — PSQI), daytime sleepiness (Epworth Sleepiness Score — ESS), and general health (SF36v2), together with psychiatric disorders, attitude, and demographics. Descriptive and multivariate analyses were performed to investigate the effect of the main exposure variable of interest (distance to the nearest IWT) on various health outcome measures. Participants living within 1.4 km of an IWT had worse sleep, were sleepier during the day, and had worse SF36 Mental Component Scores compared to those living further than 1.4 km away. Significant dose-response relationships between PSQI, ESS, SF36 Mental Component Score, and log-distance to the nearest IWT were identified after controlling for gender, age, and household clustering. The adverse event reports of sleep disturbance and ill health by those living close to IWTs are supported.

The findings provide clear evidence that supports long-standing complaints from people living near turbines that the sound from their rotating blades disrupts sleep patterns and causes stress-related conditions.

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In late February 2013, Dr. Hazel Lynn, Medical Officer of Health for Grey Bruce recently released a report on Industrial Wind Turbines. What she and her researcher found during a worldwide search is that there is NO evidence that wind turbines cause NO harm. What they found was that a certain percentage of the population are put in a state of distress by the operation of wind power plants and that this distress is reduced or erased when the power plant is not operating or the person is not in the vicinity of the plant. As to why this happens, more research needs to be conducted. The following are news stories covering the report. There are several news links...

1.“Dr. Hazel Lynn, the Grey-Bruce medical officer of health, unveiled a new report Friday that suggests wind turbines can cause physical harm.”Read more: http://london.ctvnews.ca/report-on-wind-turbine-safety-released-1.1167692#ixzz2LpYFxlXa.

2.“Wind turbines cause distress among people who live near them, but more and better studies are needed if there’s to be a policy shift in Ontario, the Grey Bruce Board of Health was told Friday.

The board was presented with a report cultivated from a comprehensive review of the most current and credible studies around the world on the effects from wind turbines. The board requested the review last fall after a plaintive appeal from local residents who said they were suffering ill health from the massive turbines and wanted help.” Studies show association between turbines,

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health effects: report<http://www.owensoundsuntimes.com/2013/02/22/studies-show-association-between-turbines-adverse-effects-report> |

3. Wind Turbines Cause Adverse Health Effects Says Doctor

Jill Young

2/22/2013 – A new report from the top medical officer for Grey and Bruce Counties says wind turbines regularly cause health problems.

Dr. Hazel Lynn says the number of issues such as headaches and sleeplessness tend to increase when there are turbines nearby.

Lynn presented the report, based on an analysis of other studies, to the Grey-Bruce Board of Health today, and it will be later sent to the Ministry of Health.

The findings counter a study done two years ago by Ontario Chief Medical Officer of Health doctor Arlene King which found no direct link between wind farms and adverse health. http://www.cjbk.com/LocalNews/story.aspx?ID=1894948>|

4. “Their review of the literature concluded that every single report about industrial turbines concludes that none of the available studies found that there are no effects from turbines on human beings.

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The report is a significant step towards showing that close proximity to wind turbines can lead to adverse health effects – as hundreds of turbine neighbours have been saying for years. Dr. Lynn said she received a request from the Ministry of Health for a copy of the report, based on media reports of its contents, even before it had been presented publicly. Their research on the matter included looking at 18 peer-reviewed studies on the subject.

“All the studies show there is distress,” Dr. Arra, said in his presentation. Dr. Arra helped Dr. Lynn research the matter. He is a medical doctor with a master’s degree in clinical epidemiology. “Not one, didn’t find an affect of distress (on people). All of these studies found there is an association,” Dr. Arra explained.

Turbines Possibly Linked To Health Effects<http://blackburnnews.com/london/2013/02/22/turbines-possibly-linked-to-health-effects/>| Blackburn news Doctor Arra performed the study and says none of the health studies could conclusively prove wind turbines are safe when placed near humans.

He says there are also suggestions that proximity to wind turbines can make health symptoms worse.

EFFECT ON CHILDREN

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There have been hundreds of studies on the effect of noise pollution on children. They are all negative. Chronic exposure to noise has been shown to be harmful to children of various ages. It can have especially detrimental effects on younger children when language and discrimination skills are forming.

There are two elementary schools in close proximity to the Sumac Ridges project – Grandview Public School and Rolling Hills Public School with a combined enrolment of 427 elementary grade students. There is also a daycare facility onsite at Rolling Hills Public School caring for children from 1.5 to 12 years of age. The schools are located approximately 1000 m from Turbine # 1 and 1400 m from Turbine # 3.

It has been demonstrated that even though computer modelling indicates that audible sound levels produced by wind power plants are acceptable with a setback of 550 m, this is not always the case in actual situations. There have been many noise complaints filed with the MOE from locations far beyond 550 metres.

Industrial wind turbines also produce infrasound. Infrasound has been shown to be the cause of ‘sick building’ syndrome. Aside from audible noise possibly disrupting the education of elementary school children, the inaudible noise (infrasound) produced by the Sumac Ridge project has the potential to

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harm the 427 young students. Several children with behavioural problems and/or learning difficulties attend these schools. There are at least 3 students who display a level of ASD (Autism Spectrum Disorders). Autistic children are peculiarly sensitive to noise. Several students have medical conditions that can become exacerbated and dangerous under increased stress levels.

