Comments Re: Amherst Island Energy Project – Keith Stelling – Part 1

July 26, 2013

Comments Re: EBR Registry Number: 011-9446
Amherst Island Wind Energy Project
Permit for activities with conditions to achieve overall benefit to the species –
ESA s.17(2)(c) Ministry of Natural Resources (MNR)
Submitted by Keith Stelling

1.0 Issuing an Overall Benefit Permit for Amherst Island is inconsistent with the mandate of the MNR. …………… 3
1.1 Summary …. 3
2.0 Economic, social, and scientific considerations…. 4
2.1 Economic cost of wind turbines …. 4
2.2 The fallacy of CO2 savings ….. 5
2.3 Social issues ….. 7
3.0 Failure to consider body of scientific research ….. 9
3.1 Numbers decline when habitat is fragmented or reduced…. 10
3.2 Reproductive success is lower in small habitat fragments .10
3.3 Bobolink sensitivities to area, habitat size, edge habitat and nest predation ….. 10
4.0 Industrial wind turbines are a new, cumulative, limiting factor ….. 11
4.1 The ecosystem disturbance during construction has not been considered ….. 14
4.2 Bird and bat abundance declines at wind turbine sites … 15
4.3 Noise from wind turbines is detrimental to survival of wildlife …. 16
5.0 Mitigation ….. 18
5.1 Can industry self-monitoring be considered unbiased? …. 19
6.0 The cumulative result of “Overall Benefit Permits” ….. 21
7.0 Requirements for clause 17(2)(c) are not met ….. 22
8.0 Illegal contravention of existing federal and provincial legislation ….. 26
9.0 Conclusion ….. 26
References ….. 27

1.0 Issuing an Overall Benefit Permit for Amherst Island is inconsistent with the mandate of the MNR. It is incumbent upon the Ministry of Natural Resources under its mandate as confirmed in its Statement of Environmental Values, (Environmental Bill of Rights, (1994)) to protect and conserve “ecologically sensitive areas or processes”.
1.1 Summary
Amherst Island is an example of the type of critical habitat, and increasingly rare biological and ecological diversity that is the Ministry’s duty to protect. It is a migratory staging area, a recognized IBA (Important Bird Area) and its rich island ecological system contains three provincially significant wetlands and habitat for 34 species at risk. Many bird species protected by the federal Migratory Birds Convention Act and the Ontario Endangered Species Act (ESA) use the entirety of the island. The development has the potential to adversely affect Bobolink, Eastern Meadowlark and Eastern Whippoor-will habitat (among others). All three are experiencing critical population declines and have been listed by COSEWIC (Committee on the Status of Endangered Wildlife in Canada) as “threatened.”

This presentation shows why issuing an “Overall Benefit Permit” to allow a 75-megawatt wind power facility to be constructed on Amherst Island would be a contravention of the ministry’s mandate to protect and conserve “ecologically sensitive areas or processes”. Such a decision would also have to be made in wilful blindness of existing scientific evidence (set forth below) as to the devastation such a development would cause to the three species facing critical declines. Since the MNR is committed to using up-to-date scientific evidence in making its decisions, this would be a further dereliction of duty. Finally, the issuing of an Overall Benefit Permit to allow the destruction of habitat of endangered species would contravene existing federal and provincial legislation and could not be justified on the basis of the incomplete and ineffective mitigation plan that has been presented.

Leave a Reply

Your email address will not be published. Required fields are marked *