Co-Chair, Environmental Coalition of Prince Edward Island
December 5, 2019
The Environmental Coalition of Prince Edward Island (ECOPEI) fully supports wind energy. It is important that we move away from fossil fuels if we are to deal with the climate crisis. Wind is not the only potential source of alternate energy, but it certainly a valuable one. I also confess to loving the East Point area – I go up there a couple of times a month for its birds and beauty. I’ve written about it, taken photos, and suffered some of the worst weather through the years in order to see such a magnificent display of bird life, unprecedented in the province. It really is a jewel.
The one thing about engaging in a public process is that it takes time. The provincial assessment carried out by Wood Environment and Infrastructure Solutions is 299 pages. I also looked at the Environmental Assessment of the 30MW East Point Wind Plant, prepared in 2006 by Frontier Power Systems. That one is 256 pages. Then there was “Wind Turbines and Birds – A Guidance Document for Environmental Assessment,” from Environment Canada, 2006, which is 50 pages. Plus, there are lots of articles on both the positive and negative aspects of wind power. That’s a lot of reading that most people just don’t have the time to do.
The Environment Canada document is very interesting. It notes that “As the wind energy sector rapidly expands, it is important to ensure that it does so in a manner that does not result in adverse effects on other aspects of the environment.”
That is certainly my goal – to understand whether this project will have adverse effects on other aspects of the environment.
This wind development cannot be viewed in isolation. First, there is a lot of good science out there that tells us that bird populations in North America have declined by 29% since 1970. There are lots of reasons for this, but it is a shocking fact. Our birds are already under stress. And our bats? I used to see them everywhere and now bats are a rarity. Again, lots of reasons, predominantly white nose syndrome. But clearly they are already under stress.
There is a lot at risk here. We have some bird and bat species protected under the federal Species at Risk Act. We also have lots of plants, at least in the area, that are listed by the Atlantic Canada Conservation Data Centre as either S1 (Critically imperiled in the province because of extreme rarity [often 5 or fewer occurrences] making it especially vulnerable to extirpation from the province) or S2 (Imperiled in the province because of rarity due to very restricted range, very few populations [often 20 or fewer], steep declines, or other factors making it very vulnerable to extirpation from the province.) We also have migratory birds protected under the Migratory Birds Convention Act, though this piece of legislation actually does little to protect many species.
Regarding that last piece of legislation, the consultants recognized the need to protect nesting birds during the construction phase. While noise and disturbances will still be generated, at least there will be no clearing, grubbing or trimming taking place during the prime bird breeding season of May 1st to August 31st. That is great to see.
My reading on the development has made me all the more aware that we desperately need provincial legislation on rare and endangered plants and animals. We cannot simply depend on the Species at Risk Act and pretend that if something is not on SARA, it is not that important. The consultants often mention “none of the floral species are legislatively protected”, but that doesn’t mean they shouldn’t be. In my work with Macphail Woods, we collected seed from plants that had only two specimens left in the province. Without those two plants, the future of this species would be in doubt. And I collected spores from a rare fern in this area which is found in only one other location in the province. Clearly, we need to better understand the importance of rare plants and why they need protection.
The SARA-listed species found in the area include two bats and the piping plover (endangered); barn swallow, bank swallow, bobolink, Canada warbler, and olive-sided flycatcher (threatened); and eastern wood-pewee, peregrine falcon, and rusty blackbird (species of special concern). These are species to be worried about, but they are not the only ones.
The Environment Canada report found that “Generally, objects over 150m in height appear to pose a greater threat to nocturnal migrants; such taller objects can cause mass bird kills, as found at communication towers and tall buildings. Any turbines taller than 150m in height should be subject to closer scrutiny to ensure their environmental impact is minimised, especially for sites close to arrival and departure sites of nocturnal migrants, on mountain tops or in foggy areas.” These turbines will be 175m tall and as far as I know, we have very little experience with turbines this high.
It also brings up a term I’d never seen before, called Motion Smear. “Birds do not recognise the threat posed by a quickly turning blade and cannot learn to avoid them. Even larger turbines that have lower hub rpms have tip and blade speeds that are fast enough to prevent birds recognising the threat they pose.”
I am pleased to hear that the province has set up a radar system to track birds, and a songbird acoustic monitoring system to better identify what is flying around, especially during migration. The East Point area is an important migratory corridor for songbirds, raptors and other species. The report states, “The MERLIN system classifies “biological targets” (i.e., birds and bats) into size classes generally corresponding to small, medium, large sized birds, as well as flocks; however, the system cannot definitively distinguish species.” This will be useful if the turbines will be shut down when large numbers of birds are migrating, but it won’t be able to tell if there is a threat to smaller numbers of rare species.
I look forward to reading the supplementary report on these findings.
It is worrisome that we don’t have all the information needed on the effects this project might have on birds, yet it seems to have been given the green light. It is no good saying you’ll shut them down at certain times in order to mitigate problems. That may throw your economic projections out the window, since you don’t know what you might have to mitigate for.
The problems associated with wind turbines and bats are widely known. Especially with their already declining populations, there is cause for concern. The report states that “According to the PEIDEWCC, the Eastern Kings site is situated near two features of known importance to bats (swarming/over-wintering sites). Further, they state that it is possible that Northern myotis use the forest in question as maternity roost habitat.” I want to make sure that we use the best science to protect these species.
We need to look at this wind project carefully and with all the information on the table, fairly presented. For example, when looking at the consultant’s report, I disagree with the claim that the existing wind farm is producing “emission-free electricity.” The turbines took huge amounts of carbon to build, the transportation and installation certainly used carbon, and every time a turbine needs to be serviced, have a blade replaced, or is decommissioned, that also uses carbon. Wind has a much, much smaller carbon footprint than coal or natural gas, but I would just like to see an accurate accounting of what these emissions are. At the very least we need to know that a consultant’s accuracy is beyond question.
Again, I firmly believe that wind energy is an essential aspect of any strategy to ensure a rapid transition to a carbon-neutral energy system, as climate scientists have warned we must do. I’m not saying “don’t build turbines here”, and I’m definitely not saying “don’t build turbines at all.” But I am saying “do your homework first, and make sure you have all the facts you need to make good decisions.” The impacts on birds of turbines of this height have not been adequately studied. Therefore, a precautionary approach is called for.
If the project does go ahead, after a fair and transparent process, I would propose stringent post-construction monitoring. The 2011 Ontario Ministry of Natural Resources publication “Birds and Bird Habitats: Guidelines for Wind Power Projects” calls for three years of monitoring consisting of regular bird mortality surveys around specific wind turbines; monitoring of bird carcass removal rate by scavengers, and monitoring of searcher efficiency, among other things. Given the height of the turbines and the uncertainties, the radar tracking should also be continued. This is how we learn and get better at what we do.
In the end, we might find that the present proposal is the best one we can design in order to reduce our dependency on fossil fuels, once the studies are all done, adequate local benefits are guaranteed to the community, and the assessment process has treated the public fairly. Or it might need some tweaks, such as moving or removing one or two turbines that are closest to the red triangle and figuring out some added safety measures for birds and bats. Or it might make sense to find another site that isn’t so close to one of the most important birding areas in the province – even if that means less than ideal wind speeds.