“Infrasound is especially dangerous, due to its strong vibrations, or oscillations. Infrasound waves hug the ground, travel for long distances without losing strength, and are unstoppable. Not much amplitude is needed to produce negative effects in the human body, and even mild infrasound exposure requires several hours, or even days, to reverse symptoms.” http://www.lowertheboom.org/trice/infrasound.htm

Sick Building Syndrome: Acoustic Aspects

1. Tyrrell Burt

1. Division of Heating and Ventilation, Department of Energy Technology, Royal Institute of Technology, Stockholm, Sweden

Abstract

Low-frequency noise, centred around a frequency of about 7 Hz, was found to occur in several office rooms investigated. Symptoms resulting from exposure to infrasound can include

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fatigue, headache, nausea, concentration difficul ties, disorientation, seasickness, digestive disorders, cough, vision problems and dizziness, that is, symptoms typical of the sick building syndrome. Many of the occupants exhibited such symptoms. It is shown that the low-frequency component of ventilation noise is often being amplified in the tightly sealed rooms. Repeated or long-term exposure to such amplified infrasound may be triggering an allergic-type response in individuals.

http://ibe.sagepub.com/content/5/1/44

A recent study on the impact of infrasound created by industrial wind turbines released at the end of 2012. Titled,

A Cooperative Measurement Survey and Analysis of Low Frequency and Infrasound at the Shirley Wind Farm in Brown County, Wisconsin",

this study was conducted by four acoustical consulting firms. Channel Islands Acoustics (ChIA) has derived modest income while Hessler Associates has derived significant income from wind turbine development projects. Rand Acoustics is almost exclusively retained by opponents of wind projects. Schomer and Associates have worked about equally for both proponents and opponents of wind turbine projects. However, all of the firms are pro-wind if proper siting limits for noise are considered in the project design.” As a result of the study,

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“The four investigating firms are of the opinion that enough evidence and hypotheses have been given herein to classify LFN and infrasound as a serious issue, possibly affecting the future of the industry. It should be addressed beyond the present practice of showing that wind turbine levels are magnitudes below the threshold of hearing at low frequencies.”

The Sumac Ridge project has the potential to harm many small children. As stated, several students attending these schools have behavioural issues, at least three students have been diagnosed with varying degrees of autism and there are at least three children that have heart problems. Stress can aggravate these conditions. Aside from the potential negative impact audible and inaudible noise may have on the student population, the flicker effect produced by industrial wind turbines has been demonstrated to impact those suffering from Autism Spectrum Disorders (ASD). Studies conducted have suggested that people suffering from ASD experience a certain effect due to common fluorescent flicker. The flicker effect produced by industrial wind turbines as evidenced in this video http://youtu.be/MbIe0iUtelQ may affect children attending the schools located adjacent to the Sumac Ridge

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Project.

In addition there are school children that will be affected not only by the noise and flicker affected during school hours, but at home as well. There are children who attend the school who also reside in homes designated as noise and flicker shadow ‘receptors”.

The Effects of Wind Turbines on Children

The constant noise produced by wind turbines can have detrimental effects on all children, but especially children with Special Needs. Children with Autism and Attention Deficit Disorder or Attention Deficit Hyperactivity Disorder (ADD/ADHD) are particularly vulnerable to the negative effects of intrusive noise. Children and adults who live with these disorders have difficulty processing auditory sensory input; they often do not possess the ability to filter noises. Thus they may hear all noises at the same level. The noise created from wind turbines would produce a noise that can cause continuous auditory sensory overload. This would result in severe interruptions in the person’s ability to concentrate and focus. Many children with Autism do not have the communications skills to effectively communicate their needs, thus the constant wind turbine noise, coupled with communication deficits, could result in significant increases in aggressive behaviors among children

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with Autism. Aggressive behaviors could also increase in individuals with ADD/ADHD. Not addressing the needs of children with ADD/ADHD, could potentially lead to increased violent crime, as was proven Dr. Susan Young, of Broadmoor Hospital, who conducted research on the connection between ADD/ADHD and crime. Children with Autism or ADD/ADHD have enough trouble concentrating and focusing both in school and in life in general. The noise created by wind turbines could definitely cause interruptions in their ability to learn, concentrate, think and function. This noise would also negatively affect children and adults who are severely hearing impaired and have a cochlear implant. The microphone on a cochlear implant picks up noise from the environment, as well as speech sounds. The constant noise from the turbines would severely inhibit the ability of a person with a cochlear implant to process sounds, especially speech.

The intrusive sounds created by wind turbines do not only affect children with special needs, but also negatively affect all children. The constant noise can negatively affect the physical and mental well being of all children. The cardiovascular system, central nervous system, memory, language processing and cognition as well as learning abilities can all be affected by intrusive noises, such as the noise made from wind turbines.

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Before forging ahead with wind turbines, more research needs to be done regarding the life-long complications arising from them.

Julie Eby B.A., E.A.

Preschool Behavior Therapy

“Opening Windows When Doors are Closed”

wpd Canada Corporation has not met with school officials or with Trillium Lakelands District School Board to discuss the Sumac Ridge project and has not demonstrated that audible noise, infrasound or the flicker effect will not impact the attendees at Grandview or Rolling Hills schools.

FLICKER SHADOW EFFECT

wpd Canada Corporation has indicated that the strobe light effect known as the ‘flicker effect’ may impact nearby residences. When questioned about the flicker effect, the spokesperson for wpd Canada Corporation responded: “Under certain conditions the sun shining behind a turbine produces recurring shadows. Depending on a number of factors, including location, time of day/year and weather conditions, shadows may be produced inside a dwelling. It is possible to calculate very

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precisely whether a flickering will fall on a given location near a wind project, and for how many hours a year. wpd would be happy to run a shadow analysis for adjacent landowners upon request.”

The proponent has not revealed how many residences will be affected by the flicker effect and if the two nearby elementary schools will be subject to the strobe light effect. The proponent should contact all residences that will be affected beforehand, not state that residents have to contact wpd Canada Corporation to find out if they will be affected. The total number of residences that will be affected should be known before construction of the project. Other proponents have, and are providing, a complete list of residences that will be affected by the flicker effect including the calculated lengths of time per annum. At least one family will be subject to flicker shadow effect from two sources - a business at one location and their residence at another nearby location. One member of this family is very sensitive to the strobe lighting effect. This family member becomes ill when in a vehicle driven even a few meters where the sun flashing through tree foliage along the side of the road creates a temporary flicker effect. The noise and the flicker shadow effect is a concern to another resident who has several employees who work out-of-doors. If these workers become ill, this resident will face loss of valuable employee time as well as possible financial losses.

