The MOE and MNR “trust” Proponents Not to Lie. Feel No Need to Check Applications for Accuracy.

Ms. Garcia-Wright, Mr. Boysen,

B821406432Z.1_20131006220008_000_GOB1386DL.3_ContentAfter sitting through several days of the Fairfield vs. MOE Environmental Review Tribunal, I thought it prudent to respond to your last letter regarding the mistakes made by the Niagara Region Wind Corporation in identifying properties.  Your response provides no assurances that the MOE intends to verify these errors and that gives me cause for concern since there may very well be other errors of an even more critical nature in the application.  

At this hearing I learned that the MOE does not verify property line set back distances.  Mr. Vic Schroter testified that the ministry “trusts” the proponent to get it right. We all know that the property line assessment report was missing from the application yet the MOE approved it.  I also learned that the Ministry of Natural Resources does not verify the presence or absence of natural features. Inaccurate sizes of woodlands appeared in the Natural Heritage Report and yet it was approved as well.  Even the ERT chair commented on the training gaps of the person that authored that Natural Heritage Assessment Report.  To quote Mr. Schroter, the proponent “screwed up” and the error was only identified when the public brought it forward.  

What a dichotomy we have here.  The MOE continually states that wind developments are approved to ensure that both people and the environment are protected.  At the same time,the MOE advises that it’s up to proponents to ensure accuracy of applications.  How can you ensure protection if you don’t check the veracity of applications?  As we all know, the public has been identifying errors and bringing them forward to the MOE.  I have to wonder how many established wind developments are harming people and the environment simply becausethe public didn’t catch the errors.  In one case, a proposed turbine location was planned for within the 550m setback and again, it was the public that identified the problem – not the MOE.

 I would like to know what is considered in your technical review because it seems pretty clear that many things are being missed.  

As has previously been reported to you, the NRWC reports contain errors such as measurements taken from the roof a tractor-trailer and the roof of a barn rather than a true point of reception. The application of the NRWC shows that there will be receptors at the maximum permissible 40 dBA and that is based on a very suspect (and I submit, non-compliant) sound power level of 104.8. Given the 40 dBA prediction, if the government is truly interested in protecting health and environment,  it is incumbent upon you to check each and every measurement.  I believe this is warranted given the number of errors that the public has identified with other wind developments and by the fact that the proposed project will subject people to the maximum noise level.   

The government’s track record in approving wind developments is appalling and the public deserves better.  These are not the actions of a government that professes to protect human health and the environment.  How can you make that claim and then “trust” the people who will make millions of dollars from the developments will do it properly?  I demand better and feel that each and every component of the NRWC application must be reviewed by the government agencies in charge.  I believe it has been clearly demonstrated that the proponents cannot be “trusted” to provide complete and accurate reports and at this point, it would appear that the public cannot trust the government agencies in charge of renewable energy approvals to properly verify submissions either.

An early response from both ministries would be appreciated.

Thank you

Bonnie Tuson


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