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REVIEW OF THE ARRAN WIND ENERGY PROJECT DRAFT PROJECT DESCRIPTION REPORTSubmitted to the Director, Environmental Approvals Branch, Ontario Ministry of the Environment By The Friends of Arran Lake and Central Bruce-Grey Wind Concerns Ontario 22 July, 2010

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Page 1: REVIEW OF THE ARRAN WIND ENERGY PROJECT ...ontario-wind-resistance.org/wp-content/uploads/2010/07/...2 This report is a review report of concerns identified in ―Arran Wind Energy

REVIEW OF THE “ARRAN WIND ENERGY PROJECT

DRAFT PROJECT DESCRIPTION REPORT”

Submitted to the Director, Environmental Approvals Branch,

Ontario Ministry of the Environment

By The Friends of Arran Lake

and Central Bruce-Grey Wind Concerns Ontario

22 July, 2010

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This report is a review report of concerns

identified in

―Arran Wind Energy Project

Draft Project Description Report‖

As Submitted to the Director, Environmental Approvals Branch

Ontario Ministry of the Environment

Identified as:

Report No. 09-1112-6081

Dated April 2010

Prepared by: Golder Associates

For Arran Wind Project ULC

And it has been sent to the signatories of the report:

For Golder Associates Ltd.,

Ian Callum, Golder Project Manager

and Danny da Silva, Associate, Golder Project Director

For Arran Wind Project ULC:

Joanna Szarek, Development Officer, Leader Resources Services Corp.

and Charles Edey, President, LRS Corp

A full, detailed written explanation of all the issues raised, is requested from the project manager as part of the public consultation process.

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With copies to:

The Honourable Dalton McGuinty, Premier of Ontario; The Honourable Brad Duguid, Minister of Energy and Infrastructure; The Honourable Linda Jeffrey, Minister of Natural Resources; The Honourable Michael Chan, Minister of Tourism and Culture; The Honourable James Bradley, Minister of Municipal Affairs and Housing; The Honourable Deborah Matthews, Minister of Health and Long-Term Care; The Honourable David Onley, Lieutenant Governor of Ontario; and André Marin, Ombudsman of Ontario; Chief Randall Kahgee, Saugeen First Nation; Chief Ralph Akiwenzie, Chippewas of Nawash Unceded First Nation; President Patsy McArthur, Historic Saugeen Métis; Tammy Schummelketel, Energy Consultations Coordinator, Historic Saugeen Métis; Bill Murdoch, M.P.P. Bruce-Grey-Owen Sound; Larry Miller, M.P. Bruce-Grey-Owen Sound; Tim Hudak, M.P.P., Leader of the Official Opposition; Ben Lobb, M.P. Huron-Bruce; Andrea Horwath, M.P.P.; Mayor and Councillors, Municipality of Arran-Elderslie; Mayor and Councillors, Municipality of Saugeen Shores; The Honourable Jim Prentice, Minister of the Environment; The Honourable Chuck Strahl, Minister of Indian Affairs and Northern Development and Federal Interlocutor for Métis and Non-Status Indians; Elaine Hardy, Ministry of the Environment E.A.A.B.; Dr. Scott Petrie, Executive Director, Long Point Waterfowl, Port Rowan; Caroline Shultz, Executive Director, Nature Ontario; Grey Sauble Conservation Authority; Saugeen Valley Conservation Authority; Owen Sound Field Naturalists; County of Bruce Tourism and Agriculture Committee.

Web site: http://windconcernsontario.wordpress.com/

Email: [email protected]

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TABLE OF CONTENTS

INTRODUCTION 6

THE NATURAL HERITAGE SYSTEM (MNR) AT ARRAN LAKE 7

KNOWN NEGATIVE ENVIRONMENTAL IMPACTS OF WIND TURBINES ON

NATURAL HABITATS 21

SPECIES AT RISK AT ARRAN LAKE: PROTECTED, COSEWIC, SARA AND

MNR ENDANGERED AND THREATENED SPECIES 69

BATS AT RISK AT ARRAN LAKE 88

ANIMAL STUDIES AND LOW FREQUENCY NOISE 91

HERITAGE AND ARCHAEOLOGICAL FEATURES 104

TOURISM, BUSINESS USE 110

ADVERSE HUMAN HEALTH EFFECTS 115

ANALYSIS OF NOISE AND SAFETY ISSUES 127

APPENDICES 129

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ACKNOWLEDGEMENTS

The Ontario Ministry of Natural Resources helpfully provided information on endangered and threatened species in the Arran Lake area and extensive use was made of their website. Kathy Dodge of the Ontario Ministry of Natural Resources Owen Sound Office kindly provided documents specific to Arran Lake.

We are grateful to Bird Studies Canada for the use of the IBA map and to Dr. Scott Petrie, Executive Director, Long Point Waterfowl, for his help in tracking down additional European research.

Cindy E. J. Cartwright, a member of the Ontario Field Ornithologists and an active observer of bird migrations in Bruce County, read the manuscript and provided helpful suggestions and local expertise. She has spent many years cataloguing the birds on Chantry Island and served as the Bruce County Regional Coordinator for The Atlas of the Breeding Birds of Ontario 2001-2005.

We also appreciate the help of The Society for Wind Vigilance and especially Carmen Krough, B.Sc. (Pharm) in supplying recent health research.

We are also indebted to William K. G. Palmer, P. Eng., for his analysis of safety and noise issues.

Editorial team: Professor James Strecker, M. A.; Judith Posthumus, B.A., M.Ed.; Jeanne Cechovsky, R.N. Research and photos: Keith Stelling, B.A. (Hons), M.A. (McMaster), M.N.I.M.H, Dip. Phytotherapy, M.C.P.P. (England).

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ARRAN LAKE WETLANDS IN SPRING

INTRODUCTION

It would be difficult to imagine a natural habitat more inappropriate for an

industrial wind turbine development than the one that has been selected for the

Arran Wind Energy Project.

Within its boundaries is a functioning Natural Heritage System (MNR)

comprised of six Life or Earth Sciences ANSIs1, three Provincially Significant

Wetlands forming a 1235.6 hectare wetland complex; several migratory bird

staging areas and an international migratory flight corridor; two Conservation

Authority lands; recreational and tourism facilities; as well as canoeing, kayaking

and fishing access points to the Saugeen River. There are also a dozen listed

archaeological sites both excavated and unexplored from the Middle Woodland

period (300 BC to 500 AD), of critical cultural, spiritual and historic importance

to the Saugeen First Nation and to the Historic Métis of the Saugeen.

1 Areas of Natural and Scientific Interest

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The application for this development will trigger alarm bells within the Ministry

of the Environment, the Ministry of Natural Resources, the Ministry of Tourism,

nature, conservation, and outdoor sports organizations across the province, as

well as First Nations Councils.

The fact that it has even been proposed under the Green Energy Act (GEA)

indicates serious inadequacies in the Regulations that could allow such an

unsuitable location even to be considered.

This report recommends an immediate revision of the GEA Regulations by the

Cabinet and the various ministries to take account of the Provincial Policy

Statement governing such valuable natural heritage assets in order to protect

them from degradation and loss of biodiversity and ecological function. It also

insists that this development proposal be completely rejected by the MOE

Approvals Branch and that legislative provision be made to prevent any future

such projects from ever being contemplated within this or similar areas.

THE PROPOSED PROJECT SITE

THIS SITE IS ONE OF VERY HIGH SENSITIVITY

Extending into both the Municipality of Arran-Elderslie and the Municipality of

Saugeen Shores in Bruce County, the proposed wind turbine development area

impinges upon:

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Arran Lake North Life Sciences ANSI (Area Id. 1017) (of Regional

Significance)

This 450 ha wetland complex at the north end of Arran Lake is comprised of an

extensive lowland forest on muck deposits along a tributary of the Sauble

River, a large zone of marsh and shrub carr at the stream outlet from Arran Lake

and the forested portions of several drumlin slopes.

Arran Lake South Life Sciences ANSI (Area Id: 1018) (of Regional

Significance)

This large wetland complex (approx. 250 ha) at the south end of Arran Lake

occupies muck deposits in an interdrumlin depression. [Lindsay 1984]2

Arran Lake Wetland (Area Id. 7905) a Provincially Significant

Wetland

Made up of three individual wetlands, composed of three wetland types (0.2%

fen, 68.2% swamp and 31.6% marsh) (Toth et al, 1985).3

Saugeen River Life Sciences ANSI (Id. 4615) (of Regional

Significance)

Saugeen River valley system from north of Paisley to south of Port Elgin (20 km

in length). Consists of forested terraces, floodplain, islands and agricultural land.

Alluvial islands contain butternut stands, upland scrub and meadow. It is an

2 Lindsay, K.M. 1984. Life Science Areas of Natural and Scientific Interest in Site District 6-5. A Review And Assessment of Significant Natural Areas in Site District 6-5. Ontario Ministry of Natural Resources, Central Region, Richmond Hill. SR OFER 8408. iv + 93 pp. + maps.

3 Toth, G., J. Morton and A. Hill. 1985. Wetland Data Record and Evaluation- Arran Lake. Second Edition.

June 10-13 and July 16, 1985. Grey Sauble Conservation Authority. Manuscript. 22 pp + 4 maps + 12 pp supplement.

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important part of the Saugeen River linkage system for movement of

faunal species.

Saugeen River Valley

Saugeen River East of Southampton ANSI (Area Id: 1587) (of

Regional Significance)

160 hectares of undulating sand dunes and flat to gently rolling knolls with

trembling aspen and mature sugar maple-beech forest. Several regionally rare

plants.

Saugeen River South East of Port Elgin Life Sciences ANSI (Area

Id: 18661)

There are several islands in the river. Some of these are heavily wooded, with

a few very old examples of Eastern White Cedar (Thuja occidentalis)

and other tree species. (Eagles, P. 1983. Saugeen River Southeast of Port

Elgin Environmentally Sensitive Area Inventory Checksheet. 17 pp.)

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Saugeen Valley Conservation Authority: Saugeen Bluffs

Conservation area is adjacent to the southwest corner of the project

area.

This is a popular 200-site camping and canoeing area within full viewshed of the proposed

turbines.

Sang‘s Creek Fen (Area Id: 10478) Provincially Significant

Wetland

A Provincially Significant Wetland Complex, made up of two individual wetlands,

composed of three wetland types (8% fen, 90% swamp and 2% marsh) (Atkinson,

1993).4

Two Grey Sauble Conservation Authority sites including a

recreation area

The Arkwright Drumlins Provincially Significant Earth

Sciences ANSI (Id 7914) (Located 1.35 km northwest of the northwest

boundary of the Study Area).

Recreation Access Point (No 14) to Saugeen River

NATURAL HERITAGE SYSTEM

The land encompassed by the proposed project, between and surrounding these

features, forms a functioning Natural Heritage System (MNR) of outstanding

4 Atkinson, J. 1993. Southern Ontario Wetland Evaluation, Data and Scoring Record- Sangs Creek Fen. Third

Edition (March). July 25- 27, 1992. Atkinson & Huizer Biosurveys. Manuscript. 42 pp + 19 pp supplement.

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biodiversity. All seven natural heritage features are present in the Arran Lake

system:

significant wildlife habitats

significant portions of the habitat of threatened and endangered species;

significant old growth woodlands

significant valley lands

important fish habitat

Provincially Significant Earth Sciences ANSI

Provincially Significant Wetland Life Sciences ANSI

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INTERLINKING ECOTONES AND BUFFER AREAS AT ARRAN LAKE The interlinked yellow circles on this map demonstrate the interdependence of interrelated natural habitats. Red square indicates the area of the natural heritage system. Satellite photograph (from Canadian Important Bird Areas, Bird Studies Canada) (http://www.bsc-eoc.org/iba/mapviewer.jsp)

Arran Lake

Arkwright Drumlin ANSI

Arran Lake (South)Wetland Complex

Saugeen River East of Southampton ANSI

Chantry Island Migratory Bird Sanctuary and Important Bird Area

Arran Lake (North) Wetland Complex

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Significant wildlife habitat

Provincially significant wetlands

Arran Drumlin Fields

MIGRATORY BIRD STAGING AREA AND SEASONAL

MIGRATORY FLYWAY

The lake and wetland complex are a spring and autumn waterfowl migratory bird

stopover and staging area, designated by the Grey Sauble Conservation Authority.

The migratory staging area stretches south to include the farmland surrounding

Arkwright Creek, Burgoyne Creek and Snake Creek.

Section 4.3.2 of the Draft Project Description Report notes: ―Burgoyne Creek

flows through the centre of the site to join the Saugeen River west of the study

area. There are a few turbines located within 120 m of Burgoyne Creek as well as

Arran Drumlin

Fields

Significant fish habitat

Significant valley lands ANSI

Provincially significant wetlands

Significant

woodlands

Significant portions of habitat of endangered and threatened species

Chantry Island Migratory Bird Sanctuary and

Nationally significant IBA

Significant wetlands

Significant wildlife habitat

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an access road and underground cable crossings of Burgoyne Creek and a

tributary of Burgoyne Creek‖.

The seasonal migratory flyway extends to the south and north of Arran Lake,

through the entire proposed wind turbine complex site. The proponents propose

to place wind turbines around three sides of the southern portion of Arran Lake,

in effect forming a barrier across this corridor.

Map showing seasonal and daily migration corridors. Diagonal shading indicates proposed location of wind turbine development. An additional wind turbine development is said to be planned just north of the lake.

DIURNAL MIGRATORY FLYWAY

In addition, the project dissects the diurnal migratory corridor between Arran

Lake and the Chantry Island Federal Migratory Bird Sanctuary Important Bird

Daily migratory

flyway

Seasonal

migratory

flyway

Seasonal

migratory

flyway

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Area (IBA ON 154), only approx. 5 k distant. The IBA is the breeding ground of

two species of National Significance. Many of these birds roost on the Island at

night forage in the fields and wetlands around Arran Lake during the day. A

barrier would also be formed across this flight corridor also.

The Draft Project Description Report proposes to keep the turbines a mere 120

metres from the Arran Lake Wetlands Complex. At a time when five mile setbacks

from shorelines are being considered to avoid interference with migratory

species, this distance is ludicrously inadequate since it will not prevent

degradation of the Natural Heritage System nor respect the migratory corridors.

CHANTRY ISLAND GULLS FORAGING IN FIELDS BESIDE ARRAN LAKE

ARRAN WETLANDS: VALUE INCREASED BY SIZE AND

DIVERSITY

The value of the Arran Wetland is increased both by its size and by its diversity. It

rates a score of 798 making it ―Class I‖ under the 1985 Ministry of Natural

Resources evaluation with a Biological component of 194.9; Social Component

190.2; Hydrological component 163; Special features component 250.0. (A

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wetland that scores 600 or more points or has 200 or more points in either the

biological or special features component is provincially significant).5

The complex of wetlands and Life and Earth Sciences ANSIs and the Natural

Heritage System linking them contains:

Colonial bird nesting sites

Waterfowl stopover and staging areas

Waterfowl nesting

Shorebird migratory stopover areas

Landbird migratory stopover areas

Raptor winter feeding and roosting areas

Wild turkey winter range

Reptile hibernacula

Turkey vulture summer roosting areas

Bat hibernacula

Bullfrog concentration areas

Migratory butterfly stopover areas

Rare vegetation communities

Specialised habitats for wildlife

Habitat for area-sensitive species

Forests providing a high diversity of habitats

Old-growth and mature forest stands

Foraging areas with abundant mast

Amphibian woodland breeding ponds

Turtle nesting habitat

Snake hibernacula

5

It should be noted that this evaluation took place before the First Nations archaeological features had been discovered, a factor which would today increase the score substantially.

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Specialised raptor nesting and hunting habitat

Animal movement corridors

Special woodland feeding habitat

Areas of high diversity

Lake Nipissing and Lake Algonquin beach ridges, bluffs and dunes

SIGNIFICANT EARTH SCIENCES ANSI: ARRAN DRUMLIN

FIELD/ARKWRIGHT DRUMLINS ANSI

The areas east and west of the lake are made up of the Arran Drumlin Field. It

includes the provincially significant Earth Sciences ANSI (Id 7914), the Arkwright

ARRAN DRUMLIN FIELDS

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Drumlins which covers 654 hectares (1614 acres) just east of the lake.6 Rolling

hills and ridges comprise much of the land between Arran Lake and the Saugeen

River as well as the uplands on the east side of the lake. As an area of scientific

research, the drumlins have the potential to provide information on ancient

climate history including global warming. They were laid down by the retreat of

glacial ice during the last ice age:

―The last major glacial ice advance to cover Bruce County started about 23,000

years ago. Generally, glaciers destroy or cover landforms during an ice advance

and construct landforms when the ice melts during a retreat. Intermittent pauses

by the ice during retreat produced significant landforms such as drumlins and

moraines. Drumlins are elongated, streamlined hills or ridges formed at the base

of the ice mass. They are composed of glacial till which is sediment deposited

from the melting of the glacier. The movement of the ice over the till moulds the

sediment into small, short ridges or large, long hills. The long axis of the drumlin

indicates the direction of flow of the glacier.

―Drumlins in the ANSI, which belong to the Arran Drumlin Field, are aligned

northeast-southwest indicating the ice came from the northeast. They are classic,

thin, oval-shaped and were formed about 16,000 years ago. These drumlins were

exposed from ice cover only after the retreat of the ice nearly 12,000 years ago.‖7

Wind turbines placed anywhere on the drumlins or in the

vicinity of an ANSI would devalue its significance.

The drumlins are significant habitat for hunting by raptors

which soar over the ridges.

6

Site District: 6E-5 Topographic Maps: 41A/6 UTM Centroid: 17 485000 4924000 Decimal Latitude/Longitude: 44.4711511806146 -81.1884533066782

7 Ministry of Natural Resources Earth Science Database,

http://nhic.mnr.gov.on.ca/MNR/nhic/areas/areas_report.cfm?areaid=7914

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FIRST NATIONS CULTURAL AND HISTORIC SIGNIFICANCE

The proposed site area is of critical cultural, spiritual and historic importance to

the Saugeen First Nation, the Historic Métis of the Saugeen, The Chippewas of

Nawash Unceded First Nation, and the Six Nations of the Grand River.

The area included within the proposed project boundaries contains a rich

treasury of Middle-Woodland period archaeological sites both excavated and

awaiting investigation dating back at least as early as 300 B.C. As such, it

represents a major component of First Nations heritage and includes a

multiplicity of sacred burial grounds. Arran Lake has always been an important

fishing, hunting, and harvesting resource for the First Nations People. Many of

the medicinal plants used in traditional North American indigenous herbal

medicine still thrive here today.

It is part of the territory where the Historic Métis of the Saugeen traditionally

hunted, fished, traded and lived.

TOURISM

The proposed project site is also an important tourism and business resource for

the local tourism dependent economy. The Minister of Energy and Infrastructure

has received requests from the Tourism Industry Association of Ontario warning

that the placement of wind turbines near Ontario‘s tourism resources will have a

negative economic effect.

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ADVERSE EFFECTS OF WIND TURBINES ON HUMAN HEALTH

Unfortunately, the Draft Project Description Report contains a number of

inaccuracies and assertions which must be disputed. For example, the claim that

this project will have no adverse effect on the health of residents living within the

project site is not supported by credible evidence. The Draft Project Description

Report dismisses the existence of ―wind turbine syndrome‖ and the possibility of

human health problems resulting from exposure to noise, vibration, shadow

flicker and low frequency noise merely on the basis of the AmWEA-CanWEA

―Expert Panel Report‖ and the Arlene King report. However, both these

incomplete literature searches have met with derision in international

professional medical and scientific circles on account of their flawed design,

failure to include an epidemiologist, prejudicial selection of literature and

ignoring more recent contradicting studies, industry influence, and incorrect

statements. An analysis of these reports is included in the section ―Wind Turbine

Syndrome‖ below.

The Draft Project Description Report (section 4.0) also misleadingly states

―negligible effects to natural heritage features and functions are anticipated and

an Environmental Impact Study (EIS) is not required under Reg. 359/09‖.

KNOWN NEGATIVE ENVIRONMENTAL IMPACTS OF WIND

TURBINES ON SENSITIVE NATURAL HABITATS

The Draft Project Description Report also minimizes the adverse effects of

industrial wind turbine complexes on sensitive natural habitats, threatened and

endangered species, and the functionality of Natural Heritage Systems (MNR).

This review compiles some of the studies by North American and European

biologists of the adverse effects on natural habitats which have occurred and are

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occurring near wind turbine complexes. These studies do not seem to have been

taken into account before the project was proposed.

International scientists agree that wind turbines can have a devastating effect on

biodiversity and the survival of threatened and endangered species when placed

anywhere near locations of high bird or bat use, migratory flight corridors or

significant wetlands and their surrounding ecosystems.

Regrettably, industry claims that very few birds are destroyed have now been

demonstrated to be false by actual studies in Ontario including the most recent

fatalities monitored at Wolfe Island, a sensitive site similar to Arran Lake.

Biologists are also very worried about compounding and cumulative collision

mortality rates, habitat degradation, long term abandonment, barrier formation,

and observed reproductive problems associated with nearby wind turbines.

NOISE, SAFETY AND ICE THROW ISSUES

The Draft Project Description Report ignores the very real possibility of safety

issues and fails to explain how noise and vibration pollution will be ―negligible‖.

This report outlines concerns over these issues.

II. DETAILED ANALYSIS

KNOWN NEGATIVE ENVIRONMENTAL IMPACTS OF WIND

TURBINES ON NATURAL HABITATS

There is a growing consensus that wind turbines must be kept well away from

migratory corridors, Important Bird Areas (IBAs), significant Areas of Natural

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and Scientific Interest (ANSIs), sensitive habitat systems, or areas frequented by

endangered and threatened species. Biologists, governments, environmentalists

(i.e. David Suzuki) and even national wind energy developers‘ organizations

admit that the only way to prevent impacts on sensitive habitats is to avoid them

altogether. Environment Canada, US Fish and Wildlife Service (USFWS), Nature

Canada, Ontario Nature and the Audubon Society advise that turbines should be

kept well away from Important Bird Areas and other sites critical to bird

migration and breeding. And yet industrial wind farms continue to be planned

and constructed near sensitive natural areas that will suffer environmental

degradation and loss of threatened species habitat as a result.

Biologists have observed mounting evidence of harm to migratory birds and long-

term degrading effects on the quality of sensitive wildlife habitats. Increasing

concerns include not only collision mortality for migratory birds (especially

songbirds, and raptors) as well as bats. Habitat disturbance (especially for

waterfowl) and habitat fragmentation, (causing barriers to movement between

feeding and breeding areas) are also being observed. These have potentially

disastrous effects upon threatened and endangered species.

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DIAGONALLY SHADED AREA INDICATES APPROXIMATE LOCATION OF PROPOSED WIND TURBINE DEVELOPMENT WHICH FORMS A BARRIER AROUND THREE SIDES OF THE LAKE AND INTERCEPTS

THE MIGRATORY CORRIDORS.

US FISH AND WILDLIFE SERVICE GUIDELINES FOR WIND

TURBINES

As early as 2003, the USFWS issued Interim Guidelines to Avoid and Minimize

Wildlife Impacts from Wind Turbines: 8

―1. Avoid placing turbines in documented locations of any species of

wildlife, fish, or plant protected under the Federal Endangered

Species Act.

8

U.S. Department of the Interior Fish and Wildlife Service, Service Interim Guidelines on Avoiding and Minimizing Wildlife Impacts from Wind Turbines. Letter to Regional Directors, Regions 1-7, May 13, 2003.

Saugeen River

East of

Southampton

ANSI

Arran Lake North

Wetlands

Already installed

meteorological

towers

Arkwright

Drumlins ANSI

Arran Lake

South Wetlands

ANSI

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2. Avoid locating turbines in known local bird migration pathways or

in areas where birds are highly concentrated. . . . Examples of high

concentration areas for birds are wetlands, State or Federal refuges

[sanctuaries], and staging areas. . . . Avoid known daily movement

flyways (e.g., between roosting and feeding areas).

3. Avoid placing turbines near known bat hibernation, breeding, and

maternity/nursery colonies, in migration corridors, or in flight paths

between colonies and feeding areas.‖9

CANWEA‘s website displays the Kingsley and Whittam background review: Wind

Turbines and Birds published by the Canadian Wildlife Service:

―Staging areas

When birds migrating over land or water encounter a coastline, they often turn

along that coastline and form a concentrated stream of migration along the coast.

Some types of migrants (e.g. shorebirds and waterfowl) concentrate in restricted

areas of suitable habitat while resting and feeding between migratory flights.

These are often interior lakes or marshes, coastal estuaries, mud flats, or other

areas that can provide food and/or shelter for large numbers of birds (Richardson

2000).

At staging areas, flights of large numbers of migrants are often concentrated into

corridors when the birds are either taking off or approaching to land (Richardson

2000). The flight height of these migrants is often at the height of wind turbines

9 Many European studies have documented habitat degradation and avian collision mortality. The USFWS guidelines were based on peer-reviewed scientific avian studies written by biologists: Orloff and Flannery 1992, Leddy et al. 1999, Woodward et al. 2001, Braun et al. 2002, Hunt 2002 as well as studies of bats: Keeley et al. 2001,Johnson et al. 2002, Johnson et al. 2003, Manes et al. 2002, and Manville 2003.

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and whether the distance from the stopover area within which flight altitudes will

be low enough to be at risk of collisions with turbines will depend on the type of

bird and other factors. Some birds, like swans, typically climb only very gradually,

and may remain low for a considerable distance after takeoff from the stopover

area. Other birds climb (or descend) more rapidly (Richardson 2000).‖

MENACE TO ARRAN LAKE’S SANDHILL CRANES, HERONS,

BITTERNS AND WATERFOWL

Among the birds observed to climb very slowly around Arran Lake are the

Herons, Bitterns and other waterfowl. This is a major roosting area for migrating

Sandhill Cranes. Cranes forage in fields around the lake, including those in the

immediate vicinity of the proposed wind power development. Flocks of Sandhill

Cranes are regularly seen feeding in the area or flying over the site. It should be

remembered that the staging birds associated with Arran Lake move daily from

the wetlands area to the adjoining fields to feed. At other times these fields are

frequented by other slow climbing birds such as Gulls, Terns, and Geese.

THE 2007 BELGIAN STUDY

A key study comes from Europe. Joris Everaert and Eckhart Kuijken of the

Belgian Research Institute for Nature and Forest have undertaken a long-term

project to study the impact of land-based wind turbines on birds and to act as a

consultancy for proposed wind farms in Flanders. In 2007 they published Wind

turbines and birds in Flanders (Belgium): Preliminary summary of the

mortality research results. These researchers emphasize that proper site

selection plays a very important role in limiting the impact of wind farms on

nature.