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There are two elementary schools that will be affected by the strobe light effect by the adjacent project, Snowy Ridge. This is clearly indicated on maps provided by the proponent. It stands to reason that turbines Nos. 1 and 3 in the wpd Canada Sumac Ridge project which are in closer proximity to the schools than the turbines in the Snowy Ridge project will also create flicker shadow effects. How the flicker shadow effect will manifest itself from the two projects is unknown – i.e. possible overlapping of the shadow pattern arrangement, possible extended periods of flicker effect as the sunlight passes through consecutive turbines etc . There are over 400 children that attend the two elementary schools. Several have medical conditions that might be affected by the shadow flicker effect being produced.

While wpd Canada did not make a flicker shadow report to the public and those who will be most affected by this strobe-like effect, almost 6 months after wpd submitted an application for approval to the MOE, the City of Kawartha Lakes planning department received on December 17th, 2012, a cover letter and two page flicker shadow and map report.

The cover letter does not indicate what software program was used to conduct the flicker report. It is stated that objects in between receptors were not accounted for and that parameter model settings were set to ‘greenhouse’. From this, it would appear that wpd Canada is using the

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same software as Sportt/Zep for the adjacent Snowy Ridge project.

In this wpd Canada flicker shadow report which lists 36 receptors, only 7 of the those match noise receptor distances listed by the proponent. The fact that the setback distances are disparate for noise and shadow flicker for 80% of the receptors means that either the noise receptor setbacks are inaccurate or the flicker setbacks are.

One flicker receptor - Q cannot be matched up to a noise receptor location. None of the participating noise receptors are registered on the map or on the chart. The participating receptors are listed for the adjacent Sportt/Zep Snowy Ridge project.

A cluster of homes at the intersection of Galloway/Beers/Pitt Road are not listed in the flicker report but nearby ones are. Receptors 017, 106, 115, 100, 99, 103, 105, 104, 98, 40, 102, and 112 are not listed in the flicker report but are very near others that are. No vacant lots are listed in the shadow flicker report; vacant lots are listed in the Sprott/Zep Snowy Ridge flicker report.

The adjacent project Snowy Ridge which is in very close proximity to the Sumac Ridge project, boasts a similar topography. The Snowy Ridge turbines are approximately the same distance away from various receptors as ones for the Sumac Ridge project. The wpd Canada flicker shadow

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effect report indicates that the majority of receptors will not experience any flicker effect with the worst case scenario being 4.46 hours per annum. As indicated above, not all receptors including participating receptors are included in the one page list or map. The report for the Snowy Ridge project with receptors at the same distance away and in the same direction indicates that receptors might experience anywhere from 18 to 125 hours per annum of flicker effect with the median being between 40 to 70 hours annually. This is a notable discrepancy.

The Shadow Flicker Report indicates that the provincial highway Hwy 7A will be subject to flicker shadow. According to the adjacent Snowy Ridge report Hwy 7A could be subject to flicker shadow effect for 20 to 30 hours per annum. The wpd Canada report on Sumac Ridge provides no indication of how many hours per annum Hwy 7A will be subject to the flicker shadow report.

According to MTO traffic volume records from 2009,

http://www.raqsa.mto.gov.on.ca/techpubs/TrafficVolumes.nsf/fa027808647879788525708a004b5df8/f51986ea499a13b08525745f006dd30b/$FILE/Provincial%20Highways%20traffic%20Volumes%202009%20AADT%20Only.pdf,

Highway 7A between Cavan and the junction of Highway 35 sees an average vehicular traffic volume of 4500 vehicles.

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This highway route is more heavily used in the summer months since it is a popular destination route to cottage country and local tourist attractions. It is indicated in the wpd Canada report that the flicker effect will reach the busy intersection of Highways 35 and 7A. The stretch of 7.6 kms of Highway 35 and the junction at Highway 7A sees an average daily volume of 6300 vehicles per day. Highway 35, due to increased summer traffic volume is slated to be widened in the project area. Two elementary schools, Rolling Hills and Grandview are located at the junction of Hwys 35 and 7A. Many school buses are used to transport children to and from these schools. There is no indication that either the Kawartha Pine Ridges School Board or STSCO – Student Transportation Services of Central Ontario have been notified of this possible transportation hazard.

There is no indication that the MTO has been notified of the possibility dangerous distraction that will effect drivers using this highway.

ECONOMIC IMPACT

While WPD did not supply handouts about the construction of the Sumac Ridge project and natural heritage assessments to attendees at the final public meeting on

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June 19th, 2012, there was no shortage of handouts indicating that local property values would not be affected and will actually increase after an industrial power plant is constructed on this magnificent and scenic section of the Oak Ridges Moraine.

The handouts included the two studies referred to in WPD’s Sumac Ridge application: Wind Farm & Property Values: A Pooled Hedonic Regression Analysis of Property Values in Central Illinois, and, Impact of Wind Power Projects on Residential Property Values in the United States - A Multi-Site Hedonic Analysis

It must be pointed out that these two American studies contain important caveats:

"Currently, the severe lack of statistical rigor, unbiasedness, and reliable methodologies across the wind farm proximity and property value studies cannot allow any general conclusions to be made - only site-specific findings". page 86 (Property Values in Central Illinois)

"This work builds on existing literature in a number of respects, but there remain a number of areas for further research. ... Additional research on the nature of reported in this paper could be pursued, but with a

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greater number of transactions, especially for homes particularly close to wind facilities. A more detailed analysis of sales volume impacts may also be fruitful, as would assessment of the potential impact of wind facilities on the length of time homes are on the market in advance of an eventual sale. Finally it would be useful to conduct a survey of those homeowners living close to existing wind facilities and especially those residents who have bought and sold homes in proximity to wind facilities after facility construction to assess their opinions on the impacts of wind project development on their home purchase and sales decision". (page XVII Multi-Site Hedonic Analysis).

