Electricity Distributors Association Organization Name Enbridge Gas Distribution A Enniskillen Environmental Association Enniskillen Township Association of Municipalities of Ontario Enwin Utilities Association of Power Producers of Ontario Association to Protect Amherst Island H Ashfield-Colborne-Wawanosh Residents’ Group H.A.R.M. B (sub-group of Central Bruce Grey Wind Concerns) BayNiche Conservancy Biogas Association I Bruce Peninsula Wind Turbine Action Group Innergex Renewable Energy Inc. C International Association for Public Participation IPC Energy White Paper on Large FIT Procurement C4CA Canadian Nuclear Association K Canadian Solar Industries Association Canadian Union of Public Employees Ontario King Township Canadian Wind Energy Association L Cavan Monaghan Township Central Bruce-Grey Wind Concerns Ontario Lake Superior Action Research Conservation Chartwell-Maple Grove Residents Association Legacy Holsteins City of Barrie City of Burlington M City of Guelph City of Kawartha Lakes Mississauga Residents’ Associations Network City of Toronto and Toronto Hydro Multi Municipal Wind Turbine Working Group Common Voice Northwest Energy Task Force Municipality of Grey Highlands County Coalition for Safe and Municipality of Kincardine Appropriate Green Energy Municipality of North Perth Municipality of Northern Bruce Peninsula D N Durham Region Natural Resources Canada NextEra Energy Niagara Region Northland Power NRStor

Ontario Dialogue on Regional Planning and Siting Large Energy Infrastructure

A Discussion about Energy Planning & Infrastructure Siting in Ontario Follow-Up Meeting with C4CA, CHIP and MIRANET and OPA & IESO

Nancy Robertson, Frank Clegg, Lee Battiston Pauline Watson, Susan Hyatt, Dr. Boyd Upper

July 29, 2013 Oakville/Mississauga We support (7 and 10) We strongly support community engagement in Municipal and Regional electricity planning •It has to be meaningful and substantive and involve the right people with appropriate resource support. •Caution in whom you chose make sure it is a true cross-section representation; Balsillie report as an example (Lee to provide either at the meeting or within 24 hours)

Location: (15) •Real estate decision should be a jointly derived between the municipality and the OPA before procurement •Siting regulations need to be developed and implemented before any new large natural gas plants are approved (excluding co-gen plants). Community consultation is necessary to make these guidelines effective based on scientific studies; Community consultation is advised for site selection amongst similar alternatives

(17) – more transparency and accountability about the total process from end to end

Improvements Lack of provincial long term energy plan (IPSP) makes it difficult to plan at the region and municipal level •Issues such as proximity of power to use of power need to be debated •Use calculator as example to show trade-offs •Where it says plan, should say approved plan •(11 and 12) – cost sharing/allocation discussions should only occur after there is agreement on the principles.

(17-19)Procurement and siting •Process has not been re-engineered •Concern is that safety is being passed off to MOE; D2, D4, D6 guidelines are useful but black swan events do occur (often due to human error)

(18) – Should engage and consult with the community, not run information sessions (reference Mowat Energy; Getting the Green Light report, Nicole Swerhun book “Discuss, Decide, Do”.)

(19) – Safety and health must be included in the criteria; An inherently flawed site overrides any proponent’s efforts

Appendix A - Risk assessment should not be done by the proponent after contract award

(21) – Unclear what this means? Isn’t an alternative of a centralized approach seems counter to a regional approach

(20) – Appeals process is critical and it should be very clear and understandable to the average citizen

3 Quick Wins

 Publish siting criteria and guidelines o provide certainty to communities and power planners; o address the legitimate safety and health concerns of residents; o level the playfield for power developers; o ensure consistency with siting policies and requirements for other types of sensitive developments, including wind farms, railway corridors, propane stations, landfills, etc.

 Implement cumulative air-shed management o Accelerate Balsillie task force o Making this work will be a huge win for everyone

 OPA and municipalities choose location site before procurement

 Implement IRRP Advisory committee

4 Next Steps

• Minister to act promptly on recommendations with appropriate allocation of resources • OPA publicly supports • Identify timelines, accountability framework, budget and responsibility of senior execs • Community support follows above

5 Appendix

6 From July 10th RECOMMENDATIONS relating to PROCUREMENT

• Limit the use of Ministerial directives • Real estate, engineering and finance should not be the sole drivers of this process • Environmental impacts and need for IEA must be included • Safety and Black Swan risks cannot be ignored • An objective risk assessment is critical • Provide full transparency regarding deadlines, contract dates and planning assumptions and calculations

July 15, 2013

Bruce Campbell, CEO Independent Electricity System Operator Station A, Box 4474 Toronto, ON M5W 4E5

And

Colin Andersen, CEO Ontario Power Authority Suite 1600 120 Adelaide Street West Toronto, ON M5H 1T1

DELIVERED VIA EMAIL

RE: Regional Energy Planning and Siting Dialogue

Dear Mr. Campbell and Mr. Andersen,

Thank you for the opportunity to provide this submission regarding regional energy planning and siting of large scale energy infrastructure. CanSIA was pleased to be invited to the information session at the OPA offices on July 4th. We found the conversation to be informative and it helped us put into context the approaches and perspectives of different stakeholders involved.

The following submission will address several of the key questions you have outlined in your discussion guidelines, specifically from the perspective of the solar industry. Solar is unlike other sources of generation, with a variety of favourable characteristics, notably:

 High public support: Solar energy enjoys the strongest and most widespread support of any electricity generation source with 98% of Ontarians supporting the technology (70% strongly support, 28% somewhat support).

 Empowered Consumers: Distributed solar is a core component of the smart grid and smart home future that is being enabled by Ontario’s investment in smart meters. As the electricity consumers of tomorrow will be able to interactively manage their electricity consumption through smart grid and smart home technologies, they will also have choices to ‘self-supply’ their energy needs by installing solar systems.

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 Municipalities as Willing Hosts: Solar is easily integrated into communities, both urban and rural. It is scalable and can be located close to electricity consumers. As an embedded resource, solar can be developed in strategic locations to help meet local needs, similar to strategic implementation of CDM programs which provide longer term stability to the grid. Solar can be deployed quickly due to short permitting and construction schedules.

 Greenest Form of Energy: Solar has the lowest environmental footprint of any electricity resource. It has zero airborne emissions, zero hazardous waste emissions, almost zero noise. Further, it is inexpensive to decommission and land can be returned to previous use.

 Decreasing Costs: Unlike other forms of generation, solar electricity has and continues to decline in cost. The fact that the fuel source is free ensures that input costs will never rise.

 Peak Shaving Capabilities: Solar is peak load shaving and reduces the occurrence and cost of extreme summer peak prices. Energy production from solar is highly correlated with the peak times of energy consumption, therefore effectively reducing peak demand.

 Deferred Transmission & Distribution Investments: Distributed solar, like other sources of distributed generation and conservation demand management (CDM) measures, helps to defer capital outlay for transmission and distribution infrastructure expansion and therefore resulting in overall cost savings for consumers. The Ontario Energy Board’s Regional Planning for Electricity Infrastructure is expected to address how utilities can best capture this benefit.

 Price Hedge and Predictability: The development of solar in the near term can help to mitigate delays with the commencement of nuclear refurbishment and/or nuclear new build. Since solar is a front loaded capital investment, resulting in predictable long term cost, it is integral in the energy supply mix as a hedge against other long term fuel costs.

 Employment and Solar: Solar supports more jobs than any other energy source. The distributed nature of solar generation ensures that it produces high-quality local jobs such as engineering, design and installation.

 Land reclamation solution: Solar can be developed on brownfields and can be a productive use for exhausted mining, oil and gas exploration sites and other industrial sites which may otherwise have no useful life. It also provides income for community members that may no longer be able to farm or use their property as productive land.

Our recommendations and suggestions put forward in this submission are made with these benefits in mind. Overall, CanSIA recognizes the need for the continued improvement of the municipal engagement process for large scale ground mount projects; however, we are cautious of any approach that would serve to increase the costs of developing solar in Ontario. We do not believe any changes need to be made in respect of microFIT or rooftop projects, as the impacts of these projects are minimal, and the Small FIT and microFIT programs have introduced siting restrictions on ground-mounted projects.

Regional Planning

Who needs to be engaged in regional electricity planning to represent municipal, Aboriginal, and community interests?

Within municipalities, we recommend that those involved in municipal development and planning (e.g., Chief Planning Officer), and municipal staff that represent development, planning and public

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works as well as elected officials on municipal councils be involved in regional electricity planning. The community interests should be represented through municipality’s elected officials. We are mindful that energy planners will need to engage with technical experts on infrastructure investment as well. Approval within municipalities should be balanced with staff and elected officials as it can remove some bias from siting considerations.