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―In general, current knowledge indicates that there should be

precautionary avoidance of locating wind farms in regional or

internationally important bird or bat areas and/or migration

routes. Locations with high bird or bat use are not suitable for

wind farms.‖

―Large modern turbines of 1500 kW or more can have as much as, or even

more collision fatalities than smaller turbines.

―The average number of collision fatalities in different European wind

farms on land varies between a few birds up to 64 birds per turbine per

year.

―‗Site selection‘ can play an important role in limiting the number of

collision fatalities.

―Actual observed collisions (thermal image intensifiers) was performed in

The Netherlands (Winkelman 1992b). These results showed a remarkably

high nocturnal collision probability of 1 on 40 passing birds (2.5%) at

rotor height.

―An exhaustive study before the selection of future locations is a key factor

to avoid deleterious impacts of wind farms on birds and bats.

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―Cumulative negative impacts with an increasing number of wind turbines

must be taken into account (Langston & Pullan 2003). This especially is

developing along fixed bird migration corridors (coasts, mountain

passes). More wind farms also means an extra pressure on top of the

already existing sources of negative impact (powerlines, traffic etc.).

―A number of environmental impact assessments (EIA) have

important shortcomings because of the lack of data and time

or the use of incomplete data (e.g. not covering the annual

cycle). It is very important that EIA's are made independently

or are at least evaluated independently. When important factors

remain unclear and an indication exists for an important

negative impact, the precautionary principle must be applied. A

constructive working method is to map potential and no-go locations for

wind energy in a certain country or region, based on all available

information, long before concrete projects are planned.

―It is clear that if a wind farm could have an important negative impact on

wildlife, landscape, etc., the obligation exists to look for alternatives first.

In most cases there will always be less vulnerable locations or other

alternatives for wind farms‖.10

In the U.K., the Royal Society for the Protection of Birds has intervened with legal

action to halt a number of inappropriately sited commercial wind projects. It has

10

Web link: http://www.semantise.com/~lewiswindfarms/Download%... Download complete File(s): everaert_kuijken_2007_preliminary_b.pdf (119.38 kB) FROM HTTP://WWW.WINDACTION.ORG/DOCUMENTS/11725

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begun publishing maps of some of England‘s most sensitive sites-- areas that

should be avoided by wind farm development. Dr. Mark Avery, the RSPB‘s

Conservation Director, says: ―We have been appealing to the government for

many years to publish maps like these, primarily to help developers avoid sites

that are important to wildlife‖.

BIRD STUDIES CANADA: THE PROBLEM IN ONTARIO

In Ontario the problem is already critical. Dr. Scott Petrie, a biologist with Bird

Studies Canada notes that ―the current rush for approvals and substantial

competition between companies has resulted in the consideration of

sites that are critically important for migratory birds and bats, e.g.,

closely associated with Ramsar Sites, Important Bird Areas, Biosphere Reserves,

National Wildlife Areas, Provincial Parks, etc.‖ 11

Dr. Petrie who is a Canadian waterfowl expert and Executive Director of Long

Point Waterfowl, believes that:

―there has not been a rigorous coordinated approach to the

assessment of suitable sites, or to addressing concerns about

existing proposals. There also do not appear to be sufficient

guidelines for the placement of wind farms; hence the proposals and

possibility that wind farms will be placed on the shorelines of Lake St. Clair

and Long Point, two of the most significant wetland complexes in North

America.‖

11

From an email from Dr. Scott Petrie sent March 15, 2008 to Harry Verhey of the Chatham Kent Wind Action Group for presentation at the Kent Council meeting of March 25 2008. Dr. Petrie himself addressed the council on February 11, 2008.

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In Ontario citizens tend to assume that protection of important natural heritage

sites is being carried out by the Ministry of Natural Resources, or the Ministry of

the Environment. But under the present system, proponents of wind power

developments are being allowed to conduct their own environmental screenings

by commissioning their own ―studies‖. According to Dr. Petrie,

―most of the ‗studies‘ that I have seen pertaining to bird activity are simply

based on casual observations done over an insufficient number of

days/seasons/weather conditions. For example, one contractor concluded

that a proposed wind farm would not impact tundra swans; however, his

assessment amounted to a few days of observations prior to the fall arrival of

tundra swans (early Oct) and a few days of spring observations after tundra

swans had departed (mid-April). In many cases there has been an inadequate

use of local expert knowledge during the planning process.‖ Instead of local

experts, consultants are hired from the city.

Dr. Petrie‘s concerns with wind turbines can be grouped in three areas: mortality,

impact on migration and impact on foraging.

―With so many turbines planned, Petrie is concerned it will be like a wall. With

waterfowl and most bird species migrating at night, he fears there will be

collisions with turbines.

He is also concerned in some locations the turbines will go up between resting

areas and feeding areas.

―Petrie would like to see guidelines developed to protect migrating waterfowl and

coastal wetlands. He wants guidelines on setbacks from wetlands for both

onshore and off shore turbines and requirements for monitoring. Petrie believes

Ontario has an obligation under the North American Bird Treaty to protect

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waterfowl habitat‖.

―It could have an impact on traditional movement patterns and access to prime

habitat and food. Petrie also believes the present approval process could

contravene the Species at Risk Act.

―You couldn‘t get approval to build an office tower beside a coastal wetland, why

would you put an industrial wind turbine beside one,‖ he said. ―Especially since

we lost 85% of our coastal wetlands, it‘s critical we protect what‘s left from

human-induced impacts.‖12

WOLFE ISLAND:

Contractor-prepared baseline environmental screenings are normally rubber-

stamped by the Ministry of the Environment. Recently published data now

demonstrates that this is not acceptable.

For example, an elevation request was denied by the MOE for the wind project on

Wolf Island in Lake Ontario—a well known migratory bird staging area near an

IBA-- similar to Arran Lake. However the release of a bird and bat monitoring

report from Canada's second-largest wind farm, the Wolfe Island EcoPower®

Centre has revealed that in the first eight months of operation, the centre

reported 1,962 bird and bat deaths involving 33 bird species and five bat species.

The second report, covering the six months between July 2009 and December

2009, documented 602 bird fatalities and 1,270 bat fatalities. The number of

raptor and vulture fatalities -- 13 in the six-month period -- were "among the

highest" of any wind farm in the province, according to an official with the

Ontario Ministry of Natural Resources.

12 Simcoe Reformer newspaper, 5/5/10.

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Colliding with blades is hardly the only risk wind power poses to birds and bats.

Researchers have also found that the construction of wind farms and associated

infrastructure (e. g., buildings, roads and electrical transmission lines) renders

wide swaths of habitat less suitable for birds.

Wind farms also require large plots of open land -- an estimated 2.5 acres per

turbine, on average. As a result, a variety of wildlife also is affected.

Dr. Petrie notes that:

―In most instances there has been an inadequate use of existing scientific

literature pertaining to the potential impacts of turbines on wildlife (waterfowl,

bats, passerines [songbirds]). There is ample European literature on the subject

which has not been adequately utilized in the planning process.‖

SETBACKS FROM ENVIRONMENTAL FEATURES

• Under existing legislation, Ontario communities have the responsibility to

protect natural heritage features and their ecological functions.

However, the Draft Project Description Report (section 4.4.1)

indicates that even the 120 m setback from significant natural

heritage features will be maintained only ―where possible‖ and that

―some vegetation removal may be required if watercourse crossings

that possess riparian vegetation are required‖ and that the ―Project

layout development will seek to avoid watercourse crossings‖ only ―to

the extent possible‖. This would indicate that the site chosen for the project

may not even allow adherence to the 120 m setback from significant natural

heritage features.

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The Draft Project Description Report (section 4.4.1) contends that ―the noise

associated with heavy machinery and construction activities may result in

sensory disturbance and, under exceptional circumstances, habitat alienation,

displacement, or desertion, particularly with birds (desertion of nests, eggs, or

young). However the level of activity and noise may not be dissimilar from the

current noise conditions at the site (e.g. agricultural machinery) and the timing of

construction is therefore relevant in the effects assessment‖.

QUIET COUNTRY ROAD BESIDE ARRAN LAKE. (NOTE ABSENCE OF TRANSMISSION LINES)

It must be pointed out that part of the reason for the continued survival of this

natural high quality, quiet undisturbed habitat is the general absence of

human activity. The roads surrounding three sides of the lake, for example, are

unpaved, unfrequented and used mostly by local residents. Most human

habitation is confined to a single house on the original 100 acre farmsteads.

Agricultural activity is limited to pastures, haying and a few cattle feed crops, the

majority of the farmers having retired. The all-pervasive quietness of the area is

normally broken only by the calling of Loons, croaking of Sandhill Cranes, or

singing of Spring Peepers.

PRESERVING CRITICAL ECOLOGICAL FUNCTION

In the past, it seemed sufficient to designate the most outstanding areas as

―provincially significant‖ or ―areas of natural and scientific interest‖ (ANSIs). The

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understanding was that if we protected these isolated areas, they would remain

intact for future generations.

However, our growing understanding of ecosystems has shown us that protecting

an isolated wetland, for example, no matter how well intentioned, was simply

inadequate for preserving its many critical ecological functions. This is because

the wetland habitat itself and many of the life forms found in it depend on the

surrounding upland meadows, the creeks and streams that drain into the wetland

watershed and the upland forests that supply vital support for creatures living

part of their lives beyond the immediate vicinity of the water.

For this reason, the 1996 Provincial Policy Statement under the Planning Act

(which gives Ontario municipalities the responsibility for protecting natural

heritage features and areas within a land use planning context) was amended in

2005 as follows:

“2.1 Natural Heritage

―2.1.1 Natural features and areas shall be protected for the long term.

―2.1.2 The diversity and connectivity of natural features in an area, and the long-

term ecological function and biodiversity of natural heritage systems should be

maintained, restored or, where possible, improved, recognizing linkages between

and among natural heritage features and areas, surface water features and

ground water features.

―2.1.6 Development and site alteration shall not be permitted on adjacent lands to

the natural heritage features and areas identified in policies 2.1.3, 2.1.4 and 2.1.5

unless the ecological function of the adjacent lands has been evaluated and it has

been demonstrated that there will be no negative impacts on the natural features

or on their ecological functions.‘‘

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In 1999, the Ministry of Natural Resources published its Heritage Reference

Manual as a technical document intended to be used in assessing the ―Natural

Heritage Component of the Provincial Policy Statement‖.13 It focuses on

identifying and prioritizing significant wildlife habitat.

To be ecologically functional, the best examples of all of the natural heritage

features should be identified and protected. ―The mosaic of natural heritage

features on the landscape and the connections among them is known as a Natural

Heritage System (OMNR 1999).‖

The holistic approach of the OMNR Reference Manual emphasizes the

requirement to prevent degradation of a natural heritage system by

fragmentation. It stresses that there is a need for unobstructed corridors

for the use of migratory flyways. Therefore surrounding upland pastures

must remain free from any development which could affect the foraging activities

of wetland species.

It is now acknowledged by scientists that these connecting areas between

sensitive habitats are just as important for the biological function of the wetlands

themselves.

Birds, bats, reptiles, animals and amphibians do not recognize an artificial 200

metre boundary surrounding a wetland. They depend on these wildlife

corridors as links between specialized habitats for foraging, laying eggs,

hibernation, migration and flight displays. ―Only when we have a full

understanding of what these habitat needs and tolerances are can we effectively

manage our landscapes for all marsh nesting species. This is called "holistic

management." 14

13

The manual is available online at: http://www.mnr.gov.on.ca/mnr/pubs/SWHTG.PDF 14

Ibid.

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The important links between the areas surrounding Arran Lake remain largely

intact in the form of upland woodlands and small streams running in an east-

west direction. These form all-important interconnecting passageways.

The case of Arran Lake with its rich system of provincially significant wetlands

and ANSIs illustrates:

the developer‘s indifference to conserving the natural assets of the

community,

failure to take into account the exigencies of the Provincial Policy Statement

which emphasizes the importance preserving and promoting biodiversity and

the of interrelated functionality of Natural Heritage Systems (MNR)

the inadequacy of proposing ―mitigation measures‖ in so complex and inter-

related system

the failure of the Regulations of the Green Energy Act to protect the

remaining 20% of Ontario‘s wetland inheritance.

the unacceptable position of the local municipalities whose responsibility it is

to protect natural heritage features and areas within a land use planning

context but are not permitted to do so under the GEA.

Given the effects of habitat degradation and abandonment that international

biologists are warning are the result of wind turbines placed within functioning

Natural Heritage Systems, the developer‘s contention that it ―is committed to

identifying significant natural heritage features and finding opportunities to

revise the layout to increase setbacks from these features‖ lacks all credibility.

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SPECIES LIKELY TO BE ADVERSELY AFFECTED

The Atlas of the Breeding Birds of Ontario 2001-2005 indicates the presence of

approximately 101-150 different avian species nesting in this area.15

The following list issued by Bird Studies Canada indicates those species present

in the area that are a conservation priority for Bruce County.

Species listed by Bird Studies Canada as Level One priority for conservation in

Bruce County:16

Forest Birds: American Redstart, American Woodcock, Barred Owl, Black-

billed Cuckoo, Black-capped Chickadee,Black-capped Chickadee, Black-throated

Blue Warbler, Black-throated Green Warbler, Blackburnian Warbler, Brown

Creeper, Canada Warbler, Cerulean Warbler*, Cooper‘s Hawk, Eastern Phoebe,

Golden-winged Warbler, Gray Catbird, Least Flycatcher, Magnolia Warbler,

Mourning Warbler, Nashville Warbler, Northern Goshawk, Northern Saw-whet

Owl, Ovenbird, Philadelphia Vireo, Pileated Woodpecker, Purple Finch, Red-

headed Woodpecker*, Red-shouldered Hawk*, Ruby-throated Hummingbird,

Ruffed Grouse, Scarlet Tanager, Veery, Whip-poor-will, White-throated Sparrow,

Winter Wren, Yellow-bellied Flycatcher, Yellow-bellied Sapsucker, Yellow-billed

Cuckoo, Yellow-throated Vireo.

15 Atlas of the Breeding Birds of Ontario 2001-2005. Edited by Michael D. Cadman, Donald A. Sutherland, Gegor G. Beck, Denis Lepage, Andrew R. Coutourier. Toronto: co-published by Bird Studies Canada, Environment Canada, Ontario Field Ornithologists, Ontario Ministry of Natural Resources, and Ontario Nature, 2007. 16

Conservation Priorities for the Birds of Southern Ontario, (Technical appendicies) http://www.bsc-eoc.org/conservation/conservmain.html, * Indicates threatened or endangered species.

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Marsh Birds: American Bittern, American Black Duck, American Coot, Black

Tern*, Blue-winged Teal, Common Tern, Green Heron, Northern Harrier, Pied-

billed Grebe, Rusty Blackbird, Sandhill Crane, Sedge Wren, Short-eared Owl*,

Sora, Swamp Sparrow, Virginia Rail.

Open Country Birds: American Goldfinch, Bank Swallow, Barn Swallow,

Bobolink, Brown Thrasher, Clay-coloured Sparrow, Cliff Swallow, Dickcissel,

Eastern Bluebird, Eastern Kingbird, Eastern Meadowlark.

All these birds would be affected by habitat fragmentation,

disturbance and disruption from wind turbines in the vicinity.

MIGRATORY BIRDS

The records of the Cabot Head Research Station, the closest migratory bird

monitoring station further up the Bruce Peninsula, on the same migratory flyway,

are useful in estimating the diversity of migratory birds using the site. Raptors

and Passerines (underlined) are considered to be particularly vulnerable to wind

turbine collision, especially during migration in adverse weather conditions.

Manville notes:

―Many species from raptors to passerines – and bats (in several

studies, in large numbers) have been documented killed during

flight by rotating turbine blades‖.

This list is made up of the migratory species monitored during spring and

autumn migrations over the years 2002-2006. 17

17

Bird Migration Monitoring at Cabot Head, 2002-2006 Menu, S. Bruce Peninsula Bird Observatory.

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TRANSMISSION LINES AND TURBINES FORM A BARRIER AT BRUCE TOWNSHIP DEVELOPMENT

ANSERIFORMES ANATIDAE

Anserinae

Snow Goose (Chen caerulescens)

Black Brant (Branta bernicla)

Canada Goose (Branta canadensis)

Mute Swan (Cygnus olor)

Anatinae

Wood Duck (Aix sponsa)

Gadwall (Anas strepera)

American Wigeon (Anas americana)

American Black Duck (Anas rubripes)

Mallard (Anas platyrhynchos)

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Blue-winged Teal (Anas discors)

Northern Shoveler (Anas clypeata)

Northern Pintail (Anas acuta)

Green-winged Teal (Anas crecca)

Ring-necked Duck (Aythya collaris)

Greater Scaup (Aythya marila)

Lesser Scaup (Aythya affinis)

Common Eider (Somateria mollissima)

Surf Scoter (Melanitta perspicillata)

White-winged Scoter (Melanitta fusca)

Black Scoter (Melanitta nigra)

Long-tailed Duck (Clangula hyemalis)

Bufflehead (Bucephala albeola)

Common Goldeneye (Bucephala clangula)

Hooded Merganser (Lophodytes cucullatus)

Common Merganser (Mergus merganser)

Red-breasted Merganser (Mergus serrator)

GALLIFORMES PHASIANIDAE

Tetraoninae

Ruffed Grouse (Bonasa umbellus)

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GAVIIFORMES GAVIIDAE

Red-throated Loon (Gavia stellata)

Common Loon (Gavia immer)

PODICIPEDIFORMES PODICIPEDIDAE

Pied-billed Grebe (Podilymbus podiceps)

Horned Grebe (Podiceps auritus)

Red-necked Grebe (Podiceps grisegena)

PELECANIFORMES PHALACROCORACIDAE

Double-crested Cormorant (Phalacrocorax auritus)

CICONIIFORMES ARDEIDAE

American Bittern (Botaurus lentiginosus)

Great Blue Heron (Ardea herodias)

Great Egret (Ardea alba)

Green Heron (Butorides virescens)

CATHARTIDAE

Turkey Vulture (Cathartes aura)

FALCONIFORMES ACCIPITRIDAE

Pandioninae

Osprey (Pandion haliaetus)

RAPTORS:

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Accipitrinae

Bald Eagle (Haliaeetus leucocephalus)

Northern Harrier (Circus cyaneus)

Sharp-shinned Hawk (Accipiter striatus)

Cooper‘s Hawk (Accipiter cooperii)

Northern Goshawk (Accipiter gentilis)

Red-shouldered Hawk (Buteo lineatus)

Broad-winged Hawk (Buteo platypterus)

Red-tailed Hawk (Buteo jamaicensis)

Rough-legged Hawk (Buteo lagopus)

Golden Eagle (Aquila chrysaetos)

FALCONIDAE Falconinae

American Kestrel (Falco sparverius)

Merlin (Falco columbarius)

Peregrine Falcon (Falco peregrinus)

GRUIFORMES RALLIDAE

American Coot (Fulica americana)

GRUIDAE Gruinae

Sandhill Crane (Grus canadensis)

CHARADRIIFORMES

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CHARADRIIDAE Charadriinae

Black-bellied Plover (Pluvialis squatarola)

Semipalmated Plover (Charadrius semipalmatus)

Killdeer (Charadrius vociferus)

SCOLOPACIDAE Scolopacinae

Greater Yellowlegs (Tringa melanoleuca)

Lesser Yellowlegs (Tringa flavipes)

Solitary Sandpiper (Tringa solitaria)

Spotted Sandpiper (Actitis macularius)

Whimbrel (Numenius phaeopus)

Sanderling (Calidris alba)

Semipalmated Sandpiper (Calidris pusilla)

Least Sandpiper (Calidris minutilla)

Dunlin (Calidris alpina)

Short-billed Dowitcher (Limnodromus griseus)

Wilson‘s Snipe (Gallinago delicata)

American Woodcock (Scolopax minor)

LARIDAE Larinae

Bonaparte‘s Gull (Larus philadelphia)

Ring-billed Gull (Larus delawarensis)

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Herring Gull (Larus argentatus)

Lesser Black-backed Gull (Larus fuscus)

Great Black-backed Gull (Larus marinus)

Sterninae

Caspian Tern (Sterna caspia)

Common Tern (Sterna hirundo)

Forster‘s Tern (Sterna forsteri)

Black Tern (Chlidonias niger)

COLUMBIFORMES COLUMBIDAE

Rock Pigeon (Columba livia)

Mourning Dove (Zenaida macroura)

CUCULIFORMES CUCULIDAE

Coccyzinae

Black-billed Cuckoo (Coccyzus erythropthalmus)

Yellow-billed Cuckoo (Coccyzus americanus)

STRIGIFORMES STRIGIDAE

Eastern Screech-Owl (Megascops asio)

Great Horned Owl (Bubo virginianus)

Boreal Owl (Aegolius funereus)

Northern Saw-whet Owl (Aegolius acadicus)

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CAPRIMULGIFORMES CAPRIMULGIDAE

Chordeilinae

Common Nighthawk (Chordeiles minor)

Caprimulginae

Whip-poor-will (Caprimulgus vociferus)

APODIFORMES

APODIDAE Chaeturinae

Chimney Swift (Chaetura pelagica)

TROCHILIDAE

Ruby-throated Hummingbird (Archilochus colubris)

CORACIIFORMES ALCEDINIDAE Cerylinae

Belted Kingfisher (Ceryle alcyon)

PICIFORMES PICIDAE Picinae

Red-headed Woodpecker (Melanerpes erythrocephalus)

Red-bellied Woodpecker (Melanerpes carolinus)

Yellow-bellied Sapsucker (Sphyrapicus varius)

Downy Woodpecker (Picoides pubescens)

Hairy Woodpecker (Picoides villosus)

Black-backed Woodpecker (Picoides arcticus)

Northern Flicker (Colaptes auratus)

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Pileated Woodpecker (Dryocopus pileatus)

PASSERINES

PASSERIFORMES

TYRANNIDAE Fluvicolinae

Olive-sided Flycatcher (Contopus cooperi)

Eastern Wood-Pewee (Contopus virens)

Yellow-bellied Flycatcher (Empidonax flaviventris)

Alder Flycatcher (Empidonax alnorum)

Willow Flycatcher (Empidonax traillii)

Least Flycatcher (Empidonax minimus)

Eastern Phoebe (Sayornis phoebe)

Tyranninae

Great Crested Flycatcher (Myiarchus crinitus)

Eastern Kingbird (Tyrannus tyrannus)

LANIIDAE

Northern Shrike (Lanius excubitor)

VIREONIDAE

White-eyed Vireo (Vireo griseus)

Yellow-throated Vireo (Vireo flavifrons)

Blue-headed Vireo (Vireo solitarius)

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Warbling Vireo (Vireo gilvus)

Philadelphia Vireo (Vireo philadelphicus)

Red-eyed Vireo (Vireo olivaceus)

CORVIDAE

Blue Jay (Cyanocitta cristata)

American Crow (Corvus brachyrhynchos)

Common Raven (Corvus corax)

ALAUDIDAE

Horned Lark (Eremophila alpestris)

HIRUNDINIDAE Hirundininae

Purple Martin (Progne subis)

Tree Swallow (Tachycineta bicolor)

N. Rough-winged Swallow (Stelgidopteryx serripennis)

Bank Swallow (Riparia riparia)

Cliff Swallow (Petrochelidon pyrrhonota)

Barn Swallow (Hirundo rustica)

PARIDAE

Black-capped Chickadee (Poecile atricapillus)

SITTIDAE Sittinae

Red-breasted Nuthatch (Sitta canadensis)

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White-breasted Nuthatch (Sitta carolinensis)

CERTHIIDAE Certhiinae

Brown Creeper (Certhia americana)

TROGLODYTIDAE

Carolina Wren (Thryothorus ludovicianus)

House Wren (Troglodytes aedon)

Winter Wren (Troglodytes troglodytes)

Marsh Wren (Cistothorus palustris)

REGULIDAE

Golden-crowned Kinglet (Regulus satrapa)

Ruby-crowned Kinglet (Regulus calendula)

SYLVIIDAE Polioptilinae

Blue-gray Gnatcatcher (Polioptila caerulea)

TURDIDAE

Eastern Bluebird (Sialia sialis)

Townsend‘s Solitaire (Myadestes townsendi)

Veery (Catharus fuscescens)

Gray-cheeked Thrush (Catharus minimus)

Swainson‘s Thrush (Catharus ustulatus)

Hermit Thrush (Catharus guttatus)

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Wood Thrush (Hylocichla mustelina)

American Robin (Turdus migratorius)16

The Ausauble Bird Observatory at Pinery Provincial Park indicates a similar bird

list and the records from Haldimand Bird Observatory are also similar. Banders

have noted that the species composition is almost identical as the birds migrate

up the Lake Huron coast. Cindy Cartwright indicates that she has shared several

recaptures (birds banded in one location and recaptured later at another site)

with the Ausauble station.

Because of annual use of Arran Lake by significant numbers of

staging birds, and the importance of the adjacent fields for

feeding areas, the site must be considered as ―very high

sensitivity‖.

However, the wind turbines themselves would not be the only hazard for

migrating birds. According to the Kingsley and Whittam background review,

―disturbance can be a factor for migrants if wind turbines are

located near important staging areas, where large numbers of

birds concentrate to rest or feed . . .(e.g., stage during fall

migration). Additionally, the alteration or destruction of habitat

used by birds on migration can also contribute to adverse

environmental effects (see Milko 1998a).18

18

(http://www.canwea.ca/images/uploads/File/Resources/Wind_Turbines_and_Birds_a_Background_Review.pdf)

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Manville also reminds us that there are miles of transmission lines associated

with wind turbine developments.

―In addition, birds can collide with towers, nacelles,

meteorological tower guy wires, power lines, their associated

structures, and ―bird-unfriendly‖ wiring can electrocute

them.…The Service has special concerns about project

development on avifauna‖ 19

The Canadian Wildlife Service document also notes the danger of overhead wires

to birds:

NEWLY INSTALLED TRANSMISSION LINES AT BRUCE TOWNSHIP WIND TURBINE DEVELOPMENT NEAR KINCARDINE

―5.5 Mortality Caused by Wires Onshore Facilities

Since the late 1800s, high-tension lines have been noted as a cause of avian

mortality in North America. The U.S. Fish and Wildlife Service (Manville 2000)

estimates that there are tens of thousands of bird fatalities a year due to collision

with overhead wires. However, this estimate may be too low if a study by Koops

19

Manville, op. cit.

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(1987) in the Netherlands is applicable to the North American situation. Based on

estimates of Koops (1987), approximately 174 million birds could be killed

annually by transmission wires in the U.S.