In Great Britain it has been recognized that property values are affected by close placement of industrial wind power plant complexes. The government of Denmark has recognized that property values are affected.

According to the Danish Department of Energy http://www.ens.dk/en-

us/supply/renewable-energy/windpower/onshore-wind-power/loss-of-value-to-real-property/sider/forside.aspx

“Loss of value to real property due the erection of wind turbines

An erector of a wind turbine has a duty to pay compensation for loss of value of real property following the erection of the wind turbine. The size of the loss of value is determined

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by an appraisal authority.”

Properties listed for sale within the Sumac Ridge power plant project are not being sold. Few, if anyone wishes to live next to an industrial complex. The region that contains the Sumac Ridge project is attractive because of the stunning hillside views. The value of local real estate is tied-in to the vistas. The 500 foot tall structures will be visible for miles. They will be the tallest structures in the entire region. Residents have received inquiries about the status of the Sumac Ridge project from prospective buyers; buyers no longer when they are told that the project is in the application stage.

On February 5th, 2013, a special meeting was convened at the request of the council of the City of Kawartha Lakes. This meeting, to decide whether or not to support the findings of a staff report, allowed members of the public to address council in short 5 minute deputations. One of those who addressed council, was Rose Saller a real estate agent associated with Urban Landmark Realty. Ms. Saller made it quite clear that in the past two years, it has been next to impossible to sell properties listed for sale in the Sumac Ridge project area. Ms. Saller also indicated that once potential customers are made aware that an industrial wind energy project is proposed for the area, these potential customers are no longer interested.

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The Ontario Real Estate Association has issued a new set of disclosures to be complied with.

The new Green Energy clauses are:

• GREEN-1: Condition – MicroFIT Contract

• GREEN-2: Acknowledgement – MicroFIT Contract

• GREEN-3: Decommissioning Renewable Energy Facility

• GREEN-4: Renewable Energy Projects

• GREEN-5: Wind Turbines – Warranty

Clause GREEN-1 provides the buyer with the opportunity to review the terms of an existing microFIT contract on the property, if applicable.

Clause GREEN-2 confirms the buyer has reviewed the microFIT contract, if applicable.The balance of the clauses confirms/warrants the following:

•GREEN-3 – confirms that the buyer understands he/she may be responsible for decommissioning the renewable energy installation at expense of the property owner

• Green 4 confirms that the buyer is aware of proposed or existing renewable energy projects in the area

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• GREEN 5 – warrants that the seller is not aware of any renewable energy projects for the immediate area

Clause GREEN-5 can be altered to reference solar energy collectors.Green energy is a complicated topic. REALTORS® must be prepared to create specific clauses to deal with unique circumstances as they arise.

In addition, REALTORS® should be aware that renewable energy installations can affect the insurability of a property, and clauses may be required to verify the insurability of the property.

Recent regional news stories confirm that property values are being negatively affected by the nearby installation of industrial wind power plants. http://www.cbc.ca/news/canada/story/2011/09/30/ontario-wind-power-property-values.html

http://www.sashamiletic.com/wind-turbines-blow-down-resale-value-of-windsor-homes

A Case Study on Diminution of Real Estate Values was released in October 2012. It was prepared by Lasink Appraisals & Consulting - a Division Wellington Realty Corporation. This case study examined the values of 5

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properties in the Melancthon/Shelburne area; properties that do not host industrial wind turbines but are located in the vicinity of wind turbines. This case study of 5 properties purchased by Canadian Hydro Developers and then re-sold came to the conclusion that Median Loss in Market Price was -37.30% and the Average Loss in Market Price -38.81%. The study also came to the conclusion:

“The erection of a wind turbine creates apprehension in the general public, which makes the property less desirable and thus diminishes the prices of neighbouring property. Continuing scientific uncertainty over the adverse health consequences of wind turbines only serves to perpetuate the debilitating effect of wind turbines on property prices.

By including the Transfer of Easement in Gross in the deed/transfer of the properties sold by Canadian Hydro Developments, Inc., it is reasonable to conclude that Canadian Hydro Developers, Inc. was fully aware of problems associated with…heat, sound, vibration, shadow, flickering of light, noise (including grey noise) or any other adverse effect or combination thereof resulting directly or indirectly from the operation of the Transferee's wind turbine facilities situated…within the Townships of Melancthon and Amaranth, in the County of Dufferin…’ and that the turbines …’may affect the living environment’…

The covenants imposed by Canadian Hydro Developments, Inc. and accepted by the five buyers

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suggest an official admission by Canadian Hydro Developments, Inc. that there are living environment issues with the result that there is a diminution in price as a result of wind turbines.

It is also reasonable to assume that a property that has a wind turbine erected on it will suffer a similar price diminution and will be injuriously affected. The Future: Given that wind turbines are a relatively new phenomenon in Ontario (2005), it may be that in the future a buyer will simply refuse to purchase a property within the vicinity of a wind turbine. If there is no buyer, there may be no value.”

It is expected that the region bounded by Highways 35 and 115 will become a highly desirable settlement area after the extension of Highway 407 is completed. An industrial power plant will prove to be a disincentive to relocate to this area. Pontypool, the closest settlement area to the Sumac Ridge project is an unincorporated village that has seen its population decline. With the expansion of the Highway 407 system, the potential exists for Pontypool to also expand and thrive. This will not be possible if an industrial power plant is in close proximity. The presence of industrial wind power plants is a detriment to those who wish to reside in an area known for its breathtaking vistas.

