We need your help. After sorting through the entrails of the NRWC proposal for the last eight months the Ministry of the Environment has decided that the documents have all been submitted. The West Lincoln municipal council and concerned citizens in the community have spent thousands of hours pouring over the same documents and have sent hundreds of letters to the MOE drawing attention to errors, omissions, inconsistent noise sound levels, etc. …. the list goes on. The NRWC proposal has been posted for a 60 day public review and comment period starting December 03, 2013.
As members of the community we now have an opportunity to submit questions or comments until February 01, 2014. Relevant comments received as part of the public participation process for this proposal will be considered by the Ministry of the Environment prior to sending the proposal for technical review. All comments on this proposal must include the EBR Registry Number: 012-0613 And must be directed to:
Sarah Raetsen, Senior Program Support Coordinator Ministry of the Environment Operations Division Environmental Approvals Branch 2 St. Clair Avenue West Floor 12A Toronto Ontario M4V 1L5 Phone: (416) 326-6089 Fax: (416) 314-8452 Toll Free Phone: (800) 461-6290
You can make comments on line by accessing the Environmental Review Board ERB site. Simply copy the following address into your browser and the on line comment section is in the lower right hand section. http://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do? noticeId=MTIxMTM5&statusId=MT gxMzM1&language=en You are encouraged to submit comments, questions and concerns frequently. Suggestions:
First I would like to register my extreme opposition to the NRW Industrial wind turbine project. We are all aware that Industrial Wind Turbines produce mechanical noise, acoustical noise, low frequency noise, infrasound, in addition to electro magnetic radiation, “dirty electricity” or transient voltage, light flicker, vibration as well as electricity. Any of which can create problems for the neighboring recipients. With all these additional “by products” of wind energy it is reasonable we would want an independent third party scientific investigation to determine if any health and safety issues exist for people in communities that are forced to host Industrial wind turbines. According to the 2013 Auditor General’s Report p.316 “the report issued by Ontario’s Chief Medical Officer of Health citing no linkage between wind turbine noise and adverse health effects was NOT OBJECTIVE!” Please consider the work of Carmen Krogh – Open Submission: Risk of Harm to Children and Industrial Wind Turbines – Health and Social-economic Impacts in Canada Submitted by Carmen Krogh, BScPharm May 15, 2013 Children living in homes exposed to the noise and other emissions of industrial wind turbines are reported to suffer adverse health effects and may be at risk of mental and / or physical adverse health effects similar to that of their parents. Vigilance and long term surveillance systems regarding risks and adverse effects related to children are lacking. Such programs are necessary to evaluate the risks to children who have been exposed to industrial wind turbines. This evaluation should take place before proceeding with additional approvals. Canada has committed to four general principles: “… non-discrimination, the best interests of the child, the right to life, survival and development, and respect for the views of the child”. An inequity appears to violate the principle that all children are to be treated equally i.e. that of “non-discrimination”. Rural children are at risk of harm when wind energy facilities are sited in close proximity to family homes and many parents do not consent to this risk. As the result of the anticipated proliferation in the future of industrial wind turbine facilities in Canada, it is expected more Canadians, including children in general, and those with special needs such as autism, epilepsy, migraine and those with respiratory disorders will be at risk of harm. Risk of learning/cognitive difficulties is a risk. Action by Health Canada would support its “Mission and Vision”” as the responsible authority to help “people of Canada maintain and improve their health” and its “Objectives” to “prevent and reduce risks to individual health and the overall environment”. The Policy Interpretation Network on Children’s Health and Environment comments on the use of the precautionary principle i.e. prevention: Policies that may protect children’s health or may minimise irreversible health effects should be implemented, and policies or measures should be applied based on the precautionary principle, in accordance with the Declaration of the WHO Fourth Ministerial Conference on Environment and Health in Budapest in 2004. Regarding precaution, the World Health Organization states: “…where there is a reasonable possibility that public health will be damaged, action should be taken to protect public health without awaiting full scientific proof.” There is an opportunity for Health Canada to invoke the precautionary principle. Until guidelines are established that protect human health and social-economic viability , no further development of wind energy facilities should occur and existing sites reporting health issues should be resolved to the satisfaction of the those reporting health impairment or risk factors.
2. The MOE’s Renewable Energy Approval (REA) regulations, recommendations and requirements are inadequate for today’s wind turbines and were hastily conceived but, even worse, they are not rigorously and rigidly applied. The 3 MW Enercon industrial wind turbines proposed by NRWC are the largest IWT’s installed onshore in North America. These 60 story industrial installations require extensive “mitigation” strategies and this proposal should be rejected. These industrial wind turbines are too big, too many and too close to schools and rural homes where we live, work and play.
3. Where are your Health studies? Where is your procedural outline for how members of the community record impacts to their health caused by the Industrial wind turbines you propose to erect in West Lincoln? Where is the mitigation policy for health impacts?
4. How will the maximum 40 decibel noise pollution level be monitored? What is the mitigation procedure when the noise level is above 40 decibels? Who will have the authority to shut the Industrial wind turbines down when the noise pollution level is above the 40 decibels? Under what conditions will the municipality have the authority to shut the Industrial wind turbines down?
5. The installation of Industrial wind turbines is an Industrial use of agricultural land. What is the classification of the agricultural farm land being taken out of production for each specific Industrial wind turbine? How many acres of farm land will be removed from agricultural production for the installation of each turbine? How many acres of farm land will be removed from agricultural production for the service roads required for each turbine?
6. How many ground water wells are within 1 km of each turbine? 2 km? 5 km? Where is the mitigation plan if the ground water wells become contaminated or the flow decreases or ceases? How will you guarantee safe drinking water for the people and the animals in this agricultural community?
7. What is the depth of the footings required to erect a 600 foot Industrial wind turbine? Where is your study of the underground topography at each Industrial wind turbine site to the depth of the footings?
8. Members of the community are continually reassured that property values will not be affected by this initiative. Denmark compensates people if the property devaluation is more than 1%. Why has no compensation package been developed for rural people who experience loss of property value?
9. Where are your commitments to meet 100% decommissioning costs and restoration of our farmlands? What financial guarantee is provided for the decommissioning of these Industrial wind turbines or will the members of West Lincoln and ultimately the Province of Ontario be left responsible for financing the clean up? (Just like the PCB fiasco West Lincoln already experienced in the 1980’s.)
10. Where are your Emergency Plans for fire in the nacelle? Who will pay for the equipment needed for such an emergency? What additional insurance will be provided to neighboring receptors whose person, property and livestock may be affected by fire, ice throw, blade throw, contamination from oil spills, electro-magnetic radiation, transient voltage, etc.
11. Bats are extremely important to agriculture and it is irresponsible of you to locate an Industrial wind turbine within two km of a bat colony. Bats are being killed by Barotrauma, as in the change of air pressure behind the turbine blades. According to NASA and a Danish Study this change of pressure requires 2000 meters to return to ambient conditions so your mitigation if more than 10 bats are killed per turbine per year is an insult and instead you will reduce or eliminate this colony. How will you compensate neighbouring farmers who will be using more chemicals to control insects that the bats would have eliminated?
The BATS ARE GREEN not your Industrial wind turbine that produces mechanical noise, acoustical noise, low frequency noise, infrasound, electro magnetic radiation, “dirty electricity” or transient voltage, light flicker, vibration as well as decreasing property values for everyone in the view shed! 12. more to follow.
PS As I sit here in my snowsuit, freezing in the dark, maybe coal will be a good gift this Christmas.