MASSIVE HABITAT DESTRUCTION AND FRAGMENTATION AT BRUCE TOWNSHIP WIND TURBINE DEVELOPMENT SUBSTATION NEAR KINCARDINE

―Several groups of birds appear to be the most susceptible to collision

with wires, most notably waterfowl, shorebirds and raptors (Stout and

Cornwell 1976, Curtis 1977, Anderson 1978, Enderson and Kirven 1979, NUS

Corporation 1979, Olsen and Olsen 1980, Moorehead and Epstein 1985, Faanes

1987). Raptors are frequent victims of wire collisions (Enderson and

Kirven 1979, Olsen and Olsen 1980). For example, overhead wires are believed to

be one of the main causes of injury and death to Merlins (Falco columbarius)20 in

Great Britain (Olsen and Olsen 1980).

20

Merlins are known to migrate through the Arran Lake site.

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―Waterfowl and shorebirds may show avoidance behaviour to turbines, but

significant numbers have been known to collide with associated

power lines, especially when located near wetlands (Anderson 1978,

NUS Corporation 1979, Moorehead and Epstein 1985). At a power plant in

Illinois, an estimated 400 birds each autumn (0.4% of the peak number present)

were killed by colliding with overhead power lines; most of the known victims

were Bluewinged Teal (Anas discors; Anderson 1978). Powerline strikes are the

cause of up to 64% of collision fatalities for certain waterfowl species, but wires

also take a toll on shorebirds. At Trinidad, California, more than 150 Red-necked

Phalaropes (Phalaropus lobatus) were killed on 6 May 1969 by striking electric

wires along the coast (Gerstenberg 1972)‖.21

At Arran Lake, the raptors that spend much of their time

soaring over the drumlin ridges, would be susceptible to

entanglement in the maze of new transmission lines required

for this project as well as rotor blades. Raptors fail to perceive such

hazards during concentrated hunting and the wind turbines and

interconnecting wires would be spread throughout their customary

hunting territory.

Clearly, migratory birds using a wetland or lake as a stopover

or staging area will not be protected unless an adequate

corridor of at least ten miles is kept open for their approach

and departure around the lake.

21

Kingsley and Whittam. Wind Turbines and Birds. Canadian Wildlife Service 2005.

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Birds from Chantry Island Federal Migratory Bird Sanctuary are also

threatened. At Arran Lake, however, there is a further complication. Birds

using the Chantry Island Bird Sanctuary (IBA On 154) are regularly observed to

spend part of their day foraging in the fields around the lake. Their presence has

also been recorded in the historical documents of the OMNR specific to Arran

Lake. In effect this means that there is an additional, daily avian flight

path between roosting areas on the island and foraging areas around

the lake. This corridor is used by Herring Gulls, Black Terns, Caspian Terns,

Great Blue Herons, Black-crowned Night Herons, and Great Egrets among

others. Many of these birds are slow to gain height on takeoff and their path

would take them through the proposed wind turbine site.

Wind turbines if situated between Arran Lake and the Saugeen

River would, effectively fragment the habitat of species roosting

on Chantry Island and feeding in the wetlands and uplands

surrounding the lake.

Transmission lines would be an additional hazard. This would

have a direct effect on the survival of birds in the nesting

colonies on the Federal Bird Sanctuary (IBA) at Chantry Island.

INTERCONNECTING WILDLIFE CORRIDORS

It can be seen from the wildlife corridors on the map below, how closely this

natural heritage system is knit together. Studies have shown the importance of

wildlife corridors in maintaining diversity and resiliency in an ecosystem (Riley

and Mohr 1994).

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WILDLIFE CORRIDORS: Orange blocks represent corridors within the wildlife habitat system that follow streams and woodlands between the Saugeen River valley lands and the Arran Lake wetlands complex. The yellow arrow represents daily movement flyway between roosting and feeding areas used by birds from IBA at Federal Bird Sanctuary on Chantry Island (Southampton) (10 kilometres) regularly observed foraging in fields surrounding Arran Lake.

Around Arran Lake, these links follow upland forested areas—a series of

farmstead woodlots that were never cleared on the back forty acres of each crown

land grant. Despite their gradual diminishment over the years, they still form a

residual wooded section at the back of most farms, each converging onto the

midpoint between two concession roads. This provides a singularly undisturbed

wildlife corridor, seldom visited by humans.

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The siting of wind turbines near these quality forest habitat

corridors would result in habitat fragmentation.

SIGNIFICANT WOODLAND/OLD GROWTH TREES

The Ontario Nature Reserves Program—Life Sciences Inventory Check-sheet for

Arran Lake dated 2 December 1984 notes:

―A small forested drumlin is part of Arran Lake South (41A/6 790230)

and forested drumlin slopes occur in Arran Lake North (41A11 810275).

Forested drumlin and wetland complexes are scarce in this site

district [6-5 and 6-2] and in southern Ontario as a whole. This

candidate nature reserve should be examined in field.‖22

RARE FORESTED DRUMLIN WITH MATURE TREES IN KRUG WOODLOT BESIDE ARRAN LAKE

Several of these forest corridors are uncommon woodland dominated by

old trees and old-growth. The Krug woodlot on Arran Side Road 5, (known

22 Ministry of Natural Resources Earth Science Database, http://nhic.mnr.gov.on.ca/MNR/nhic/areas/areas_report.cfm?areaid=7914

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locally as Billy Macintosh‘s Hill) for example, has remained totally undisturbed

for many decades. Not even dead trees are removed from the site and these

provide shelter for a range of animals and birds. Its contiguity with the lake

provides an important specialized habitat for sensitive species. It contains

Butternut stands (a provincially threatened tree species).

OLD GROWTH FOREST, KRUG WOODLAND AT ARRAN LAKE

The lands adjoining the Saugeen River are also wooded and some of the islands in

the river contain a few very old examples of Eastern White Cedar (Thuja

occidentalis) as well as Butternut stands.

RAPTOR HABITAT AND HUNTING TERRITORY

Notable in many of the woodlots found on the ridges of the drumlins are the

raptors nesting in tall trees. Several species of Hawk, (including the Red

Shouldered Hawk), vultures, owls and the Bald Eagle (protected under the Fish

and Wildlife Conservation Act) favour this habitat. The adjacent fields (in the

immediate vicinity of the proposed turbine installations) contain high densities of

voles and field mice, favourite raptor prey. Even larger numbers of hawks and

owls are attracted to this area during years of the peak cycles of these rodents.

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RAPTORS USING THE SITE DURING MIGRATION WOULD

INCLUDE:

Northern Harrier (Circus cyaneus)

Sharp-shinned Hawk (Accipiter striatus)

Cooper‘s Hawk (Accipiter cooperii)

Northern Goshawk (Accipiter gentilis)

Red-shouldered Hawk (Buteo lineatus)

Eastern Screech-Owl (Megascops asio)

Broad-winged Hawk (Buteo platypterus)

Red-tailed Hawk (Buteo jamaicensis)

Rough-legged Hawk (Buteo lagopus)

Golden Eagle (Aquila chrysaetos)

Boreal Owl (Aegolius funereus)

Northern Saw-whet Owl (Aegolius acadicus)

American Kestrel (Falco sparverius)

Merlin (Falco columbarius)

Peregrine Falcon (Falco peregrinus)

Snowy Owl (Bubo scandiacus)

Additionally present at other times of the year are:

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Bald Eagle (Haliaeetus leucocephalus)

Great Horned Owl (Bubo virginianus)

Wind farms can affect local populations of Eagles and other

raptors whose breeding and recruitment rates are naturally

slow

Manville and many other researchers specifically mention their apprehension

over the safety of raptors nesting and hunting in close proximity to wind energy

facilities.

Appendix 7 of the USFWS Interim Guidelines to Avoid and Minimize Wildlife

Impacts from Wind Turbines lists the ―Known and suspected impacts of wind

turbines on wildlife‖. It is particularly concerned about the safety of raptors,

waterbirds, passerines and bats:

―However, even with a bright future for growth, and with low speed tubular-

constructed wind turbine technology now being stressed, larger and slower

moving turbines still kill raptors, passerines, water birds, other avian

species, and bats. Low wind speed turbine technology requires much larger

rotors, blade tips often extending more than 420 ft. above ground, and blade tips

can reach speeds in excess of 200 mph under windy conditions (J. Cadogan, U.S.

Department of Energy, 2002, pers. comm.). When birds approach spinning

turbine blades, ―motion smear‖ – the inability of the bird‘s retina to process high

speed motion stimulation – occurs primarily at the tips of the blades, making the

blades deceptively transparent at high velocities. This increases the likelihood

that a bird will fly through this arc, be struck by a blade, and be killed (Hodos et

al. 2001).

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―What cumulative impact these larger turbines will have on birds and bats has yet

to be determined. Johnson et al. 2002b raised some concerns about the impacts

of newer, larger turbines on birds.

―Their data indicated that higher levels of mortality might be associated with the

newer and larger turbines, and they indicated that wind power related avian

mortality would likely contribute to the cumulative impacts on birds.

―Howell and Noone (1992) estimated U.S. avian mortality at 0.0 to 0.117

birds/turbine/yr., while in Europe, Winkelman (1992) estimated mortality at 0.1

to 37 birds/turbine/yr. Erickson et al. (2001) reassessed U.S. turbine impact,

based on more than 15,000 turbines (some 11,500 in California), and estimated

mortality in the range of 10,000 to 40,000 (mean = 33,000), with an average of

2.19 avian fatalities/turbine/yr. and 0.033 raptor fatalities/turbine/yr. This may

be a considerable underestimate. As with other structural impacts, only a

systematic turbine review will provide a more reliable estimate of mortality‖.23

WOLFE ISLAND INDICATES THAT MORTALITY TO RAPTORS

IS MUCH HIGHER:

―The estimated total bird mortality for the Reporting Period is 6.99 birds/turbine

(3.04 birds/MW).‖

“Correcting seasonally for searcher efficiency, scavenger and other removal

rates, and the percent area searched, the 12 raptor/vulture and 88 other

23 USFWS Interim Guidelines to Avoid and Minimize Wildlife Impacts from Wind Turbines p. 50.

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bird carcasses recovered represent approximately 602 bird fatalities over

the course of this [six month] Reporting Period”.

(FATALITIES) Seven of the species have been identified as species of

conservation priority by Ontario Partners in Flight (2006):

American Kestrel (one on each of July 1 and August 31),

Northern Flicker (one on October 8),

Black-billed Cuckoo (one on July 14),

Eastern Kingbird (one on each of July 28 and August 17),

Bank Swallow (one on August 17),

Savannah Sparrow (one on September 10),

and Bobolink (eight fatalities between July 27 and September 10). In late

summer and fall, young Bobolinks have left the nest and have joined mobile

flocks of fledglings and adults that move about the breeding habitat.

Over the Reporting Period, a total of 28 Tree Swallow fatalities were recorded at

22 different WTGs. Sixteen of 28 (57%) Tree Swallow fatalities were juvenile

birds. Together with Bank Swallow (one fatality), Barn Swallow (two fatalities),

and Purple Martin (seven fatalities), swallows and martins represented 38 (38%)

of the 100 recorded bird fatalities during the course of the Reporting Period.

Two WTGs were each responsible for three swallow/martin fatalities, and five

turbines were each responsible for two swallow/martin fatalities. There was no

apparent clustering of swallow/martin fatalities.

Twelve raptor and vulture fatalities were recorded over the course of this

Reporting Period:

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six Turkey Vultures,

three Red-tailed Hawks,

two American Kestrels, and

one Merlin.

Correcting seasonally for searcher efficiency, scavenger and other removal rates,

and the percent area searched, the 12 raptor/vulture and 88 other bird carcasses

recovered represent approximately 602 bird fatalities over the course of this

Reporting Period.

The estimated total bird mortality for the Reporting Period is 6.99 birds/turbine

(3.04 birds/MW)‖.

While some have argued that turbine impacts are small (Berg

1996), especially when compared to those from communication

towers and power lines, turbines can pose some unique

problems, especially for birds of prey. Mortalities must be reduced,

especially as turbine numbers increase. . . .

Wind farms can affect local populations of Eagles and other

raptors whose breeding and recruitment rates are naturally

slow and whose populations tend to have smaller numbers of

breeding adults (Davis 1995).

Large raptors are also revered by Native Americans as well as

by many others within the public. They are symbolic mega

fauna, and provide greater emotional appeal to many than do

smaller avian species.

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Raptors also have a lower tolerance for additive mortality

(Anderson et al. 1997). As with all other human caused

mortality, we have a responsibility to reverse mortality

trends.24

Because of the Arran Lake site‘s importance to raptors it must

be considered of ―very high sensitivity‖.

Deliberately jeopardizing the raptor population within this natural

heritage system would severely upset its balanced ecological functions

(including rodent control). Raptors would be at risk of being pushed

into the blades by strong winds coming off Lake Huron. The slow

breeding rates and lower tolerance for additive mortality of raptors and the fact

that the wind turbines would be placed in the middle of their hunting territory

would be an unacceptable formula for disaster for this group of birds.

STORM APPROACHING ARRAN LAKE

24

Ibid.

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Failing to protect the Bald Eagle from such harm would also be

an offence under the Fish and Wildlife Conservation Act.

IMPORTANCE OF THE UPLANDS AT ARRAN LAKE

It can be seen from the map above that these corridors follow creek beds running

either towards the lake or to the river. Because of the surrounding elevated ridges

of the drumlins, these creeks follow fairly deep, wooded valleys and swales—land

that was never considered useful for agriculture and has therefore remained

largely undisturbed since settlement.

Adjacent uplands are important for many wetland species at

Arran Lake, and they are critical for the maintenance of its

wetland functions.

Waterfowl such as Canada Geese forage in the fields around the wetlands.

Grassland nesters include Meadowlark, Bobolink and certain grassland sparrows.

The abundant population of woodland frogs such as Spring Peepers rely on the

spring-flooded thicket swamps and marshes for breeding, but forage and

hibernate in the surrounding upland forests and plantations. Other frogs at Arran

Lake such as the Bull Frog, Northern Leopard Frog, Wood Frog, and Green Frog

forage in fields a considerable distance from the wetlands. They also move

between wetlands, hibernating in the bottom of deeper permanent ponds, and

breeding in more shallow wetlands.

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The Lake and wetlands are abundant with fish.25 The Snapping Turtles and

Painted Turtles at Arran Lake live year-round in permanent wetlands, but lay

their eggs in the surrounding uplands. These areas provide a source of prey for

some of the water birds.

It is well known that amphibians are particularly sensitive to

noise disturbance. It is beyond dispute that the noise

disruption caused by wind turbines would result in

abandonment by this part of the system‘s population.

The normally referred to 40-50 db is the noise at a point of reception usually 300

to 600 metres away from the turbine—well above the normal background noise in

this exceedingly quiet area).26 But the ―noise at source‖ from modern turbines

can be much higher. Clearly any animals in close proximity to the turbines may

encounter db levels much higher than 40-50 db.

This would have potential impact on endangered grassland

species. The knock on effect would be loss of prey for many of

the bird species inhabiting the wetlands.

It is also known that wind turbines transmit vibrations into the ground that can

be measured at a distance of a mile away.

25

Fish species found in Arran Lake include: largemouth bass, smallmouth bass, northern pike, yellow perch, rock bass, pumpkinseed, white sucker, brown bullhead, yellow bullhead, golden shiner, back chin shiner, emerald shiner, black nose shiner, river chub, blunt nose minnow, common shiner, Iowa darter, and Johnny darter. All of these species are typical of a warm water lake. List courtesy Kathy Dodge, OMNR Owen Sound. (From the inventory of fish in Arran Lake done in the late ‘80’s). 26

Traffic noise on has now been proved to reduce bird breeding density. Four Dutch ornithologists (Rien Reijnen, Ruud Foppen, Cajo ter Braak and Johan Thissen) took paired sites close to and distant from busy roads and analyzed the densities of 43 different species of breeding birds in woodland. Of these 26 species (60%)

showed evidence of reduced density. The analysis clearly showed that it was the noise and not the sight of the traffic that was affecting the birds. Two other studies also published in the Journal of Applied Ecology - one of the scientific journals published by the British Ecological Society, (1994 31, 95-101; 31, 85-94 & 32, 187-202), confirm this finding.

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WIND TURBINES CAUSE LONG TERM HABITAT

DISTURBANCE AND DEGRADATION

Many biologists who have studied the effects of wind turbines are even more

worried about long term habitat degradation and disturbance.

Manville is apprehensive about the long term effects on wildlife:

―B. Habitat fragmentation, disturbance and disruption

―Habitats can be fragmented, disturbed, and disrupted, forcing

out birds and bats, preventing breeding, altering behaviours, and

possibly impacting populations (evidence raised in Europe).

―Indirect effects, although frequently difficult to quantify, can include:

reduced nesting/breeding densities;

2) loss of population vigour and overall density;

3) habitat and site abandonment, and increased isolation between

patches;

4) loss of refugia;

5) attraction to modified habitats;

6) behavioural effects including stress, interruption, and behavioural

modification; and

7) disturbance and displacement resulting in habitat unsuitability.

―As taller and larger wind turbines are installed on land nationwide, the potential

for growing numbers of deaths and large-scale habitat fragmentation increases.

As the industry grows, these indirect effects will also become cumulative.

Both direct and indirect effects could become additive to normally compensatory

mortality – a scenario we wish to avoid. More than 20,000 commercial turbines

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presently operate in the U.S., and within 10 years that number is projected to

increase to > 155,000 (M. Tuttle pers. comm., AWEA data, National Renewable

Energy Laboratory estimate). This explosive growth without the

availability of ―tools‖ to address it – specifically to avoid or minimize

impacts to bird, bats, and their habitats – is troubling.‖27

In his Senate testimony Mike Daulton of National Audubon also stressed the

problem of loss or degradation of habitat, disturbance and displacement as well

as disruption of ecological links:

―Development of wind power facilities results in destruction of

habitat from support roads, storage and maintenance yards,

turbine towers, and associated infrastructure. It may involve

blasting and excavation to bury power lines. Such activity may cause

contiguous blocks of habitat to become fragmented, leading to

increased abundance of predators, parasites, and invasive species. . . . It

can have substantial impacts if the wind energy facilities are sited in areas

of pristine or rare native habitats.

DISTURBANCE AND SUBSEQUENT DISPLACEMENT FROM

HABITAT:

―The impacts of wind energy facilities extend well beyond the

footprint of the roads, power lines, and other structures.

27

Dr Albert Manville. Current Avian Issues and Land-Based Wind Turbine Developments. U.S. Fish and Wildlife Service briefing dated April 4, 2008.

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Disturbance from human activity and turbines may displace

animals from the habitat. While this is seldom lethal, it may cause

birds and other animals to abandon preferred habitat and seek lower-

quality habitat elsewhere, where disturbance is less. This may result in

reduced survival or reduced breeding productivity, which may

cause lower or declining populations.

“In cases where the birds affected are already in decline, the

turbines could push them closer to extinction.

DISRUPTION OF ECOLOGICAL LINKS:

Large wind energy facilities may interfere with the ability of

birds and other wildlife to travel between feeding, wintering,

and nesting sites. Alternatively, they may cause birds to make longer or

higher flights between such areas. This results in higher metabolic costs,

and therefore may reduce survival and reproduction.28

HABITAT ABANDONMENT / REDUCTION OF ABUNDANCE

Abandonment of habitat is also a finding of one of the most recent research

projects at the Centre for Evidence Based Conservation, School of Biosciences,

University of Birmingham in the United Kingdom. In their SYSTEMATIC

REVIEW NO. 4: Effects of wind turbines on bird abundance Review Report,

Stewart, Pullin, & Coles concluded:

28

Impacts of Wind Turbines on Birds and Bats. Testimony of Mike Daulton Director of Conservation Policy National Audubon Society before the U.S. Senate Committee on Natural Resources Subcommittee on Fisheries, Wildlife and Oceans May 1, 2007.

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―Available evidence suggests that windfarms reduce the

abundance of many bird species at the windfarm site.

―There is some evidence that Anseriformes (ducks) experience

greater declines in abundance than other bird groups

suggesting that a precautionary approach should be adopted to

windfarm developments near aggregations of Anseriformes

and to a lesser extent Charadriformes ( Gulls and Terns).

―There is also some evidence that impact of windfarms on bird

abundance becomes more pronounced with time, suggesting that

short term bird abundance studies do not provide robust indicators of the

potentially deleterious impacts of wind farms on bird abundance‖. 29

These findings suggest that a wind turbine development near the

Arran Lake natural heritage system would have long term and

permanent negative effects on bird populations and would

likely lead to declines in the population of ducks, gulls and

terns using the site. Two of these species, the Black Tern and

the Caspian Tern are already threatened, area sensitive and in

serious decline.

29 Stewart, Pullin, & Coles. SYSTEMATIC REVIEW NO. 4: Effects of wind turbines on bird abundance Review Report. University of Birmingham: 2006.

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The lake and surrounding wetlands are habitat for an abundance and diversity of

Anseriforme species. These include Mallards, Common Mergansers, Golden-eyed

Buffleheads, Wood Ducks, Redhead Ducks, Pinheads, Northern Pintails, as well

as Canada Geese. Tundra Swans have also been catalogued by local ornithologists

on the river, over the lake and over the surrounding uplands during migration.

Horned Grebes frequent the lake. Many of these species are regularly seen

foraging in the surrounding fields, the site of the proposed wind turbines. They

are also often seen during flight displays and are noted for their very slow ascent

on takeoff, a factor which would expose them to the rotating blades of the

turbines, especially during migration.

It must therefore be assumed that if wind turbines were built

adjacent to the wetlands, a major component of the natural

heritage system would suffer decline.

In the light of this evidence, it would be impossible to

demonstrate that there would be no negative impacts on the

natural features or on their ecological functions from such

development.

In view of the growing body of scientific literature that points to the adverse

effects of wind turbines on environmentally sensitive areas, it would be

impossible to conclude, beyond any reasonable doubt, that a wind

turbine project proposed for farmland within the Arran Lake natural

heritage system would be without negative impacts on the natural

features or on their ecological functions.

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Since the project, taking mitigation into account, is likely to lead to significant

adverse long term effects, it should be abandoned. Proponents should consider

other locations.

It is clear from the species found here and their dependence on the interrelating

habitats within this natural heritage system that this site is highly sensitive and

should be avoided by wind turbine development.

SPECIES AT RISK AT ARRAN LAKE

―At a minimum, municipalities must protect the habitat of

endangered and threatened species‖. Conservation Priorities for

the Birds of Southern Ontario, Ministry of Natural Resources.

―The presence of listed species at risk, the residences of individuals of those

species or their critical habitat is an indication that special considerations are

required. Proponents must comply with the requirements of the SARA [Species

At Risk Act].‖

―The SARA protects plants and animals listed in Schedule 1 of the Act (the List of

Wildlife Species at Risk). SARA prohibitions apply to aquatic species and

migratory birds protected under the Migratory Birds Convention Act, 1994

wherever they are found‖.30

―The SARA also requires that every person required by federal law to ensure that

an EA is conducted must (1) notify the competent minister(s) in the likelihood

that a project will affect a listed wildlife species or its critical habitat; (2) identify

30

EA Guidance Document: Wind Turbines and Birds, Page 25. April 2007

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the adverse effects of the project on the listed wildlife species and its critical

habitat.

For more information on listed species and environmental assessment

requirements, please consult the SARA Public Registry at

http://www.sararegistry.gc.ca/default_e.cfm. Guidance material on species at

risk and environmental assessment is also available on the CWS Web site at

http://www.cws-scf.ec.gc.ca/publications/eval/index_e.cfm.

The Migratory Birds Convention of 1916 between the USA and Canada is an

international treaty implemented in Canada by the federal Migratory Birds

Convention Act, 1994 (MBCA) and accompanying regulations.

The Migratory Birds Regulations (MBR), in Section 6, prohibit the disturbance,

destruction, and taking of a nest or egg of a migratory bird; or the possession of a

live migratory bird, or its carcass, skin, nest or egg, except under authority of a

permit. It is important to note that under the current MBR, no permits can be

issued for the incidental take of migratory birds caused by development projects

or other economic activities‖.

• The Arran Lake Natural Heritage System is an important

habitat for many protected, endangered or threatened

species.

• These include one significant percentage of the national

population and one species in recovery program.

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• The effects of habitat fragmentation and disturbance

resulting in habitat avoidance raise potentially

enormous issues for declining species.

• New evidence shows that the impact of wind farms on

bird abundance becomes more pronounced with time.

According to Environment Canada:

―Many bird populations in Canada and North America have been declining,

especially over the past thirty years. Several species have lost half their numbers

in only one human generation, and this rate of decline is of concern to scientists,

naturalists and increasingly, to the general public. These declines are due to a

number of factors, including loss and degradation of breeding and

wintering habitats, impacts of chemicals such as pesticides, as well as

collisions with tall structures (buildings, towers, power lines, etc.) on

migration or while staging, wintering, or breeding.

―Most birds that occur in Canada migrate between breeding and wintering areas.

As the conservation of migratory birds is the joint responsibility of all countries

they visit during the year, the Canadian government is a party to international

efforts to protect migratory birds and their habitats.‖31

Environment Canada has indicated that 11 to 15 species at risk

are found in the Arran Lake vicinity—the second highest

category in Canada. 32

31

Wind Turbines and Birds A Guidance Document for Environmental Assessment. April 2007; Environment Canada: Canadian Wildlife Service, p.7. 32

http://www.sis.ec.gc.ca/ec_species/

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PROTECTED, COSEWIC, SARA AND MNR ENDANGERED AND

THREATENED SPECIES AT ARRAN LAKE33

The Arran Wetlands Natural Habitat System is home to over a dozen avian

protected, COSEWIC, SARA or MNR endangered and threatened species and

Ontario Birds at Risk (OBAR) or species protected under the Fish and Wildlife

Conservation Act and listed under Ontario Endangered Species Act. The

Natural Heritage component of the Provincial Policy Statement under

Ontario's Planning Act provides for the protection of significant

portions of the habitat of species listed in regulation under the

Endangered Species Act.

BIRDS AT RISK AT ARRAN LAKE:

1. THE BALD EAGLE (Haliaeetus leucocephalus)

Bald eagles are known to nest in the Arran Lake area. They are also regularly seen

soaring over the lake and the river. Since ―wind farms can affect local

populations of Eagles . . . whose breeding . . . rates are naturally slow

and whose populations tend to have smaller numbers of breeding

adults‖ (Davis 1995), it is probable that any wind turbines sited in the

Arran Lake vicinity would have a detrimental effect upon this

protected species which is regulated under the Fish and Wildlife Conservation

Act and also Ontario's Endangered Species Act (E.S.A.) in southern Ontario.