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The property line setback assessment report prepared for WPD indicates that Turbine # 1 overlaps the adjacent property line of a non-participating landowner to the west by 32.1 metres. Turbine # 5 overlaps the non-participating property line to the north by 8 .6 metres. While the report suggests that in the event of turbine collapse, unspecified compensation would be offered for the destruction of property, there is no indication that these property owners are aware of the overlapping of the project on their lands. There is no indication that wpd Canada has advised these landowners that a section of their property will not be amenable to any future plans for building structures or a variety of activities. The value of these non-participating properties will be affected if portions of the property will be subject to hazardous conditions.

According to the reports prepared for the proponent wpd Canada, it is indicated that there is the possibility that,

“While there is a potential that television signals in the immediate vicinity of the project may experience interference actual impacts to OTA reception are dependent upon several factors including local topography, meteorological conditions, antenna quality and location. Based "upon the above an OTA compensation program is recommended for receptors within the 10 km consultation zone

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which may include:

Relocation or repositioning of aerial antennas antenna upgrades, or payment of monthly subscription for satellite television services.

According to the Radio Advisory Board of Canada ( http://www.rabc-cccr.ca/Files/RABC%20CANWEA%20Guidelines.pdf ) ,

“Experience and studies in Europe and the United States have indicated that both the physical structures of the tower/turbine and the rotating blades can cause interference on conventional and Doppler radar signals (see references). Wind turbines, which are within the “Line of Sight” (LOS) of

radars, can have a negative impact on radar data.

Based on this, the following systems could be negatively impacted by the proximity of wind turbines:

- Cable distribution off-air (over-the-air, OTA) receive systems (Head-ends);

- Satellite uplinks and receive systems;

- Direct-to-home (DTH) receive systems (Shaw Direct, Bell TV);

- Radar (weather, defence and air traffic);

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- Airport communications and guidance systems;

- Broadcasting – radio (AM, FM) and TV (analog and digital);

- Coast Guard communications and vessel traffic radar systems;

- Point-to-point radiocommunication systems;

- Point-to-multipoint radiocommunication systems, and

- Cellular and land mobile networks.

Wind turbines can affect radiocommunication and radar signals in a number of ways including shadowing, mirror-type reflections, clutter or signal scattering.”

Residents within the 10 km radius of the Sumac Ridge project have not been notified of the possibility that over-the-air reception may be affected. The villages of Pontypool and Bethany are within 10 kms of the project area. The reports prepared by the proponent do not identify how many households could be affected. While it is recommended that as mitigation the proponent pay for a monthly satellite television service for residents who experience reception problems, there are no details as to the level of satellite service that will be provided or for how long. Satellite service may also be affected by the location of the turbines.

Other wind developers have indicated that not only OTA television reception may be affected, cell phone service,

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GPS systems which play an important role in the agricultural community, internet or broadcast radio frequency may also experience disturbances. There is no evidence in the reports prepared that the proponent contacted the appropriate and mandatory authorities such as Xplornet, Rogers Communications, NAV Canada, RCMP, DND, Environment Canada etc. There is a cell tower within 1 km of the Sumac Ridge project. Under O. Reg 359/09 consultation with the cell tower owner/operator is required. The wpd Canada application does not adequately address the subject of telecommunication interference. The possibility that over the air interference will play havoc with radio, television, internet and cell phone transmission will not make this region an attractive settlement area. Interference could place emergency responders in an untenable situation. Interference could affect local commercial, industrial and agricultural ventures.

The proponent makes the argument that the Sumac Ridge project will bring economic benefits to the community through the construction process. There is no indication that local companies will be contracted for any part of the construction process. The movement of industrial wind turbine components requires specialized transport mechanisms; none that are likely to be found locally. The proponent also indicates that area stores will see benefit during the construction process. The closest settlement area to the Sumac Ridge project is Pontypool. Pontypool has

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a convenience store, LCBO, a Chinese/Pizza restaurant, a gas station, community centre, church and post office. The convenience store, gas station and restaurant might see a temporary boost in sales, but no permanent employment opportunities will be realized. The Sumac Ridge project will be monitored from a remote location. Maintenance crews require specialized skills. Maintenance contracts will likely be outsourced to urban based companies. Post construction monitoring contracts will likely also be awarded to urban based companies. The touted annual municipal tax benefit of approximately $3000 to $5000 per annum by the proponent may be offset by increased pressure on emergency services which in turn would place a greater financial burden on the taxpayers of the City of Kawartha Lakes. The road allowances that will be widened will add financial costs to the City of Kawartha Lakes Public Works department which will be responsible for maintaining the roadways.

PUBLIC CONSULTATION

WPD did not make a presentation before the City of Kawartha Lakes Council about this project. There were two pre-consultation meetings with WPD and CKL planning staff in June 2011. There was no definitive layout of the project at that time.

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WPD was asked for a number of reports including a hydrogeological report by the CKL staff. The hydrogeological report was never provided. A request was made that the maps included in WPD’s draft application be replicated to a scale so that they might be compared to maps on file in the municipal planning office. This request has yet to be honoured. On March 14th, 2012, the planning department of the CKL received an email from a representative of WPD stating:

‘I have confirmed with our staff that there are some Project design questions that might require the City's input in order to facilitate the design process. These include questions concerning the power lines and the general permitting process.’ The proponent had two years to request information from the City but did not do so; instead the proponent chose to seek important information a mere three months before the second and final public meeting. There is no record of the required information being provided to WPD by CKL staff.

The REA Technical Guide – specifically section 9.3 on p. 132, states:

“Applicants for a REA are encouraged to refer to the O. Reg. 140/02 made under the Oak Ridges Moraine Conservation Plan Act and to consult with local municipalities and conservation authorities who have additional experience interpreting the plan as it relates to the project location.”

