EBR Comment 30

RE: Environmental Effects Monitoring

This report seems to ignore the effects on people and the community – we are part of the environment


indicates project commissioned January 2014. This is an impossible date given when the report prepared, submitted and potentially approved. All construction assumed to occur in summer / fall may now occur in fall / winter / spring – the environmental impacts of a delayed schedule or potential winter construction is not addressed.

Once again the difference between construction and operations seems to have been lost on the proponent – the EEMP will be maintained by the Project Manager, and duties are assigned to construction – there is no real information on how the EEMP will be carried out during OPERATIONS – this is an operations report isn’t it?


is really a construction related section. There is no information related to design and operation. Again as in previous sections, this report is NOT an operations report or information, it seems to be a regurgitation of Construction information.

The complete lack of operation related emergency and environmental effects monitoring information in this report suggests that the proponent wither ignored the requirements or didn’t understand how to prepare a report/ information. Either wasy the MOE cannot accept this report as sufficient to meet requirements of the Technical Bulleting for Design and Operations Reports. It is completely substandard.

Section 6.2

this section is so deficient it is not possible for an average person to address all the problems- The MOE should get in touch with people who submitted comments and have a working group of committee. It is an overwhelming job and unfair that the public has to waste time (again after 2 crappy draft reports) to review and comment on substandard work. There is minimal mitigation and virtually no contingency planning identified.

Birds. it says there may be impacts. obvious mitigation is to work outside of specific breeding or migration times – that is not identified . neither are contingency plans – these are NA – certainly there are some known contingency measures?

Construction noise – to minimise they say minimise work during non daylight hours – are there times? its daylight to 11pm in summer and only 4pm in winter. Do they understand that clocks have hours and construction could be limited between say 7am and 8 pm?

Land Clearing impacts- they say they will replant trees and allow natural revegetation – that sounds like the do nothing alternative- that isn’t mitigation. They say they will prevent unauthorised access, but a few weeks ago Ms. Mackenzie of Horizon said they were negotiating with the Nordic skiers and ecologic group to install a parking lot on top the mountain. SO which is it, restrict people or side deals while REA is in review?

For archaeological impacts, mitigation is to call agencies and there are no contingency plans- so what will they do- it seems that there must be some idea of whether they will move tower or road locations as a contingency, or will they halt construction and carry out a complete assessment and careful excavation (as was done during highway 11/17 2 laning). What about first nations – will they be contacted if a site is found?

new road construction. They say roads will follow least impactive route and are shortest- but I suggested alternative turbine layout that was shorter and seemed to have less impact- that isn’t acknowledged anywhere in reports. also what is contingency plan if something new is found- will they reroute roads? what are alternatives?

Foundation construction – they ignore the issue of blastomyoisis which was raised during process. will they test for that? Also because they have no idea what kind of foundation or depth (because they haven’t done geotech survey) they will have to design the foundations on the fly. What if conditions are not as expected? will they move towers? will they have to dig/blast deeper? What if they dig or blast into a water area or groundwater pathway? will they need to grout? will they have to excavate additionally? how will they remove water and where will they put it? Will they build rebar cages on site? what are impacts of that?

This item (foundation) does not acknowledge potential for groundwater disturbance or damage to rock cliffs or slopes. That is subject of a separate report, so it is known to be a concern and potential impact- its omission here is inexcusable.

Tower assembly – does not acknowledge the mitigation to time work in day or season to minimise impacts on birds and wildlife or human activity. What about contingency plans – will adjusting of schedule be done if impacts are identified? that is not noted.

Water taking- it indicates that groundwater table is 10m below ground in areas of construction. How do they know that? there have been no studies or tests and the rea reports have no information in that regard. This statement in the rea seems to be pure conjecture and wishful thinking. Also, they say that there will be no impacts on groundwater because the water table is supposedly 10m below ground – but their own EXP report discusses blasting and groundwater, and the LRCA report (which they do not acknowledge) indicates this area is a sensitive and recharge groundwater area. There may be groundwater impacts, the foundations may well be more than 10 metres deep, the groundwater may be higher, and blasting may impact groundwater. How will they mitigate, and what are contingency plans?