33

MNR Natural Heritage Information Centre Data on rare species in Ontario: http://nhic.mnr.gov.on.ca/MNR/nhic/species/listout.cfm?el=ab&sort=elcode

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2. LEAST BITTERN (Ixobrychus exilis)

The presence of this SARA and COSEWIC ―threatened‖ species and its use

of the proposed wind turbine site as part of its habitat makes this site one of

―very high sensitivity‖. In view of the documented destructive effect of

wind turbines on low flying birds and the fact that the least bittern is an

important species found at Arran Lake, it would be impossible to

demonstrate that this development would not effect the ecological

function of the wetlands or the surrounding natural heritage system.

Its very small and declining population depends on high quality marsh habitats

that are being lost and degraded across the species' range. For more details on

this species please see Appendix 2.

3. RED SHOULDERED HAWK (Buteo lineatus)

The Red-shouldered Hawk is a specially protected raptor under the Fish and

Wildlife Conservation Act. It is listed as Special Concern by the Ontario

Ministry of Natural Resources. It is one of the raptor species that is particularly

vulnerable from wind turbine developments. Its hunting territory around

Arran Lake corresponds to the elevated drumlin ridges-- the precise

sites of the proposed wind turbines. The vulnerability of the Red-

shouldered Hawk to wind turbine development at Arran Lake

illustrates the importance of protecting an entire natural heritage

system as a functioning ecological unit.

This is an area sensitive species and an indicator species that requires all the

elements of an unfragmented, undisturbed natural heritage system consisting of

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wetlands, open fields, upland ridges, old growth forests and wooded wildlife

corridors.

This site is therefore of ―very high sensitivity‖ and not suitable

for wind turbine development. For more details on this species

please see Appendix 2.

4. KING RAIL (Rallus elegans)

The King Rail is protected under the federal Species at Risk Act (SARA) and listed by

the MNR/ROM as endangered provincially and nationally. It has a very small

population in Canada which shows continued decline. Few patches of remaining habitat

are large enough and of sufficient quality to support this species. ―Loss of wetland

habitat‖ and disturbance ―has been the greatest single factor in the decline of the King

Rail in Ontario, and is the greatest threat to their continued existence.‖ Most of the

wetlands suitable for King Rails have been eliminated. The quality of

the remaining habitat is also deteriorating.34 In view of the sensitivity

of this species to habitat disturbance and the intimate relationship

between the wetland and the ecological function of the surrounding

uplands, it would be impossible to prove that the siting of wind

turbines within this natural heritage system would not cause

disturbance to the wetland and degrade its quality sufficiently that it

could no longer support this endangered species. The presence of this

bird makes the area one of very high sensitivity and it should be

avoided by wind turbine developments. For more details on this species

please see Appendix 2.

5. BLACK TERN (Chlidonias niger)

34

Ibid.

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This bird is listed by the MNR as a species of special concern with the general

Ontario Status as ―sensitive‖.35 The presence of the Black Tern was noted on the

1985 Field Evaluation of the Arran Lake Wetland by the Grey Sauble

Conservation Authority as one of the nesting colonial waterbirds found at the

lake. The Black Tern and its nest are protected under the Migratory

Birds Convention Act. Terns and Gulls are susceptible to wind turbine

mortality. The presence of wind turbines intercepting its migratory

landing at the lake would be an additional threat to this species of

special concern, especially during adverse weather conditions during

the migratory season. For more details on this species please see Appendix 2.

TYPICAL MIGRATORY SEASON FOG AT ARRAN LAKE. EARLY SPRING MIGRANTS ARE FREQUENTLY CAUGHT IN SNOW BLIZZARDS AND FORCED TO FORAGE BESIDE THE ROADS WHEN FIELDS ARE SNOW COVERED.

6. GREAT EGRET (Ardea alba)

35

http://nhic.mnr.gov.on.ca/MNR/nhic/elements/el_report.cfm?elid=180239

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This is one of the birds known to use the daily movement flyway

between breeding and roosting areas at the Federal Bird Sanctuary IBA on

Chantry Island and feeding areas around the Arran Lake wetlands and the

Saugeen River valley lands. The Chantry Island colony represents a

significant part of the Canadian population of this species. The

presence of a significant percentage of the national population of this

species and the fact that it frequently flies directly over the proposed

wind turbine site make this a ―very sensitive area‖. In addition this large

bird is slow to climb on take-off and slow in flight, making it more vulnerable to

collision mortality from the turbine blades, especially during adverse weather

conditions. It is therefore reasonable to expect that if wind turbines

were placed along the daily migratory pathway of this species, some

mortality of a significant part of the national population would occur.

For more details on this species please see Appendix 2.

7. BLACK-CROWNED NIGHT HERON (Nycticorax nycticorax)

The Black-crowned Night Heron is listed by COSEWIC as a ―sensitive‖ species

and by OBAR (Ontario Birds at Risk) as a target species of rare breeding

birds in Ontario.36 The 1985 MNR wetland data record confirms that the

Arran Lake wetlands are a ―feeding habitat for this Provincially Significant

Animal Species‖. This links it to the protected Federal Bird Sanctuary on Chantry

Island. The records of Bird Studies Canada indicate that the field surveys of

Chantry Island in 1991 found 100 nests of Black-crowned Night-Herons. ―This is

at least 2% of the national population. In 1989 and 1990, nationally significant

numbers of this species were also found, with 56 and 97 nests, respectively‖.37

36

http://www.bsc-eoc.org/obar.html 37 http://www.bsc-eoc.org/iba/site.jsp?siteID=ON154

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For more details on this species please see Appendix 2. The presence of

nationally significant numbers of this species and its documented use

of the flyway between the Island and Arran Lake is another reason the

Arran Wetlands Natural Habitat System must be regarded as an area

of ―very high sensitivity‖. The construction of a wind turbine

development along this flyway would endanger a significant number

of the population of this species.

8. CASPIAN TERN (Hydroprogne caspia, formerly Sterna caspia)

The presence of this species is listed in the Ontario Ministry of Natural Resources

Wetland Data Record: Arran Lake.38 In Canada, breeding colonies are few, and

the total numbers of birds relatively low. It was designated as rare by COSEWIC

(1997) and considered to be a vulnerable species in Ontario. It is considered

a target species by the Rare Breeding Birds of Ontario.39 The presence of a

rare tern at Arran Lake makes this an area of very high sensitivity. The

recent research project at the Centre for Evidence Based Conservation, University

of Birmingham referred to above, found that wind turbines reduce the

abundance of many bird species at a wind farm site, and that ―Gulls

and Terns (along with Ducks) experience greater declines in

abundance than other bird groups suggesting that a precautionary

approach should be adopted to wind farm developments near

aggregations of Anseriformes (Ducks) and to a lesser extent

Charadriformes (Gulls and Terns)‖.40 In the same report, there is also

38 Toth, G, Morton, J, & Hill, A. Wetland Data Record: Arran Lake. Ministry of Natural Resources South Western Administrative Region and District Owen Sound: 8 August, 1985. 39

Ontario Birds At Risk (OBAR) Site Registry. Rare breeding birds of Ontario, target species. http://www.bsc-eoc.org/obar.html Site Registry maintained by the Ministry of Natural Resources and the Ontario Rare Bird Breeding Program (Austen et al., 1994). 40

Stewart, Pullin, & Coles. SYSTEMATIC REVIEW NO. 4: Effects of wind turbines on bird abundance Review Report, (2006).

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evidence that the impact of wind farms on bird abundance becomes

more pronounced with time. This, of course, is a major issue for a

rare bird such as the Caspian Tern, whose numbers are already in

decline.

8. SHORT-EARED OWL (Asio flammeus)

This bird has been listed by COSEWIC (April 2008) and by SARA as a species of

Special Concern. It is on the MNR Bruce county priorities for conservation list

of species that are sensitive to disturbance or that are declining. A

functioning, unfragmented natural wildlife system is crucial to to its survival.

Like the other raptors found within the proposed wind turbine development site,

the Short-eared Owl would be especially endangered by the presence of rotor

blades on the drumlin ridges used for hunting. The presence of the turbines and

associated disturbance amid these hunting pastures and hay fields would

inevitably lead to a decline in the abundance of its prey and eventual

abandonment of this traditional habitat by the Short-eared Owl. For more details

on this species please see Appendix 2.

9. RED HEADED WOODPECKER (Melanerpes erythrocephalus)

―This species has experienced a significant decline over the long-term

associated with habitat loss and the removal of dead trees in which it nests.

There is no evidence to suggest that the population trend will be

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reversed.‖41 It is known to nest in old growth forests of the Arran Lake Wetlands

Natural Heritage System, including the Krug woodlot immediately adjacent to the

proposed wind turbine site. The COSEWIC Assessment and Update Status Report

of 2007 lists it as ―threatened‖. It is protected under the Migratory Birds

Convention Act, 1994. In 1996 it was designated by COSEWIC as a species of

Special Concern. (The SARA Registry indicates that it is still declining).42

NatureServe ranks the species as vulnerable in Ontario. In Ontario, the Ministry

of Natural Resources has designated it a species of special concern and it

appears on the provincial species at risk list.

SPECIES IN RECOVERY PROGRAM:

11. LOGGERHEAD SHRIKE (Lanius ludovicianus migrans)

There is also the likelihood of use of this habitat by the Loggerhead Shrike

(COSEWIC, SARA endangered provincially and nationally). It is now a species

in a recovery program. The birds and their eggs are protected by the federal

Migratory Birds Convention Act, 1994. Rare and Endangered Species of Grey

and Bruce County, published by the Owen Sound Field Naturalists, indicates

this part of Arran Township as one of the few traditional nesting

habitats for this bird. Loggerhead shrike nested successfully within

41

COSEWIC Assessment and Update Status Report on the Red-headed Woodpecker Melanerpes erthrocephalus in Canada. Committee on the Status of Endangered Wildlife in Canada. Ottawa, 2007. (www.sararegistry.gc/status/status_e.cfm). 42 http://www.sararegistry.gc.ca/virtual_sara/files/cosewic/sr_melanerpes_erythrocephalus_e.pdf (Technical Summary)

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the proposed site in 2002. They are also historically documented nesting in

the Dunblane area, and near Arkwright, both within the project perimeter.

The Arran Lake uplands, part of the Shrike‘s traditional territory, still

provide a perfect habitat for this bird because of the short grass

pasture land, presence of mature hawthorn trees used for nesting,

and abundance of split rail fences and dead trees used as perches

when hunting. The proposed development would certainly be at odds

with this important rescue program for such a shy bird near

extinction.43

SPLIT RAIL FENCES AND HAWTHORN WITH NEST AT ARRAN LAKE

12. BOBOLINK (Dolichonyx oryzivorus)

43

Elaine Williams, Executive Director, Wildlife Preservation Canada, contact person for the Eastern Loggerhead Shrike Recovery Strategy wrote in an E-mail: “The last known nesting pair in that area was in 2002. However, last year, we had one of our 2006 release birds return to the Dyer’s Bay area, and later that season a reliable birder spotted three shrikes, one was definitely an adult and the other a juvenile (he couldn’t see the other one properly), so there was nesting last year on the Bruce.” The Arran Lake area “is shrike nesting habitat (as long as it has the right mix of habitat features that shrikes require, i.e. short grass or active pasture land, has some snags or hydro poles from which the shrikes can perch and hunt and has hawthorns or thorny apples of the right size for a nesting tree and impaling site), and it should be preserved for the recovery program”.

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In spring, the upland fields around Arran Lake are abundant with this species

notable for their aerial flight displays. The Ontario Breeding Bird Atlas indicates

that Bobolinks have suffered a 28% loss of area occupancy over the last 20

years. The cause is thought to be declining quality and quantity of wet

meadow habitats. As a result, the Bobolink has been placed on the COSEWIC

candidate species list ―Group 1‖—of the highest priority for assessment because it

is ―suspected to be at high risk of extirpation from Canada‖.44 It is

probable that the presence of wind turbines would provide sufficient disturbance

and quality loss to wet meadow habitats of this bird that they would further

contribute to the serious population decline it has already suffered: 84% of its

population over the last 37 years and an even more accelerated population

decline of 53% in only the last 10 years.

Two other similar COSEWIC ―candidate species‖ list birds found at Arran Lake

are:

13. BARN SWALLOW (Hirundo rustica) of concern across Canada.

14. FIELD SPARROW (Spizella pusilla), of concern in Ontario.

REPTILES AT RISK AT ARRAN LAKE:

44

http://www.cosewic.gc.ca/eng/sct3/sct3_1_e.cfm#p2

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SNAKE HIBERNACULUM ARRAN LAKE

15. SPOTTED TURTLE (Clemmys guttata).

In Canada, the Spotted Turtle was designated vulnerable, a Species of Special

Concern) by COSEWIC in 1991. The Ontario Ministry of Natural Resources lists

the species as Vulnerable (1996), and the Ontario General Status is Sensitive

(1999). The Spotted Turtle is listed as a Specially Protected Reptile in

Ontario.45 Because of the habitat range of this vulnerable species and its presence

during part of its annual cycle on land proposed for wind turbine construction, it

is easily foreseeable that habitat fragmentation and disturbance, the building of

roads to the turbine sites, increase of truck traffic during and after construction,

and elimination of some of the traditional nesting environment would have an

adverse effect upon this protected species. Any mortality would be all the more

serious because of the low rates of reproduction of this reptile. Please see

Appendix 2 for additional information on this species.

45 (Schedule 9) in the Fish and Wildlife Conservation Act (1997; Bill 139, Chapter 41, Statutes of Ontario).

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16. EASTERN MILK SNAKE (Lampropeltis tirangulum)

COSEWIC Special Concern. There is increased concern over this species in

Canada resulting in a designation of Special Concern nationally by COSEWIC

in May 2002. It is protected under the federal Species at Risk Act

(SARA). The Eastern Milk Snake is listed as a "specially protected species" in

schedules of the Fish and Wildlife Conservation Act, 1997. It is listed by the

Royal Ontario Museum as a species of special concern provincially and

nationally. This species would certainly be further threatened by the

additional invasiveness of cement trucks, cranes, the vehicles of work

crews and heavy transport vehicles associated with wind turbine

construction. Its traditional habitat would be fragmented by the

construction of new roads to the sites and the subsequent regular

invasion of servicing vehicles after construction. Since this

diminishing species is found throughout the entire proposed Arran

Lake wind turbine development area, each of these threats would be

multiplied by the number of turbines actually constructed i.e. now

believed to be in excess of 30. In addition, low frequency noise levels and

earth-absorbed vibrations from operational turbines would result in habitat

disturbance since snakes are extremely aware of vibrations and use this means of

sensing threats rather than hearing. All of these disturbances would apply also to

all snakes and reptiles found in the area—the more common ones being a source

of prey for the waterfowl and other birds. Please see Appendix 2 for additional

information on this species.

17. EASTERN RIBBON SNAKE (Thamnophis sauritus)

COSEWIC designated this snake of Special Concern for the Canadian Great

Lakes population in May 2002. The Royal Ontario Museum/MNR lists this

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species as Special Concern provincially and nationally. This species is

included in the Greater Georgian Bay Reptile Awareness Program. Habitat

stewardship projects for it are ongoing in Ontario and Quebec under RENEW

(Recovery of Nationally Endangered Wildlife), the national recovery program

established under the Accord for the Protection of Species at Risk. Please see

Appendix 2 for more information on this species.

MAMMALS AT RISK AROUND ARRAN LAKE:

18. GREY FOX (Urocyon cinereoargenteus)

COSEWIC: Threatened (May 2002). MNR/ROM: Threatened nationally

and provincially. The proposed wind turbine site is part of the

traditional, preferred habitat of the Grey Fox, which has been seen on

two recent occasions by local naturalists in this area. Its presence

demonstrates the use by a single animal of both upland forest and

marsh habitat within the Arran Wetlands natural heritage system: the

grey fox prefers deciduous forests (where it climbs trees to escape

enemies) and marshes; and it may also be found in agricultural areas. The

local population is part of the south western Ontario population, the

only known resident breeding population for grey fox in the province.

Habitat disturbance for this animal would result from the intrusive

nature of wind turbine construction, operation and maintenance.

The effect would be cumulative since the turbines would be located

amid its hunting territory.

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PLANTS AT RISK AT ARRAN LAKE:

The Ministry of Natural Resources, Owen Sound Office, has indicated that at least

three plant species considered by the Ministry of Natural Resources to be at risk

and COSEWIC species of special concern are found at Arran Lake. These include:

19. TUBEROUS INDIAN-PLANTAIN (Arnoglossum plantagineum)46

―Status: Special Concern. Reason for designation: limited occurrences present

within five shoreline areas of Lake Huron. The Ontario population consists

of just 5000 flowering plants. It is probable that the known drying effect of

the wind turbines would eliminate some of the wet meadows that are the habitat

of this plant. Please see Appendix 2 for more information on this species.

20. LONGLEAF DROPSEED (Sporobolus asper)

21. RIGID SEDGE (Carex tetanica)

This plant is very rare in native habitats.47

46

COSEWIC 2002. COSEWIC assessment and update status report on the tuberous Indian-plantain Arnoglossum plantagineum in Canada. Committee on the Status of Endangered Wildlife in Canada. Ottawa. vi + 11 pp. White, D.J. 2002. Update COSEWIC status report on the tuberous Indian-plantain Arnoglossum plantagineum in Canada, in COSEWIC assessment and update status report on the tuberous Indian-plantain Arnoglossum plantagineum in Canada. Committee on the Status of Endangered Wildlife in Canada. Ottawa. 1-11 pp. Previous Report: Keddy, C. 1988. COSEWIC status report on the Indian-plantain Cacalia plantaginea in Canada. Committee on the Status of Endangered Wildlife in Canada. 28 pp. 47

30774 Argus, G.W. and D.J. White (eds.) 1982. Atlas of the Rare Vascular Plants of Ontario. Part 1. National Museum of Natural Sciences, Ottawa. Argus, G.W., K.M. Pryer, D.J. White and C.J. Keddy (eds.) 1982-1987. 8438 Atlas of the Rare Vascular Plants of Ontario. Four parts. National Museum of Natural Sciences, Botany Division, Ottawa. Looseleaf. 79886 Flora of North America (FNA) Editorial Committee. 2002. Flora of North America, Volume 24, draft species accounts for Cyperaceae. Unpublished draft species accounts. 57021 Oldham, M.J., and W.J. Crins. 1998. Atlas of the Vascular Flora of southern Ontario. Draft 2. Natural Heritage Information Centre, Ontario Ministry of Natural Resources, Peterborough, Ontario. 378 pp.

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The presence of all three rare plants further illustrates the

unique quality and high sensitivity of the Arran Lake natural

heritage system.

FISH AT RISK IN THE SAUGEEN RIVER

22. LAKE STURGEON (Acipenser fulvescens)

The Project Draft Description Report lists ―NHIC records for Lake Sturgeon

(Acipenser fulvescens) in the Saugeen River at the northwest portion of the study

area near the community of Southampton‖.

CUMULATIVE IMPACT ON SPECIES AT RISK

The impact of wind turbines on declining species raises serious

issues.

Manville emphasizes the inadequacy of many of the studies that

have been completed with regard to predicting the probable

devastating impact wind turbines can have on declining

species.

In 1999, Methods and Metrics for Determining or Monitoring Potential Impacts

on Birds was published (DMBM peer-reviewed), to provide the best advice on

how to conduct research at wind sites. That document has been updated to reflect

new findings. Assessing Impacts of Wind-energy Development on Nocturnally

Active Birds and Bats: a Guidance Document was recently released (DMBM also

peer-reviewed):

―Modeling in 2001 placed nationwide annual avian mortality at an estimated

33,000 average for all birds killed (2.19 avian fatalities/turbine/year; 0.033

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raptor fatalities/turbine/year), based on reviews at 14 western and midwestern

wind facilities. Unfortunately, the estimates tell us nothing about the

relative risk to declining species, nor what may be happening at a site-

specific location (e.g., APWRA, or Buffalo Mountain, TN). In addition, the

model has some critical flaws due to comparisons drawn between studies lacking

proper study design, unequal and large intervals between carcass searches (e.g.,

once/5 wk.), and a lack of eastern and north-eastern comparison studies. These

estimates need to be updated and should be subject to peer review.

More troubling, the estimates are often treated as ―fact.‖ Ideally, we

need a nationwide cumulative impacts analysis – especially since the

industry continues to grow exponentially.

―The newer generation of larger, slower-moving turbines may be as deadly as

older, smaller turbines, especially in inclement weather and especially to some

species. While RPM rates are much slower, blade tip speeds – at full operation –

still may spin in excess of 170 mph. As blade length and size and rotor swept

areas continue to increase, blade tip vortices and blade turbulence increase,

resulting in what may be decompression impacts to bats (e.g., collapsed lungs

with no apparent evidence of blunt force trauma; E. Arnett pers. comm.) and

perhaps to small neotropical migratory birds. More detailed research will be

necessary to assess these potential impacts. The effects of habitat

fragmentation, site disturbance, and habitat avoidance raise

potentially enormous issues that must be addressed‖.

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BATS AT RISK AT ARRAN LAKE

The huge negative effect of wind turbines on bats has economic repercussions.

Bats are one of the most important species in maintaining the balance

of nature. Their economic value as a biological control agent for

insects is estimated at multi billions of dollars annually in the US

alone. Wind power kills bats in very large numbers.

Seven species of bats are found at Arran Lake. Some of these are

migratory species and therefore more vulnerable to wind turbines.

The siting of wind turbines in this area would decimate this

important species.

One of the first studies on bats was carried out at Pincher Creek in Alberta. The

astonishing numbers of bat fatalities there alerted biologists and the

general public to the devastating effect the turbines are already

having on this animal.

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Dr. Michael Gannon, Professor of Biology at Pennsylvania State University and a

representative of the Pennsylvania Biological Survey on the Pennsylvania Wind

and Wildlife Consortium,48 is an acknowledged expert on bats, bat ecology, and

bat population biology. He has spoken out about the adverse effect wind turbines

are already having on bats. Citing the Government Accountability Office Report

commissioned by congress in 2005: Wind Power, Impacts on Wildlife and

Government Responsibilities for Regulating Development and Protecting

Wildlife,49 he emphasizes that ―wind power kills bats in large numbers.

That is a fact, not in dispute. Estimates I have seen, have gone from

the conservative of 5000 bats per wind site per year, to the very

liberal of about 60,000 bats per site per year.‖50

According to the congressional report:

―Recent studies conducted in the eastern United States in the Appalachian

Mountains have found large numbers of bats killed by wind power turbines. A

2004 study conducted in West Virginia estimated that slightly over 2,000 bats

were killed during a 7-month study at a location with 44 turbines. More recently,

a 2005 report that examined wind resource areas both in West

Virginia and Pennsylvania estimated that about 2,000 bats were

killed during a much shorter 6-week study period at 64 turbines.

Lastly, a study conducted of a small 3-turbine wind facility in

Tennessee estimated that bat mortality was about 21 bats per turbine,

per year, raising concerns about the potential impact on bats . . . .

Various species of bats have been killed at these wind power facilities and experts

48

A committee formed by Governor Rendell to advise on wind development and wildlife issues in Pennsylvania. 49

GAO-05-906. Washington D. C. 64 pp. http://www.windaction.org/documents/134 50

Letter to Mayor Kilmartin by Dr. Michael Gannon, biology professor at Penn State Altoona (November 4, 2007) by Dr. Michael Gannon http://www.windaction.org/documents/12514

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are concerned about impacts to bat populations if large numbers of deaths

continue. For example, one expert noted that ‗it is alarming to see the

number of bats currently being killed coupled with the proposed

number of wind power developments‘ in these areas‖.

These recently discovered statistics are acknowledged as true by the

wind industry. But wind energy proponents have rather flippantly

dismissed them by saying ―there is a problem with bats, but,

fortunately, bats do not have a very charismatic image with the

public‖. But Dr. Gannon emphasizes the often forgotten economic importance

of bats: ―The economic value of bats has been documented many times.

Bats are the major predators of all our nocturnal insects. They

consume large numbers of insect pests including many of our most

troublesome crop pests‖.

Bat Conservation International (BCI) estimates that a "little brown bat" eats its

own weight in insects every day (or 1200 mosquitos per hour), and because of its

control of the mosquito population, influences public health by limiting the

spread of West Nile virus.

All the species of bats found at Arran Lake have been documented as vulnerable

to the effect of wind turbines. Several are also migratory species which increases

their vulnerability. It has been observed that wind turbines situated near

wetlands are more destructive of bats.

For more information, please see Appendix 3. This research would indicate that

all of the species found at Arran Lake are at risk from proposed wind turbine

development.

ANIMAL STUDIES AND LOW FREQUENCY NOISE [L.F.N.]

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A literary report by Ivan Buxton51 has combined a variety of study findings and

concludes ―there is a case to answer when land based animals and freshwater

creatures are exposed to noise at low Hz levels. Because of the limitations of our

hearing it would be easy to suppose that noises beyond our receiving range do not

exist and should therefore be of no concern to us. Yet both very high and

extremely low inaudible sounds may be harmful to us and other animals with

similar but not identical ranges of hearing‖.

―Other creatures have lower acceptance levels, as their survival is more reliant

upon instinct and interpretation of unusual sounds as a source of danger.

―Wind turbine generators were raised as a noise concern some years ago. Yet only

recently have reports been released by the wind industry with results of desktop

studies and none seem to have been conducted on wild animals at wind farms. A

few seconds is all it takes at very low Hz and high dB levels before severe problems

arise. Even at a level of dB normally found comfortable for listening to music for

example, if the Hz level is low then a significant adverse reaction has been reported.

―There is reason to suppose that similar effects would also occur with wild

animals if exposed to the sounds for long enough periods. The presumption must

be that as soon as they felt uncomfortable they would move away from the zone of

discomfort. A term more properly described as, disturbance and displacement,

which in the case of protected species would be contrary to appropriate

legislation.

51

Low Frequency Noise and Infrasound (Some possible causes and effects upon land-based animals and freshwater creatures): A literary comment. Ivan Buxton. 2006.

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―Laboratory studies upon animals have been reviewed with quite chilling results,

as it clear that deformities, damage and impairment occur to the subjects with

regularity. Admittedly the animals were contained and subjected to exposure

times of several hours per day at moderate to high intensity levels of LFN and

infrasound. Yet fish and aquatic creatures contained in ponds and lakes would

certainly be unable to escape whatever the level of sound intensity or duration of

exposure. Aircraft noise and sonic booms have been blamed for reduction in egg laying

by domestic poultry. The use of military aircraft at supersonic speeds resulted in some

successful claims for damages following alleged injury or loss involving livestock.

Goats have been adversely affected by exposure to jet noise resulting in reduced

milk yields. Pigs suffered excessive hormonal secretion as well as water and

sodium retention after being subjected to continuous noise over several days.

