Wednesday, October 10, 2012

December 12, 2007 ~ RE: Wolfe Island Wind Project –Environmental Review Report

December 12, 2007


Mr. Robert Miller
c/o Canadian Hydro Developers Inc.
190 Collingwood Street
Kingston, Ontario K7L 3X8

RE: Wolfe Island Wind Project –Environmental Review Report

Dear Mr. Miller:

I am a retired biologist from the New York State Department of Environmental Conservation and a 38-year resident of Cape Vincent. During the time I have lived and worked in Cape Vincent, I have developed an affection and attachment to Wolfe Island and its people. For that reason, I am very interested in how your proposed wind power project will ultimately affect the island and the community. I reviewed the Wolfe Island Wind Project Environmental Review Report prepared by Stantec, Inc., and hope that you consider some of my comments and suggestions. I assumed you would welcome my comments, since copies of the ERR report were made available at the Cape Vincent Village office.

My focus is on the section of the report that deals with waterfowl resources of Wolfe Island. The report provides an adequate description of the various avian resources that are common to Wolfe Island and it rightly concludes they are extremely valuable and sensitive. My chief concern, however, is that the analysis of the impacts of the windfarm project are inadequate. Furthermore, without some form of quantified analysis of your proposed project’s impacts, it is impossible to understand how your windfarm will eventually affect Wolfe Island’s waterfowl.

Let me first outline important points the report substantiated. In the conclusion of the Bird Report (Appendix C5), it states:

“Wolfe Island has been identified as an IBA (Important Bird Area) due to the presence of globally and continentally significant congregatory species (i.e., wintering hawks and owls) and for continentally significant migratory waterfowl concentrations,” and “As a result, Wolfe Island is a Category 4 Level of Concern project from the perspective of bird use, based on Environment Canada (2007a) criteria.”

Environment Canada’s Wind Turbines and Birds: A Guide to Environmental Assessment (Environment Canada 2007a), which you cite, provides a matrix approach that considers site sensitivity and facility size to establish an overall level of concern category. Category 4 Level of Concern is described as a “…relatively high level of potential risk to birds, and consequently are likely to require the highest level of effort for the environmental assessment.” The guide further notes:

“Depending on the findings of baseline studies, project proponents whose projects fall into this category may be encouraged or even required to seek alternative locations if significant adverse effects on birds are anticipated. The environmental assessment will need to determine the likely significance of adverse effects, including effects on birds. Projects in this level of concern are more likely to lead to significant effects on birds, which is why proponents are encouraged to consider other locations.”

After presenting the bird study findings, the ERR report concludes:

“Disturbance effects related to habitat and behavioural change are generally considered to be more likely than direct mortality (Kingsley and Whittam, 2007). Operational turbines may result in displacement of staging waterfowl from bay areas adjacent to the wind plant, to more distant areas. They may also result in local changes to overland movement between inland foraging and bay staging areas, or displacement from foraging areas. The proposed scattered distribution of turbines is not expected to create a barrier to the movement of waterfowl.”

In Environment Canada’s (2007a) guidelines, it requires that your assessment “determine the likely significance of adverse effects.” I did not see in the report any analysis to determine the likely significance of displacement and local changes in habitat utilization. I agree with the conclusion that wind turbines will likely affect waterfowl distribution on Wolfe Island, but there is no analysis that leads to this conclusion.

The matrix approach used in Environment Canada’s Guide to Environmental Assessment was adopted from Percival (2001). In a more recent study, Percival (2003 1 ) emphasizes the need to quantify impacts in order to assess the magnitude of the effects:

“Once the species/populations in the windfarm area have been evaluated in terms of their sensitivity, the next step is to determine the magnitude of the possible impacts that may occur on those species/populations. The methodology addresses this issue by quantifying the effect as far as possible, and expressing the size of that effect in relation to the existing baseline conditions.”

Percival (2003) provides a guide to assessing the magnitude of effects (see his Table 4 below). For example, before you can begin to establish the magnitude of displacement effects on waterfowl, you need to quantify the potential loss of bird populations and habitat, e.g., a 20-80% loss is associated with a HIGH magnitude effect. No where in the ERR is there any information that could be used to assess the magnitude of the disruption you believe will occur, yet gauging the magnitude of potential effects is crucial to this environmental assessment methodology.

1Percival, S.M. 2003. Birds and windfarms in Ireland: A review of potential Issues and Impact Assessment. Durham, UK: Ecology Consulting.







Percival (2003) then suggests, “The assessments of magnitude and sensitivity lastly need to be brought together in order to determine the significance of the potential impact, and hence their acceptability in a planning context.” Wolfe Island waterfowl resources are considered highly sensitive (Category 4) and if we assumed the magnitude of the disturbance and displacement effects are HIGH, then Percival’s matrix approach shows the Significance of the Effect to be very high.

A very high significance could then be used to determine if the impacts would be acceptable or not. The methodology suggests the following interpretation:

“Very high and high represent a highly significant impact on bird populations and would warrant refusal of a planning proposal.” (Percival 2003)

This example suggests that you need to do a quantified assessment of the significance of the impacts that you admit will occur. Noting qualitatively that a disturbance may occur does not qualify as a serious look at impacts. You need to quantify the size of the bird populations and the numbers lost, the habitat they use, the habitat they are expected to lose etc. The ERR report has not quantified these effects and hence it is impossible to comply with the environmental assessment guideline.

