Shannon McNeill, Senior Project Evaluator
Ministry of the Environment
Environmental Approvals Branch
2 St. Clair Avenue West Floor 12A
Toronto Ontario M4L 1L5
Re: EBR Registry Number: 011-5239 , Ministry Reference Number:2718-8GWQJP
Dear Ms. McNeill:
I strongly oppose the proposal by Gilead Power to construct a Class 4 Wind Facility at Ostrander Point in Prince Edward County.
My opposition to this project is based primarily, but not only, upon the project’s certain destructive impact upon the birds and animals that now inhabit the area, and on its indiscriminate slaughter of, or removal of necessities of life from, the thousands of birds that annually migrate through what is officially designated as an Important Bird Area.
Two of these creatures are listed as Threatened Species on the MNR Species at Risk website. That website shows the following risk factors for each of these:
Blanding’s Turtles are slow breeders – they don’t start
to lay eggs until they are in their teens or twenties –
so adult deaths of breeding age adults can have
major impacts on the species. (my emphasis)
Although there is some uncertainty surrounding the
decline of the Whip-poor-will, the main threat to the
species is likely habitat loss and degradation. (my emphasis)
I have noted in your Environmental Registry posting that the Proponent proposes a number of measures to offset or ameliorate the threats to two threatened resident species. I challenge the Proponent’s claim that these measures will bring “overall benefit” to both species. Furthermore, I see no measures that would stop birds from migrating, or that would cause them to detour around the project.
For the Blandings Turtle and the Whip-poor-will, the Proponent claims that an “overall benefit” to both species would be achieved through five activities:
1. The Proponent proposes to acquire and manage a property outside the project area for the habitat preservation, rehabilitation and/or improvement of both Blanding’s turtle and Whip-poor-will. But how can Man, better than Nature, select an area equal or better than the Ostrander Point area that Nature has already decided is best for these creatures? And how can Man convince Nature’s natural creatures to relocate?
2. The Proponent proposes publication of Whip-poor-will survey methodology and the results of pre-construction monitoring, but how would this affect the Whip-poor-will’s natural behaviour? Will the poor Whip-poor-wills learn anything useful from the survey results? Is this information not already published? If not, why not?
3. The Proponent proposes financial support to fund graduate research related to Whip-poor-will for one of several possible subjects of interest, but the Proponent provides no evidence that this research will bring potential benefits to the creatures whose habitat the Proponent will destroy or degrade.
4. The proponent proposes “value added” monitoring for multiple years on both the newly acquired property, as well as the windpower site, to gather new information and knowledge about Blanding’s Turtles and how they use their habitat. But this assumes that this species can be convinced to relocate to the newly acquired property, and the Proponent provides no evidence that such relocation of resident species can be achieved. Furthermore, how can such “value added” monitoring possibly benefit those creatures that are already gone from the site because their homes have been destroyed or degraded by the Proponent?
5. Other “value added” monitoring efforts are being considered by Gilead (but these are not specified even though this proposal has been in planning for many months).
The Senate of Canada has unanimously supported a resolution for a moratorium on wind power developments for this Important Bird Area until more is known about their impact on migrating wildlife. Ted Chesky, Manager of Bird Conservation Programs, Nature Canada advises that “Wind Turbines should not be built in Important Bird areas”. Many residents of Prince Edward County are concerned that large Wind Power projects will be deleterious not only to Nature’s creatures, but also to the health and livelihood of our local citizenry. Surely, MNR and MOE could better deploy their resources to redirect wind power Proponents to areas of our Province in which Industrial Wind Turbines present a much lesser threat to the health and livelihood of both animal and human species.
Why bother having a Ministry of Environment if it and MNR will not respect and enforce their own measures to protect endangered species, human health, and Important Bird Areas?
James A. McPherson
Copy to local media and Todd Smith, MPP