CanSIA is supportive of improved engagement and consultation with Aboriginal community interests, and the industry will follow the Province’s lead of best practices and approaches for engagement with Aboriginal communities.

Although, Advisory Boards may be effective for large scale infrastructure such as natural gas generation facilities or transmission infrastructure, we do not believe that is an effective approach for solar generation.

What is needed to ensure that municipal and community information is integrated at each stage of regional electricity planning?

In addition to the technical requirements of the local electricity infrastructure, social, economic and sustainability issues should be considered. From a technical perspective, municipalities need to be provided information on technical limits and constraints of their electricity grid to clearly articulate the need for future investments.

Municipalities and communities should understand the full costs and benefits of different solutions. For example, as a distributed source of power, small scale solar has similar characteristics of conservation and demand management initiatives.

A municipality’s sustainability plans should be considered in energy planning initiatives. Regional planning should have clear feedback loops between technical options, evaluation of solutions, and municipal growth plans and sustainability objectives.

Other observations:

Ontario’s policy target for solar set by the Long-Term Energy Plan is the key driver for large-scale solar systems. These systems are not built to provide local-reliability per se, but are built to provide clean electricity to the electricity grid and achieve certain social, economic and policy goals of the government.

The volume of small-scale solar is also currently constrained by provincial policy targets, but perhaps should be reconsidered if there is high demand for small-scale solar to reach a local policy priority. For example, perhaps a municipality might set a sustainability goal of 1000 residential rooftop systems but cannot achieve their goals due to local grid constraints or procurement target caps.

With respect to regional energy planning, small-scale rooftop solar should be considered along-side CDM options available to the community. For example, as a low-impact source of on-peak power, solar should be considered in regional plans prior to investments in other large-scale infrastructure. Solar could be a cost-effective solution or may help defer need to invest in such large scale options.

Overall, depending on what the local needs may be, the approach to engage the local municipality may vary. For example,

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1) Planning for load growth, local reliability of grid and/or asset replacement in urban centres: Low impact options such as rooftop solar should be fully considered and evaluated prior to proceeding with large-scale infrastructure projects. Solar is a reliable, distributed peaking resource.

2) Planning to relieve local connection constraints: Municipalities that are supportive of solar should be prioritized to relieve any grid constraint that may be hindering the development of solar projects. For example, municipal support for solar can be considered by the OEB in the LDC distribution system plans.

3) Planning in regions with connection capacity: OPA/IESO/Hydro One should post detailed capacity availability maps. The regions where connection capability exists today will likely be the locations where large-scale solar will be procured in the future. If capacity exists, municipal energy plans can be tailored and municipalities can prepare in advance of OPA procurements for renewable energy. Municipalities should be given the authority to “over-ride” the solar site restrictions set out by the OPA in the procurement process should they believe that there is a location in their region that is best suited for solar development.

Siting

CanSIA notes that available sites are currently restricted per the FIT 2.1 program. There are site restrictions for agricultural lands, residential, commercial, and industrial lands, and areas of the province that are connection capacity constrained. The following comments are in respect of large ground-mount solar facilities.

What works well with the existing siting process? What doesn’t work well?

Developers are restricted to certain lands in the province (as noted above), which could have the effect of increasing costs by eliminating lands that might be most cost-effective to develop on. During the FIT 1 procurement, early engagement of the municipality was not required prior to an application to the OPA. In rare cases this lead to local opposition, increases in permitting costs, or delays in achieving REA consultation requirements.

Although there were some drawbacks in the site selection process for solar, developers were given the flexibility to optimize their project portfolio through self-selection of project sites.

What advice do you have for OPA and IESO as they work to improve the siting process?

CanSIA believes that siting priorities can be accommodated in procurement policy and that there is no need to make wide changes to REA for renewables. Such regulatory changes will lead to uncertainty and unnecessary delays in future procurements. The results of the Ministry of Energy’s Land-Use Working Group have established an acceptable framework for siting large and small scale ground mounted solar projects, which can be deployed in future procurements if necessary. Above all, there is a need for continuity in the siting process for the solar industry.

What are the pros and cons of the alternative approaches above?

Siting Boards: Ideally, siting boards would be set up as neutral third parties, and provide unbiased advice and recommendations on the most acceptable location for energy infrastructure. However,

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there are issues with establishing its member composition. Further, an additional layer of decision- making and procedure could cause delays and increase development costs. Overall, the use of siting boards is not an approach that we recommend for the solar industry, particularly as there is limited and isolated opposition to the construction of solar projects.

Government site selection: Generally speaking, there is little benefit for the solar industry by allowing government to select sites. Arguably, the land use restrictions that have been enforced has already set out what sites are unacceptable and has narrowed the availability of eligible sites. One area where site selection may be beneficial is identifying sites for Aboriginal projects and facilitating projects located on Aboriginal lands. Except for the facilitation of site selection for Aboriginal projects, CanSIA is not supportive of this approach because it could cause additional delays in procurement, increase costs and timing, and create uncertainty. This approach is not recommended for solar systems, particularly considering the procurement process has rules on the type of sites that are acceptable through the land use restrictions.

Multi-Stage Competitive Processes: CanSIA agrees that clear siting rules can be set out in a procurement process, although a multi-stage procurement process may not be necessary for solar. Overall, this option could be effective, however much depends on the procurement design and whether there is a significant increase in costs or delays in development timelines. We note however, that the RFQ to RFP process has been shown to decrease costs in some cases, provided that an RFQ clearly defines what is wanted from the procurement process.

Individual EA for all large generation: There are no benefits with this mechanism for solar. Solar was never subject to EAs, therefore a new regulation would need to be developed and implemented. For solar, the REA process is working, however CanSIA acknowledges that engagement with municipality should happen outside the REA at earlier stages of site selection and development.

Community Funds for Hosts: As large scale solar is typically built to meet provincial policy objectives, we agree that community funds for hosts could give municipalities an incentive to host large-scale solar projects. However, we note that these funds will increase the costs of developing a solar project, which would ultimately be covered by electricity ratepayers broadly. If this approach was to be implemented, clear principles and guidelines need to be established, and likely regulated by the province. For example,  Community funds should be standardized and have clear rules across the province;  The nature of such funds should be aligned with the principles of predictability, transparency and fairness;  Discussions around community funds should align with the consultation and project development process and not impede or delay a project’s development;  The benefit structure should be made to be as simple as possible; and  Community funds should not hinder industry’s ability to continue to drive the cost of Solar PV downward.

CanSIA is cautious about a one-size-fits-all approach. Solar can and should be treated differently from other generation types in terms of siting as it is far less contentious and has fewer perceived negative impacts on the communities they are located in. Siting can be worked into procurement process through upfront municipal engagement prior to a contract application submission (via an RFP or other competitive mechanism). Further, the procurement mechanism should be flexible in assessing if municipal support has been achieved; for example, it could be demonstrated by the signing of a community fund agreement, a municipal council support resolution, a Memorandum of Understanding, or other means that demonstrates the municipality and the community have been meaningfully engaged. CanSIA also notes that there is a

The Canadian Solar Industries Association Page 5 need for greater transparency about regions where connection capability exists to focus efforts on regions of the province where solar generation can be accommodated.

CanSIA recommends adopting the following key principles in respect of future solar procurement:  A greater emphasis on front end community and municipal engagement is beneficial for both communities and developers;  The continued development, investment and growth of the solar energy sector is a benefit to the environment and the economy of Ontario;  Recognition of the need for continued price digression that balances low cost energy with effective social and environmental policy;  Predictability, transparency, uniformity and consistent application from both the developer and the municipality in the treatment of Solar PV projects across the province is critical for the continued growth of the industry which in turn encourages continued price digression;  Improved communication of grid-connection capability and future grid improvements;  Additional regulatory burden or increased delays for a Solar PV project results in additional costs;  The retroactive application of new rules and regulations will serve to increase the cost of renewables; and  A clear and efficient dispute resolution process should be established for developers and municipalities.

Thank you again for your consideration of CanSIA’s recommendations. We are committed to developing a sustainable, efficient solar industry for all solar sectors and segments, and appreciate the opportunity to provide our advice. Please feel free to call or email me at any time should you wish additional feedback on any of the above recommendations. I am also happy to meet with you at any time. We look forward to future consultations and discussions.

Sincerely,

John Gorman President of the Canadian Solar Industries Association.