Although the report failed to quantify potential impacts on waterfowl, quantified assessment of windfarm impacts was done for other issues elsewhere in your report. For example, in the noise section of the report, baseline information was collected and then models were used to predict noise levels at different residences in order to quantify the impacts. This analysis even provided detailed isonoise contour maps, so we could visually interpret the results and see the impacts of turbine noise on various residences. However, had the noise assessment been conducted in the same way you approached the waterfowl issue you would have: 1) presented a baseline, background noise assessment; 2) cited a small number of unrelated wind turbine noise studies; and 3) made a general statement that your windfarm may be audible. I have no doubt that such a noise study would have been severely criticized and rejected, and for that same reason I believe the waterfowl assessment is inadequate too.

Although the lack of an adequate, quantified impact assessment is my principal concern with the ERR report, I am also disturbed by the misleading use of a study reference. In Section 4.2.1 of the Bird Report, it references a study by James and Coady (2003):

“Some species such as the Canada Geese will forage on the ground in proximity to wind turbines with little apparent disruption (James and Coady 2003, Kingsley and Whittam, 2007).”

I think anyone reading this citation, without checking out its source, would conclude that migrating Canada Geese will be right-at-home amongst wind turbines on Wolfe Island. They might further conclude that if they can feed at the base of the towers, then collisions, mortality, disturbance and habitat loss are probably all inconsequential. The truth of the matter is that James and Coady (2003) reported on bird studies associated with a single wind turbine abutting the Pickering Nuclear Power Station in Pickering, Ontario. The photograph below provides the proper background and context and it also explains why I believe the use of this citation is very misleading.



The reason Canada Geese were foraging on the ground in proximity to the Pickering wind turbine is probably related more to the fact the geese may have been resident park geese – they may have been more attracted to popcorn, birdseed, and other handouts than from the “natural habitats” around the wind turbine. No reasonable person should make any kind of comparison of the Wolfe Island situation with James and Coady’s (2003) studies. This kind of a reference does not belong in a serious assessment of the impacts of wind turbines on a natural area with wild waterfowl.

There is an important reference, however, that should have been included and discussed in the Wolfe Island ERR report, but was not. Stewart et al. (2007 2) recently published a report Poor evidence-base for assessment of windfarm impacts on birds . They applied systematic review methodology and meta-analysis to review 19 different windfarm datasets worldwide. They found reductions in bird abundance associated with windfarms, with waterfowl and wading birds most affected. They also found that longer periods of operation resulted in greater declines in abundance, suggesting that birds do not become habituated to the presence of windfarms. They also concluded that:

“There is clear evidence that Anseriformes(waterfowl) and Charadriiformes (waders) experience declines in abundance, suggesting that a precautionary approach should be adopted to windfarm development near aggregations of these taxa in offshore and coastal locations.”

The work by Stewart et al. 2007 is extremely important and should be studied carefully instead of misrepresenting other studies that have marginal value for the Wolfe Island assessment.

2 Stewart, G.B., A.S. Pullin, and C.F. Coles. 2007. Poor evidence-base for assessment of windfarm impacts on birds. Environmental Conservation 34(1): 1-11


I also want to comment on the last sentence in the previously mentioned concluding paragraph, i.e., “The proposed scattered distribution of turbines is not expected to create a barrier to the movement of waterfowl.” Considering the sensitivity and significance of the waterfowl resource, I would expect a rather detailed accounting of how your siting plan will minimize and mitigate disturbance and displacement effects. Unless I missed this section in your analysis and assessment, just saying so doesn’t make it so. You need to provide more than a citation or two to draw this very important conclusion.

In summary, I do not believe the ERR report is a complete analysis of the impacts of your proposed windfarm. There are no quantified impacts, instead the basis of analysis seems to rely on quoting other studies to gauge these impacts. Regrettably, the best studies used for comparison are from very small, offshore European windfarms and for species other than those common to Wolfe Island. Furthermore, important work was not cited while misrepresentation of irrelevant research was highlighted.

Given the extreme sensitivity of the area, I do not think you have made a case that the impacts on waterfowl will be tolerable. From what you have presented, we just don’t know with any certainty how bad the disruption and displacement of avian species will be – you are only guessing. Going back to Environment Canada’s Wind Turbines and Birds: A Guide to Environmental Assessment it states, “Depending on the findings of baseline studies, project proponents whose projects fall into this category (#4) may be encouraged or even required to seek alternative locations if significant adverse effects on birds are anticipated.” I think the Wolfe Island Wind Power ERR fits that case because you are unable to demonstrate there will be no “significant adverse effects”. I believe there is no other reasonable alternative than to drop your proposal at this time, or at the least, reconfigure the siting plan to eliminate those turbines from the area most utilized by Wolfe Island waterfowl3 . At some point in the future, after a more comprehensive, quantified assessment, you may be able say with some confidence that your project proposal will not unduly harm or disturb Wolfe Island waterfowl resources. But, until then, why take the risk?

Thank you for considering my comments.

Sincerely yours,

Clifford P. Schneider

Cape Vincent, NY 13618



3The best habitat for Wolfe Island waterfowl appears to be south of a line connecting the northern most portions of Reeds and Bayfield Bays.

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