THUNDER BAY – There are many problems with the evidence that Horizon Wind Inc. provides with respect to Environmental impact assessment of the Valued Ecosystems particularly regarding the rare and endangered species of plants and animals of the proposed site and safety of birds and bats in wind turbine area. I will mention only a few as I have limited time to review the lengthy documents. I am sure a more in-depth review of the report and the appendices will reveal many more shortcomings.
1. I am simply astonished seeing that for such a proposed development project in an environmentally sensitive area no proper ecological survey was done following any scientific method to assess the potential environmental impacts of this project. I am completely surprised to read that their method of environmental impact assessment of the Valued Ecosystems was based on “informed professional judgment of the assessment team”. It is absolutely unacceptable as a valid ecological methodology. Clearly they did not take the matter with any seriousness. They state that they are in consultation with the Ontario Ministry of Natural Resources (OMNR) on the matter of rare and endangered species in the area. How would they know what species would be lost if they did not conduct any ecological survey in the area whatsoever and what advice the OMNR can give them on that matter? If their impact assessment is invalid then by definition their mitigation measures are also invalid and therefore, unacceptable. Horizon’s voluminous reports lack relevant factual information. Instead it is replete with wordy description of poorly related and unrelated matters.
2. The study Horizon cites in their fact sheets, did not consider the increased turbine rotor size. The Horizon Wind Inc. will have to use turbines with newer higher diameter rotors to attain their projected power generation of 30 MW. This will most likely result in increased bird fatalities. These newer larger turbines were not utilized in the study they cited (see Erickson et al. (2005).
3. The wind turbine sites used in this study were much better suited in a place where it was deemed “of little use by birds” see (http://www.rnp.org/projects/stateline.html), which in the case of the Nor’Wester Mountains is inappropriate as the Nor’Wester site is near large and small water bodies and will likely cause greater mortality to waterfowl and shorebirds. It is also a peregrine falcon heritage site and a bird and bat sanctuary (see their own report.
4. The bar graphs cited in the Horizon Inc’s. fact sheets are misleading and incorrect as the methods employed to generate these histograms are unclear and flawed for the following reasons:
a. First, the technical report where they took the data from is not peer-reviewed. This is an USDA Internal Technical Report. Most of the data in the table of that report Horizon used to generate the graphs presented in their fact sheets are extrapolated rather than primary data collected by the authors of the report. The number of birds killed by cats is a pure speculation followed up by no hard evidence whatsoever. It simply is a poorly extrapolated estimate lacking the rigor of a proper research methodology that is expected in a peer-reviewed publication. In the case of the bird fatalities caused by cars, it is a similar situation based on a poorly extrapolated estimate, from an outdated, irrelevant UK study. This is NOT applicable to Canadian scenarios as the UK has a much higher population density than Canada specially Thunder Bay (more cars in the UK than Thunder Bay for similar length of road) and the former would easily have a much higher number of bird fatalities per mile of road than later. The turbines in that study were in industrial area rather than in natural area like Nor’Wester.
b. Secondly, given the size and speed of the wind turbine blades, the relatively minute size of most birds and bats, it is likely that the bulk of fatalities caused by wind turbines would end up being farther away from the wind turbine site.
c. Thirdly, given the multitude of flight paths each individual bird could take toward the turbine, the individual bird carcasses are likely to be scattered over great distances. None of these potential problems are mentioned or addressed in this study that they cited. As a result, the bulk of the fatalities caused by the wind turbines remained uncounted for. In most of the other situations that cause bird fatalities e.g. buildings, the bird is the only moving object greatly minimizing the distance between the landing site of the carcass and the building site, allowing a greater accuracy of counting all the dead carcasses. This study that Horizon Wind Inc. gives as evidence is badly flawed and lacks scientific rigor.
References
Erickson, W., G. Johnson, et al. (2005). A summary and comparison of bird mortality from anthropogenic causes with an emphasis on collisions. USDA Forest Service Gen. Tech. Rep. PSW-GTR-191.
Sincerely,
Azim Mallik, Ph.D., F.L.S.
Professor of Ecology & LU Distinguished Researcher
Past President, International Allelopathy Society
Treasurer& Executive Board Member, INTECOL (International Association for Ecology)
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