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CUPE Ontario Division

Submission to Regional Planning and Infrastructure Siting Dialogue

Ontario Regional Energy Planning Review for the Ontario Power Authority Independent Electricity System Operator

Fred Hahn President Canadian Union of Public Employees (CUPE) Ontario

July 15, 2013

Submission to the Ontario Power Authorities Regional Energy Consultation

Introduction and Issues

The Canadian Union of Public Employees (CUPE) Ontario is the largest union in the province with more than 240,000 members in virtually every community and every riding in Ontario. CUPE members provide services that help make Ontario a great place to live. CUPE represents employees at 14 of the province’s local distribution companies (LDC’s), including the largest, Toronto Hydro.

The energy sector in the province has undergone historic changes over the years, with a focus on developing green energy capacity. As part of this dramatic shift, the sector has seen many unique developments and as a result some significant challenges. One component of these challenges has been a lack of meaningful consultation in communities over new projects. CUPE members welcome the opportunity to comment on the new initiatives the Ministry is undertaking in the sector.

There has already been a significant amount of investment in the sector with more to come. Nationally, The Conference Board of Canada has calculated over $340 billion will be spent on electricity infrastructure between 2011 and 2030. They qualify the investment this way; “for every $100 million (inflation adjusted) invested in electricity generation, transmission and distribution infrastructure, real GDP will be boosted by $85.6 million and 1,200 jobs will be created.” In Ontario, there is already a significant amount of spending planned; the various transmission plans account for almost $5.5 billion over the years and over $20 billion on the distribution side over a similar time frame.i Investment in this sector is critical to support our economy.

The two major issues in this consultation – municipal and stakeholder input and major project siting – are intrinsically connected. Both project placement issues and the increased level of participation from the private sector have led to a litany of issues, which has caused damage in local communities and shaken confidence in government. In at least two cases – the Oakville and Mississauga gas plants – this has led to enormous scandal and taxpayer expense, which illustrates the downside of an over reliance of private-sector funding for public projects.

We have also seen significant investments from the private sector in the development of wind, solar and hydro energy projects as other parts of the Green Energy Act (GEA) have been implemented. Part of this consultation is about increasing stakeholder engagement and control; given the importance of energy to the province, CUPE members have questions about how this could be achieved reliably and affordably with increased private sector involvement.

Finally, the sector is faced with new changes coming out of the World Trade Organization (WTO) decision on the GEA, which seems to have acted as the catalyst for many of the Ministry’s recent announcements and consultations. As the Ministry moves forward in planning for the sector we ask the government take these consultations seriously and continue to canvass key stakeholders, which include workers in the system. We also ask that, overall, the government consider this as an opportunity to take greater control of the changes to the system, which would include increased roles to develop a more accountable public system.

Finally, municipalities need to be more involved because they face some of the greatest challenges and influence in the sector. Municipalities have Official Plans to execute; are owners of distribution infrastructure; and feel the costs of pollution. If properly included in the process,

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municipalities also have the ability to incentivise more economic and conservation oriented projects. Vesting more responsibility in municipalities not only makes more sense because of what local communities have at stake and their ability to help manage the sector, but also because it is the most accessible form of government.ii

Local Stakeholder Input and Regional Energy Plans

CUPE Ontario represents 80,000 municipal workers – our members understand municipal government and the way it works. Our members also understand it is important to engage in the political process to help achieve greater levels or service for our communities. Critical in that process is consultation and control over our communities. As the Ontario Auditor General (OAG) has pointed out in his 2011 Report, the Green Energy and Economy Act (2009) eroded some of that control by taking away planning and regulatory processes. The OAG identified that this action likely had “significant long-term costs”.iii

Although the government’s current direction is to solicit advice on how to improve consultation and collaboration in the electricity process it should be cautioned not to have predetermined outcomes. In the Minister’s late May announcement it became clear that municipalities would still not be able to ‘veto’ projects outright. In addition, there is a parallel Cabinet process with Ministers, Chiarelli, Bradley, Jeffery and Leal all tasked with improving municipal involvement. Overall, there must be more space for municipalities to negotiate than to either accept a project or declare the unwilling host designation. Changes need be meaningful and accessible; municipalities are uniquely positioned to play a critical role in a more transparent system.

Transparency and collaboration are important to ensure public funds are used appropriately. Site selection, planning guidelines, and best practices are followed and so that stakeholders have ‘skin in the game’. When people and groups are shut out of decisions which so closely affecting their well-being there is bound to be a negative reaction. CUPE believes our members, our local decision making bodies and the residents need to be consulted about infrastructure decisions in their community – particularly those as important as electricity. The OAG also addressed this in his 2011 Report, with a focus on of additional costs around green energy initiatives:

“The development of renewable energy initiatives involves planning and coordination with other parties, including the Ministry of the Environment, the Ministry of Natural Resources, federal agencies, and municipalities. We noted several instances where renewable energy initiatives led to potentially unnecessary compensation and potential lawsuits because of conflicts with environmental impact and planning decisions.”iv

Whether it is paying additional costs, which negatively affect all of us, or to ensure practices which engage people in the process, the following measures would have a positive effect:

• Give municipalities the resources they need to develop energy plans in conjunction with the Province, its agencies and other groups. This should include funding for dedicated staff and events to engage the public in the process and conservation. It should also include electronic resources to solicit opinion via the Web and social media. • Include municipal councils in the decision and ratification processes. It needs to be mandated that councils be updated throughout the process and that these meetings be open to the public comment. In addition to council, LDC’s still need to be consulted and included in the planning process. These meetings and the results of them should also be made public. Submission to Regional Planning and Infrastructure Siting Dialogue Page 3

• The developments also must be included into the municipal planning process and fit a municipality’s Official Plan. • Special effort should also be made to get the attention and opinions of equity seeking groups. Aboriginal groups and their agencies and governments should be included, but also anti-poverty, seniors and other consumer groups. It is often not enough to have a public political process; the onus to consult needs to be on the government, it’s agencies and the municipality to outreach to these groups.

Electricity is a critical part of the infrastructure underlying all private and public economic activity in the province. Adding confusion to the matter is the ruling at the WTO and the threat that privatization of energy production could destroy the use of green energy development as a local economic development tool. All of these factors mean that the government needs to pay extra attention to sound development principles to protect our investments and include municipalities and other stakeholders in a meaningful accountable process. Overall any exercise to ‘site’ new electricity infrastructure needs to have multiple stages, be inclusive and universal.

Large Project’s, Privatization in the Sector, and the Gas Plant Scandal

The ‘siting’ of larger energy projects has been fraught with difficulty, conflict and high costs. The Oakville and Mississauga gas plants have cost Ontario large amounts of both money and creditability. The government is now talking about measures to improve the system, but until political goals and privatization through public private partnerships (P3s) are removed from the process, the possibility of more fiascos is clear and present.

CUPE members are consistent in their position against all attempts to privatize parts of province’s electricity system. The interests of rate-payers, residents, and municipal governments are best met with a system of public utilities which are publicly held and operated. Increasing private-sector investment and the drive for profit in the province’s electricity system can only lead to increased costs and a decreased commitment to meeting long-term public interests for environmental protection and substantive reductions in electricity demand. The gas plant tender process and subsequent events is a benchmark moment, which reinforces that privatization is not that answer for this sector.

The ‘siting’ decisions of large-scale projects need to be made in an inclusive and open fashion; CUPE’s position on large projects also echoes our suggestions in the previous section. One of the ways this could happen is a Siting Board. The Board would need to be accountable back to potential host municipalities through an open and democratic process and made up of elected officials, community members and union representatives/workers in the sector. These Boards could be resourced with experts suggested by the Ministry and/or selected by the Board. It is likely that a Board like this would not have moved forward with the Oakville and Mississauga plants given the acrimony in the community while decisions on those projects were being made.

In addition to the Boards, one restriction which has been removed CUPE agrees with is allowing Ontario Power Generation (OPG) to bid on large scale renewable energy projects. This represents a step in the right direction to greater public control over the sector and could allow for public/public partnerships with municipalities and First Nations. In addition, giving preference to these partnerships in procurement could lead to an increased public role in the development, ownership and operation of electricity assets. The other benefit of collaborating with other public entities is a greater role for those partners, which also meets consultation goals. It is CUPE’s hope this is the beginning of OPG and municipalities taking an even greater role in large-scale projects.

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The other suggested courses for siting decisions from this ‘dialogue group’ – government decision, multi-stage procurement, or community funds – could lead to repeating the calamity experienced with the gas plants. Resting the process totally with government or having a complicated tender process echo too much the process already utilized in the Oakville and Mississauga examples. The final suggestion, community funds, is the wrong way to provide resources to a host community. Providing additional funding to communities to host a site in this fashion would take away objective decision making from the host. In all of the aforementioned cases there is the potential for repeating some of the same mistakes the Ontario energy sector needs to learn from.