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There is no indication that wpd Canada has discussed the Sumac Ridge project as it pertains to Oak Ridges Moraine Conservation Act with City of Kawartha Lakes staff or Kawartha Conservation Authority.

Despite knowing that the proponent required information from the City of Kawartha Lakes, information that could affect the design of the project, the project developer held a second and final public meeting without this important information. The proponent submitted the application for approval to the Ministry of the Environment without all the necessary information required for the design of the Sumac Ridge project.

The Sumac Ridge project calls for the major alteration of municipally owned road allowances. The project also calls for large scale removal of vegetation and trees on municipally owned property. There is no indication that wpd Canada corporation has discussed plans for alteration of property wpd Canada does not own with the actual landowner – the City of Kawartha Lakes. There is no indication that the proponent has, or will gain permission to alter municipal road allowances.

The Sumac Ridge project with plans to create access roads within road allowances and the erection of transmission lines

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contravenes the Official Plan of the City of Kawartha Lakes as it pertains to the Oak Ridges Moraine:

6.6 TRANSPORTATION INFRASTRUCTURE AND UTILITIES

a) Notwithstanding any other provisions of this By-law to the contrary, all new transportation, infrastructure and utilities uses listed below, and all upgrading or extension of existing transportation, infrastructure and utilities uses, including the opening of a road within an unopened road allowance, are prohibited on lands within an ORMEP Zone, ORMCA Zone, and ORMLA Zone as shown on Schedules A and B to this By-law:

i) public highways

ii) transit lines, railways and related facilities;

iii) gas and oil pipelines;

iv) sewage and water service systems and lines and stormwater management facilities;

v) power transmission lines;

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vi) telecommunication lines and facilities, including broadcasting towers;

Except as permitted in subsection (5), with respect to land in a key natural heritage feature or a hydrologically sensitive feature, all new transportation, infrastructure and utilities uses and all upgrading or extension of existing transportation, infrastructure and utilities uses, including the opening of a road within an unopened road allowance, are prohibited. O. Reg. 140/02, s. 41 (4). ORM Plan http://www.e-laws.gov.on.ca/html/regs/english/elaws_regs_020140_e.htm#BK47

Transportation, infrastructure, and utilities as described in Section 41 of the ORMCP are allowed, but only if the need for the project has been demonstrated and there is no reasonable alternative. http://www.city.kawarthalakes.on.ca/residents/planning-building/official-plans-zoning-by-law/ORMOPFINALMay_11_2005.pdf/view?searchterm=ORM

The need for the Sumac Ridge project has not been demonstrated, nor has a reasonable alternative been proposed. The proponent has filed an application dependent on obtaining permits from the City of Kawartha Lakes. The proponent has not obtained the required permits.

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In a Lindsay Post news article announcing the June 19th final public meeting, it is stated that WPD intended to submit its application for project approval to the MOE by June 29th.... this announced BEFORE meeting with the public.

Final consultation set for wind turbines

MANVERS TOWNSHIP – "Nearly two years since it held its first public open house, wpd Canada Corporation re-enters the lion's den next Tuesday, June 19 for its second, and final, public consultation on its plan to build five industrial

wind turbines in the former Manvers Township. .......After the public meeting, wpd Canada hopes to submit its reports and a consultation report to the Ministry of the Environment for a Renewable Energy Approval by June 29."http://www.thepost.ca/PrintArticle.aspx?e=3584449

The announcement of intent to submit the application before meeting the public demonstrates that the proponent had little interest in addressing concerns and questions raised by the public. Furthermore, the fact that the proponent publically admitted an intention to submit the application for approval to the MOE within 10 days of the public meeting speaks volumes to the company's disinterest in hearing and addressing public concerns and questions. Several wpd Canada reps reminded members of the public that the company welcomes feedback since it becomes part of the

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application process. However, the intent of the proponent to only acknowledge questions received during a very short period of time indicates that the proponent is not truly interested in public feedback.

While questions submitted by members of the public to wpd Canada before June 29th were answered immediately, questions sent after June 29th were answered weeks later or have not been answered.

Each person who entered the public meeting venue was handed an envelope in which to insert comments and mail to wpd Canada's Mississauga office.

The expectation that members of the public, many who are involved with the end of the school year, summer holiday plans, work schedules and agricultural enterprises, would have the time to sit down, gather their thoughts about the meeting, put together comments and questions, find a mailbox or head to the post office and get their comments and questions to WPD within a week was unrealistic. While many rural customers do have access to email, many do not. wpd Canada should have extended the comment period on the final public meeting to at least 30 days.

On the evening of the final meeting, attendees were greeted by a large police and security presence. Barricades erected by the proponent forced attendees to have to park their vehicles a fair distance away from the venue. Since a section of the parking lot was blocked off, many had to park

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their vehicles along the shoulders of a busy highway, placing drivers and passengers in danger. Those with disabilities found it quite difficult to access the venue. People were prevented from entering the venue despite the fact that maximum capacity had not been reached. The weather was inclement at the time, with severe thunderstorms passing through. Attendees who should have been allowed to enter the venue were left standing in the rain. Despite the severe weather, 669 persons attended this meeting which is indicative of the high level of community concern about an industrial project being constructed on the Oak Ridges Moraine. There were only 2 persons at the meeting who were in favour of the construction of this industrial wind power plant.