―Wild mice captured from a field at the end of an airport runway were compared

with mice from a rural field not exposed to high levels of aircraft sounds and

noise was concluded to be the dominant stressful factor causing adrenal weight

differences. Recorded noise from a miscellany of sources including machinery,

military hardware, electrical and diesel engines, roller coasters and many others

have been used in experiments upon sheep and lambs and the results have shown

increased heart rates, respiratory changes and reduction in feeding.

―Anthropological sources of LFN and infrasound are increasing and will continue

so to do. There is clearly a cause for concern because of the likely effects upon

wildlife and current protective measures seem inadequate.

―Thus it is recommended that better environmental assessments be made to

accompany all planning applications involving erection or construction of plant,

machinery, buildings, infrastructure or other potential sources of low frequency

noise and infrasound, irrespective of project size.

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―The measurement methods should be reviewed to embrace ‗C‘ Weighting and ‗G‘

Weighting as well as the usual ‗A‘ Weighting so that a proper appreciation of the

extent of LFN and infrasound is achieved before, during and after the noise

source is installed. Yet a wealth of other creatures relies on their sense of hearing and

indubitably is exposed to and experience low frequency noises. In the case of those living

in the wild, good hearing is quite simply a survival aid.

―Even some invertebrates without conventional auditory receptors register

vibrations and use them for either communication or as warnings. The acoustical

energy that many invertebrates can sense allows them to survive.

―Creatures have evolved senses including those of hearing for reasons of assisting

in procreation, communication and protection. The latter includes defence from

the danger of predation or to enable them to find food.

―Wind turbines are also situated on land where the effects upon the flora and

fauna are easier to monitor but are nonetheless disturbing. Many instances of

bird and bat deaths have been recorded. The wind industry has belatedly shown a

degree of concern and there are recorded instances where chosen sites have been

abandoned in deference to the potential impact upon wild life.

―Accordingly it might be supposed, that if wind turbines were shown to have a

substantial deleterious effect upon large sections of marine or land-based fauna,

proposed sites where the exposure and danger to those creatures was most likely,

would not be developed.

―Unfortunately this is not always the case and besides, such a policy does nothing

to reduce the risk where lesser immediate creature damage is concerned.

Furthermore only limited steps have been taken to try and avoid mistakes from

the past placement of turbines.

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―The wind industry has hitherto been slowly reactive rather than speedily

proactive to the plight of birds and bats in relation to the problems caused by

their turbines. The attitude always appeared to be one of first instance denial and

it was not until overwhelming evidence was produced showing the mortality

rates, that attempts were made to ameliorate the situation.

―Some similarities appear to be developing with regard to low frequency noise

emitted by wind turbines. Although it must be accepted that no known creature

deaths have yet been recorded as the result of exposure to such noise the industry

reaction seems to have been one of denial before investigation.

―Infrasound effects upon humans from wind turbine generators were raised as a

concern some years ago. Yet only recently have reports been released by the wind

industry with results of desktop studies and none seem to have been conducted

on wild animals at wind farms.

―Amphibians such as frogs and toads also rely heavily upon sound for

communication and this plays a substantial role in their reproductive

behaviour. Most amphibians have complex ears that are dependent upon

sound frequency and directionality.

―In birds of prey, nesting failures (Boeker and Ray 1971), lowered nesting

success (Wiley 1975, White and Thurow 1985), displacement (Andersen et al.

1986), and changes in wintering distribution and behaviour (Stalmaster and

Newman 1978) were documented in response to human disturbance.

―In their study of home-range changes in raptors exposed to increased human

activity levels, Andersen et al. (1990) documented that increased military use in a

site previously subject to low human use resulted in a shift in home range and

activity areas for several raptorial species including red-tailed hawks, golden

eagles, ferruginous hawks, and Swainson's hawks.

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―Additionally, the raptors increased the size of the area used and increased

movements outside of the previously used areas, except during military use

activities when several birds remained in isolated areas within their home ranges.

Two birds, a ferruginous hawk and a Swainson's hawk completely abandoned the

area not returning until the following spring.

―Besides the obvious impacts of habitat abandonment, the changes in

home range size, activity areas, and use of habitats; increased human

disturbance may adversely impact upon an individual bird's energy

budget, and productivity might decrease with subsequent impacts at the

population level. If different raptor species demonstrate different levels of

tolerance of human activities, in time continued human disturbance could

result in a shift in the species composition in the area in favour of the

more tolerant species (Voous 1977, Craighead and Mindell 1981, Andersen

et al. 1990).

―The physiological impact of stress on animals has been the subject of many

studies, which have somewhat conflicting results. Selye (1950) suggested that an

exhaustion of the adrenal cortex occurs during prolonged stress exposure while

others concluded that prolonged exposure to acute stress results in a decline in

adrenal sensitivity (McNutty and Thurley 1973, Ader 1975).

―Alternatively, Sapolsky (1983) suggested that chronic stress might cause a

decline in cortisol production as a result of impairment of pituitary ACTH

production, while others (Friend et al. 1977, 1979, Paul et al. 1971, Barrett and

Stockham 1963) provide data, which demonstrates that stress tends to increase

adrenal sensitivity to an acute stressor.

―If chronic exposure to stressors causes sustained elevated glucocorticosteroid

levels, impairment of immuno-defensive mechanisms in affected animals may

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occur making the animals more susceptible to disease (Jensen and Rasmussen

1970, Paape et al. 1973, Hartman et al. 1976, Stein et al. 1976).

―Some animal studies have concentrated on the results of deliberate exposure to

disturbance. Harlow et al. (1987) using domestic farm sheep determined that

mild, medium, and severe stress events resulted in heart rate and plasma cortisol

changes. Heart rate during mild stress events returned to resting values by 10

minutes post-stress event, while medium and severe stress events resulted in

elevated heart rates for 20 and 60 minutes post stress event, respectively.

―Plasma cortisol levels were significantly elevated above resting values within

minutes post-stress, with cortisol levels returning to pre-stress levels 30 minutes

after removal of the mild stressor; as compared to continuously elevated cortisol

levels from 90 to 180 minutes for both the medium and severe stressors.

―During chronic stress events, cortisol levels in the sheep were significantly

elevated from day 5 through day 24 at which time the random noise generator

used to create the stress event failed. Once the generator was repaired and

restarted, cortisol levels increased to previous chronic stress values.

―The results of Harlow et al. (1987) do not support the concept of adrenal

exhaustion or hypersensitization nor suggest that habituation to stressors

occurred, perhaps because of the irregular, unpredictable interval of the noise

stimuli.

―As indicated by Harlow et al. (1987), chronically elevated blood cortisol may

adversely impact the efficiency of animal production by reducing weight gain and

otherwise affecting animals in captivity (Van Mourik and Stelmasiak 1984, Van

Mourik et al. 1985) and decreasing antibody production, thereby inhibiting or

suppressing the body's ability to resist disease (Roth 1984, Jensen and

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Rasmussen 1970, Huber and Douglas 1971, Revillard 1971, Paape et al.1973,

Hartman et al. 1976, Stein et al. 1976).

―These impacts, particularly if chronic, can result in: increased

sickness, disease, and death; a decrease in animal productivity

(Knight and Cole 1991, Anderson and Keith 1980); and

ultimately result in population declines (Anderson and Keith

1980).

―Harassment of mule deer by all-terrain vehicles, for example, resulted in

reduced reproduction the following year (Yarmaloy et al. 1988). Common loons

experienced reduced productivity with increased human contacts

(Titus and VanDruff 1981).

―The previous paragraphs clearly denote that stress is a cause for concern with

regard to the effects upon creature behaviour. Noise even when at levels below

normal receptive hearing is a cause of distress.

―Noise can be perceived as a threat and Ising and Ising studied this reactor in

2002. They found a body releases cortisol even during sleep if noise is deemed

threatening. Stress disrupts the normal cortisol pattern. Children were studied

after being exposed to changed traffic levels involving exposure to high levels of

nighttime lorry noise. Indications were that the LFN content produced

concentration problems in the children.

―Laboratory studies have also been conducted upon human subjects that confirm

enhanced salivary cortisol levels were produced by exposure to low frequency

noise (Persson-Waye et al., 2002). A further study (Persson-Waye et al., 2003)

found that levels of the cortisol awakening response were depressed after

exposure to LFN and was associated with tiredness and negativity through the

effects of LFN upon sleep quality.

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―These experiments upon humans all confirm that stress and disturbance are

interrelated. There is no reason to conclude the effects upon wildlife would differ.

―A recent investigation and report published by the UK Noise Association52 into

wind farms and noise concluded that the symptoms people ‗feel‘ from LFN

emitted by land based wind turbines are very similar to those associated with

vibroacoustic disease.

―This publication contained a number of examples where human distress was

reported apparently resulting from low frequency noise and or infrasound

affecting them and their homes. Complaints included headaches, worry, lack of

sleep, anxiety, irritation and reports of ‗feeling‘ as much as ‗hearing‘ the noise.

―One of the recommendations made by the report is that no wind turbines

should be sited closer than one mile away from the nearest dwellings and

there may even be occasions where a mile is insufficient.

―Bearing in mind that many other creatures may be ‗trapped‘ in habitat

within these distances there would also seem to be potential for stress and

harm to them as well.

―Another study for the Ministry of Defence by Keele University

concluded seismic signals from wind turbines registering up to

7.5hz could be detected ten miles from a wind farm.

Presumably however the dB level at that distance would be low,

but it demonstrates how widespread LFN can become from a

known manmade source.

―Rural areas are usually much quieter than urban conurbations and the sudden

introduction of greater noise levels by building a new arterial road; airport or

52

Location,Location,Location : John Stewart July 2006

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even a wind farm is bound to have an immediate effect upon the residents of

sparsely populated regions.

―What is almost invariably forgotten during such eventualities is that the resident

population includes the natural inhabitants as well as humans. Whereas the

human population tends to endure the noise, albeit under sufferance the wildlife

(creatures in still freshwater excepted) is far more likely to be driven away.

―Behavioural studies of the effects of low frequency noise and infrasound upon

wildlife are few and far between. Those that have been conducted seem

conclusive in their findings in that all confirm harm is possible to living creatures

when exposed to prolonged high intensity noise levels.

―Mostly it appears noise is just as stressful to wildlife as to humans whether of

low or high frequency but is species dependent with regard to the extent of the

effects. Generally, creature response is one of appearing startled if the noise is

sudden with increased stress if prolonged. In essence, as might be expected, the

effects are similar to human behaviour.

―Whilst this suggests occasional disturbance is seemingly harmless or relatively

innocuous it does depend upon the duration between events as well as other

factors. Regular pulses of sound that occur between long intervals without

disturbance can sometimes lead to habituation, but on other occasions create just

as much of a startle factor as the ‗one off‘ event.

―Thus at times the startle factor seems to be of little consequence although there

are exceptions such as abandonment of habitat or in the case of nesting birds,

desertion of eggs or young. More prolonged and intense exposure however, has a

worsening effect and in the case of species contained within an enclosed

environment, such as pond dwelling creatures the results could be significantly

harmful.

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―Despite an undoubted increase in general noise levels and the growth of

manmade inventions producing differing levels of sound, very little progress

seems to have been made in terms of actual research into the effects upon wildlife

over the past 30 years.

―Environmental impact assessments rarely consider noise effects on wildlife.

According to Bender in 1977 a complete and accurate assessment of a given

impact should include an assessment of how animals will react (both physically

and behaviourally) to various noise levels of varying frequencies produced by the

impact.

―In 1980 Fletcher stated that further research is needed to answer critical

questions about the effects of noise on animals, including long and short term

noise effects and the effect of noise on declining animal population regardless of

the cause of the population decline.

―Quite clearly further research is required in an endeavour to resolve critical

aspects concerning the effects of noise on land based animals and fresh water

creatures. These should embrace studies of affected species both as individual

creatures and in accumulated groups (e.g., shoals) to examine the acoustic

frequency, intensity and temporal patterns of significant sound sources upon

mating, habitat, alarm response and nurturing.

―Permitting construction of vast numbers of large-scale

renewable energy projects that produce virtually continuous

emissions of infrasound could have wide-spread, marked

adverse consequences for the creatures they are intended to

help protect.

―More factories will be built to provide the equipment used to harness wind,

water and solar power as well as additional nuclear power stations. Old power

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stations will be rebuilt or demolished. All will give rise to some levels of low

frequency noise during the construction process and more large transport

vehicles will be required to move equipment and spoil from excavations.

―An independent environmental assessment is essential to

include infrasound and low frequency noise tests at source with

prediction models showing the anticipated noise levels at

progressive distances and showing the predicted spread.

―The assessment must also make a complete study of all wildlife

in and immediately beyond the projected vicinity with a proper

chronicle of species over a realistic period commencing with an

intensive base line study of one year of full and representative

observation before a planning application is submitted.

―Thereafter regular, periodic seasonal monitoring should be enforced as part of

the planning acceptance, conditional upon immediate cessation of noise emission

if found detrimental to any affected species.

―Unless the problem is recognised as real and acute the

potential for further chronic and significant harm to land based

animals and fresh water creatures will multiply and almost

certainly contribute to the progressive decline in species and

habitat‖.

Conservationists throughout the province should note that the Arran Lake

Wetlands Complex and its related natural heritage system is just one

of the remaining highly sensitive wetland areas that will be affected by

unregulated development of commercial wind power in Ontario.

There are many other similar sites that must be kept free of this type of

degradation from industrial development if we are to see the survival of the

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remaining fragments of Ontario‘s natural heritage survive functionally for the

next generation. Presently threatened are the following Ontario Important Bird

Areas—all of them internationally significant natural habitats:

Point Pelee; Holiday Beach/Big Creek; Eastern Lake St. Clair; Greater Rondeau

Area; Long Point Peninsula; Wolfe Island; Amherst Island; Chantry Island; Clear

Creek.

Ole Odgaard, a senior advisor to the Danish Energy Agency was recently

quoted in the Toronto Star: ―We made some mistakes. For example, the

first land-based windmills were built without any procedure to gain

public acceptance. They caused landscape pollution and now we are

paying to pull them down and re-establish better more efficient ones

in better locations.‖53

At the present time in Ontario, nothing is being done by the provincial

government to protect sensitive natural habitat areas.

In view of the potential for destruction and degradation of the Arran Lake

Natural Heritage System that has been outline above, it is difficult to understand

why the proponents of the wind turbine development have made such a poor

choice in their site location, especially when they admit in section 4.4.2 of the

Draft Project Description Report that:

―In general, turbine operations have the potential to displace some

wildlife individuals as a result of sensory disturbance (visual and/or aural).

Turbine operations have the potential to displace birds, cause nest abandonment

53 “

The Low-Carbon Diet”. Mitch Potter. Toronto Star September 27, 2008

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and stress, obstruct avian flight paths, and result in reduced breeding success

within localized areas of the project. The hazard that wind turbines pose to birds

varies by season and by species, with spring and fall migration typically of the

highest risk periods.‖

―Bat mortality has been documented at operational wind development projects in

southwestern Ontario and the mortalities have often been attributed to in-flight

collisions with wind turbine blades and/or the tower structures and, more

recently, barotraumas (James and Coady, 2003). The risk that wind turbines

pose to bats varies by season with fall swarming and migration typically being of

the highest risk periods. During fall migration mortality rates are generally ,4

bats/turbine/year although the potential exists for much higher mortalities (i.e.

>200 bats/turbine/year) at some wind parks‖. Wolfe Island data confirms 1270

bats killed in half a year though it is likely that many more were carried away by

scavenging raccoons etc.

Why would a developer who pretends to respect the need to protect the existing

wildlife in this highly sensitive area even contemplate proceeding with such a

project? Why would a government which pretends to promote biodiversity ever

allow such a project to be constructed?

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HERITAGE AND ARCHAEOLOGICAL FEATURES

THUNDERBIRD (SAUGEEN FIRST NATION BEAD WORK)

The following information is taken from the web site of the Saugeen First Nation:

―Archaeological evidence proves all of the modern Bruce Peninsula (or the

"Saugeen Peninsula" as referred to by the Ojibway) was home to the Chippewas of

Saugeen. From time immemorial, hunting and fishing were plentiful in this area.

Archaeologists are able to find artifacts from Early Woodland Period (1000 BCE

to 1000 CE), calling the culture that left artifacts in the Saugeen Ojibway Nation

Territory as the Saugeen Complex. Other than pottery, the projectile points called

Saugeen Point are typical characteristics of the Saugeen culture. Consequently,

associated with both the Chippewas of Saugeen Ojibway Territory and the

Saugeen Culture peoples were winter camps around Owen Sound, Cape Croker

and the Collingwood area, as well as summer camps in Walkerton, Wiarton,

Goderich, Tobermory and Red Bay.

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―Traditional territory also included all of the Saugeen River watershed. Thus,

places such as Tobermory, Meaford, Goderich, Cape Croker, Owen Sound and

Orangeville are located in the traditional Saugeen Ojibway Nation Territory. The

permanent settlement at the outlet of the Saugeen River which lent its name to

the region and its people was called Zaageeng, meaning "mouth of river."

LEGAL OBLIGATIONS

The original people of Saugeen never surrendered or signed away

their land or water.

The Duluth Declaration of 1995 affirms Saugeen First Nation's

jurisdiction over the waters around the Saugeen/Bruce Peninsula.

A 1993 Canadian Federal Court decision declaring that the Ojibways' right to

fish commercially takes precedence over any other activity. The Saugeen

First Nation have made it clear that it does not intend to endure a

direct assault on Tribal Sovereignty, which the Saugeen First

Nation have never abrogated authority or relinquished to any

other entity.

CULTURAL AND SPIRITUAL CONSIDERATIONS

―The Kewaquom name is from an original family of the Saugeen Territory. It is

associated with the sound Thunder Going Home. They are of the Eagle clan. Peter

Jones said that by "taking this name I was dedicated to the Thunder God."

Thunder birds are represented by eagles. Eagle feathers are used in all sacred

Ojibwe ceremonies‖.

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Bald eagles (Haliaeetus leucocephalus) are known to nest in the Arran Lake area.

They are regularly seen soaring over the lake and the river.

There is international concern over the threat of wind turbines to the survival of

the eagle species. In The United Kingdom, Spain, Australia, Scandanavia and

California, these birds have already suffered alarming losses. A news release

from Save the Eagles International underlines the need to overhaul the impact

assessment procedure.54

The BBC recently reported that ―Wind farm turbine blades are killing a key

population of Europe's largest bird of prey, UK wildlife campaigners warn.

The RSPB says nine white-tailed eagles have been killed on the Smola islands off

the Norwegian coast in 10 months, including all of last year's chicks.

Chick numbers at the species' former stronghold have plummeted since the wind

farm was built, with breeding pairs at the site down from 19 to one.

Scientists fear wind farms planned elsewhere could also harm birds.

RSPB conservation director Mark Avery told BBC News more care needed to be

taken when choosing a site for wind farms. He said: "The problem is if wind

farms are put in stupid places where there are lots of vulnerable birds and lots of

vulnerable rare birds.‘" 55

Closer to home, the Windsor Star recently reported the slaughter of a Bald Eagle

at a wind turbine site near Tillsonberg.56

54

Save the Eagles International, Partida La Sella, 25, 03750 Pedreguer, Spain. Tel : + 34 693 643 736 [email protected] www.iberica2000.org/Es/Articulo.asp?Id=1875 (2) Yaloak to kill 200-300 eagles www.iberica2000.org/Es/Articulo.asp?Id=4313 55

http://news.bbc.co.uk/2/hi/5108666.stm> 56

Chris Vander Doelen, www.windsorstar.com 4 15 2010

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The official cause of death: ―Blunt force trauma,‖ according to Scott Petrie, a PhD

waterfowl biologist who says he was ―privy to the results‖ of the autopsy. ―They‘re

trying to keep it hush-hush,‖ he says of government biologists.

Petrie says the bird was killed in the Erie Shores Wind Farm, an installation of 66

land-based turbines south of Tillsonburg, 10 kilometres from where he works as

staff biologist with the non-profit education group, Long Point Waterfowl.57

57

“The wind farm, completed in 2006, is owned by the Macquarie Power and Infrastructure Income Fund and is one of Ontario’s largest, so far. Petrie, 43, who is also an adjunct professor at the University of Western Ontario, calls the loss of the eagle “very significant. If I was an eagle biologist I’d be screaming from the rooftops.” He does think the casualty should convince the province and its swarm of eager wind farm developers to slow down their mad rush to remake the electrical grid. He’d like some research done before thousands of wind towers form a barrier of whirling blades across the south end of the province. Without some sober second thought about wind farms, Petrie warns, Ontario might be committing the province’s ecosystem to cascading and unpredictable long term changes. “But I think this is biggest threat to waterfowl in Ontario. And everybody’s in such a rush to put them up,” Petrie groused in an interview this week. “Nobody is talking about the cumulative effects of these things. Nobody is talking about siting them properly. There are some places they should never be built — such as Lake St. Clair.” Wind farms would be very destructive to the huge populations of waterfowl which feed and live offshore on that lake, Petrie says. The big worry for Ontario’s valuable bird populations is “displacement of waterfowl from their key foraging and staging areas.” North America’s migrating waterfowl have been flying the same routes for up to 13,000 years, back to when there was just one enormous lake of glacial meltwater feeding the St. Lawrence River: Lake Iroquois. But with 1,500 turbines now proposed for Lake Erie on the Canadian side alone – and those are just the ones planned in the water — that could be more than enough machinery to frighten migratory birds out of their habits. That’s what happened in Denmark after that country installed 25,000 turbines, Petrie says: A “barrier effect” caused by the forest of steel towers. Even if the blades don’t kill many birds, wind farms spook the skittish species into moving away. What happens then to Ontario’s multibillion-dollar tourism and hunting industries? People travel from around the world to see migratory phenomena such as the recent arrival of tens of thousands of huge tundra swans on the shore of Lake Erie along Highway 3. A thrilling sight, if you haven’t caught it yet. As a scientist, Petrie doesn’t believe wind farms are a solution to any of our energy problems anyway. “And as a taxpayer I’m totally opposed to wind turbines because they’re subsidized. Without subsidies there would be no wind turbines. “You know we will never shut down a single fossil fuel plant due to wind turbines. Never.” Denmark hasn’t shut any of its fossil-fuel generators despite almost carpeting the country with wind turbines — and doubling the cost of their electricity”.

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SACRED BURIAL GROUNDS

Archaeologists have confirmed that the area of the proposed wind turbine project

contains important archaeological sites, some of which have not yet been fully

investigated. The Thede site on the Saugeen River is just outside the project area

east of Burgoyne. The Donaldson site further north on the Saugeen River is also

adjacent to the site. Radio carbon dating at both sites has revealed artefacts from

Saugeen Culture dating from 300 BC. A long stretch of river valley flows between

these two sites, through the project area. It is without human habitation, virtually

in its pre-settlement era state, and has not been investigated for likely similar

summer or winter camps from the Middle Woodland period.

GLACIAL RADIC

Near one of the wind testing towers for the proposed project can be found a

glacial radic. This is believed locally to have been used both as a grind stone and

also as a ―pulpit‖ for the delivery of orations. It is therefore likely to have been

associated with ancient customary rituals and ceremonies. Sometimes

grindstones form part of a village dating from the Middle or Early Woodland

Period. It is most probable that archaeological exploration would reveal burial

grounds near this site.

There are ten other known archaeological sites within the project boundaries.

Most have not been properly investigated.

The most completely excavated of these two Saugeen River sites is the Donaldson

site at Denny‘s Dam adjacent to the north west corner of the project boundary.

It revealed ancient burial grounds and archaeologists were able to learn much

about Saugeen Culture burial practices. Archaeologists believe that a more

thorough excavation of the Thede site than was possible in the 1970s may have

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disclosed similar burial grounds since it was the custom to bury the deceased

within a short distance of winter or summer camps. (At the time, work was

hampered by the owner‘s eagerness to plant a strawberry crop and by the refusal

of the team to penetrate dense poison ivy).

There is ample evidence that Arran Lake and the interconnecting countryside

between the lake and the river, as well as the uplands on the east side of the lake

and the lowlands to the south as well as the interconnecting animal movement

corridors, streams and creeks between the lake and the river are all a traditional

fishing and hunting resource for Traditional Saugeen Culture. The location of an

unexcavated Middle Woodland site in fields adjacent to Arran Lake—only metres

from one of the wind measuring towers, is also known to archaeologists. It is

likely that this site too dates at least to the Middle Woodland Period. And the

existence of burial grounds nearby both these locations, within the project

boundaries, is a strong likelihood.

However, because all the geographic features of the entire area of the proposed

project were exploited by early Saugeen Culture, and by the Native People during

historic times, it would be impossible, without extensive, lengthy and costly

archaeological investigation to ascertain that even earlier sites were not being

disturbed by the deep footings required for a wind turbine.

It should also be noted that the Saugeen First Nations Reserve No 49 is adjacent

to the north western corner of the project area.

The developers suggest in section 4.2 of their report that ―should areas with

archaeological potential be identified, a more detailed Stage 2 investigation will

be undertaken by qualified archaeologists to confirm the presence of

archaeological resources. Should archaeological resources be discovered,

appropriate mitigation measures will be assessed, which depending on the

resource could include any of the following:

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Preservation in-situ, requiring changes to project layout;

Removal and preservation; and

Further assessment (i.e. Stage 3 Archaeological Assessment)‖.

The First Nations People, who by law must be consulted and accommodated, will

undoubtedly construe any talk of ―mitigation‖ of the burial sites of their ancestors

as insulting arrogance.

―Like Chief Wahbudick, many people of Saugeen still do not believe in

surrendering their rights or the birthrights of their children‖.

―The original people of Saugeen still defend their territory‖.

―It is also important to remember where Kegedonce was found as Dudley George

and other warriors defended traditional burial grounds by Ipperwash-Ausable

River‖58.

TOURISM, NATURE STUDY AND BUSINESS USE:

The area is used as an important natural study resource. One of the events of the

Huron Fringe Birding Festival takes place within the Arran Lake South Wetlands

each year.

The lake and surrounding countryside is also an important recreational asset for

the twin towns of Southampton and Port Elgin (Saugeen Shores). Local business

centres on tourism and the lake is an important recreational retreat for fishermen

and outdoor canoeing and kayaking enthusiasts, many of whom seek

accommodation and food in town. There are also three holiday summer camps

near the lake.

58

Saugeen First Nation web site.

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The Southampton Art School also conducts painting and sketching classes

around the lake. This activity is dependent on an unspoiled view scape. Another

local business rents canoes and kayaks for use in the Saugeen River.

CANADIAN ART INSPIRED AT ARRAN LAKE

As the novelty of wind turbines wears off and the potential menace to the habitat

is becoming known, tourists are fast learning to avoid these industrialized areas.