There are no measures that can be taken if the mountain rock groundwater flow network is altered. It will be permanently and irreparably damaged- the MOE must take this issue seriously and employ precautionary principle for these are enormous structures (over 10 stories tall) with giant blades, significant side forces, and deep large footings (over 16 metres in diameter and likely10 to 25 metres deep).

Spills (oils etc) – there are no contingency measures indicated. In seems as if a contingency would be to initiate a cleanup, and have cleanup materials on site. this is not identified.

Access road grading – the access road will climb 250 metres at least in less than 1500 metres. This is at least a 1:6 slope – this is extremely steep and will result in significant ongoing erosion (as well as problems for large equipment to access site and cause further erosion). Nowhere in any of the reports is this issue of road grade identified or acknowledged. Certainly this will be a fundamental problem for the project construction as the large equipment will need to be pulled/ pushed up the hill. Obvious mitigation is to have routed the road in a manner that keeps grades lower, Contingency measures for erosion could be to pave the road up. This issue will be exacerbated by the cut and fill required because the road is on a steep side slope, where runoff from the side will be high, and the downhill of the side slope will be steep and highly erodible. This inattention to a fundamental issue in construction is likely a result of poor consultation with public, and with inattention to site specifics and features. Interesting that I was told by developer at open house that the road up the hill was a significant cost – they know its a problem- so why isn’t it in reports?

bird and bat impacts (operational) there are no contingency measures identified – but what will be done if there is a problem – the developer stated at an open house that turbines would be shut down during bird migration but that is not in reports. also, permanent shutdown of turbines is possible. also, what turbines will be built first? if there is a problem with first 8, then maybe a contingency is to consider alternative locations for next 8.

moose impacts- it says project no closer. than 4km to moose feeding areas.

as if there are no other impacts other than feeding areas- there is life and birth habitat. what about increasing predation? what about increased people in area keeping moose away? will this disrupt entire area? There are no mitigation measures identified or contingency plans.

.Noise -it says turbines move farther away from people / homes. but that is not entirely correct. Turbines were actually moved CLOSER to homes , then a few moved back. Overall they were moved closer to people/ homes. There are 20,000 acres and it was possible to move turbines farther back – in fact the developer has plans with city to build 24 more turbines and has zones/ height areas identified (part of new contract and city council meeting info). so obvious mitigation nis to move turbines back to future sites, and then if ok build turbines closer in future phases. Contingency measures are night time noise operation, monitoring noise and replacing blades once they are worn/noisy, and shutting down turbines dependant on wind and direction. The developer has omitted information here that was subject of public issues and meetings. It presents only part of the story. The various layouts and tower moves (and even the present specific locations) is not clearly identified in reports anywhere. Exactly what were the various layouts at various times? How and why did they change? With the various layouts the numbering stayed the same, so tower 1 in layout 2008 is not tower 1 in layout 2009 is not tower 1 in layout 2012 and so on. Tower numbers for specific layouts should have been unique to avoid confusion.

Noise modelling was not conducted using worst case scenario. The model was inappropriate for this terrain, and the rock faces and steep slopes are not modelled. Neither are the winter snow and ice surfaces. The location of receptor AX is not in center of property as per Tech Bulletin requirement. What if noise isn’t as modelled? what will be done? will they shut down turbines? will they do modelling or measurement during various wind atmospheric conditions? none of this is answered.

land use and economy – it indicates 3 jobs will be created for lifetime of project. What 3? Horizon vice president, horizon public relations, and a person to plow roads? regardless, job or two created will be more than offset by the impacts on the norwester hotel and the local economy. The loss of that land as potential other better uses is not addressed. Also, Horizon is now actively negotiating with some interest groups to get special access (ski club and ecological group). This is outside and in conflict with REA and reports and what has been stated publicly.