The Canadian Wind Energy Association (CANWEA) http://www.canwea.ca/pdf/canwea-communityengagement-report-e-final-web.pdf , guide under the section Public Consultation, recommends the proponent provide channels of access, create regular opportunities for dialogue, hold 'kitchen table' meetings, create a public advisory committee, hold workshops and engage local community and civic leaders. wpd Canada did not follow any of these recommendations

Instead, wpd Canada Corporation elected to hold an 'open house' knowing full well that many people would have many questions. Security teams and armed police officers were to be found at every turn; even when one headed to the restrooms. It was impossible to hear what was being said at

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the Open House - the acoustics were terrible. It was also nearly impossible to be heard. It was impossible to ask all questions one would wish to since there were not enough representatives to handle all the questions. Display boards at a two and a half hour noisy public meeting were of little or no value. Similarly, the expectation that the public would want to, and be able to, sit and watch and hear a video in a crammed-packed and raucous school gym was very short-sighted.

wpd Canada Corporation representatives were quick to pass out many handouts of the ERT ruling and property valuation studies from the United States, but did not have nearly enough of the wpd Canada reports concerning the Sumac Ridge project available to hand out; there were only a very few. The fact that wpd Canada contracted a large security force for the meeting, it was clear that a large public turnout was expected. Considering that the wpd Canada security team logged 669 persons entering the venue, wpd Canada should have anticipated that copies of all reports should have been provided in ample supply and be made available to the public.

A wpd Canada Corporation rep did state that there were no copies of the archaeological study available. There was also no one available to answer questions in reference to the archaeological reports. The archaeological reports indicate that the project area may be rich in ancient aboriginal artifacts and might possibly contain an ossuary. Not having the archaeological reports on hand or someone to answer

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cultural heritage questions might be construed as an insult to the many aboriginal persons who reside in the region. The government of Ontario has placed a great emphasis on engaging First Nations peoples in renewable energy projects. The omission of archaeological reports and someone to answer questions at the June 19th meeting does not honour the commitment of the government to First Nation inhabitants to be included in the consultation process.

Ortech, the company responsible for many of the reports - noise, construction etc. has been replaced by another company, Stantec. The Stantec rep at the public meeting would not, and could not, defend sections of Ortech's studies. Considering the enormity of this project that will see the tallest and largest structures between this region and the city of Toronto, representatives from Ortech should have been present at the Open House to defend their reports and to answer questions from the public.

Attendees found that many of their questions went unanswered. Many questions were referred to multiple representatives since no one seemed to be able to answer questions dealing with technical issues. Several of the wpd Canada reps at the meeting were recent employees and were unable to answer questions about the project. Even more seasoned wpd Canada staff and consultants often could not answer questions and would direct people to other reps who would in turn direct persons to someone else... around and around in circles. Several members of the public noted this Q & A merry-go-round. Others discovered that

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very different answers were given by wpd Canada reps to the same question. There were numerous complaints that due to bad acoustics, responses to questions by wpd Canada Corporation representatives could not be heard.

When it was pointed out to the CEO of wpd Canada Corporation the Open House format with helter-skelter display boards lacking key information, maps positioned in a manner that made no logical continuous sense together with the obvious communication and acoustic problems could have been handled differently and thus better serve the proponent and the public, the response was that another approach would be 'a waste of time'.

Considering that this huge industrial project will affect and influence the landscape, the environment, and residents for decades to come, no effort should be spared on the part of wpd Canada Corporation to consult with the public.

1569 residents have signed a petition calling for a halt to the Sumac Ridge project.

Furthermore, the south side of Hwy 7A to Weston Road (inclusive) and west from Porter Road (both sides) to include Glengarry (both sides) and the subdivisions to the east of Glengarry were canvassed in early June 2012 before the second and final meeting. Only one person was in favour of the Sumac Ridge project, one was unsure, and the rest were strongly opposed. Approximately 100 residences were

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visited during this survey. Another door to door survey was taken during the same time period. Six residents canvassed approximately 500 people residing in the nearby communities in Janetville, Omemee, Ski Hill Road, and the Devil's Elbow area. The result - not one person spoke in support of the Sumac Ridge project.

No support for the Sumac Ridge project could be found in the nearby community of Pontypool.

Ministry of the Environment staff have acknowledged that many letters of complaint and concern were received after the June 19th final public meeting.

During the first week of December 2012, an announcement was made by wpd Canada that it would be signing contracts for REpower MM92 turbines. There was to be an official announcement that an affair was to be held in the morning of December, 17th 2012, at the Royal Fairmont York, Toronto.

From the press release:

“REpower Systems Inc. and wpd Canada, a wholly-owned subsidiary of wpd Europe, will be officially signing a contract for the delivery of 52 MM92 turbines for six wind farms in Ontario. The wind farms have a combined total of 105 MW of installed capacity and will be located in the counties of Simcoe, Middlesex, Prince Edward, Dufferin, Wellington and Kawartha Lakes. As a result of this agreement,

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REpower has committed to a multi-million dollar investment in a manufacturing facility in Southern Ontario in order to meet the 50% domestic content requirement of the Green Energy Act. This investment will result in the creation of 175 sustainable jobs, with the potential to increase as business grows.”

At this time of the announcement, the Sumac Ridge was undergoing a technical review and screening to see if the application submitted to the MOE was in order. The project, at the time of this announcement, was not posted to the EBR, nor had it received final approval.