On March 15, 2010, Bill Allen, President of the Tourism Industry Association of

Ontario wrote the following letter to Minister Brad Duguid asking him to

consider the negative impacts on tourism business when locating proposed wind

farms.

“Dear Minister:

Subject: Impact of Wind Farms on Tourism Destinations

We recognize the Ontario government has developed a clear policy to

replace fossil fuel electricity generation with “green” energy alternatives.

Under Bill 150, The Green Energy and Green Economy Act, a number of

amendments were made to the Planning Act which allows certain approval

process exemptions for green energy projects. These amendments have

reduced the opportunity for the public and businesses to raise concerns

with negative impacts that could arise from these projects.

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A case in point relates to the sighting of wind turbines in

tourism regions. Ontario is known for its natural beauty and

pristine countryside. Many destinations throughout the

province highlight this splendour in their marketing

campaigns. This is particularly true when marketing

internationally in Europe and Asia. Our association is very

concerned that locating wind turbines within certain tourism

regions will have a detrimental impact on the natural appeal of

that area.

Currently there are numerous wind farms proposed for significant tourism

destinations such as Prince Edward County, Ontario’s South Coast,

Ontario’s West Coast, Kingston & the Islands and Muskoka to name a

few.

The lead tourism products in these areas are based on nature

and the outdoors with their sandy beaches, numerous lakes

and spectacular vistas.

The Tourism Industry Association of Ontario supports the move of

the Province to a more environmentally sustainable energy

strategy. However, we do not support a strategy that will unduly

disadvantage tourism areas and businesses. We ask that due

consideration be give to the potential negative impacts on

tourism businesses when locating proposed wind farms. We

strongly recommend establishing minimum distance guidelines

for sighting of wind turbines near tourism destinations

particularly for those areas that rely on maintaining an

unblemished viewscape for visitors.

The Tourism Industry Association of Ontario represents the diverse

organizations and businesses that generate in excess of $22 Billion

annually from tourism activity. The industry employs over 300,000

people in direct and indirect jobs”.

POTENTIAL LOSS FOR TOURISM INDUSTRY

Concerns about the adverse effect of wind turbines on the tourism industry have

been expressed by tourism agencies in Wales, Scotland, England, Australia and

the United States.

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Claims by the industry that wind turbine towers are tourist attractions have not

been substantiated by reality. In England, two wind turbine visitor centres were

forced to close due to bankruptcy owing to a dearth of visitors. In fact, in a

number of visitor surveys, tourists have said that they prefer to avoid areas where

wind turbines have been installed because they feel their presence spoils the

natural beauty and takes away from the quality of their holiday. Entrepreneurs in

this sector are concerned that their investments will be jeopardized by the arrival

of wind turbines in their areas. Once again, the Ontario Government has done

nothing to demarcate wind turbine-free tourism zones to preserve

this important source of livelihood in many rural parts of the province.

A study conducted by ―Visit Scotland‖ 59 on Wind Turbines and Rural Tourism

showed visitors to be less enthusiastic about turbines than was perhaps expected.

It contradicted the findings of an earlier poll commissioned by the British Wind

Energy Association and the Scottish Renewables Forum.

Four out of five of the visitors interviewed said they came to Scotland for the

beautiful scenery and almost all said they valued the chance to see unspoiled

nature; More than half agreed that wind-power sites spoiled the look of the

countryside, saying that one of their main attractions is the fact that they are few

and far between; Over a quarter said they would avoid parts of the countryside

with wind developments; Heading the list of things that most detracted from a

visit to the country were electricity pylons and mobile phone masts followed

closely by wind turbines and telephone poles. (It is not clear if respondents

were aware, when questioned, of the height of wind turbines.)

59

http://www.viewsofscotland.org/library/docs/Wind_turbines_and_rural_tourism.pdf

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Fifteen per cent of those surveyed by VISITSCOTLAND answered categorically

that they would steer clear of an area with a wind development. Nationally, this

would result in the loss of over 3,750 tourist-related jobs, 430,000 trips and over

£80 million in revenue. A further ten per cent said they would be ‗less likely‘ to

return to the Scottish countryside if the number of wind-power sites increased.

If these are included, the figures rise to over 6,250 jobs, 780,000 trips and

nearly £140 million in lost revenue.

These losses do not include the self-employed.

MELTING ICE ARRAN LAKE

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ADVERSE HUMAN HEALTH EFFECTS

The Draft Project Description Report is disturbing because it relies on the

American Wind Energy Association and Canadian Wind Energy Association

sponsored report entitled ―Wind Turbine Sound and Health Effects‖ (A/CanWEA

Panel Review) which concludes that ―sound from wind turbines does not pose a

risk of hearing loss or any other adverse health effect in humans.‖ This

denial does not withstand scrutiny.

Dr. Carl V. Phillips, MPP, PhD, is an epidemiologist formerly from the University

of Alberta School of Public Health, with a PhD in public policy from Harvard

University, having completed a post doctoral fellowship in public health policy

and the philosophy of science. He provided testimony before the Wisconsin

Public Service Commission in reference to the Commission's effort to establish

siting standards for large-scale wind turbines.

His testimony is significant in light of the report released by the American and

Canadian Wind Energy Associations which asserted "the number and

uncontrolled nature of existing case reports of adverse health effects alleged to be

associated with wind turbines are insufficient to advocate for funding further

studies."

Following his detailed review of existing literature, Dr. Phillips arrived at a very

different conclusion:

"There is substantial evidence to support the hypothesis that wind turbines have

important health effects on local residents. If forced to draw a conclusion based

on existing evidence alone, it would seem defensible to conclude that there is a

problem. It would certainly make little sense to conclude that there is definitely

no problem, and those who make this claim offer arguments that are

fundamentally unscientific. But there is simply no reason to draw a conclusion

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based on existing evidence alone; it is quite possible to quickly gather much more

useful information than we have". 60

The A/CanWEA Panel Review report has been refuted by two

independent medical bodies.

On January 11, 2010 The Society for Wind Vigilance released a critique of the

A/CanWEA Panel Review and concluded that it was ―…neither authoritative nor

convincing..‖ and ―…independent third party studies must be undertaken to

establish the incidence and prevalence of adverse health effects relating to wind

turbines. Beyond that a deeper understanding of the potential mechanisms for

the impacts must be elucidated in order to define the mechanisms by which the

sleep disturbance, stress and psychological distress occur.‖

On January 19, 2010 The UK National Health Service (NHS) released an

independent critique of the A/CanWEA Panel Review and concluded ―The link

between psychological distress and physical symptoms has not been explored by

this report. The acknowledgment that some people exposed to wind turbine noise

suffer annoyance suggests that monitoring and maximum permitted levels need

to be considered carefully in areas where turbines are planned. Overall, this

review will probably not resolve this controversy as there was a lack of high-level

evidence on which to base any solid conclusions. What is now needed are studies

that compare people exposed to turbine noise with well-matched control subjects

who have not had that exposure.‖

The NHS critique is based on ―the best scientific knowledge currently available‖.

60http://www.wind-watch.org/documents/wind-turbines-health-ridgelines-and-valleys/

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―Health Canada advises…that there are peer-reviewed scientific articles

indicating that wind turbines may have an adverse impact on human

health.‖

The Society for Wind Vigilance has compiled a short primer of references which

indicate that industrial wind turbines may have an adverse impact on human

health.

Both these critiques use whenever possible, authoritative and peer reviewed

citations.

This primer may be downloaded and distributed to assist in educating and

informing those who are not aware of the potential adverse human health effects

of placing industrial wind turbines close to humans.

Click to download ―A Primer on Adverse Health Effects and Industrial Wind

Turbines‖ http://www.windvigilance.com/primer_ahe.aspx

'Studies of European wind turbine facilities have consistently concluded

that wind turbine noise is more annoying than other commonly

experienced noise sources such as traffic, aircraft and rail.'

'Current research demonstrates that annoyance must not be trivialized.'

'Annoyance is acknowledged to be an adverse health effect which

contributes to stress, sleep disturbance and an increased risk of

regulation diseases.'

'Annoyance with wind turbine noise was associated with psychological

distress, stress, difficulties to fall asleep and sleep interruption.‖

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'The US Environmental Protection Agency (EPA) states ―…‖annoyance‖

can have major consequences, primarily to one‘s overall health.' 61

The Chief Medical Officer of Health and the Ontario Agency for Health

Protection and Promotion concur in that they acknowledge wind turbines

may cause annoyance, stress and sleep disturbance. 62, 63

―The sound level associated with wind turbines at common residential

…may lead to annoyance and sleep disturbance‖64and evidence

demonstrates that wind turbine induced ―Annoyance and sleep

disruption are common when sound levels are 30 to 45 dBA.‖ 65

Paradoxically the conclusions of the A/CanWEA Panel Review are not supported

by its own contents in that it acknowledges wind turbine noise may cause

annoyance, stress and sleep disturbance and as a result people may experience

adverse physiological and psychological symptoms.66 In a radio interview one of

the authors of the A/CanWEA Panel Review W. David Colby, M.D. stated: ―We‘re

61

US Environmental Protection Agency web site, Noise Pollution, [cited June 30, 2010]

http://www.epa.gov/air/noise.html 62

Arlene King M.D., Ontario Ministry of Health and Long Term Care Memorandum, October 21, 2009,

http://windvigilance.com/primer_ahe.aspx 63

Copes, R. and K. Rideout. Wind Turbines and Health: A Review of Evidence. Ontario

Agency for Health Protection and Promotion, September 2009 64

Rideout K, Copes R, Bos C. Wind turbines and health. Vancouver: National Collaborating Centre for Environmental Health; 2010 Jan [cited 2010 June 3]. Available from: http://www.ncceh.ca/files/Wind_Turbines_January_2010.pdf. 65

Rideout K, Copes R, Bos C. Wind turbines and health. Vancouver: National Collaborating Centre for Environmental Health; 2010 Jan [cited 2010 June 3]. Available from: http://www.ncceh.ca/files/Wind_Turbines_January_2010.pdf. 66 W. David Colby, M.D et al., Wind Turbine Sound and Health Effects, An Expert Panel Review 2009, Prepared for American Wind Energy Association and Canadian Wind Energy Association

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not denying that there are people annoyed and that maybe some of them are

getting stressed out enough about being annoyed that they‘re getting sick.‖67

The Ontario Ministry of Health and Long Term Care also acknowledge

wind turbines may cause annoyance, stress and sleep disturbance.68

The A/CanWEA Panel Review acknowledges wind turbine noise induced

symptoms may include palpitations, insomnia, nose bleeds, dizziness,

nausea, eye strain, feeling vibration and headache.69

In 2010 Geoff Leventhall, an author of the A/CanWEA Panel Review is quoted as

stating ―… there was no doubt people living near the turbines suffered a range of

symptoms, including abnormal heart beats, sleep disturbance, headaches,

tinnitus, nausea, visual blurring, panic attacks and general irritability.…it‘s

ruining their lives – and it‘s genuine…‖70

―Health Canada advises…that there are peer-reviewed scientific articles

indicating that wind turbines may have an adverse impact on human

health.‖71

67

W. David Colby, M.D., Sounding Board, 97.9 FM The Beach December 17, 2009. 68

Arlene King M.D., Ontario Ministry of Health and Long Term Care Memorandum, October 21, 2009. http://windvigilance.com/primer_ahe.aspx 69

W. David Colby, M.D et al., Wind Turbine Sound and Health Effects, An Expert Panel Review 2009, Prepared for American Wind Energy Association and Canadian Wind Energy Association 70

Countryside News, Wind turbines set to get bigger, January 28 2010 http://www.walesonline.co.uk/countryside-farming-news/countryside-news/2010/01/28/wind-turbines-setto-get-bigger-91466-25701853/ 71 Safe Environs Program, Health Canada Environmental Assessment Nova Scotia, August 6, 2009, http://windvigilance.com/primer_ahe.aspx Click to download Safe Environs Program, Health Canada Environmental Assessment Nova Scotia, August 6, 2009

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Peer reviewed studies of European industrial wind turbine facilities have

documented high annoyance and sleep disturbance in respondents.72

World Health Organization recognizes annoyance and sleep disturbance

as adverse health effects. 73

In 2009 World Health Organization released a 184 page peer reviewed summary

of research regarding the risks to human health from noise induced sleep

disturbance. Some of the adverse health effect documented in the report include

poor performance at work, fatigue, memory difficulties, concentration problems,

motor vehicle accidents, mood disorders (depression, anxiety), alcohol and other

substance abuse, cardiovascular, respiratory, renal, gastrointestinal,

musculoskeletal disorders, obesity, impaired immune system function and a

reported increased risk of mortality.74

The A/CanWEA Panel Review acknowledges that wind turbine low

frequency noise may cause annoyance.75

Some of the documented effects of low frequency noise induced annoyance

include task performance deterioration, reduced wakefulness, sleep disturbance,

headaches, and irritation.76

―Unlike higher frequency noise issues, LFN is very difficult to suppress. Closing

doors and windows in an attempt to diminish the effects sometimes makes it

72 Pedersen, E. and K. Persson Waye. 2004. Perception and annoyance due to wind turbine noise: A dose– response relationship, Journal of the Acoustical Society of America 116: 3460–3470. Pedersen, E. and K. Persson Waye. 2007. Wind turbine noise, annoyance and self-reported health and well being in different living environments Pedersen et al., 2008,Project WINDFARMperception Visual and acoustic impact of wind turbine farms on residents 73

World Health Organization, Guidelines for Community Noise,1999 http://www.euro.who.int/mediacentre/PR/2009/20091008_1 74

World Health Organization, Night Noise Guidelines for Europe, 2009 http://www.euro.who.int/InformationSources/Publications/Catalogue/20090904_12 75

W. David Colby, M.D et al., Wind Turbine Sound and Health Effects, An Expert Panel Review 2009, Prepared for American Wind Energy Association and Canadian Wind Energy Association

76 DeGagne et al., Incorporating Low Frequency Noise Legislation for the Energy Industry in Alberta,

Canada Source: Journal of Low Frequency Noise, Vibration and Active Control, Volume 27, Number 2, September 2008 , pp. 105-120(16)

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worse because of the propagation characteristics and the low-pass filtering effect

of structures. Individuals often become irrational and anxious as attempts to

control LFN fail, serving only to increase the individual‘s awareness of the noise,

accelerating the above symptoms‖77

The NASA Technical paper ―Wind Turbine Acoustics‖ states ―People who

are exposed to wind turbine noise inside buildings experience a much

different acoustic environment than do those outside….They may actually

be more disturbed by the noise inside their homes than they would be

outside….One of the common ways that a person might sense the noise-

induced excitation of a house is through structural vibrations. This mode

of observation is particularly significant at low frequencies, below the

threshold of normal hearing.‖78

Geoff Leventhall one of the authors of the A/CanWEA Panel Review

acknowledges the serious nature of low frequency noise induced annoyance by

asserting ―The claim that their "lives have been ruined" by the noise is not an

exaggeration…‖79

In a 2009 article the UK National Health Service stated ―…it is physically and

biologically plausible that low frequency noise generated by wind turbines can

affect people…‖80

The Canadian Wind Energy Association claims that wind turbine ―installations

meet strict government regulations with respect to sound‖.81 but at the same time

77

DeGagne et al., Incorporating Low Frequency Noise Legislation for the Energy Industry in Alberta, Canada Source: Journal of Low Frequency Noise, Vibration and Active Control, Volume 27, Number 2, September 2008 , pp. 105-120(16)

78 Harvey Hubbard et al, NASA Technical Document, Wind Turbine Acoustics, 1990

79 Leventhall HG. Low frequency noise and annoyance. Noise Health [serial online] 2004 [cited 2009 Dec

31];6:59-72. Available from: http://www.noiseandhealth.org/text.asp?2004/6/23/59/31663

80 UK National Health Service, Are wind farms a health risk? Monday August 3 2009,

http://www.nhs.uk/news/2009/08august/Pages/Arewindfarmsahealthrisk.aspx

81 CanWEA Paper Addressing Concerns With Wind Turbines And Human Health, January 2009

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acknowledges that noise modelling typically used does not purport to consider

the worst case and that actual noise levels may exceed that predicted.82

According to the Ontario Ministry of Environment ―There is currently no

scientifically accepted field methodology to measure wind turbine noise to

determine compliance or non compliance with a Certificate of Approval limits.‖83

In most jurisdictions there is no requirement for the wind energy industry to

monitor or address for wind turbine low frequency noise.

The World Health Organization states: ―The precautionary principle. In all cases

noise should be reduced to the lowest level achievable in a particular situation.

When there is a reasonable possibility that the public health will be endangered,

even though scientific proof may be lacking, action should be take to protect the

public health, without awaiting the full scientific proof.‖84

Michael A. Nissenbaum, MD is a medical advisor to the Society of Wind

Vigilence. He is a graduate of the University of Toronto (MD), McGill University

(Specialty Diagnostic Imaging), University of California (Fellowship) Harvard

University Medical School (junior faculty, Associate Director of MRI, BIH) and

currently, Radiologist, NMMC, Ft. Kent, Maine. He has published his experience

with patients suffering adverse health effects from wind turbines in rural Maine.

―It is a medical fact that sleep disturbance and perceived stress result in ill effects,

including and especially cardiovascular disease, but also chronic feelings of

depression, anger, helplessness, and, in the aggregate, the banishment of

happiness and reduced quality of life.

82

Howe Gastmeier Chapnik Limited, Wind Turbines And Sound: Review And Best Practice Guidelines, Submitted To: CanWEA Canadian Wind Energy Association, February 15, 2007

83 Correspondence from Ministry of Environment September 30, 2009 ENV1283MC2009-4305,

http://windvigilance.com/primer_ahe.aspx 84

World Health Organization, Guidelines for Community Noise,1999 http://www.euro.who.int/mediacentre/PR/2009/20091008_1

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―Cardiovascular disease, as we all now, leads to reduced life expectancy. Try and

get reasonably priced life insurance if you are hypertensive or have suffered a

heart attack.

―If industrial wind turbines installed in close proximity to human habitation

result in sleep disturbance and stress, then it follows as surely as day follows

night that wind turbines will, over the long term, result in these serious health

effects and reduced quality of life.

―The question is, then, do they?

―In my investigation of Mars Hill, Maine, 22 out of about 30 adults

(‗exposed‘) who live within 3500 feet of a ridgeline arrangement of 28 1.5

MW wind turbines were evaluated to date, and compared with 27 people

of otherwise similar age and occupation living about 3 miles away (Not

Exposed).

[Note: the wind turbines planned for the Arran project are

almost twice this size: 2.5 MW].

―Here is what was found:

―82% (18/22) of exposed subjects reported new or worsened chronic sleep

deprivation, versus 4% (1 person) in the non-exposed group. 41% of

exposed people reported new chronic headaches vs 4% in the control

group. 59% (13/22) of the exposed reported ‗stress‘ versus none in the

control group, and 77% (17/22) persistent anger versus none in the people

living 3 miles away. More than a third of the study subjects had new or

worsened depression, with none in the control group. 95% (21/22) of the

exposed subjects perceived reduced quality of life, versus 0% in the

control group. Underlining these findings, there were 26 new prescription

medications offered to the exposed subjects, of which 15 were accepted,

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compared to 4 new or increased prescriptions in the control group. The

prescriptions ranged from anti-hypertensives and antidepressants to anti

migraine medications among the exposed. The new medications for the

non exposed group were anti-hypertensives and anti-arthritics.

―The Mars Hill study will soon be completed and is being prepared for

publication. Preliminary findings have been presented to the Chief Medical

Officer for Ontario, and have been presented to Health Canada, by invitation.

Earlier partial results were presented to the Maine Medical Association, which

passed a Resolution calling for caution, further study, and appropriate

modification of siting regulations, at its annual meeting in 2009.

―There is absolutely no doubt that people living within 3500

feet of a ridgeline arrangement of turbines 1.5 MW or larger

turbines in a rural environment will suffer negative effects.

―The study was undertaken as a pilot project to evaluate for a cluster of symptoms

after numerous media reports, in order to present data to the Maine Medical

Association, after the Maine CDC failed to more fully investigate.

―While the study is not perfect, it does suggest a real problem that warrants not

only further more detailed investigation, but the tenderest caution, in the

meantime, when decisions on how to site industrial wind turbines are made.

―What is it about northeast USA ridgelines that contribute to these ill effects, and

how can they be avoided?

―Consider, the Northeast is prone to icing conditions. Icing will increase the

sound coming off of turbines by up to 6 dBA. As the icing occurs symmetrically

on all blades, imbalance detectors do not kick on, and the blades keep turning,

contrary to wind industry claims.

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―Sound is amplified coming off of ridgelines into valleys. This is because the

background noise in rural valleys is low to begin with, increasing the sensitivity to

changes, particularly the beating, pulsatile nature of wind turbine noise, and

sound sources at elevation do not undergo the same attenuation that occurs from

groundcover when noise sources are at ground level. The noise travels farther and

hits homes and people at greater amplitude that it would from a lower elevation.

Even though this is not rocket science, it was conclusively proven in a NASA

funded study in 1990.

―Snow pack and ice contribute to increased noise transmission. Vermont valleys

have both, I believe.

―Preconstruction sound modeling fails to take the tendency of the homes

that people live in to respond and vibrate perceptibly to sound at

frequencies that the occupants of the dwellings cannot necessarily hear.

They hear, and feel, the walls and windows rattle, and the floors vibrate,

in a pulsing manner at a frequency or the turbine rpm.

―When preconstruction modeling fails to take the pulsatile nature, propensity for

icing, and ridgeline elevation into account, as well as a linear as opposed to point

source of noise, problems can be expected. What distance is safe? It depends on

the terrain, the climate, the size of the project and the turbines themselves.

Accurate preconstruction modeling with safe targets in mind is critical. The WHO

says that 30dbA is ideal, and noise levels of above 40dbA have definite health

consequences. At Mars Hill, where affected homes are present at 3500 feet,

sound levels have been measured at over 52.5dbA. The fiasco there has been

acknowledged by the local wind energy company, and by a former Maine

governor.

―Vermont would do well to learn from the affected people in Mars Hill.

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―I have seen the preliminary plans for the planned Deerfield Wind Facility, and

have particular concerns regarding the dwellings to the north and northeast of

the northernmost extension of the turbine layout. These homes are well within a

mile, generally downwind, and downhill from what I am told may well be 2 MW

turbines (or larger?), in a snowy and icy part of the Northeast.

―The parallels to Mars Hill are striking.

―We know that preconstruction sound modeling failed at Mars Hill. No matter

what the preconstruction modeling at Deerfield shows, the real world experiment

at Mars Hill suggests that there will be problems for homes at the setbacks that

seem to be planned for Deerfield on the attached image.

―The people who live within 3500 feet at Mars Hill are truly suffering.

Learn from Mars Hill. It is not a matter of not having wind turbines. It is a

matter of putting them where they will not affect people‘s health.

―Newer technology to accurately measure sound at a quantum level improvement

in temporal, frequency and amplitude resolution over commonly used

acoustician‘s equipment now exists, though it is costly and not readily available.

But it will be widespread, soon, well within the tenure of the individuals

responsible for making siting decisions today.

―Avail yourselves of these findings and familiarize yourselves with the new

technologies. You will not only be future proofing your current decisions, you will

also be helping people who would otherwise end up too close to industrial wind

turbines escape the fate of the exposed residents of Mars Hill, and many other

sites in North America (Mars Hill, Maine, merely represents the first small

‗controlled‘ study).

―I have seen the results of this cutting edge equipment, and how it has revealed

drastic short duration excesses over allowed sound levels, levels that set homes

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vibrating and rendering them unlivable, but also levels of lower frequency

transient noise at the audible level, that demonstrates not only failure of

preconstruction sound modeling as currently practiced, but also the inadequacy

of the measuring tools in the toolkit of the everyday practicing acoustician-

consultant who generates reports for industry and local government.

—Montpelier, VT, May 7, 2010‖

CONCLUSION

As part of the community consultation process under the Green Energy Act, we

require full written answers to all of the questions raised above in this report.

ANALYSIS OF NOISE AND SAFETY ISSUES

William K. G. Palmer has completed a special analysis of noise and safety issues

for this project. His report is attached. We require also, full written answers to the

following questions raised in his report:

1. The Golder Report states categorically, ―Through adherence with to MOE Noise Guidelines, operations-related noise that may be perceived to nearby residents will not represent a significant adverse effect.‖ Will Golder Associates please provide a detailed justification of their statement? Neither the MOE ―Noise Guidelines for Wind Farms‖ (October 2008) nor the Project Description demonstrate any evidence to prove that an A-weighted sound level limit for the cyclical sound of a wind turbine which has a significant low frequency component (as found at other Ontario wind power developments) ―will not represent a significant adverse effect.‖

2. Will Golder Associates please ensure the ―details‖ of the Wind Energy Project are actually provided?

3. Please provide a detailed assessment for the justification that a setback of 60 metres from roads considerably reduces risk of injury from ice throw or falling ice.

4. Please provide a detailed justification for the statement that these scenarios are ―highly unlikely‖ compared to the probability of accident considered to be acceptable for other generating system accidents.

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5. Please provide a detailed explanation of how the Golder Report comes to a conclusion that a 60 metre setback to roads and a 100 metre setback to lot lines provide public safety protection.

6. Please provide a rationale as to why the Golder Report failed to review the lack of shielding of electrical fields on the majority of the project overhead collection lines, and the radio frequency interference shown to overwhelm broadcast communication frequencies, in contravention of Industry Canada regulations.

7. Please provide an assessment of what is meant by the term ―significantly below this voluntary provincial guideline‖ in particular for members of the public with homes adjacent to the overhead 34.5 kV collector lines.

8. Please provide an assessment of what is meant by saying the effects of shadow flicker would be negligible.

9. Please explain the clinical reviews that Golder Associates used to identify that the cluster of symptoms identified by Dr. Pierpont which appeared when the individual was first exposed to wind turbines, which disappear if the person leaves the environment of the wind turbines, and which reappear when the person is re-exposed to wind turbines are the same as those seen in the general population due to stresses of daily life?

10. Considering the facts presented, would Golder Associates please comment on their choice of the statement ―the sounds emitted by wind turbines are not unique‖?

11. Would Golder Associates please explain why they chose to report only on noise and shadow flicker, excluding the issue of the constant motion of the turbines‘ rotor blades, since clearly the annoyance by shadow flicker depends on the relative siting of the turbine and the observer‘s position relative to the sun‘s position in the sky?

12. Considering the more recent evidence available from the same researcher, Dr. Eja Pedersen, calling for more study since “adverse effects on health and well-being can therefore not be excluded”, please comment on why the Golder Associates report chose to use as it‘s ―bottom line‖ words from this researcher documented 7 years ago that there was no evidence that wind turbines could cause health problems other than annoyance.