There is little merit in rehashing all of the details surrounding the Mississauga and Oakville gas plant cancellations; however, it is worth noting several observations about the process and outcomes:

• Public private partnership deals are structured under the guise of risk transfer from government and the taxpayer. When the OPA agreed to take on financing liabilities in the Mississauga deal this became yet another example which illustrates this is a fallacy in these deals. • A hallmark of privatization is also hidden or unknown costs, which materialize along the process – this is especially true if the parties find themselves in dispute. In the Mississauga example, it has been found there were millions of extra costs associated with the cancellation of the deal and relocation of the plant. • The secret complex nature of P3s perpetuates bad deals and restricts accountability. It took an exceptionally long process for the truth to come out over these deals and the OAG Report on the Oakville plant has yet to be released. Ontario residents saw exceptional behaviour such as deleting e-mails and covering the true costs of the plants. These deals alienate communities and put profit before the services that we need.v

Despite the gas plant experience, the private sector is still keen to invest with government in privatization schemes. The government should not be seduced again into deals that do not benefit Ontarians. Recently, the Globe and Mail’s Report on Business highlighted several Public Private Partnership examples while quoting energy investor Capstone Infrastructure Corporation’s CEO Michael Bernstein, “For an investor such as Capstone and others... there is potentially the opportunity for private sector investment in assets that were previously owned and managed by government.”vi As the provincial government makes adjustments to the way it decides on projects, it must consider public options with input to ensure accountability is the practice. We must not repeat costly privatization mistakes in P3 deals or outright asset sales.

Recommendations

The energy sector is a significant contributor to Ontario’s economy. Electricity touches every aspect of our lives and is one of the most critical public services, powering commerce, industry, transit and our homes. This importance cannot be overstated and should be kept top of mind as Ontario conducts this and other electricity consultations.

A common thread through all of our recommendations is that municipalities need support from the province in this sector. As a key actor in the system and the most accessible and democratic body, the province must both include municipalities in the decision making-process and provide resources to develop a more public system. Most of the tax dollars collected go to other levels of government, while municipalities are largely responsible for the infrastructure in communities. Only 20% of municipal dollars come from government transfers, while at the Submission to Regional Planning and Infrastructure Siting Dialogue Page 5

same time local governments face downloads in other areas of service delivery. If clean reliable public energy is to become a reality, the province and federal levels of government need to make long-term commitments to the sector.vii

The GEA provides incentives for development of private green energy generation at the expense of publicly owned production. Instead of looking at access to energy as a human right and public good, the Ontario government has relinquished democratic control to the private and for-profit sectors for building the backbone of the province’s future renewable energy infrastructure. The loss of publicly controlled, long-term planning of the energy sector has resulted in a short-term over-production of electrical energy resulting in rate increases for consumers and the prioritization of private energy production over that of publicly produced energy.

Additionally, the vast majority of the energy being generated under GEA contracts is being purchased from large energy conglomerates and not independent Ontario start-ups meaning that we are paying extra to replace regulated public utilities with private monopolies.viii CUPE agrees with the position put forward by Marjorie Cohen that electricity should be viewed, treated, regulated and priced as a common resource, a common good – that it is an “essential part of modern life [that] has been too significant to be left to the vagaries of the market”.ix

As a key stakeholder in the sector CUPE submits the following recommendations to this dialogue:

1. Decision making: formally include municipalities in the decision-making process for siting and large scale capital developments. Councils should have a formal opportunity to debate the merits of projects and this process must include input from the residents/public at large. Conservation must also be present in these plans.

2. Energy Plans: provide resources to municipalities so they can be an effective partner in planning with the Ministry and its agencies and conduct their own consultations.

3. Planning Process: new small and large scale developments must consider a municipality’s Official Plan and other relevant planning process.

4. Siting Board: establish a publicly accountable siting board made up of community members, local leaders, union representatives/workers and other stakeholders for large- scale projects.

5. Communication: In any consultation all parties must consider how to effectively outreach to equity seeking groups. Additional effort must be considered in how to communicate, considering factors such as translation, accessibility of materials and/or public meetings.

6. Communication: The Ministers tasked with examining this issue should publish the results of their working group along with this dialogue.

7. Partnerships: go farther to encourage and develop public/public partnerships with First Nations, municipalities and OPG. These partnerships, in both procurement and development, will lead to a more accountable public system.

Submission to Regional Planning and Infrastructure Siting Dialogue Page 6

i The Conference Board of Canada. Shedding Light on the Economic Impact of Investing in Electricity Infrastructure. Economic Performance and Trends. February 2012 Report. ii The Columbia Institute. A Canadian Energy Strategy Why should local governments care? James Glave, John Chapman, Robert Duffy and Charley Beresford. May 2013 iii Ontario Auditor General 2011 Report. Overview: Electricity Sector—Renewable Energy Initiatives. Pg. 5 iv 2011 Annual Report of the Office of the Auditor General of Ontario. Co-ordination and Planning for the Procurement of Renewable Energy. Chapter 3; VFM Section 3.03; pg. 109/10 v Auditor General of Ontario, Mississauga Power Plant Cancellation Costs: Special Report, April 2013, p18. Available; http://www.auditor.on.ca/en/reports_en/mississaugapower_en.pdf & Information and Privacy Commission of Ontario Release June 5, 2013. Commissioner Cavoukian dismayed by the indiscriminate deletion of emails in Ontario cabinet ministers’ offices; available: http://www.ipc.on.ca/images/Resources/2013-06-05- Ministry-of-Energy-e.pdf. vi The Globe and Mail. Private sector plugs into public projects; Partnerships with governments seen as a way to stimulate investment and growth in electric sector. Thu Jun 20 2013; Page: B15; Section: Report on Business: Canadian. Byline: Daina Lawrence vii The Columbia Institute. A Canadian Energy Strategy Why should local governments care? James Glave, John Chapman, Robert Duffy and Charley Beresford. May 2013. The institute also cited the Federation of Canadian Municipalities, canadainfrastructure.ca, and the federal Standing Committee on energy, the environment and natural resources viii CUPE Factsheet. Free-trade is blocking the path toward sustainable development. Available in authors files. ix Cohen, Marjorie Griffin. “Electricity Restructuring's Dirty Secret: The Environment” in J. Johnston, M. Gismondi, James Goodman, Eds., Nature's Revenge: Reclaiming Sustainability in an Age of Corporate Globalization, p. 74.

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Submission to Regional Planning and Infrastructure Siting Dialogue Page 7

July 15, 2013

Regional Planning and Infrastructure Siting Dialogue c/o Ontario Power Authority 120 Adelaide St. West, Suite 1600 Toronto, ON M5H 1T1

Sent via email: [email protected]

Dear OPA/IESO: The Canadian Wind Energy Association (CanWEA) is pleased to contribute to the OPA and IESO led discussion on Energy Planning and Infrastructure Siting in Ontario. This document draws on input from industry and key stakeholders to present CanWEA’s recommendations with respect to processes for ensuring that municipalities are engaged in the siting of large energy infrastructure projects. The wind industry in Ontario is committed to industry best practices within the existing policy framework to provide a transparent mechanism of consultation throughout the planning process.

CanWEA’s recommendations and comments are as follows:

1.1 Continued Support through the Provincial Policy Statement The Provincial Policy Statement should continue to include strong, clear and prescriptive direction requiring municipalities to develop and maintain Official Plan policies and language that support and encourage development of energy options, including renewable energy.

Rationale: The 2005 Provincial Policy Statement (PPS) was a key milestone for the wind industry in Ontario. The Province committed to the production of renewable energy to address challenges of climate change. In Ontario’s existing Long Term Energy Plan, new supply in Renewables is projected to be 26.3 Twh by 2030, promoting Ontario as a world leader in clean energy. This commitment is consistent with the Planning Act, where Provincial Interest is stated in Section 2.(e) as…“the supply, efficient use and conservation of energy and water.” In the Provincial Policy Statement 2005, Section 1.8 Energy and Air Quality, renewable energy is mandated by the Province in all municipalities. In contrast to this direction, the Draft Provincial Policy Statement 2012 policies have reduced the significance of renewable energy. They have maintained the general intent of Sections 1.8.1. and 1.8.2, but it no longer mandates municipalities’ to permit renewable energy systems in settlement areas, rural areas and prime agricultural areas found in Section 1.8.3.

The PPS is a key policy document for municipal guidance and there is a Provincial need to be consistent with its commitment to renewable wind energy. The industry needs to have clear municipal direction

consistent with the Green Energy Act (GEA) legislation, in order to signal continued industry investment and support for renewable energy projects. Although renewable energy projects are currently separate from the Planning Act provisions as a result of the GEA, there remains a need for consistency for municipalities through the PPS that supports renewable energy projects. Section 1.8.3 permitting renewable energy in all land areas, must be added back into Section 1.8 of the Draft PPS, directing municipal consideration of renewable wind energy development in keeping with the legislation. The GEA requires municipalities to consult with renewable energy proponents and they will do so by seeking policy guidance from the PPS as well as Official Plan policies described below.

