EBR Comment 42

I am very concerned about the long term, likely permanent, negative impacts of the proposed Horizon Wind Park development on the Nor’Wester Mountain Range, especially on Mount Johnson. I am pleased to add my comments to the Environmental review.
I have hiked into the Nor’Westers for decades, just recently up Mount McRae, and have always appreciated the incredible geological formations. It is a paradox that the Nor’Westers are both ancient and fragile, as one can note from the incredible rock faces resulting from the deep cleavages, and the massive rocks along the bases of these cliffs, accumulated over millennia. My comments will be specific to Horizon’s Project Description Report of October 19, 2012 on their Big Thunder Wind Park project:
In section 2.2.1 Wind Turbine Technologies, paragraph 2 on page 5, they refer to the foundations, with no detail beyond a basic requirement for poured concrete. “The foundation specifications will depend on the results of a geotechnical investigation of the proposed wind farm location”. Where are the details of the geotechnical investigation? Moreover, given the geology, reports will have to be site specific on each proposed foundation. When one is putting in septic fields, separate reports on the soil of each is required, so how can a ‘blanket’ study possibly suffice?

Section 2.2.3 refers to new, unpaved roads. Again, there is no way this could proceed without geotechnical study, especially seismic, given the geology of the area, never mind the major considerations based on grade steepness. Later in Section 2.3.2 – Construction, Building of Construction Roads, on page 7, it refers to removal of topsoil. I suggest given that route, topsoil will be the least of the challenges. The fact that it refers to a 2 month construction period, with no reference to the blasting and other requirements, demonstrates a complete lack of understanding of the complexity, and such an omission must be on purpose, although I cannot fathom why.

Later in that Section – 2.3.2.4, there is a statement regarding the construction of the foundations, again merely referring to poured concrete and reinforcing steel, and that a ‘backhoe to excavate the foundation sites and wooden forms will be used in the construction process’. Having been through the region, I am at a loss to figure out the purpose of the backhoe, unless it is for some minor site prep. In the Mount Forest residential subdivision, a backhoe will be severely challenged in dealing with the Canadian Shield outcroppings on many of the lots; on top of the mountains themselves, it is again must be a purposeful minimizing of reality. The section then notes “In some cases, blasting may be necessary to excavate the foundation site; this operation will be at the discretion of construction site manager, and will be based on detailed geotechnical analyses.” The blasting will not be in some, but in all cases, leading to major consequences from the impacts of fracturing, and cannot be dismissed in this cavalier fashion. Geotechnical analysis, specific to the depths of each proposed foundation, given the weight and height of the structures proposed, must be undertaken. Indeed, the results may necessitate the search for alternative locations for towers. This will be beyond the ‘discretion of the construction site manager’, as it must be addressed rigorously prior to any commencement of the project construction, including the ‘access roads’.

Section 3.1 Regional Geography and Topography, provides a short paragraph as follows: “The project surface area is largely covered by Glacial Till (chiefly ground moraine and includes recent talus) and the soil is mostly stony clay and stony loam. There are small areas of bedrock outcrop, mostly along areas of steep terrain. There are some very small patches of muck and peat in some of the lower lying areas with soil that is mainly organic. There are also some small patches of glacial outwash (gravelly sand and silt) with soil that is primarily gravelly, fine and sandy loam (GSC 1929).” I suggest that this is not a reflection at all of the area under consideration. The ‘stony clay and stony loam’ is not found much at the top of the range, which is where this development is planned to be. And to note ‘small areas of bedrock outcrop’, the opposite of the geology in question, indicates the need for a detailed analysis of the geology on the specific sites for the towers, not lifting a paragraph from a previous overview of the region’s terrain.

Finally, these major shortcomings are front and centre in Section 5, the Description of Environmental Effects. While there is a section on heritage and archeological, it cannot be an oversight that there is no section 5.12 – Geological Impacts and Effects. This is where the potentially irreparable damage to the geology, from blasting and fracturing, including to the nearby ski hill and other users, must be thoroughly considered and risk assessment undertaken. This is of critical importance, and must be included before any proper review could be conducted.

When I attended the Public Open House May 18, 2011 at the Fort William Country Club, the lack of engineering study and analysis on the proposed road development and tower foundations was a great concern to me, and I expressed this to several of the consultants hired to provide work to Horizon. From my reading of their October 19, 2012 Report, not only has this information not been addressed, but its importance and the potentially irreparable damage that could result has been further minimized. To risk such huge, negative, permanent consequences for what at best is minimal benefit for a few people for a few years would be unconscionable.

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