13. Since the independent review report appears to have made no statement that wind farms do not contain significant LFN and/or infrasonic components, and that report was made without actually doing any measurements, in light of the information shown regarding low frequency noise differences near and far from wind turbines shown on the previous pages, would Golder Associates please provide specific references for the statement in your report?

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14. Will Golder Associates please explain why the material extracted from the paper by Leventhall failed to even mention what Leventhall describes as the main noise source?

15. The Golder Report states, ―High levels of LFN and/or infrasound may cause physiological health effects, but to-date, there has been no definitive proof in peer-reviewed journals or information provided by governments that indicates high levels of LFN and/or infrasound can be associated with wind farms.‖ In light of the information provided showing the increase in low frequency noise at homes near wind turbines, would Golder Associates please comment on the apparent conclusion that your statement would lead to?

16. Would Golder Associates please comment on the request for an epidemiological study, which has repeatedly been made by medical doctors, and the desirability to proceed with development of more wind power developments before such a study is conducted? Your report states, ―Epidemiological studies, in conjunction with acoustic studies, would be necessary to definitely confirm a link between these physiological effects and wind farms.‖

APPENDIX 1

EXTRACTS FROM: Low Frequency Noise and Infrasound (Some possible causes

and effects upon land-based animals and freshwater creatures): A literary

comment. Ivan Buxton. 2006.

―Apart from some species of marine and land mammals, the need by other

creatures to harness and utilise infrasound for their own benefit has not

apparently been of importance. Neither has the requirement to identify and avoid

infrasound been particularly necessary. This may explain why the ecological

process has not generally equipped them with hearing ranges to detect such low

levels of noise.

The shallower regions of coastal waters, estuaries and perhaps the larger inland

areas of water such as Lake Erie, USA are all considered ideal because they

embrace some of the windier regions of the planet.

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A recent press article85 confirmed a tower rising 165ft above the surface of Lake

Erie and three miles offshore has been installed to accommodate a weather

station. The purpose being to gather data over a two year period as a pre-curser to

installing wind turbines on the ecologically sensitive western end of the lake.

Unlike turbines off the seacoasts they would be in freshwater that freezes. A

wildlife biologist has expressed concern because of the effects of noises and

vibrations on creatures as small as mayflies that at one stage in their lives burrow

beneath the lake sediment.

The lack of accumulated research on humans does nothing to dispel fears and

leaves the wind industry open to accusations of concealment. Nor do they appear

to have taken the next logical step to discover what the effects might be upon

mammals other than humans.

Outside of the wind industry there is some evidence of research and an

independent report86 sponsored by a number of interested parties including the

Society for Conservation of Marine Mammals was produced in 2003. It

concluded that both harbour porpoises and harbour seals reacted to the water

borne simulated sound of a 2 MW wind turbine.

Another illustration was reported in The Toronto Star, Canada on 6th

June 2005

when witnesses described a minute-long blast of sound emanating from a white

Israeli military vehicle. Within seconds, protesters began falling to their knees,

unable to maintain their balance. An Israeli military source, said ―the intention is

to disperse crowds with sound pulses that create nausea and dizziness.‖

Professor Hillel Pratt, a neurobiologist specialising in human auditory response

at Israel‘s ‗Technion Institute‘, says ―It doesn‘t necessarily have to be a loud

85

The Toledo Blade, Ohio – An article by Tom Henry, September 4th

2005. 86

Behavioural reactions of free-ranging porpoises and seals to the noise of a simulated 2MW windpower generator, 2003.

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sound. The combination of low frequencies at high intensities, for example, can

create discrepancies in the input to the brain.‖

Later he explained, ―that by stimulating the inner ear, which houses the auditory

and vestibular (equilibrium) sensory organs with high intensity acoustic signals

that are below the audible frequencies (<20Hz), the vestibular organ can be

stimulated and create a discrepancy between inputs from the visual system and

somatosensory system (that report stability of the body relative to the

surroundings) and the vestibular organ that will erroneously report acceleration

(because of the low-frequency inaudible sound). This will create a sensation

similar to sea or motion sickness. Such cases have been reported and a famous

example is workers in a basement with a new air-conditioning system that all got

sick because of low frequency noise from the new system.‖

There are a great number of articles that include reference to the effects of

infrasound upon humans. The frequency ranges are recorded in many of these

and the overall result always appears to depend upon the exposure time when

coupled with the dB and Hz levels.

A few seconds is all it takes at very low Hz and high dB levels before severe

problems arise. Even at a level of dB normally found comfortable for listening to

music for example, if the Hz level is low then significant adverse reaction has

been reported.

Very low frequency sound can travel long distances, penetrate buildings and

vehicles and does not significantly diminish its properties when it changes

mediums such as from air to tissue. This is because unlike ultrasound it travels ‗in

band‘ more effectively due to the propensity of low frequency sound waves to

travel in a straight line.

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Intermittent bursts of infrasound would presumably not be as damaging as

continuous exposure and if the levels of both cycles per second (Hz) and strength

(dB) were not high then it is possible that little or no adverse effect would be

delivered. Regular or irregular pulsating strong infrasound would however, at

least be debilitating.

It is the level of tolerance that must be anticipated if any meaningful comment

can be made upon the likely detrimental result of infrasound exposure upon

wildlife whether inhabiting urban, suburban or countryside areas.

A research paper, ‗Human Body Vibration exposure and its Measurement‘ by G

Rasmussen looked at body vibration exposure at frequencies of 1Hz –20Hz. Part

of a table shows:

Symptoms Frequency

General feeling of discomfort 4Hz – 9Hz

Head symptoms 13Hz – 20Hz

Influence on speech 13Hz – 20Hz

Lump in throat 12Hz – 16Hz

Chest pains 5Hz – 7Hz

Abdominal pains 4 Hz – 10Hz

Urge to urinate 10Hz – 18Hz

Influence on breathing movements 4hz – 8Hz

In order to bring the levels of infrasound into perspective it should be

remembered that the human brain functions as a transmitter and receiver. In his

paper, ‗EEG Measurement‘, G Blundell states:

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―The brain operates; Normal activity 13Hz – 30Hz

Relaxed 8Hz – 13Hz

Drowsiness 4Hz – 7Hz

Deep Sleep 0.5Hz – 4Hz

Interrupting, conflicting or overriding signals of unwanted sound (perceived as

noise) at any frequency will have an effect on the brain and associated senses but

predominantly auditory functions and those directly connected via the ear. The

lower frequency sounds (<20Hz) stand a greater chance of interference with

operation of the brain.

The evidence appears to show that harm created by LFN to humans, ranges from

simple sleep disturbance (aggravating in small doses, dangerous through fatigue

if prolonged) through temporary disablement (sometimes deliberately imposed)

to the extreme cases of permanent injury and possible death.

In the circumstances the medical implications are worrisome. A number of

studies have been conducted into the health risks caused by body vibration from

infrasound, increased cortisol from infrasound, endocrine effects and

cardiovascular risks arising from noise exposure. (See References below).

The problem with infrasound is that a doubling of loudness occurs when the level

of the sound is increased in air by 5dB and at the same time it becomes about

three times as intense. Therefore only a small increase in source sound can be

significant.

Erection of barriers can reduce some types of noise and are most effective when

close to the source, but are not very effective in tackling low frequency sound and

infrasound. These sounds are very hard to muffle as they spread easily in all

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directions and may be heard for miles and are mostly perceived not as sound but

as pressure.

The concerns of the effects of infrasound are clearly real whether they are upon

humans, marine life and freshwater creatures or land based animals and in

extreme cases the results of high levels of exposure could be lethal. Even

relatively low levels can be debilitating and create disturbance. The concerns of

the effects of infrasound are clearly real whether they are upon humans, marine

life and freshwater creatures or land based animals and in extreme cases the

results of high levels of exposure could be lethal. Even relatively low levels can be

debilitating.

Whilst to the casual listener the croak of one frog may seem very like that of

another, studies have shown that closely related species, or even local

populations of those with disjunctive distribution are known to differ. The vocal

harmonics, frequencies and intensities are quite marked. Call duration, repetition

and trill or pulsation rates differ widely.

Griffin and Hopkins (1974) measured sound levels of bullfrog (rana catesbieana)

choruses at about 20dB SPL in the 1.5 to 2.5kHz frequency band up to 965metres

above small ponds. Uninterrupted sound travels upward much farther and more

predictably than along a surface so it seems the sound serving as a stimulus to the

frogs probably occurs within relatively narrow variation limits.

Acoustic avoidance behaviour was demonstrated in a natural population of the

neotropical treefrog (Eleutherodactylus coqui) by a study (Zelick and Narins

1980). The threshold for evasive action at different frequencies varied from

230Hz to 3,420Hz at between 60 – 70dB SPL.

Single tone stimuli (1-2 second duration), spaced at the frog‘s spontaneous call

interval (2 –3 seconds), were presented to the frogs. The creatures redistributed

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their calls in time such that the calls fell almost exclusively within the brief time

window between tone bursts, thereby avoiding an overlap with the tone.

The average background noise level at the frog‘s calling site was 30dB SPL at

500Hz, 59dB SPL at 1,000Hz and 66dB SPL at 2,000Hz. Thus avoidance

behaviour was observed at stimulus levels barely exceeding the noise floor of the

frog‘s environment. Disturbance or confusion by introduction of lower frequency

noise could also have an adverse affect upon receptive sensitivity.

What would happen if obfuscation occurred due to the introduction of continuous

or virtually continuous infrasound or low frequency noise during the brief

breeding cycle of the UK population of frogs and toads? These amphibians are

already diminishing rapidly in number and a further possible threat to their

survival by a proliferation of noise disturbance could lead to their virtual

extinction.

Thunderstorms emit low frequency noise and some species of amphibians are

believed to react to the sound perceiving it as a harbinger to forthcoming wet and

damp conditions and venture forth to breed. This has been particularly noticeable

amongst the spadefoot toad (Scaphiopus couchi), which is not native to the UK

but inhabits arid regions of the South-western United States.

Experiments have shown that by revving a motorcycle at around 95dBA these

toads leave their burrows and make an assumption that it is time to mate. Should

this occur when no damp or wet conditions exist the effect upon their population

would be deleterious.

British species of amphibians all tend towards winter hibernation or dormancy

and have been recorded emerging to breed earlier than ever before, with a

reduction in success rate. This change in habit is believed to be due to the milder,

wetter winters of recent years as opposed to the previously colder, dryer

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conditions. If the ‗wake-up‘ call was also partially dependent upon thunderous

conditions then could year round emission of low frequency noise from

anthropological sources also be playing a confusing part?

Reptiles such as snakes and lizards appear to rely more heavily upon

chemoreception (‗smell‘ via ‗taste‘ through air sampling) rather than sound

coupled with vision for survival purposes. Nevertheless it seems they are sensitive

to low frequency noise and infrasound. Both Grass Snakes and Adders react to

vibration and the former inhabit damp places often entering still water and small

streams or rivers in search of prey.

Studies of the Mohave fringe-toed sand lizard (Uma scoparia) in California show

it has ability to hear low-intensity, low frequency sounds (Brattstrom and

Bondello 1983). Laboratory tests using dune buggy engine recordings at 95dB

representative of such a vehicle at 5metres distance from the lizards showed all

the creatures exposed to the noise for 510 seconds suffered actual hearing loss.

Shallow burial in the sand was not considered an adequate escape from the

sounds and it was felt that exposure to noise of this intensity during the breeding

season would have adverse biological effects. A recommendation by Bondello et

al. was all unnecessary disturbance from mining, repeated low level jet over-

flights and gunnery should be restricted from the immediate area of the dune

systems inhabited by the lizards.

The British sand lizard is restricted in habitat and as such is an endangered

species appearing mainly in areas of fairly highly classified nature conservation.

This does not mean they are completely protected from such eventualities as road

building or wind farm erection and could easily fall foul of noise disturbance from

such projects. Without proper studies into the effects of low frequency noise and

infrasound upon both the habitats and their vulnerable inhabitants what damage

might ensue?

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Moles live almost exclusively underground. A study in 1978 (Konstantinov)

showed that these small mammals (from a group of 30 species of insectivores)

had hearing of the lowest frequency and relatively high thresholds. Tests denoted

that sound levels of 90dB and above caused mammals to retreat from the sound

source, freeze and display a strong startle response, but not necessarily in that

order. Sound levels below about 90dB usually caused much less adverse

behaviour.

Unfortunately the Hz level of the test noises is not known, but the behaviour

pattern is indicative of what might be expected if a wild creature is suddenly faced

with the uncertainty of danger from the source of an unexpected noise.

Vocalizations of prey species are sometimes pure-toned calls, which are more

difficult to locate than multi-frequency calls. Vertebrates do not locate all pure-

toned sounds with the same accuracy. In a controlled test, Isley and Gysel (1975)

determined how well nine red foxes (Vulpes vulpes) located 13 different

frequencies of pure sound, varying from 300Hz to 34kHz.

Using food as a reward, the foxes were trained to choose the correct location of a

74dB sound signal emitted from one of two possible loudspeaker positions. The

foxes located the sound source best from 0.9 to 14 kHz (<90% accuracy) with a

slight decrease in accuracy at 8.5kHz (84% accuracy).

They had the most difficulty locating the source at 0.3, 0.6, 18, and 34 kHz (<78%

accuracy). Foxes appear to readily locate a wide range of sound frequencies and

may have maximized their chances for locating certain calls, which are

presumably difficult to locate.

Precise results at the lowest frequency sound (300Hz) utilised are not known, but

as included in the least successful bracket for location accuracy lead to the

probable conclusion, as might be expected, that use of low frequency or

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infrasound plays little or no part in hunting/feeding activities. Thus it might be

surmised very low frequency sound could be disturbing as the animals would be

unable to identify it.

In another experiment audiograms were obtained for two least weasels (Mustela

nivalis), using behavioral methods. The hearing range of the least weasel for

intensities of 60dB SPL extends from 51Hz to 60.5kHz, with a region of best

hearing extending from 1kHz to 16 kHz (Heffner and Heffner 1985). Hearing in

the least weasel appears to be similar to other members of the order Carnivora for

which data are available.

The high-frequency hearing ability of the least weasel lends additional support to

the relationship between functional inter-aural distance and high-frequency

hearing, whereas its sensitivity to low frequencies in the absence of obvious

morphological specialization of the middle ear makes the least weasel unusual

among the small mammals (although not unique as shown with the ferret in the

chart).

By now it will be apparent that emission of noise clearly poses problems but also

many unanswered and possibly unanswerable questions in relation to the affects

upon wildlife. In order to go some way towards seeking at least a partial solution

to some of the queries raised we must establish the known output of infrasound

and low frequency noise from a variety of sources that are likely to be

encountered by land-based and freshwater creatures.

Examples of noise from wind farms and the apparent problem caused to animals

are sometimes reported and once again New Scientist magazine carried a brief

article.87 Lawrence Rabin of the University of California and his colleagues

87

New Scientist magazine, issue 2549 3 May 2006, page 21.

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compared the behaviour of two groups of Californian ground squirrels in similar

environments, except that one group lived close to a wind farm.

Recordings of alarm calls were played to each squirrel group. Those living near

the turbines were more likely to dash back to their burrows upon hearing the calls

and spent more time looking for predators. The study team felt the turbine noise

increased the squirrels‘ alertness, perhaps because of the need to compensate for

their reduced ability to communicate through sound.

Enforced behavioural change could have considerable causal chain effects. The

squirrels are a food source to predators such as the golden eagle and an acute rise

in alertness might reduce the kill rate. This could lower the breeding success of

the birds with a resultant reduction in population. The squirrels might also breed

less being unable to feed as often leading in turn to fewer being available as prey.

The squirrel burrows are also used as homes by red-legged frog and California

tiger salamander. A decreased squirrel population would lead to a shortage of

‗dwellings‘ through habitat loss with in turn, further inevitable changes to the

population of those species.

The researchers felt wind turbine noise may affect wildlife communities all over

the world. Consequently they consider more care needs to be taken over choosing

where to site them.

Symptoms Table

Symptom Test Group % Control

Group %

Chronic fatigue 59 38

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Heart ailments anxiety,

stitch, beating palpitation

81 54

Chronic insomnia 41 9

Repeated headaches 89 59

Repeated ear pulsation,

pains in neck, backache

70 40

Frequent ear vibration, eye

ball and other pressure

55 5

Shortness of breath, shallow

breathing, chest trembling

58 10

Frequent irritation,

nervousness, anxiety

93 59

Frustration, depression,

indecision

85 19

Depression 30 5

The use of ‗A‘ weighting is now considered inadequate for low frequency and

infrasound noise assessment. ‗C‘ weighting and ‗G‘ weighting respectively should

be used. (See: A Review of Published Research on Low frequency Noise and its

Effects, May 2003 by Dr Geoff Leventhall et al).

DISTRESS CAUSED BY DISTURBANCE TO WILDLIFE AND

DOMESTIC ANIMALS

(Including infrasound and low frequency noise)

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An Internet publication (Wildlands CPR) contains a synopsis of a lengthy paper

written and submitted by D. J. Schubert as a petition against Off Road Vehicle

use in U.S. National Forests. Extracts have been included in the following

amalgam of comment upon animal suffering from human induced noise and

general disturbance factors.

Distress (stress) is a consequence of disturbance, which can, if prolonged, cause

substantial adverse impacts upon individual animals. Stress may be caused by

both physical and psychological factors, but in either case results in physiological

changes to the animals.

Exposure may be short or long term leading to acute or chronic symptoms. Hence

a loud and unexpected noise may cause a bird to abandon a nest and/or young or

persistent noise might drive an animal from a frequented habitat.

Off Road Vehicle (ORV) use for example, may cause both physical and

psychological stress to a wide range of animals as a result of noise, pollution,

activity patterns, and direct and indirect harassment or disturbance. The effects

of recreation-induced stress, including lower reproductive output (Geist 1978),

may not be evident immediately, but may appear days to years after disturbances

(Gutzwiller 1991). Moreover, recreation-induced stress exacerbates the effects of

disease and competition, leading to higher mortality well after disturbances occur

(Gutzwiller 1991).

Birds are particularly prone to noise disturbance. Whilst not specifically

commenting upon LFN or infrasound there is no reason to suppose the results

from the following study résumés would be any different if the disturbance source

included or resulted entirely from such causes.

The absence of controlled experiments is understandable for rarely is it possible

outside of laboratory conditions to create situations that replicate ‗the real thing‘

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and to project the findings from an artificial environment could lead to

questionable results.

Naturally occurring wildlife populations are undoubtedly sensitive to

environmental noise imposed upon them by manmade features. Indeed the level

of sensitivity is largely determined by their response to transient perturbations

(Shepherd and Horwood 1979). When the source of noise is spasmodic or

infrequent a return to normal might be anticipated and recovery rate may be

comparatively quick.

By 1988 Manci et al. still reported a lack of field studies and opined the vital link

missing in understanding the effects of noise on wildlife was information

concerning observation of behavioural response to the physiological changes

brought about by noise exposure.

Despite the opportunities offered by proliferation of wind turbines, both on and

off shore during the late 20th

C little or nothing of substance has materialised

regarding the influence of LFN and infrasound on wildlife behaviour or their

habitat except an underlying cause for concern.

In addition investigation of the spectrum of environmental sound upon wildlife

hearing sensitivity and effects of noise on declining populations of wild creatures

should be undertaken. Attention should also be paid to examining the direct

stress effects of noise combined with any other related factors e g., habitat

damage on wildlife behaviour covering both long and short-term exposure

periods.

Prediction of the consequences of low frequency noise and infrasound upon

wildlife is difficult to second guess for in addition to not being broadly species

dependent it is also not entirely habitat relative. Some creatures could adapt and

some could not. Some habitats attenuate sound others intensify it.

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In an ideal world a full safety first approach would be adopted and low frequency

noise or infrasound emissions would be prevented from affecting wildlife entirely.

Unfortunately the doctrine of impossible perfection cannot be applied.

Consequently further studies should be made of existing and known localities

‗suffering‘ exposure to this type of noise.

Representations must be made wherever and whenever possible to those

responsible for planning, constructing, building, erecting and utilising equipment

that emit low frequency noise and infrasound to adopt a proactive and protective

attitude towards wildlife.

The track record is neither admirable nor encouraging despite tightening of

wildlife legislation across Europe. Even the sudden shift of high-level emphasis

upon combating global environmental change resulting from apparent human

climatic influence does not auger well.

Meanwhile there is unlikely to be a reduction in road, rail and air travel or

erection of new housing, schools, shops and offices in areas currently inhabited

by wildlife. This means more quarrying, road laying, rail improvements, airports

and building activities encompassing green field sites.

The prospects are not good. Infrasound and low frequency noise problems will

multiply unless more stringent checks are devised at the manufacturing and

operating stages. This can only be done by stricter legislative controls on noise

emissions and more sensitive placement of any structure that has the capability

of emitting these types of sounds.

Measuring methods must therefore be reviewed to include ‗C‘ Weighting and ‗G‘

Weighting at all stages of planned development where LFN and infrasound

emissions are anticipated.

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Planning authorities should be properly equipped with the means, personnel and

equipment to undertake noise investigation and monitoring for at present it

appears in many instances they are not able to embark upon even the most

rudimentary testing.

REFERENCES TO BUXTON RESEARCH

i) Seidel H. “Selected Health risks caused by long term, whole body vibration”. Federal Inst. Of Occupational Health, Berlin. (Am J. Med. 1993 Apr. 23(4) ; 589 – 604.)

ii) “Characterising the effects of airborne vibration on human body vibration response” by Smith S.D. Air Force Research Lab., Wright – Patterson AFB, USA. (Aviation. Space Environment. Med. 2002 Jan; 73 (1); 36 – 45. iii) “Low frequency noise enhances cortisol among noise sensitive subjects during work performance” by Kerstin person-Waye. J Bengtsson, R. Rylander, F. Hucklebridge. P. Evans, A. Clow. (Dept. Environ. Medicine, Univ. of Gothenburg. (Life Science 2002 Jan 4; 70(7) 745 – 58. . [See also by same team ―Effects of night time LFN on the cortisol response to awakening and subjective sleep quality) iv) ―Noise induced Endocrine Effects & Cardiovasccular Risks‖ by H. Ising, W Babisch, B. Kruppa, Federal Environ. Agency, Inst. Of Water, Soil & Air Hygiene, Berlin.(Noise Health 1999; 1 (4); 37 – 48. v) ―Coping with stress; Neuroendocrine Reactions & Implications for Health‖ by U. Lundberg, Dept. of Psychology, Stockholm. (Noise Health 1999; 1 (4); 67 – 74 vi) “Possible health effects of noise induced cortisol increase” by M. Spreng. Dept. Physiology, Univ. Erlangen, Germany (Noise Health 2000; 2(7); 59 – 64 vii) “Acute and chronic endocrine effects of noise”: Review of the research conducted at the Inst. For Water, Soil & Air Hygiene, Berlin. H. Ising, C. Braun (Noise Health 2000;2(7) 7 – 24.

APPENDIX 2: ADDITIONAL INFORMATION ON THREATENED

SPECIES:

LEAST BITTERN

This is a National Species of Special Concern.88 It is also one of the level one

priority species for conservation in Bruce County. Researchers believe that this

population is still in decline, because the habitats it requires are still being

88

Sandilands, A.P. and C.A. Campbell. 1988. Status Report on the Least Bittern, Ixobrychus exilis. COSEWIC. 40 pp. Austen, M.J., M.D. Cadman and R.D. James. 1994. Ontario Birds at Risk: Status and Conservation Needs. Federation of Ontario Naturalists and Long Point Bird Observatory, Ontario. 165 pp.

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assaulted by developmental and agricultural interests. The Natural Heritage

Information Centre rates the Least Bittern as S3 (rare or uncommon). The Arran

Lake Wetlands provide its preferred habitat: ―Least Bitterns nest in freshwater

marshes, with dense tall aquatic vegetation, interspersed with clumps of woody

vegetation and open water. They are most regular in marshes that exceed 5 ha in

area. Smaller marshes may be used on occasion, but do not sustain populations.

In the northern part of their range they are most strongly associated with cattails

(Typha), which is the most common tall emergent (Gibbs et al. 1992), but they

may also nest in bulrush (Scirpus), reed grass (Phragmites), horse tail

(Equisetum), sedges (Carex), grasses (Graminaceae), Willows (Salix), and

dogwood (Cornus) (Peck and James 1983)‖.89 The Arran Lake Wetlands provide

all of these plants in abundance.

―Destruction of wetland habitat is the greatest single threat to Least Bitterns

(Gibbs et al. 1992). More than 90% of the original marshes in south-western

Ontario are now gone (Snell 1978).

―Because Least Bitterns tend to fly very low, collisions with cars, fences, and

transmission lines are a threat to mortality. (Gibbs et al. 1992). If development is

allowed through or too close to wetlands, the habitat is obviously degraded for

the bitterns. The clear perception among field observers is that the Least Bittern

population in Canada is still declining. There has been an obvious loss of

numbers in some Great Lakes marshes.‖ 90

RED SHOULDERED HAWK

―This species is protected by provincial game and fish legislation. It was classified

as Special Concern by COSEWIC in 1996. In Ontario, Red-shouldered Hawks are

classified as Special Concern by the Ontario Ministry of Natural Resources. Active

89

Ibid. 90

Ibid.

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nests are also afforded protection under the Fish and Wildlife Conservation Act

(1997), and the species is a Specially Protected Raptor under the Fish and

Wildlife Conservation Act.‖91

―The Red-shouldered Hawk is considered an indicator species of sustainable

forest management because it is an area sensitive species that requires mature

forest habitat (McLaren et al. 1998). Red-shouldered Hawks are also top

predators, which means that they may be potentially valuable as indicators of

environmental health‖.92

―The main threat to the species is habitat loss and degradation, which is likely to

be most serious in the southern parts of its Canadian range‖.93

The breeding habitat of the Red-shouldered Hawk includes ―bottomland

hardwood, riparian areas, flooded deciduous swamps and upland mixed

deciduous/coniferous forest. Nearby wetlands or other aquatic areas are

essential. This species is area sensitive, preferring extensive forest stands

consisting of mature to old-growth canopy trees with variable amounts of under

story. Large, contiguous forest tracts are essential to sustain breeding populations

of this species‖.94

―The most serious threats facing Red-shouldered Hawks in the southern portion

of their Canadian range (i.e. south of the Canadian Shield) include habitat loss,

and fragmentation or degradation of favoured deciduous forest breeding areas

91

http://www.sararegistry.gc.ca/species/speciesDetails_e.cfm?sid=58#habitat 92

Ibid. 93

Ibid. 94

2006. COSEWIC assessment COSEWIC and update status report on the Red-shouldered Hawk Buteo lineatus in Canada. Committee on the Status of Endangered Wildlife in Canada. Ottawa. vi + 27 pp. http://www.sararegistry.gc.ca/status/status_e.cfm Previous reports: Kirk, David A. 1996. Update COSEWIC status report on the Red-Shouldered Hawk Buteo lineatus in Canada. Committee on the Status of Endangered Wildlife in Canada. 1-11 pp. Risley, Christopher J. 1983. COSEWIC status report on the Red-Shouldered Hawk Buteo lineatus in Canada. Committee on the Status of Endangered Wildlife in Canada. 1-71 pp.