1.2 Official Plan Policies

Municipalities should adopt Official Plan policies that support land use and development patterns which promote design and orientation which maximize the use of alternative or renewable energy.

Rationale: As stated above, a municipality’s Official Plan is the primary guidance document for land use within a municipality. The Official Plan is informative to both the municipality, i.e. Council and staff, and the wind energy proponent in defining expectations for consultation, design, development, and construction. The relevance and authority of the Official Plan seems to have been lost since passage of the GEA in 2009. The Provincial Policy Statement requires municipalities to develop such policies. Development of, and adherence to, Official Plan policies provides guidance and accountability to the consultation process.

This requirement is not meant to add an additional level of approval or create policy which is contrary to Provincial policy. Rather the Official Plan is intended to be used as a basis for both municipalities and proponents moving forward as a means to consider local matters. In fact, official plan policies should not be prescriptive and are not intended to regulate development regardless if it is a wind installation or a plan of subdivision. Rather official plan policies should reflect how a municipality sees development moving forward over a prescribed period of time (usually 20 years) that is reflective of their goals and objectives (ie: protecting agriculture, concentrating growth areas).

Language within an Official Plan should include broad wording such as “should consider”; should be supportive of renewable energy; and should generally address issues such as those found in the current Municipal Consultation Form within the REA. Official Plans should not be prescriptive in the identification of setback requirements for renewable energy projects as project design criteria is mandated and managed through the Renewable Energy Approval process as stated in the GEA to provide a consistent approach across all municipalities.

CanWEA has drafted Official Plan policy wording which municipalities can use as a template to tailor to their local situation. (APPENDIX A)

1.3 Municipal Energy Plans and the Identification of Need

If incorporated through consultation and planning processes similar to the Official Plan and Growth Plan exercises undertaken by the municipality or region, the Municipal Energy Plan (MEP) can be utilized as a major economic development tool leading to more competitive and sustainable communities. In that regard, the MEP should be a mandatory undertaking and like the Official Plan, should NOT be used to attempt to prohibit any particular means of energy planning or siting of infrastructure.

While CanWEA is generally supportive of increased regional planning and integration of municipal, community, and Aboriginal input into energy planning on a whole, we are concerned with how power system planning needs in Ontario may be structured in the future.

At present, electricity generation opportunities in Ontario are identified by the Ontario Power Authority, following directives issued by the Minister of Energy. Under this model, overarching provincial policy sets the stage from which planners can adequately ensure that the electricity system remains stable, reliable, and affordable.

We believe that this model should be sustained under a regional planning methodology, measured through the following factors: • Environmental Attributes • Generation Costs • Fuel Supply • Community and Aboriginal Acceptance • Connection/Transmission Constraints • Land Use Compatibility • Operational Flexibility

Along with assessment of the above factors, costs to develop different types of generation should be assessed in order to determine the preferred generation resources to be developed to meet future Ontario power system needs. Therefore, levelized unit electricity costs (LUECs) for various types of generation resources compare relative costs of different generation options.

Input from municipalities, Aboriginal communities and other stakeholders should be considered, but only once other formative factors have been taken into account. Essentially, CanWEA believes that engagement options need to take place during the “Planning Integration” phase. Broad engagement during the “Needs Identification” phase would include factors beyond electricity and conservation needs, such as local infrastructure, industry/employment, future grid infrastructure, to name but a few.

In addition, CanWEA is concerned with the availability of resources and competences to undertake assessments based on the aforementioned factors solely at a regional level. As such, a strong provincial policy statement must be in place in order support the regions as they undertake the MEP process.

1.4 Municipal Public Meetings

Municipalities should be required to host public meetings on energy plans/proposals and seek public input on proposed facilities.

Rationale: There is a need to communicate and inform the public, on a basic understanding of electricity choices, where the power comes from, the needs for the power, including the policy rationale.

Prior to 2009 and the passage of the GEA, municipalities were required to host a public meeting as part of the municipal planning process. This was an effective way for the municipality to ask specific questions and seek input from their community. The REA process now only requires the proponent to host two Public Information Consultation (PIC) meetings. However, many project proponents still have public meetings with municipalities as an effort to go beyond the 2 PICs and have more structured public dialogue with municipalities.

The goal and agenda of the municipally led meeting should be informed by the Provincial Policy requirements, the Municipality’s individual Official Plan policies and the Municipal Energy Plan. The ownership and management of the meeting would be that of the municipality. This requirement would allow municipalities to factor in early engagement considerations from within the local community.

1.5 Community Funds for Hosts

As an approach to incenting and supporting communities, CanWEA believes wind energy proponents are leaders in this regard. Many CanWEA members have developed projects in Ontario and other jurisdictions where some type of community benefit has been negotiated. There are a number of successful models and each agreement is reached based on the unique circumstances negotiated between the project proponents and the municipal authorities involved. As such, there is no single formula or model that CanWEA wishes to promote at this point in time. This aspect of incentivizing should not be mandated or restricted to a single formulary and should be encouraged through best practices as demonstrated by the many successful agreements that wind energy proponents have negotiated with participating municipal authorities.

Thank you for the opportunity to engage in this dialogue. CanWEA and our members are committed to working closely with all stakeholders to ensure wind energy projects in Ontario (and Canada) are a success in the communities in which they operate. We believe this is the best way to ensure a responsible and sustainable industry. For further clarification of these comments please feel free to contact the undersigned.

Sincerely,

Brandy Giannetta Ontario Regional Director The Canadian Wind Energy Association

APPENDIX A

Renewable Energy Systems 1. The Municipality of ______recognizes the development of renewable energy systems for electricity production, as a source of renewable energy for the economic and environmental benefit of the Municipality and the Province, including wind, solar, hydro and biogas/biofuel energy systems. The municipality has renewable energy resources suitable for commercial development in accordance with the applicable Provincial and Federal legislation. 2. Renewable energy system proponents should contact the municipality prior to commencing any necessary background studies, to determine the nature and scope of the local needs which need to be addressed as per the municipal consultation requirements under Ontario Regulation No. 359/09. 3. Wind energy systems should be located on large parcels of compatible land uses having limited potential for future residential development on-site or nearby and should have consideration for the following policies when evaluating renewable energy proposals: a. The proposed sites should be separated from fully serviced settlement areas that may experience further growth beyond their existing settlement area boundary designations identified on Schedule “A”. b. The proposed sites should have access to public road(s) with the design capacity to accommodate construction and maintenance vehicles needed during construction and operation phases of the project. c. Access roads should be designed and located in a manner which limits the impact on agricultural activities and operations. d. The proponents shall consider the aesthetics and visual impact of the project both day and night time, on surrounding dwellings; designated cultural landscape, which may include significant views or vistas. e. The proposed sites should consider the impact on any locally significant natural heritage features or areas identified in the Plan, (including local parks and recreational areas). f. The development of wind energy projects will consider the cumulative impact of several wind projects where they are proposed in proximity to each other. g. Wind energy projects shall be developed in consultation with the municipality and using current best practices in the selection, operation and management of

equipment in order to minimize the potential impact on the surrounding community and municipality. h. The construction and operation phases of the project will be undertaken in a manner which maintains the health and safety of the municipality and limits potential temporary disruption to normal living and farming activities.

4. Wind energy systems comprised of one or more utility scale turbines may be subject to agreements for the location of road access, location of external works/facilities, storm water management/drainage and any other identified impacts outlined in studies supporting an application for approval under Ontario Regulation 359/09.

CENTRAL BRUCE-GREY WIND CONCERNS ONTARIO

14 July, 2013

Regional Planning and Infrastructure Siting Dialogue c/o Ontario Power Authority 120 Adelaide St. West, Suite 1600 Toronto, ON M5H 1T1 [email protected]

Hon Kathleen Wynne, Premier of Ontario Legislative Building, Queen's Park, Toronto ON M7A 1A1 [email protected]

Hon Bob Chiarelli, Minister of Energy [email protected] [email protected]

Hon Jim Bradley, Minister of Environment [email protected]

Hon Linda Jeffrey, Minister of Municipal Affairs [email protected]

Hon Jeff Leal, Minister of Rural Affairs [email protected]

RE: YOUR REQUEST FOR INPUT

PURPOSE AND DESIGN OF REGIONAL ENERGY PLANNING CONSULTATIONS The current Regional Energy Planning Consultations while ostensibly attempting to address the widespread outrage of rural Ontarians that has resulted from the government’s so-called “green” energy policy, and in particular the proliferation of industrial wind turbines in our communities, fail to meet the criteria for consultation.

