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Keith Stelling 7.0 – Requirements for clause 17(2)(c) are not met

7.0 Requirements for clause 17(2)(c) are not met.

The MNR defines overall benefit as:
1. “increasing the number of reproductively-capable individuals of the species living in the wild;
2. “increasing the distribution of the species within its natural range;
3. “increasing the viability or resilience of existing population(s);
4. “bringing about an abatement or reversal of a declining population trend (i.e. reduction of key threats to the species survival);
5. or “increasing the quality or amount of habitat for the species”. (23)

Where there is an increased potential for risk to the species or its habitat or proposed overall benefit actions carry a higher degree of uncertainty, determination of the adequacy of the overall benefit plan will err on the side of caution in favour of affording greater benefits to the species or habitat.

The MNR policy decisions are required to be based upon the principles that the “MNR staff should exercise caution and special concerns for natural values in the face of . . . uncertainty” and that “it is less costly and more effective to anticipate and prevent negative environmental impacts before
undertaking new activities than it is to correct environmental problems after the fact”.

By issuing “Overall Benefit Permits”, it appears that the MNR would be failing to anticipate and prevent the negative environmental impacts outlined above. The MNR would also be failing to recognize the threat of significant reduction or loss of biological diversity associated with the issuing of “Overall Benefit Permits”.

The action agreed to in the permits does not reduce key threats to these endangered species’ survival but rather compounds them.
There is every reason to believe that the increased potential for risk to the species and its habitat or proposed overall benefit actions carry a higher degree of uncertainty. However there is no evidence to show that “determination of the adequacy of the overall benefit plan has erred on the side of caution in favour of affording greater benefits to the species or habitat”.

It is therefore “necessary to require demonstration of the overall benefit before the proposed activity may commence”. However, demonstration to the contrary has already been provided at Wolfe Island. (24)

Therefore:
1. (i) There is no evidence that the mitigation plan has considered the cumulative negative effect of wind turbine development across Ontario in terms of collision mortality and habitat degradation to migrating passerines.
(ii) Nor has it taken into account, the known species sensitivity to habitat degradation and fragmentation—the single most important factor in these species decline.
(iii) The MOE and the MNR have not taken precautionary measures with regard to noise impacts from wind turbine developments on these species. Nor have they considered the masking effect of turbine blades which biologists believe is a threat to wildlife survival.
(iv) The MNR makes no indication that it has considered noise from wind turbines including low frequency noise as part of the cumulative impacts analysis of the wind facility on these species which biologists have observed are sensitive to noise.

2. There is no evidence that the proposed activity meets the legislated requirements for an overall benefit permit as listed by the MNR in its Endangered Species Act Submission Standards for Activity Review and 17(2)(c) Overall Benefit Permits February 2012.

3. There is no evidence that “the determination of the sufficiency of overall benefit actions has involved the consideration of the baseline condition of the species (e.g., numbers, current state, trend, sensitivity to disturbance, life processes) or habitat (e.g., amount, current state, trend,
sensitivity to disturbance and functionality) that would be adversely affected by the activity”.

4. MNR must consider the cumulative effect on the Eastern Meadowlark and the Bobolink of the other “Overall Benefit Permits” granted or being considered across Ontario. (25)

5. The MNR must also consider “the severity, geographic extent, duration and permanency of the potential adverse effects likely to result from the proposed activity”; likewise, the cumulative long term, geographically extensive and permanent effect (at least for 20 years = 6 generations of Bobolinks and Eastern Meadowlarks) of multiple wind developments in Ontario and the Eastern USA as an additional limiting factor for these species.

6. It would appear from the above that, given the sensitivity of this ecological system the proposed overall benefit actions are biologically and ecologically” inappropriate for the species given sensitivity to habitat fragmentation and noise disturbance.

7. In view of the body of peer reviewed scientific knowledge referenced above, there is no evidence that the proposed actions are based on the best available scientific information, another legislative requirement.

8. Given the already documented vulnerability of these species to habitat fragmentation and disturbance, there is no reason to believe that “new knowledge acquired through actions to fill
critical information gaps” has the potential to contribute to an overall benefit plan where the lack of this knowledge is directly limiting the species’ protection and recovery. On the contrary, there is every reason to suggest that the activities allowed by the “Overall Benefit Permit” will directly lead to
the further decline of these species.

9. It has not been demonstrated that the overall benefit actions will improve the ability of the species at risk to carry out their various life processes; rather, in view of the scientific information available, quite the opposite effect is immediately foreseeable.

10. The MNR must recognize that “in some circumstances it may not be possible to achieve an overall benefit for the species”.
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