Tourism – its says that the project will minimise noise and visual effects – but that is not true – the project is located AS CLOSE as possible to people and as possible on the 20,000 acre site. While it may be the developers prerogative to put towers wherever the heck he wants- why is it ok to put an untruth in the REA? tower locations do not minimise noise and visual impacts – they MAXIMISE them (within regulatory limits)

Property values – says that numerous studies show that turbines do not lower property values. This is bunk – many studies and common sense says turbines lower property values especially where the natural beauty of the area is a big part of property value. The REA should not allow for only one side to be provided it should be accurate, entirely true, and balanced – this report is none of those

Aeronautical obstruction – the area is a place where MNR planes gather water for water bombers, and MNR does moose habitat training from helicopters. This I not acknowledged. The towers will be a problem. the flights to thunder bay airport regularly travel over this area as do small planes. Sooner or later there will be an accident in bad weather and MOE will be held to account for approving these absurd locations

shadow flicker – its says performance objective is to minimise shadow flicker – but turbines are located as close to people as possible – a mitigation strategy would be to move towers slightly back- contingency plans could include shutting down turbines during specific shadow flicker times for specific towers.

Section 6.3

once again construction activities are included in a deign and operations report – I suppose better in the wrong place than nowhere.

6.3 to 6.6

It is hoped that MOE/ MNR etc will critically review these sections in light of concerns raised, and the lack of mitigation and contingency planning identified. It seems to be a matter of the proponent putting in lots of text , but avoiding the significant issues and easy mitigation – that easy mitigation is relocating towers within or without site .


interesting to note that tornadoes are expected to have no impact on the turbines- are these built to such standard? this seems to be absurd

hail can damage blades- the action that should be taken is blade replacement or at least monitor for additional noise because worn or damaged blades increase noise, and some receptors are just beyond limits of noise 40dB – any small increase will result in noise above guidelines – will turbines then be shut down?.

Lightning- the mitigation for potential fire in nacelle is lightning protection. HOW does lightning protection mitigate against fire? once a fire starts is there a fire suppression system? how will fire be put out? will fire spread to neighbouring communities? MOE will be responsible for results of fire spreading if they do not deal with this issue.

Forest fire – steel and concrete are not flammable, but other parts may be damaged. What kind of moron wrote this sections? steel and concrete can be damaged by fire. The mitigation is simply a statement of possible fire impacts- real mitigation would be fire suppression systems in place on ground and in towers, a fire response plan in place with specific water bomber protocol (if they will even fly in the area with towers), fire breaks in place, fire responders available with equipment. Fire is a serious issue in the north – one that seems to have been glossed over – perhaps they had some new grad write this section, who doesn’t comprehend the seriousness of a forest fire adjacent to a community – think slave lake Alberta.

6.8.2 Past present and future projects

this section ignores identifying the 3 further projects horizon has applied to OPA for. These are 1,2 and 4 of the list of priority projects, identified as shovel ready by OPA

These projects have been the subject of questions and concerns at open houses but are not identified here . This omission is unacceptable given the high level of interest from the community. These projects are part of the City agreement with horizon and are identified on the secret contract

6.9 key contact list

this list is once again a half hearted effort. RCMP is not contacted via 911, and the purpose of placing RCMP on key contact list is unclear

neebing fire brigade is listed as 911, but earlier thunder bay fire is identified as contact.

there is no such facility as Thunder Bay Hospital – it is Thunder Bay Regional Health Sciences Centre.

7. Qualifications and Limitations

Good to see that now the Ministry can rely on these reports, unfortunately the public apparently cannot.

If the public cannot rely on the reports, and Horizon, Ince will not stand behind their work, what is the point in wasting time reviewing?

Post Construction followup DRAFT report

Because this report is a draft, no serious review was done – this is supposed to be a final report for review as part of REA – drafts are not part of REA


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