Across the province, reaction to the wpd press release was

swift. “The implication is that wpd Canada knows the outcome and that further public consultation is irrelevant. This shows contempt for Ontario citizens and undermines trust in government.”

http://wellingtontimes.ca/?p=7739On December 16th, 2012, City of Kawartha Lakes Councillor Heather Stauble sent a letter of concern Ministers Bradley and Bentley

Subject: Wpd Canada/REpower's announcement is premature and should not be

endorsed by the Government. Wpd

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Canada/REpower's announcement is premature, undermines public confidence and should not be endorsed by the Government.This announcement by wpd/REpower is misleading and premature. Statements such as the projects "will be located in".. and "awarded 6 wind energy contracts" are misleading and distressing to those who have been lead to believe that there is an objective review, approval and appeal process in place.Wpd has not received approval for many of these contracts. They have Feed -in -Tariff (FIT) contracts which are conditional on approval by the Ministry of the Environment...very different from approval.Announcements such as this one suggest that these projects have a pre-determined outcome. They undermine the public's confidence in the Government and the Ministry of the Environment's ability to review these projects independently and objectively and the likelihood that their concerns will be heard at any point in the process.The projects in the City of Kawartha Lakes have not even been posted on the Environmental Registry for public comment let alone approved by the Ministry of the Environment. If these projects are approved they may very well be appealed through an

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Environmental Review Tribunal.Bottom line: Announcements suggesting approval where none exists should not be allowed or endorsed by the Government.Heather StaubleCouncillorWard 16City of Kawartha Lakes

The concerns expressed by Councillor Stauble were reinforced in radio interview: http://www.zoomerradio.ca/shows/goldhawk-fights-back/podcast-goldhawk-fights-back/gfb-podcast-heather-stauble/

Due to public pressure and outcry, the wpd Canada REpower Royal York affair was cancelled.

However, public outcry did not seem to faze wpd Canada for long. On February 1st, 2013, an ad appeared in the local paper, The Lindsay Post offering possible employment opportunities with regard to the Sumac Ridge project . At the time of the placement of the ad, the Sumac Ridge project application was listed as being ‘being screened for completeness”. http://www.ene.gov.on.ca/environment/en/subject/renewable_energy/projects/index.htm)

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City of Kawartha Lakes Councillor Heather Stauble send the following letter to Ms Doris Dumais on February 2, 2013:

Doris Dumais

Director

ENVIRONMENTAL APPROVALS ACCESS AND SERVICE INTEGRATION BRANCH Ministry of the Environment 12A Flr, 2 St Clair Ave W Toronto ON Dear Ms. Dumais,

Attached please find a copy of a wpd Canada ad that ran in the Friday, Feb 1, 2013 edition of the Lindsay Post and a wpd Canada/REpower press release by wpd Canada December 10, 2012.

* The wpd Canada ad lists: "Construction Opportunities with Sumac Ridge Wind Project"

* The wpd Canada press release, which was attached to an invitation sent to all members of City of Kawartha Lakes Council on December 10, 2012

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stated: "wpd Canada...will be officially signing a contract for the delivery of 52 MM92 turbines for six wind farms in Ontario. The wind farms ...will be located in the ...Kawartha Lakes" pg 1 and "wpd Canada has been awarded 6 wind energy contracts" p.2

Both the press release and the ad have resulted in phone calls and emails asking for clarification.

Press releases such as the one attached are misleading and suggest that the projects have been approved or worse, that there is a predetermined outcome. They are distressing to the public who are asked to believe that there is an objective review, approval and appeal process in place.

The most recent ad has aggravated existing tension and served to further undermine public confidence in the Ministry of the Environment REA review process.

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wpd Canada has not yet received a Renewable Energy Approval for the Sumac Ridge wind project by the Ministry of the Environment. Approval by the Ministry of the Environment is NOT guaranteed and the full process has yet to take place.

It is inappropriate for proponents to claim or suggest approval, or advertise employment for a project that has not yet been been approved by the Ministry of the Environment. These actions suggest a decision has been made without the appropriate consultation, review and comment period and are not in the public interest.

Your assistance is requested in addressing this issue and ensuring that proponents are advised not to suggest or state their project has been approved until they have in fact been "approved" by the Ministry of the Environment.

Your sincerely,

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Heather Stauble

Councillor

Ward 16

City of Kawartha Lakes

These actions taken on the part of wpd Canada implies that Section 2 of the Green Energy Act that “This Act shall be administered in a manner that promotes community consultation” does not apply nor does O. Reg 359/09 or the Renewal Energy Approvals process apply to this company.

City of Kawartha Lakes council has passed unanimous and near unanimous resolutions of concern about the Sumac Ridge Project and its potential to negatively affect the medical, social and economic health of its citizens as well as the region’s natural heritage. The proponent has not demonstrated that the health and safety of the many residents in the project area and surrounding area will not be affected. On February 5th, 2013, City of Kawartha Lakes council convened a special council meeting with regard to a staff report prepared on the wpd Canada Sumac Ridge project. http://www.city.kawarthalakes.on.ca/city-hall/agendas-and-

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minutes/council-meetings/SCA_Agenda_2013_02_05.pdf

As part of these meeting, deputations from the public were heard. After the deputations, council voted on a motion whether or not to support the recommendation contained in the staff report.

Summarv

This application does not conform to the policies contained in

either the City of Kawartha

Lakes Official Plan or the Oak Ridges Moraine Conservation

Plan. This project also

does comply with the relevant provisions of the Oak Ridges Moraine Zoning By-law or

the Township of Manvers Zoning By-law. The proponent has not

demonstrated that the

proposed development will not negatively impact the integrity and sensitive features of

the Oak Ridges Moraine. ln addition, Council has requested a minimum two (2) km

setback from the base of any turbine to the property line of any sensitive receptor. This

project does not meet that direction. Finally, Council has requested provincial evaluation

criteria to determine the impact of low frequency noise and

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perceptible infrasound

(vibration) originating from industrial wind turbines. There is no provincial evaluation

criteria established, and no study or information addressing this issue in support of this

project. Accordingly, staff recommends that Council not endorse

this project.

City of Kawartha Lakes council voted 15-2 in support of a staff recommendation urging the Province to refuse an application for the Sumac Ridge wind turbine project in Manvers Township: http://www.mykawartha.com/news/article/1576354--council-to-send-strong-message-against-wind-turbine-project ; http://www.thepost.ca/2013/02/07/council-to-send-message-against-wind-project

Premier Wynne has indicated that projects are to be located in willing host communities... this is clearly NOT a willing host community.

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EBR Tech. SR TOC

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Transcript of EBR Tech. SR TOC