Because stakeholder meetings have been confined exclusively to cities located well away from the communities hosting the wind turbines and experiencing their associated problems, rural distrust and cynicism has intensified.

Since this consultation process appears to be weighted in favour of urban dwellers who, for the most part, are quite unaware of the complexities of problems resulting from the massive installation of industrial wind facilities, it is meaningless. The input of lobbyists from the multinational energy corporations who are profiting at taxpayers expense is an obvious conflict of interest. Paying costly consultants to organize round table “discussions” carefully set up to isolate dissenters, complete “work books” and fill out online questionnaires which predetermine the issues is not consultation. It continues the same process of wilful deafness that took place for the Green Energy Act itself when dissenting comments were carefully buried and never presented to the public so that decisions to rush forward what has been a disastrous episode in the conduct of public affairs could be predetermined by an inexperienced energy minister without input from those affected, without proper cost estimates and even without input from the government’s own experts.

THIS CONVERSATION BEGAN 6 YEARS AGO. WHY ARE YOU STILL NOT LISTENING? When Ontario Power Authority (OPA) published its Integrated Power System Plan, in October, 2007, it warned that a “high wind power” scenario for the province would require additional generation capacity with better load-following characteristics . . . to be installed”. Obtaining this by installing additional gas-fired generation would incur further capital costs for the gas generation installation, and higher gas usage resulting in higher greenhouse gas emissions. Of course OPA could not foresee the monstrous cost of the bungled gas plant cancellations. “Wind and solar power will never be more than a niche supplier of power in Ontario,” the report concluded.

Despite lessons still unlearned, the Premier’s much publicized “conversation” once again excludes the basic element of dialogue: the process of listening. Rural citizens have been providing input to the continually changing succession of ministers at the Ministry of Energy, Ministry of Natural Resources and Ministry of the environment for the last six years. Seldom have they even been given the courtesy of an acknowledgment of their letter and never has their input been utilized.

The government has already been offered the expertise of dozens of carefully compiled reports and studies, many of them peer reviewed, all of them factual and carefully considered. They continue to be ignored.

CONSEQUENCES OF FAILURE TO LISTEN Provincial decision makers are reminded that this chapter in our history is by no means over: rural anger is very close to boiling over.

The current lack of democratic process not only endangers public credibility in the electoral system and the prospects for the government’s re-election to a majority position: popular frustration, which is now spreading to the cities in the form of anger at the skyrocketing electricity bills which have resulted from the ideologies of the Green Energy Act, may soon lead to the expression of far more threatening challenges to the cohesiveness of civil society.

This consultation process assumes a priori, the validity of the established “green” energy doctrine and the legitimacy of the Green Energy Act. But without amendments to that act and its regulations, none of the issues that are aggravating public indignation will be resolved.

FAILURE OF ONTARIO’S `GREEN ENERGY POLICY` There is no rational basis for adding more wind generators to the Ontario electrical system: it will threaten grid stability, make electricity unaffordable, increase CO2 emissions and increase the harm already being done to citizens, communities, significant wildlife habitats and the Ontario economy.

AUDITOR GENERAL`S REPORT The government has also received evidence from the Auditor General of Ontario as to the economic and practical lack of feasibility of expanding the input of wind energy on the grid. The recommendations of the Auditor’s report have been disregarded. This is a serious oversight in public process. We are therefore attaching a summary of that report as part of the current consultation process. We trust that the government will not further risk its credibility and sincerity by failing to act on those recommendations which include a proper cost accounting and business plan for the implementation of the Green Energy Act.

QUESTIONABLE CLAIMS FOR WIND ENERGY We have also already provided detailed explanations of why wind is not replacing coal-fired generation. As the Auditor has pointed out, wind is not available when needed. The practical application of the wind energy hypothesis has proven that adding intermittent wind output actually increases CO2 emissions. In Ontario, operating wind turbines increased the need for coal fired generators on the system. Continuing with the present Energy Ministry policy will further increase the required operation of fossil fuelled generation in Ontario, not reduce it. The report sent to the Minister of Energy on 15 March 2013 by the Multi-municipal Wind Turbine Working Group, illustrates these statements. A copy is attached. It should be included, along with all the other attachments, as part of this submission.

LOCAL PROBLEMS AND IMPACTS ON BRUCE COUNTY These consultations ask for local input reflecting local problems. Here in Bruce County and all along the Lake Huron coast line, the proliferation of operational and planned industrial wind turbines represents a serious challenge to our tourism industry.

Lack of proper planning and foresight may also mean the restriction of emergency helicopter service to our hospitals. Little thought has been given to the placing of turbines near our airports. Turbulence from a wind energy development affects aircraft navigation and also interferes with radar.

We have also learned that the process of appealing Ministry of the Environment decisions at Environmental Review Tribunals is costing our residents unnecessary major financial commitments to pay lawyers and experts. We resent having to pay to fight the lawyers provided by our own government—at our expense—and the legal counsel deployed by deep pocketed energy companies. The reversal of onus clause in the Green Energy Act which requires citizens to prove harm to health and the environment (with its unrealistic 15 day time limit) is unjust, and an unacceptable burden on our rural communities. It must be removed from the Act.

OUR ALREADY SUBSTANTIAL CONTRIBUTION TO THE PROVINCE`S ENERGY Our contribution to energy production for the province is presently greater than any other region and our consumption of electricity comparatively minimal. We operate the world’s largest nuclear power plant which supplies 6,300 MW of Ontario’s non-

CO2 producing electricity. We also live among hundreds of wind turbines and are being asked to accept hundreds more. In view of the adverse health effects many of our residents are already experiencing, we take exception to this continued imposition upon our region. Like many other regions in Ontario, we demand the right to veto all proposed wind energy projects.

INCREASED BURDEN ON OUR LOCAL HOSPITALS AND AGING POPULATION For us, health issues are a major concern. Regionally, our hospitals are under funded and less adequate than those in urban areas. Our regional doctor shortage means that one third of all our residents are without a family physician. Because of the disproportionate concentration of wind facilities in our region, we are experiencing a more concentrated proportion of adverse health effects among those living within their proximity. Many of our residents are retired or elderly, and exposure to ongoing harm is putting an increasing number of our population at risk. Despite the report from one of our local MOE officers recommending curtailing the operation of the turbines during the night, even his input on our behalf has been ignored. Our Grey-Bruce Medical Officer of Health has added her voice to the growing international concern of the medical professional over the adverse health effects caused by industrialization of the countryside. At present there is no support available for those reporting harm.

The attached summary of peer reviewed references on the health issue is an April, 2013 update.

ECONOMIC BURDEN ON BRUCE COUNTY Bruce County has traditionally been a marginal economic area. Family farming operations are being severely impacted by the skyrocketing cost of electricity. Retirees and young families are now facing energy poverty.

Operators of a modest sized wind development of 60 MW are guaranteed payment of $ 21 million per year (based on an anticipated capacity factor of 30% and the feed in tariff guaranteed contract payment of $135 per MWH) whether the energy is needed or not. 5045 MW of wind turbines are now identified by the OPA, IESO, and Environmental Registry as being in various stages of approval. This implies a committed charge to be borne by consumers of $1.76 Billion per year, or over $336 per residential consumer on average. Even if an individual’s consumption falls, this committed expenditure must be recovered, so that would just result in an increase in rates to pay the commitment. Storage options being discussed will more than double this committed cost.

Clearly, the economic drain to individual households and our local businesses is unacceptable.

ECONOMIC BENEFITS OF THE GREEN ENERGY ACT HAVE NOT MATERIALIZED. We have observed that most of the labour required to construct the turbines in our area has come from outside the region, consisted mainly of temporary construction jobs, and required ongoing maintenance from only a handful of employees.

SITING: The question of siting as applied to renewable energy developments is an example of a question which presupposes the validity of an activity which may not be beneficial at all. The increasing acknowledgment of economic, health and environmental liabilities associated with adding more wind energy to the grid makes the question of where to site them superfluous.

Nevertheless, on this question as well, the government has already been amply advised by citizens and experts who have demonstrated the inadequacy of current regulation setbacks of wind turbines from human habitations and sensitive wildlife habitats. Ontario’s setbacks are certainly no longer among the greatest in North America, as the government claims. The region of Haut St Laurent, Quebec requires setbacks of 2 kilometres, almost four times greater than Ontario. Our public safety concerns over ice throw from turbines located too close to our roads (including the very busy Highway 21) and homes can only be resolved by decommissioning of unsafely located turbines.

The inadequate regulations that exist today are the result of government accepting the dictates of wind energy lobbyists and corporate sponsored consultants.

