Environmental Impact Statement – Eastern Kings 30-Megawatt Wind Project
Comments by the Environmental Coalition of PEI
Ann Wheatley, December 10, 2019
On behalf of the Environmental Coalition of Prince Edward Island, I would like to comment on the process of engaging the community in the development of 30-Megawatt Wind Project that is under consideration for Eastern Kings County. And by “community” I mean not only people living in the immediate vicinity of the proposed project, but also other people living in Prince Edward Island who may have an interest in whether or not and how the project rolls out.
The Environmental Coalition believes that wind energy is an appropriate and necessary part of this province’s plan to address the climate emergency that we know, with certainty, that we are experiencing right now. An emergency that requires a full-scale, just transition away from our carbon economy to a new economy based on renewable energy, but also based on good, green jobs, investment in public services and fairness for all.
ECOPEI has consistently spoken in favour of wind and solar energy, and has actively participated, whenever opportunities have arisen, in the development of PEI’s climate and energy plans.
It’s important to us that as much as possible, wind – in fact any kind of renewable – energy projects:
- are publicly owned and operated,
- are based on comprehensive assessments of the environmental impacts and that they include a plan for ongoing and constant monitoring,
- engage communities from the very beginning, as soon as projects are identified,
- involve community consultation that is meaningful, respectful, and follows local community norms, and
- ensure that the duty to consult with Indigenous peoples is upheld.
Good decisions, whether they are about policies or programs, or projects such as this, are made when the people most affected by those decisions are involved right from the beginning.
I appreciate that the PEI Energy Corporation has participated in or organized several community meetings in Eastern Kings, and that they have posted information on their website. And that in some cases they have responded to community concerns. However, I’m not sure you could call this meaningful consultation, and I’m pretty sure you can’t call it collaborative.
There are several inadequacies built into PEI’s Environmental Assessment legislation, and I think you can trace some of the discontent in the community back to those inadequacies.
The requirements for public consultation are minimal at best. A single public meeting advertised for 6 days in the Guardian is problematic for several reasons. Most obviously, one meeting is not enough time for people to share and discuss their concerns. Sometimes conversations need to happen over a period of time, allowing for mutual learning and problem-solving. People need time, not just to hear about any given project, but to explore the associated benefits and the risks. They need time to talk to their neighbours and deepen their understanding before they formulate an opinion.
Plus, the reading required to be able to participate in a consultation in an informed way is really onerous – the Environmental Impact Assessment document is 300 pages!
At a time when newspapers are struggling to maintain any sort of readership, when so many people get their news almost exclusively from social media, an ad in the newspaper is not the most effective way to let people know about a meeting. I’ve spent 25 years organizing different community events, workshops and meetings – one of the things I learned very early on is that you need to use multiple media and methods to bring people out. And one of the best ways is to communicate directly with local groups – Women’s Institutes and Seniors’ Clubs for example. We are not aware that this kind of outreach has happened with this project and as a result, there are people who may have been left out.
This project was presented to the community after a plan had been made. But we know there are real advantages when a community is brought into the process early, in the planning stages. In the first place, people in the community see they have a role in the project, and in the planning. It becomes more about building relationships, than it does about managing conflict which I think one could argue is what has happened in this case. And it could be that by involving the community earlier, you can actually come up with a better plan.
When the public consultation process is limited to the people who live in or close to the location of any proposed project, some valuable information and perspectives may be lost. And, it just doesn’t make sense. This evening you are hearing from several people who, despite living in other parts of the province, know this area intimately, and have a deep appreciation for its ecological integrity and for its beauty. Their observations add to the quality of the discussion of the pros and cons of the proposed development. Besides, we are all affected by climate change, and whether this development goes ahead, or even if it does not, it will have an impact on all residents of PEI.
It was therefore disappointing to see that only two non-governmental organizations were consulted as part of the EIA process. (The Mi’kmaq Confederacy of PEI and the Rural Municipality of Eastern Kings, both of which are more institutional than NGO.) Why was arguably the most important environmental group in the area, the Souris & Area Branch of the PEI Wildlife Federation not on that list? Other organizations such as the Nature Conservancy, Island Nature Trust, Nature PEI, Macphail Woods, Sierra Club Atlantic, may also have valuable perspectives to add.
People want to see that their contributions will be valued, and that their input will be considered when decisions are made. They participate in the process in good faith, because something about the issue is important to them.
In the case of this project, trust was broken when the Minister responsible, Steven Myers made a statement, on September 30, to the effect that the project would be going ahead. This was before the environmental assessment had been completed, and before the community had a chance to respond. Yet according to Steven Myers, “the plan was set”. The Minister later attempted to walk back his comments, claiming that they were taken out of context, but it was too late. He had shown his bias, but more importantly his comments revealed alarming attitudes about the role of community consultation, and of the environmental assessment process in decision-making. It was apparent that at least in his view, these are exercises, necessary to get projects up and running – but that really, decisions are made outside of any consideration of the results of such processes.
Besides being quite shocking, given the Premier’s direction in his mandate letters to all of the Ministers, “We seek the involvement of the People, ensuring our progress is measurable through transparent decision making and broad public engagement”, Myers effectively demonstrated that in the case of this project, public participation is in no sense of the word, meaningful. Because if it were meaningful, the public would feel confident that their input could influence or even change the project.
This isn’t helped by the fact that components are being ordered for the proposed turbines, and that construction is slated to happen by the spring of 2020. Admittedly, this is a climate emergency, but that doesn’t negate the importance of a process that is more respectful of the needs and interests of the community, and of the wisdom that exists in the community.
This project has really demonstrated the weaknesses in PEI’s Environmental Impact Assessment Guidelines. We can view it as a learning opportunity and make a plan to overhaul those guidelines and make sure that from now on public consultation is meaningful and thorough. [ ECOPEI has asked two successive Ministers of the Environment to do this, and has offered good advice, but to no avail, sadly.] In the meantime, there should be more time set aside to explore the concerns already expressed by members of this community.
We know that we need to make this kind of investment in wind and other renewable energy in order to make the transition away from fossil fuels. Decisions – about energy projects and anything else – are more durable when everyone knows they’ve been heard. And that requires paying more attention to how people and communities are engaged. It depends on building relationships and approaching projects as opportunities for collaboration where everyone involved is willing to listen, to learn and to change.
The community perception that this project has been a “done deal” from the beginning has caused a great deal of discontent. Instead of entering into dialogue with the community, instead of showing a willingness to modify the plan based on the expressed interests and concerns of the community, the Energy Corporation has responded by almost discounting those concerns.
I am afraid this process will have a negative impact on future wind developments, which we dearly need in order to reduce our carbon emissions. I understand that personnel in the Energy Corporation feel they’ve done a good job of consulting with community and may be puzzled, even frustrated that there has been so much resistance.
I hope that this will cause the Corporation to examine its processes for community consultation – rethinking timelines, outreach and communications, and processes that encourage fruitful dialogue and collaboration and which pay due respect to the wisdom and knowledge of people in affected communities.