THUNDER BAY – This is the text of a letter to the Ministry of the Environment from the Nor’Wester Mountain Escarpment Protection Committee:
Ms. Doris Dumais
Director, Approvals Program
Environmental Assessment and Audits Branch
Ministry of the Environment
12th Floor, 2 St. Clair Ave West
Toronto, ON M4V 1L5
Big Thunder Wind Park– New project should follow new process
Dear Ms Dumais:
We write you again out of frustration. Frustration with this project, and with this proponent. We have not received any response from this to our numerous and specific concerns, inquiries and offers to meet. We now understand this proponent is presenting a brand new project as if it were a simple minor revision. If that happens, then surely the REA process is broken. This project must consult as a new project, and start consultation anew.
The City of Thunder Bay City Council has recently voted to reach a settlement with Horizon Wind regarding the $126 million lawsuit. That settlement includes a number of provisions that dramatically alter this project, and allow significant alterations in the future – making this a new project. We are concerned that this new project will proceed in the approvals process without allowing for proper and reasonable public consultation.
The significant changes that we understand may be proposed are as follows;
1. Number of towers– we don’t know if it will be 8, 16, 18, or 52 towers
2. Locations of towers– some towers are relocated kilometers, and all towers can be moved 200 meters in any direction at any time under new Thunder Bay/Horizon agreement
3. Significantly greater tower heights, increased from 141m to 186m, and some identified as unlimited height restriction
4. New access road location– Loch Lomond Road access will impact people that may not have been concerned or contacted to date
5. Power level of turbines (and noise levels), some turbines 33% greater power- this would mean new noise studies and impacts
6. New project total size – 8 MW, or 16.5 MW or 27 MW or 36 MW, or 79 MW as identified to the City of Thunder Bay and its 100,000 citizens
7. Unexplained transmission connections for the various project proposals
Even one of the changes noted above could radically change the project and impacts. More than one change is assuredly significant and should require the proponent to step back in the process.
The latest project changes that we understand are proposed are not made in reaction to community concerns as far as we can discern – these are changes made solely for the benefit of the proponent and to accommodate their own poor planning and design. On this we ask you to not rely on the proponents or our word alone, but to investigate the timing and nature of changes, and the underlying reasons.
The poor planning and lack of open meaningful consultation should not provide a proponent with additional opportunities to alter its project solely for its benefit. Project developers should not be allowed to significantly alter projects at late stages- this is seen by the public as developers ‘gaming’ the system and using their close relationship with the provincial REFO to the developers’ benefit and publics detriment. The public should not suffer in any way for a proponent’s ineptitude or inability to follow the letter and intent of the REA process
It is a new project, new in scale, new in scope and new in impacts.
We ask that the MOE require this proponent to start its REA process . This is a simple and straightforward process, where all notice periods apply as normally required.
1. Issue the Project Description Reports (PDR) identifying the project with detailed information.
2. Hold PDR open houses. This will provide information to the proponent and allow the project to be revised if necessary before draft REA reports are written.
3. Issue draft REA reports with any changes to address information and concerns raised.
4. Hold draft REA report open houses. This will allow the public to see the details of the project, and any changes from the PDR. The draft REA reports must meet the MOE draft Technical Bulletins (as the proponent has committed).
5. Then follow remainder of REA process – application submission, posting, public comment, MOE review, MOE decision.
While the proponent may prefer to jump to the final stage of the consultation process it is important that the proper process be followed for this new project. This is the process that should have been followed from the beginning, but was not. With its transition project status, the proponent chose to not have PDR open houses, and that decision combined with its unwillingness to consult meaningfully, has resulted in the present situation.
If you allow the proponent to proceed as if this new project is only a minor revision to the existing project, the public good will suffer. People will not have sufficient time or opportunity to learn about and understand this new project. Many people who learned of the previously presented project will not be aware of this new project and will assume it is essentially unchanged.
Mr. J. Beals Mr. M. Payne
Co Chair Co Chair
Nor’wester Mountain Escarpment Protection Committee
cc D. McGuinty, Premier B. Mauro, MPP M. Gravelle, MPP
T. Hudak, MPP
A. Horwath, MPP H. Hampton, MPP
K. Hobbs, Mayor, City of Thunder Bay
Thunder Bay City Councilors (12)