Obviously, revised regulations protective of human health and the environment will require consultation and engagement with independent international researchers and experts in the field of industrial wind energy and electromagnetic emissions: Noise assessments must be based on 30 to 32 dB; a 5 dB penalty for amplitude modulation (as required for other cyclical industrial noise) must be applied; Both A (low frequency) and C weighted sound must be taken into consideration as well as the complications of multiple wind turbine noise sources both indoors and outdoors. However, even existing noise regulations are not being enforced.

In Bruce County we are perhaps more aware than some others of the irreversible environmental damage that is already being done by wind turbines. We take our responsibilities as custodians of some of the province’s most unique and significant ANSIs very seriously. We have already advised the government of research that has accumulated over the past few years from international biologists who are raising the alarm about the threat of the turbines to endangered species and the degradation of sensitive wildlife habitats. We have, however been ignored.

Others in similarly sensitive wildlife areas have also become aware of the same problem and provided similar input. For example the siting of a large turbine development on Wolfe Island, an important International Bird Area and North American migratory flyway and the failure of the MOE to do anything to protect Ostrander Point, (only recently successfully appealed at great personal expense by ordinary citizens) is seen by us as nothing short of a scandalous dereliction of duty by the MOE to protect our wildlife heritage.

However, had the Green Energy Act not disenabled existing environmental protection in the form of amendments to the Environmental Protection Act (Schedule G), Planning Act (including the Provincial Policy Statement), (Schedule K), the Conservation Authorities Act, the Ministry of Natural Resources Act, the Provincial Parks and Conservation Resources Act, and the Public Lands Act, (Schedule L), there would still be unambiguous direction as to where the turbines may be placed. These schedules must be removed from the Act.

As we have already advised many times, what is required now is a comprehensive constraint mapping system based on the already existing MNR data for the province’s ANSIs and natural heritage systems consistent with the Provincial Policy Statement to protect significant wildlife habitats from degradation by renewable energy developments. We are also demanding a withdrawal of ministerial approvals of Overall Benefit Permits for renewable energy projects—a procedure of highly questionable legality in view of the Federal Migratory Bird Convention Act. As specific detail of this concern as it applies to our region, we are attaching a policy guidance document “Threats from industrial wind turbines to Ontario’s wildlife and biodiversity” by Dr. Scott Petrie.

INCENTIVES The idea of offering rewards and enticements to local communities if they are willing to accept renewable energy facilities is nothing less than bribery. If this coercion comes from the developers whose reputations for integrity and community consideration have long ago been tarnished, it is outrageous. If it comes from the government itself which should be funding community facilities from public taxes, it is unjust. In both cases it unnecessarily exposes local politicians and government officials to the temptations of corruption.

CONCLUSION Every one of you who have been involved in making decisions that forced people to live near these pathetic excuses for power generators are knowingly complicit in ruining peoples lives both financially and health wise.

Indeed the time for “conversation” has passed. We are looking for the government to listen; but more than that, we are looking for actions that are on a professional basis and that will work. This means a proper business case analysis of what energy we have, and of what is most efficient to turn this province’s economy around, to stop the social divide in communities, and to have full and equal regard for the very basic human rights to health and enjoyment of property of all of Ontario’s citizens.

For and on behalf of Central Bruce-Grey Wind Concerns Ontario

Keith Stelling RR1 Southampton Ontario N0H 2L0 (519) 832-4160 [email protected]

Attachments: 1. Questions Arising from the Auditor General’s 2011 Report on Renewable Energy Initiatives (Chapter 3 Ministry of Energy: Electricity Sector—Renewable Energy Initiatives) 2. Multi-municipal wind turbine working group: Letter and attachment to Minister of Energy, 15 March, 2013. 3. Industrial Wind Turbines and Health: Wind Turbines Can Harm Humans if too close to Residents: A summary of some of the peer reviewed articles and conference papers, abstracts and citations, regarding impairment of health and wind turbines. Compiled by Carmen Krogh, BScPharm April, 2012. 4. Policy Guidance Document: “Threats from industrial wind turbines to Ontario’s wildlife and biodiversity” by Dr. Scott Petrie.

COPIES: Serge Imbrogno, Deputy Minister of Energy, [email protected] Mr. Andrew Hurd, Senior Policy Advisor, Office of the Premier c/o [email protected] Colin Anderson, CEO, Ontario Power Authority Bruce Campbell, President and CEO, Independent Electricity System Operator

Threats from industrial wind turbines to Ontario’s wildlife and biodiversity

Keith Stelling, MA, MNIMH, Dip. Phyt., MCPP, Friends of Arran Lake, Central Bruce-Grey Wind Concerns Ontario

Scott Petrie, PhD, Executive Director, Long Point Waterfowl; Adjunct Professor, University of Western Ontario

Threats from industrial wind turbines to Ontario’s wildlife and biodiversity

Introduction

The precautionary principle outlined in The Bergen Agreement, signed by Canada in 1990, has become, over the past fifteen years, part of customary international law and has been included in virtually every recently adopted treaty and policy document related to the protection and preservation of the environment. It states: "policies must be based on the precautionary principle. Environmental measures must anticipate, prevent and attack the causes of environmental degradation. Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation".

The unprecedented rapidity with which industrial wind turbine developments are being proposed and constructed in Ontario, raises major concerns about the efficacy of the Green Energy Act which has allowed and promoted this phenomenon.

1. Adverse environmental effects from industrial wind turbines

Industrial wind turbines do not have a benign environmental foot print as has been claimed.  Biologists1 are observing habitat fragmentation and habitat loss, wildlife disturbance and life history disruption when turbines are placed in natural habitats.  Bird and bat abundance declines at wind turbine sites and this can become more pronounced with time.  Disruption of ecological links results in habitat abandonment by some species.  The loss of population vigour and overall density resulting from reduced survival or reduced breeding productivity is a particular concern for declining populations.  The cumulative effects of multiple on- and off-shore wind developments have not been considered.  Collision mortality resulting from turbines and new transmission lines is increased during adverse weather conditions and migratory seasons. Especially vulnerable are raptors, passerines (songbirds), monarch butterflies, and bats. The consequential cost to agriculture from loss of pollination and natural insect control is a concern.  In addition there are serious concerns that turbine noise impacts within- and between-species communications, including predator defence.

1 Major studies include: Barrios and Rodriguez 2004; Stewart et al. 2004; Kingsley & Whittam 2005; Manville

2005; Desholm 2006; Stewart et al. 2006; Everaert and Kuijken 2007) , Kunz et al. 2007 among many others. 3

 Offshore installations have the added risk of causing waterfowl and waterbird displacement from feeding areas and migratory corridors, contaminant upwelling, and changes in fish communities.  Placing turbines in close association with coastal wetlands can severely compromise movements and foraging of migratory waterfowl.2

2. Ontario bird and bat mortality studies: Wolfe Island

Almost all post operational studies of wildlife mortalities from turbines in Ontario have been unavailable to the public, allowing government and industry to contend that wind turbines kill very few birds. The avian mortality records from Wolfe Island, however, have now disclosed the highest recorded rate of raptor casualties outside California. Each of the 86 industrial wind turbines on Wolfe Island killed an average of 13.4 birds during the first year of operation. Some of the species killed are already experiencing population declines: for example, the Tree Swallow and the Bobolink. Until we have public access to independent mortality studies, we will not know the full impact. Albert Manville, Senior Wildlife Biologist, Division of Migratory Bird management at the U.S. Fish and Wildlife Service has warned: "The numbers of Bird Species of Conservation Concern killed by wind turbines is increasing, and that's troubling. These species are already declining, in some cases rather precipitously."

2 Long Point Waterfowl data clearly indicate that fields within 2 km of coastal wetlands are used readily by large

populations of field feeding waterfowl (as well as many other species of migratory and non-migratory wildlife)

and that these are also critical corridors for wildlife movements. For information on the importance of the lower

Great Lakes for migratory and wintering waterfowl, also see: Dennis et al. 1984; Prince et al. 1992; Petrie et al.

2002; Petrie and Wilcox 2003; and Schummer 2005. 4

3. Serious flaws in the Green Energy Act

The government pushed through the Green Energy Act (2009) with negligible legislative or public discussion. The Act exempted renewable energy projects from much of Ontario’s existing environmental legislation.  One of its amendments to existing statutes, “Schedule G”, exempts renewable energy projects from the Environmental Protection Act, frustrating the purpose of that Act.  Another, “Schedule K”, removes planning authority from local municipalities and precludes compliance with the Provincial Policy Statement.  “Schedule L” removes approval rights from Conservation Authorities preventing them from stopping renewable energy projects on their lands.