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and wetland feeding areas (Helferty et al. 2002). Loss of wetland habitats also

negatively affects this species through the disappearance of preferred prey (i.e.

amphibians, snakes). Campbell (1975) suggested that Red-shouldered Hawk pairs

with lower access to reptile or amphibians might have lower reproductive

success‖.95

―Loss and fragmentation of habitat also have indirect effects, including reduction

in prey supply and increased interspecific competition‖.96

―Many Red-shouldered Hawks will avoid areas of human use (Helferty et al.

2002). For example, human disturbance (from ATVs, . . . etc.) has pushed this

species into the more remote wilderness areas‖.

The risks for this bird would be multiple: first there is the usual raptor collision

mortality risk from wind turbines placed on the drumlin ridges and multiple

transmission lines imposed upon the surrounding countryside. This species

would also suffer from habitat fragmentation and disturbance. ATVs are regularly

used in servicing wind turbine installations including the met towers already

installed on this site. However, the noise disturbance and earth transmitted

vibrations from the turbines themselves would certainly have a disturbing effect

on its prey: vibration-sensitive species such as snakes and frogs which use the

uplands during part of their life cycle. As well, the drying out of soil including

upland ponds and swales, could eventually lead to loss of habitat for the reptile

and amphibian prey of this bird.

95

Ibid. 96

Ibid.

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KING RAIL

Scattered breeding season reports come from a number of other places in

southern Ontario as far north as the Bruce Peninsula.

―King Rails can occupy a variety of freshwater marshes and successional marsh

shrub swamp habitats (Meanly 1992). In wetter areas wild rice seems to be

important (Cosens 1985). What is probably most important are large marshes

with more open shallow water areas merging with shrubby areas (McCracken and

Sutherland 1987). Minimum size requirements are unknown (Brown and

Dinsmore 1986), but, only where there are large expanses of marsh, not

overgrown with cattails, do birds return in successive years, and persist over time

in Ontario‖.97

Arran Lake provides one of the best of the only remaining 10% of the original pre-

European settlement marshes left in southwestern Ontario. The presence of wild

rice and open shallow water that merges with shrubby areas as well as the large

extent of the wetland complex makes it one of the few habitats suitable for this

declining species.

GREAT EGRET

The Chantry Island inventory states: ―In 1991, surveys revealed six nests of Great

Egret, which represents approximately 3% of the Canadian population‖.98

However, by 2007, the number of Great Egret nests on the island had increased

to 54, a considerable increase in national population percentage.99

97

Ibid. 98

Bird Studies Canada; IBA site listing for Chantry Island On 154. http://www.bsc-eoc.org/iba/site.jsp?siteID=ON154 99

Cindy Cartwright, Chantry Island Bird Survey, June 8 2004. http://www.chantryisland.com/birds_of_chantry_island.htm

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BLACK TERN

The relatively large size of the Arran Lake wetland complex makes it attractive to

the Black Tern. According to the MNR data, it generally requires permanent

marshes that are at least 50 ha. Black Terns have disappeared from many

marshes that have been reduced much below this threshold. ―Several species of

marsh birds are ‗area sensitive,‘ requiring large tracts of habitat in order to

successfully reproduce. The Black Tern is moderately area-sensitive.‖ 100

―Recent declines have been occurring since the 1980‘s. The Black Tern has

seriously declined throughout its range. A recent analysis of Breeding Bird Survey

data showed that the population has been declining by an average rate of 4.7%

per year since 1966. Over the span of just 30 years, this translates to an overall

loss of about 75% of the population! This species is clearly in serious trouble.

―The decline might be more directly connected to habitat loss due to development

pressures. The future of the Black Tern is quite uncertain. It is already considered

endangered in New York, Pennsylvania and Ohio, threatened in Ontario, and a

species of special concern in Michigan‘‘.101

BLACK-CROWNED NIGHT HERON

―As its name implies, this stocky, short-legged heron is active at night. About

sunset and in the gathering dusk it makes its steady way on broad wings to its

feeding marshes. It feeds largely on fishes, but also eats frogs and small rodents‖.

The Arran wetland and surrounding uplands are one of its most important

feeding resources.

100

Ibid. 101

Ibid.

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SHORT-EARED OWL

This bird prefers ―extensive stretches of relatively open habitat. It is primarily a

bird of marshland and deep grass fields. It likes to hunt and roost in abandoned

pastures, fields, hay meadows, grain stubble, and marshes in the winter. Nests

are usually slight depressions in the ground. In Ontario, some nests are cups of

dried weeds or flattened grasses.‖102

SPOTTED TURTLE

The Arran Lake Wetlands are an ideal habitat for the Spotted Turtle which occurs

in high organic content wetlands including acidic bogs and alkaline fens in the

Eastern Deciduous/Great Lakes forest region. The species prefers unpolluted

shallow waters of ponds, bogs, fens, marshes, ditches, vernal pools, woodland

streams, sedge meadows and the sheltered edges of shallow bays (Ernst et al.

1994; Haxton and Berrill 1999; Litzgus and Brooks 2000).

It also represents one of those species that moves from the wetlands area to the

surrounding uplands during part of its seasonal cycle.

―Spotted Turtles use a mosaic of habitat types, display distinct seasonal shifts in

habitat use (Haxton and Berrill 1999; Litzgus and Brooks 2000), and require

terrestrial habitats during certain times of their seasonal activity cycle. Nesting

occurs in terrestrial sites in areas exposed to full sunlight. In some populations,

excursions are made to terrestrial habitats for summer dormancy (Graham 1995;

Perillo 1997; Litzgus and Brooks 2000)‖.103

Habitat loss, destruction, and fragmentation have been implicated in the decline

of Spotted Turtle populations throughout their range104 Human-altered

102

http://www.sararegistry.gc.ca/species/speciesDetails_e.cfm?sid=60 103

ROM Litzgus 2004; Oldham 1991; Cook 1984 http://www.rom.on.ca/ontario/risk.php?doc_type=fact&id=96 104

Lovich 1989; Burke et al. 2000.

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landscapes have reduced the quantity and quality of Spotted Turtle habitats.

Spotted Turtles have a relatively low reproductive output.

―The total population trend for Canada is declining; NHIC records indicate a 35%

decline (see Technical Summary). This value is likely an underestimate given that

most of the NHIC data were collected in the past 30-40 years, and that the

average age of breeders is over 25 years, and thus 3 generations requires more

than 75 years. This extended generation time exacerbates declines resulting from

collection of adults for the pet trade. The species appears to remain abundant in

only a few localized pockets in Ontario, but with the increasing disappearance of

wetlands in southern Ontario, further decline in Spotted Turtle populations is

inevitable. (Oldham 1991)‖.

Turtles in this group may be more susceptible than other turtle species to the

current level of habitat modification occurring throughout eastern North America

(Oldham 1991). Reasons for decline in Spotted Turtles include over collection for

the pet trade, habitat destruction and fragmentation, and road mortality.105

EASTERN MILK SNAKE

This species has been designated because of characteristics that make it

particularly sensitive to human activities.106 The snake is susceptible to the

effects of human encroachment as well as habitat loss. Many Milk snakes have

been killed by vehicular traffic (―road-kill‖) or by agricultural machinery.

105

ROM op. cit. 106

COSEWIC 2002. COSEWIC assessment and status report on the milksnake Lampropeltis triangulum in Canada. Committee on the Status of Endangered Wildlife in Canada. Ottawa. vi + 29 pp. Fischer, L. 2002. COSEWIC status report on the milksnake Lampropeltis triangulum in Canada in COSEWIC assessment and status report on the milksnake Lampropeltis triangulum in Canada. Committee on the Status of Endangered Wildlife in Canada. Ottawa. 1-29 pp.

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Milksnakes are especially affected by habitat loss and modification.

Special significance of the species: The Eastern Milksnake is the only subspecies

of Milksnake found in Canada. The snake‘s presence in barns and stables has

proven to be beneficial, as the snake helps to control rodent populations (its

prey).107

This species has been observed annually in the vicinity of the proposed wind

turbine site at Arran Lake. Its preferred habitat includes farm fields, hayfields,

pastures, swamp and open woodlot. Two other important features make this area

ideal Milksnake habitat: the proximity to water, in this case Arran Lake and the

wetlands, and suitable locations for basking and egg-laying.

EASTER RIBBON SNAKE

There is little historical data in Ontario on abundance trends, but it is likely that

the reduction of wetland habitat through urban and agricultural development

resulted in a decrease in abundance in Ontario. Today it is widespread and locally

common in parts of the Bruce Peninsula, Georgian Bay and eastern Ontario.108

Its presence at Arran Lake is explained by the fact that it is usually found close to

water, especially in marshes where it hunts for frogs and small fish. At the onset

of cold weather, individuals congregate in burrows or rock crevices on land to

hibernate together in what is termed a "hibernaculum." 109

TUBEROUS INDIAN-PLANTAIN

This plant is subject to recreational development and use but with some

populations in protected areas. Status history Designated Special Concern in

April 1988. Status re-examined and confirmed in April 1999 and in May 2002.

107

Ibid. 108

Text Sources: Smith 2000; MacCulloch 2002 Royal Ontario Museum http://www.rom.on.ca/ontario/risk.php?doc_type=fact&lang=&id=295 109

Royal Ontario Museum and the Ontario Ministry of Natural Resources

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Last assessment based on an existing update status report. The species is found at

only 13 localities consisting of shoreline fens and riparian meadows. These plants

prefer open sunny areas in wet, calcareous meadows or shoreline fens‖.110

APPENDIX 3: BAT SPECIES FOUND AT ARRAN LAKE

NORTHERN LONG-EARED BAT (Myotis septentrionalis)111

LITTLE BROWN BAT (Myotis lucifugus) ―Strictly an insect-eater, it

catches its food on the wing, flying about through wooded areas or over fields, lakes and streams‖.112 The presence of this species at Arran Lake illustrates the importance of the range of habitat components within this natural habitat system since it makes use of forested areas, open fields and lakes and streams. Little Brown Bats are very efficient hunters sometimes catching ten to fifteen insects per minute by means of echolocation. (They can consume 600 mosquitoes in a single hour).‖113

EASTERN SMALL-FOOTED BAT (Myotis Leibii). This is an

uncommon bat, probably as a result of low survival rate and small litter.

SILVER-HAIRED BAT (Lacionycteris noctivagans). This is one of the

three ―tree bats‖ (along with the Red Bat and the Hoary Bat) at Arran Lake. The natural habitat system at Arran Lake is particularly suited to this animal which inhabits wooded country and stands of trees in open country, near ponds streams and lakes. It roosts in trees and forages over small bodies of water—sometimes close to the ground but also at or below tree top level. This is a migratory species and its slow flight makes it especially susceptible to wind turbine fatality. It flies south between mid-August and early October and returns about the middle of April to early summer.

RED BAT (Lasiurus borealis) This bat is found in forests and in more open

cultivated areas where shade trees are present. The proposed wind turbine site at Arran Lake is its ideal habitat. Another migratory species, it is also at risk of mortality from wind turbines during migration. Hoary Bat (Lasiurus cinereus) This is also a tree bat that roosts in foliage near the end of branches, usually on the edge of clearings or fields, such as beside the

110

Ibid. 111

The Mammals of Eastern Canada.Randolph L. Peterson. Toronto: Oxford University Press, 1966. 112

Ibid. 113

MD Tuttle, Bat Conservation International www.frontiersinecology.org The Ecological Society of America

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proposed wind turbine sites at Arran Lake. This is a migratory species which arrives in Canada in May or early June. The fall migration takes place from mid-August to October. These bats are thought to winter in Southern United States and Mexico.

BIG BROWN BAT (Eptesicus fuscus) Found in wooded and semi-open

habitats. It hibernates in old barns, attics, and tree cavities and feeds extensively on June beetles. This bat forages among and over the tops of trees at 7 to 10 m above the ground, putting it entirely within the range of the turbine blades. ―As wind turbines continue to increase in height, bats that migrate or forage at higher altitudes may be at increased risk (Barclay et al. 2007)‖. ―Relatively small numbers of bat fatalities were reported at wind energy facilities in the US before 2001 (Johnson 2005), largely because most monitoring studies were designed to assess bird fatalities (Anderson et al. 1999). Thus, it is quite likely that bat fatalities were underestimated in previous research. Recent monitoring studies indicate that some utility-scale wind energy facilities have killed large numbers of bats (Kerns and Kerlinger 2004; Arnett 2005; Johnson 2005)‖.114 ―It has been demonstrated that this species is capable of detecting relatively low-frequency sound, such as that produced by groups of insects, over a maximum distance of 600 m. Such long distance acoustic cues could help the bat locate concentrations of flying insects and thus supplement the shorter range high frequency echolocation.‖115 It is likely that this subtle natural hunting adaptation becomes confusing or dysfunctional as a result of interference from the low frequency noise projected from industrial wind turbines. ―Of the 45 species of bats found in North America, 11 have been identified in ground searches at wind energy facilities. Of these, nearly 75% were foliage-roosting, eastern red bats (Lasiurus borealis), hoary bats (Lasiurus cinereus), and tree cavity-dwelling silver-haired bats (Lasionycteris noctivagans), each of which migrate long distances. Other bat species killed by wind turbines in the US include . . . the little brown bat (Myotis lucifugus), . . . northern long-eared myotis (Myotis septentrionalis), [and] big brown bat (Eptesicus fuscus). A consistent theme in most of the monitoring studies conducted to date has been the predominance of migratory, tree-roosting species among the fatalities‖. 116

APPENDIX 4: GANNON REPORT ON BAT MORTALITY

The Maple Ridge Wind Power Avian and Bat Fatality Study Year One Report (Final Report) dated June 25, 2007 by Aaftab Jain et al, Curry and Kerlinger, LLC117 also confirms that all these species are especially susceptible to wind

114

Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses. Thomas H Kunz et. al. 115

C.G.van Zyll de Jong, op.cit., p.164. 116

Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses Thomas H Kunz, Edward B Arnett, Wallace P Erickson, Alexander R Hoar, Gregory D Johnson, Ronald P Larkin, M Dale Strickland, Robert W Thresher, and Merlin D Tuttle. 117

http://www.windaction.org/documents/8533

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turbine mortality. The study also indicates that fatalities are greater when the turbines are closer to wetlands. ―Remains of 326 bats were found by searchers during standardized surveys, representing five species (Hoary Bat, Silver-haired Bat, Eastern Red Bat, Little Brown Bat, and Big Brown Bat). The greatest number of bat incidents occurred during the fall migration period, with 228 (69.9%) bat carcasses found between July 1, 2006 and August 31, 2006. In Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses. Thomas H Kunz et. al.speculate that: ―bats may become acoustically disoriented upon encountering these structures during migration or feeding. Bats may also be attracted to the ultrasonic noise produced by turbines (Schmidt and Jermann 1986). Observations using thermal infrared imaging of flight activity of bats at wind energy facilities suggest that they do fly (and feed) in close proximity to wind turbines (Ahlén 2003; Horn et al. 2007; Figure 3). What other factors might contribute to bat fatalities? Wind turbines are also known to produce complex electromagnetic fields in the vicinity of nacelles. Given that some bats have receptors that are sensitive to magnetic fields (Buchler and Wasilewski 1985; Holland et al. 2006), interference with perception in these receptors may increase the risk of being killed by rotating turbine blades. Bats flying in the vicinity of turbines may also become trapped in blade-tip vortices and experience rapid decompression due to changes in atmospheric pressure as the turbine blades rotate downward. Some bats killed at wind turbines have shown no sign of external injury, but evidence of internal tissue damage is consistent with decompression (Dürr and Bach 2004; Hensen 2004). Additionally, some flying insects are reportedly attracted to the heat produced by nacelles (Ahlén 2003; Hensen 2004). Preliminary evidence suggests that bats are not attracted to the lighting attached to wind turbines (Arnett 2005; Kerlinger et al. 2006; Horn et al. in press). Bats foraging in the vicinity of wind turbines may miscalculate rotor velocity or fail to detect the large, rapidly moving turbine blades (Ahlén 2003; Bach and Rachmel 2004; Dürr and Bach 2004). Given the speed at which the tips of turbine blades rotate, even in relatively low-wind conditions, some bats may not be able to detect blades soon enough to avoid being struck as they navigate.‖ Bat carcasses appeared to fall closer to turbine tower bases than bird carcasses. Bat fatalities appeared to be slightly greater at turbines close to wetland areas than at turbines located farther from wetlands‖. Scientists do not yet understand why bats are particularly vulnerable to wind turbines. But anyone who has heard the invasive noise emitted by wind turbines (equivalent to constant jet roar or freight train rumbling) will have no difficulty in understanding that an animal species capable of homing in on the subtlest of frequencies emitted by flying insects is bound to be disorientated by this thundering industrial disturbance.

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Two very recent research papers suggest that the impact of wind turbines on this agriculturally important keystone species is more devastating than first understood. In Current Biology, Volume 18, Issue 16, 26 August 2008, pages R695-R696, Erin F. Baerwald, Genevieve H. D‘Amours, Brandon J. Klug, and Robert M.R. Barclay of the University of Calgary report the first evidence that barotrauma is the cause of death in a high proportion of bats found at wind energy facilities. They found that 90% of bat fatalities involved internal haemorrhaging consistent with barotrauma, and that direct contact with turbine blades only accounted for about half of the fatalities. Air pressure change at turbine blades is an undetectable hazard and helps explain high bat fatality rates. They suggest that one reason why there are fewer bird than bat fatalities is that the unique respiratory anatomy of birds is less susceptible to barotrauma than that of mammals. Another report published in the Journal of Wildlife Management 72(1):61–78; 2008 warns of the severity of impact of wind turbines on bats: Based on estimates of installed capacity and the limitations and assumptions with respect to fatality rates, projected annual fatalities of bats in the Mid-Atlantic Highlands in the eastern United States could range from 33,017 to 61,935 (2,158-MW installed capacity) or from 58,997 to 110,667 (3,856-MW installed capacity) bats per year by 2020 in just this one region (National Research Council 2007). These projections, although hypothetical, should be of particular concern for species of migratory tree bats that experience the highest fatalities at wind energy facilities in North America. North American bats consume half their weight in flying insects each night. All bats in Ontario feed on insects. (At one time health risks were associated with bats but histoplasmosis has never been found in Canadian bat colonies. Bats do occasionally get rabies, but less frequently than foxes or skunks). Today, with the introduction of the West Nile Virus carried by mosquitoes, they may have an even more important role to play in the protection of human health. Dr. Gannon continues: ―The economic value of bats as a biological control agent for insects is estimated to be in the multi billions of dollars annually in the US alone. ―As such, they are considered to be ecological keystone species. . . . The keystone is the stone that bears the majority of the weight in an archway. If it is disturbed or removed, the archway collapses. Bats are keystone species in our ecosystem. They play a vital role in maintaining it, and if disturbed or reduced, the ecosystem as we know it will collapse. However, bat populations are declining worldwide, mostly due to the actions of man. ―As bats have a very low reproduction rate, where each female produces only one offspring or pup per year, any event that causes a population decline can take many years to recover from. Any event that repeatedly kills bats, year after year, in large numbers, can be devastating to a population. The proliferation of numerous wind sites in this part of the country, most of which have or are being documented to have such an effect on bats, could be the most serious threat to our bat populations, our biological insect control, that science has seen. The chances that a wind facility in this area will have a negative impact on our bat

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populations appears to be extremely high. Government Officials, with a responsibility of protecting our valuable natural resources, have a responsibility that before they allow construction of such a facility, they insure that the sites have been evaluated for their potential impact on bats and other wildlife. Just as the power companies evaluate it for wind, and place these facilities only in areas where there is sufficient wind blowing, they need also to be evaluated for their environmental impact and sites that have a high potential to negatively impact wildlife should be avoided‖.

ADDITIONAL REFERENCES CITED BY DR MICHAEL GANNON:

Committee on Natural Resources, Subcommittee on Fisheries, Wildlife and Oceans: "Gone with the Wind: Impacts of Wind Turbines on Birds and Bats. 2007. Oversight Hearing. http://resourcescommittee.house.gov/index.php?option=com_jcalpro&Itemid=64&extmode=view&extid=47 Kunz, T. H., E. B. Arnett, W. P. Erickson, A. R. Hoar, G. D. Johnson, R. P. Larkin, M. D. Strickland, R. W. Thresher, and M. D. Tuttle. 2007. Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses. Front. Ecol. Environ., 5:315¬ 324. http://www.windaction.org/?module=uploa ... ileId=1293 National Research Council of the National Academy. 2007. Environmental Impacts of Wind-Energy Projects. National Academies Press, Washington, DC. http://www.eswr.com/latest/307/nrcwind.htm : United States Fish and Wildlife Service (2003) Memorandum to Regional Directors, Regions1-7 on Service Interim Guidance on Avoiding and Minimizing Wildlife Impacts from Wind Turbines, 13 May 2003, 57 pp. http://www.fws.gov/habitatconservation/wind.pdf

APPENDIX 5

LETTER FROM HEALTH CANADA

Safe Environments Program Regions and Programs Branch, Health Canada 1505 Barrington Street, Suite 1817 Halifax, NS B3J 3Y6 August 6, 2009 ATL-2008/09-006 / OF6-3-107 Steve Sanford Environmental Assessment Officer Nova Scotia Department of Environment Environmental Assessment Branch P.O. Box 442 Halifax, NS B3J 2P8

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Subject: Health Canada‘s response to the Digby Wind Power Project Addendum, Digby, NovaScotia1

Dear Mr. Sanford:

Thank you for your letter July 9, 2009, requesting Health Canada‘s review of the above-mentioned Project with respect to issues of relevance to human health. Health Canada has reviewed the report, and has the following comments with respect to noise.

Section 2.1 (Site Layout Review) and Table 1 (Summary of Effects and Significance Prediction Comparison of Site Layouts) – The revised layout adopted by the proponent appears to yield sound levels that should normally be below Health Canada‘s acceptable threshold value of 45 dBA for sleep disturbance at the exterior of the building of the nearest sensitive receptor (WHO, 1999). However, if a 5 dBA to 8 dBA increase in sound due to the proximity of the ocean were assumed and an additional +/- 3dBA were included to account for model uncertainties, noise levels may exceed 45 dBA. Thus, predicted sound levels, even under assumed worst-case conditions, may underestimate measured levels by 5 dBA or greater. For example, at another wind farm in Nova Scotia, maximum sound levels were estimated to be 49 dBA using ISO9613-22, however, measured values were as high as 54 dBA when wind speeds were 5 m/s blowing on-shore from the ocean (Howe, Gastmeier Chapnic Limited, 20063).

Health Canada advises that noise monitoring be undertaken under varying climatic conditions in order to ensure that noise levels do not exceed the acceptable level, and if exceedences are identified, that appropriate mitigation be implemented to reduce the noise level to an acceptable level.

1 Stantec. 2009. Digby Wind Power Project Addendum. Addendum to Environmental

Assessment Registration Document. Prepared for SkyPower Corp. July 3, 2009.

2 ISO (International Standards Organization) ISO9613-2. 2003. Acoustics -- Attenuation

of sound during propagation outdoors -- Part 2: General method of calculation.

3 Howe Gastmeier Chapnik Limited (HCG Engineering). 2006. Environmental Noise

Assessment Pubnico Point Wind Farm, Nova Scotia. Natural Resources Canada Contract

NRCAN-06-00046.

Sent by e-mail to [email protected] 2

Section 3.2.2 (Effect of Water on Noise Levels) – The report states that ―it has generally been considered that the increased background wind noise will cause some masking of the sound levels from the turbines‖ and ―if there is an enhanced stability, the wind that causes background sound may not increase as much as that which causes sounds from the turbines‖. These statements can be misleading as turbine noise is likely to be audible to the nearest receptors in the form of continuous low-level or intermittent swooshing, as well as low frequencies at approximately 50 Hertz. As such, Health Canada advises the following:

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Please omit statements about noise masking as they can be misleading; and

Please ensure that nearby residents are informed that turbine noises may be audible in terms of a low-level continuous or intermittent swooshing, as well as at low frequencies around 50 Hertz.

Section 3.2.3 (Noise Mitigation) – The report states that ―noise monitoring [will be conducted] on a routine basis or complaint basis‖. In addition to the plan for monitoring and complaint resolution, which is intended to help mitigate any adverse community reaction, it is advisable to also implement a communication strategy. Accurate information with respect to potential acoustical effects related to the operation of the turbines is an essential part of any effective communication strategy.

Please ensure that any communication effort presents factual information with respect to expected noise levels, including information pertaining to the audibility of operational noises (low-level continuous, intermittent swooshing or low frequency noise), and also includes the potential effects of specific noise levels on human health (see the following comment below).

• Appendix B (Addressing Concerns with wind Turbines and Human Health) – The final sentence in Appendix B states that ―there is no peer-reviewed scientific evidence indicating that wind turbines have an adverse impact on human health‖. In fact, there are peerreviewed scientific articles indicating that wind turbines may have an adverse impact on human health. For example, Keith et. al. (2008), identified annoyance as an adverse impact on human health that can be related to high levels of wind turbine noise. In addition, there are several articles by Pedersen (and others) related to wind turbine annoyance (as referenced below). The relationship between noise annoyance and adverse effects on human health is also further investigated in the manuscript by Michaud et. al (2008).

Health Canada advises that this statement be revised to indicate that there are peer reviewed scientific articles indicating that wind turbines may have an adverse impact on human health.

References:

Keith, S. E., D. S. Michaud, and S. H. P. Bly. 2008. A proposal for evaluating the potential health effects of wind turbine noise for projects under the Canadian Environmental Assessment Act. Journal of Low Frequency Noise, Vibration and Active Control, 27 (4): 253-265.

Michaud, D.; S.H.P. Bly, and S.E. Keith. 2008. Using a change in percentage highly annoyed with noise as a potential health effect measure for projects under the Canadian Environmental Assessment Act. Canadian Acoustics, 36(2): 13-28.

Pedersen E. and Halmstad, H.I. 2003. Noise annoyance from wind turbines – a review. Swedish Environmental Protection Agency, Report 5308.

Sent by e-mail to [email protected]

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