Report on the ERT Hearing on the White Pines Wind Project – Nov. 25, 2015
By Paula Peel, APPEC
Day Thirteen of the Environmental Review Tribunal (ERT) of the White Pines wind project focused on two witnesses: Denton Miller, a Senior Noise Engineer in the Environmental Assessment Branch of the Ministry of the Environment and Climate Change (MOECC), and APPEC witness Dr. Craig MacRae, a professional hydrologist.
Miller clarified the MOECC’s position that wind turbine noise is broadband, not impulsive, and that turbines have no low-frequency or infrasound emissions. Reports of “sensations” are among the complaints the MOECC receives. MOECC audits ensure that the sound power used in modelling is correct and complies with regulations. If compliance is an issue, there are options such as restricting operations to daytime or during certain wind conditions.
Miller explained that the MOECC’s Noise Assessment is predicated on the worst-case scenario and the model gives conservative results. Therefore, it is not a concern that sound output downwind of turbines is 6 to 7 db(A) higher than upwind, or night-time sound output may vary from 5 to 10 db(A) due to wind shear.
APPEC counsel Eric Gillespie asked Miller to consider that MOECC’s model is “practical,” not “conservative,” because acousticians suggest these scenarios happen all the time. Gillespie noted that the White Pines project is spread over a large area encompassing many receptors. At any given time would it not be possible that turbine blades will be turned away from some receptors while other receptors will be downwind? Miller replied that due to variable wind directions this might not happen and sustained impact is unlikely in any case.
Miller confirmed that the MOECC is issuing new guidelines in a few weeks to replace the 2008 Noise Guidelines. Among other things the revision includes a section on wind shear profiling and specific directions to ensure calculations are based on maximum output.
Dr. Craig R. MacRae, qualified as a hydrologist, has 32 years of professional experience in measurement and modeling of hydrologic systems, channel erosion, open channel flow hydraulics and sediment transport.
Dr. MacRae told the Tribunal that karst is an area of limestone characterized with crevices, fissures, sinkholes, and underground streams. Karst formation flows continuously throughout the Prince Edward County south shore, with different levels ranging from 2m up to 30m deep. He observed numerous karst features on his site visit of the White Pines project. Yet Stantec did not report the presence of karst and did not do any field work.
Dr. MacRae stated when karst is disturbed by construction, it is destroyed. The harm is irreversible and cannot be repaired. Underground water flows horizontally and the construction of the 16.7km access roads, cable trenches, excavations for wind turbine and crane pads, and upgrades to existing municipal roads all can damage and destroy the karst. Dr. MacRae also stated that trenching for the access roads and collector lines can drain the wetlands.
The damage is unpredictable and thus cannot be mitigated. A water management plan cannot be developed as flooding can occur in areas where there was none prior to construction. MacRae noted that the 20 culverts proposed along new access roads will not manage all the risk and more culverts would simply change the flooded areas. New access roads must be raised to allow for water flow ditches on both sides in order to prevent washouts.
Patrick Duffy, counsel for WPD, challenged Dr. MacRae in cross-examination, trying to show that there is no karst in the White Pines project area. He referenced high-level diagrams in public documents that show Prince Edward County has “unknown” karst. Dr. MacRae replied that these diagrams don’t tell the whole story and the documents describe characteristics on the south shore that are consistent with karst.
In Mr. Gillespie’s reply, Dr. MacRae identified many deficiencies in Stantec’s reports for the White Pines project. There was no field work, no methodology set out with established criteria, no physical measurements, and no topological mapping. Stream courses were insufficiently mapped, no high-water mark measurements were established, and the existing MNRF database is sorely lacking. Finally, Stantec did not identify three large sinkholes and 10 additional streams that Dr. MacCrae observed on his site visit.
ERT co-chair Hugh Wilkins asked Dr. MacRae to identify areas of concern. Dr. MacRae said that the areas of greatest risk are T1, T2 and T3 in the Black Creek Valley ANSI, T25 through T29 in the eastern portion of the township, and parts of Helmer Road and Babylon Road in the Provincially-Significant South Bay Coastal Wetland.
The ERT resumes Monday, November 30.