One of the most troubling provisions of the GEA is the reversal of onus clause that requires citizens to prove a project’s harm to the environment or human health. The Chatham-Kent tribunal demonstrated that confronting government and proponent lawyers is well beyond the financial means of most Ontarians, making a mockery of the Statement of Environmental Principles which insists that the need for public engagement and public consultation is vital to sound environmental decision- making. It also debilitates the Environmental Bill of Rights (1994) which encouraged “enhanced ongoing engagement with the public as part of environmental decision making”.

4. Regulations

An essential flaw in the Regulations is the “fast tracking” provision for environmental assessments which allows the proponents of renewable energy projects to submit their own environmental screening report by hiring an accommodating consultant. Many questions have been raised as to the scientific rigour of these reports:  Consultants often lack the proper qualifications, specialized knowledge and technical expertise to provide sound advice (for example, pertaining to waterfowl).  Studies lack scientific rigour and fail to adequately consider existing peer reviewed literature.  There is an insufficient use of local expert knowledge during the planning process and not enough use of available/historic data.  Relative to Europe and the United States, there has been insufficient pre- construction monitoring at proposed wind turbine sites in Ontario (often days/months as opposed to years).  Post-construction studies lack scientific rigour and are not standardized.  Times chosen to make observations are often unsuitable (e.g. after or before migratory seasons and during daylight hours while most migrations of birds and bats take place at night).  Radar observations are not being used to monitor nocturnal migrations and aerial observations are not being used for determining waterfowl populations even though these are the best methods for accurate assessment.  Most “studies” are based on casual observations done over an insufficient number of days, seasons, and weather conditions and they do not include

the multi-seasonal or multi-year observations necessary to determine effects on fluctuating populations.  The methodology of the reports has been questioned and serious omissions pointed out: for example, they fail to set any a priori criteria for determining if the wind development in question will have adverse impacts on birds or bats.

Proponent-commissioned reports have generally been rubber-stamped by the Ministry of the Environment and the Ministry of Natural Resources. The Wolfe Island project, for example, was approved despite its location on a major migratory bird corridor adjacent to provincially significant wetlands, staging areas and an Important Bird Area (IBA).

Although the industry continues to claim that it avoids placing turbines near sensitive habitats, far too many projects have been constructed, approved or proposed near critical ecosystems which support threatened species, provincially significant ANSIs and provincially significant wetlands—e.g. Wolfe Island, Ostrander Point, Arran Lake, Point Pelee National Park, coastal wetlands associated with Lake St. Clair, and Manitoulin Island among them. Numerous wind turbines have been proposed for construction in close association with coastal wetlands along the lower Great Lakes (Lakes St. Clair, Erie, and Ontario). Coastal wetlands provide critically important staging habitat for nearly 30 species of migratory waterfowl. In fact, millions of waterfowl use these wetlands each spring and fall to rest, feed and acquire the body fat necessary for migration and reproduction. Approximately 85% of our coastal wetlands have already been drained and converted to agriculture and urban development; those that remain are regularly being compromised by additional human impacts and invasive species. Consequently, it is critically

7 important that we do our utmost to conserve and protect all remaining coastal wetlands.3

There are other problems and inconsistencies with the Regulations and Guidelines.

 The 120 metre setback from Significant Wildlife Habitat (compared to 550 metres from human habitations) is not biologically defensible . The regulations even allow proponents to place developments within Significant Wildlife Habitats when they claim they can “mitigate” adverse effects.  The "Bird Habitat Assessment Process” requires post construction monitoring of avian mortality but does not require an adequate assessment of wildlife displacement.  Cumulative impacts of onshore and offshore industrial wind turbines (including those being proposed for American waters) are not being considered.  Guidelines don't consider bird mortality to be significant until 18 birds/turbine/year are killed. This is 7.2 times the NA average and is not biologically defensible.  Guidelines don’t consider the mortality of raptors of provincial conservation concern (i.e. Bald Eagles) to be significant unless 0.2 raptors/ turbine/year are killed. Therefore, a development with 100 turbines that killed 19 Bald Eagles per year would not require mitigation.  Community consultation (a requirement of the Green Energy Act) has been a dismal failure with proponents ignoring and evading community concerns

3 See the following for information on the importance of coastal wetlands: Herdendorf 1992; Crowder and Bristow 1988; and Petrie 1998.

and refusing to hold public consultation meetings in preference for open house product showcases.

5. Advice of international biologists

Repeatedly biologists around the world have stated the obvious and simple warning: industrial wind turbines must be kept well away from sensitive natural habitats, including important migratory corridors.

 “Avoid locating wind farms in regional or internationally important bird or bat areas and/or migration routes”. Everaert and Kuijken 2007.  “Developers should avoid sites that are important to wildlife”. --Dr. Mark Avery, Royal Society for the Protection of Birds, U.K.  “Wind turbine developments should not be placed within 1000 meters of waterfowl roost sites; not be placed within 1 kilometre of staging areas; not be placed in flight corridors between roosts and feeding grounds; not be placed on major migratory corridors, and not be erected in areas where the wind turbine development +500 m buffer zone occupies more than 1% of the known feeding areas at a site; not be placed in agricultural fields traditionally used by large flocks of waterfowl”. -- Bjarke Laubek, M.Sc., Waterfowl Biologist with extensive experience working on waterfowl and turbine placement in Denmark.  “Wind turbine developments should not be sited near populations of birds of conservation importance, particularly Anseriformes”. --Stewart, et al. 2004.  “Avoid placing turbines in documented locations of protected wildlife, known local bird migration pathways or near wetlands and staging areas and avoid known daily movement flyways between roosting and feeding

areas, as well as bat breeding and nursery colonies or migration corridors. --U.S. Fish and Wildlife Service.  “Wind turbine developments must no longer be built in any natural areas”. --Spanish Ornithological Society.  “If we are to save our emblematic bird species from this new threat, it is urgent to impose a moratorium on windfarm construction and to call for a fully independent commission to investigate the whole windfarm matter, starting with the effectiveness of this intermittent, unreliable, and ruinous form of energy”. – Mark Duchamp, Save the Eagles International.

6. Recommendations

Revision of the Green Energy Act and its Regulations and guidelines is imperative to bring it into compliance with pre-existing environmental protection legislation.

 Amendments must be made to loopholes in the Act which exempt renewable energy projects from the Planning Act (and Provincial Policy Statements), the Environmental Protection Act, and the Conservation Authorities Act, and Regulations which change the purpose of the Statement of Environmental Principles and the Environmental Bill of Rights.  Regulations must be revised to reflect the recommendations of scientists and biologists as outlined above. Regulations, guidelines and procedures must be revised to require independent mortality and displacement studies and avoid the problems related to proponent-commissioned environmental surveys outlined above. Biologically defensible setback restrictions and mortality levels must be established for wildlife habitats and migratory corridors.

 Industrial wind turbines must not be placed within 2 km of coastal and other provincially significant wetlands and should not be placed on major migratory corridors or in agricultural fields traditionally used by large concentrations of wildlife.  All post and pre-construction monitoring must be made available to the public to allow for participation in environmental decision making as required under the Statement of Environmental Principles and the Environmental Bill of Rights.

The onus of proof of environmental damage must be reversed to make developers of renewable energy projects responsible for their actions and bring these projects into compliance with the Provincial Policy Statement.

7. Questionable effectiveness in saving GHG emissions

Here we discuss wildlife issues related to poorly regulated industrial wind turbine development but the rationale for building the turbines should also be examined.

The ideology behind industrial wind turbine installation has not been validated by experience. It is now apparent that wind turbines will not diminish Ontario’s carbon footprint just as they have failed to do anywhere else in the world.

Government advisors and ministers did not listen to the warnings of electricity generation professionals who pointed out the practical complications of adding intermittent and unpredictable wind energy to the grid. Stability can only be maintained by running fossil-fuelled plants inefficiently on standby to back up all potential wind production.

European experience has demonstrated that coal plants cannot be closed in exchange for non-base load wind energy. Germany, which has installed over 20,000

industrial wind turbines, has increased CO2 and other GHG emissions and new coal plants have had to be built to compensate for the destabilizing effect of wind energy.4 Ontario is building more gas plants for this same reason.

Bennet & McBee (2011) were the first to systematically assess the emission reduction performance of wind generation based on hourly generation and

emissions data from Colorado and Texas in the Bentek study. It shows that previous

claims were significantly overstated and that actual CO2 reductions are either so small as to be insignificant or too expensive to be practical.

Summary

The dwindling areas of wetland and other specialized ecosystems which provide habitat for threatened and endangered species are especially vulnerable to disturbance and degradation from this form of rural industrialization. Migratory avian species including raptors, waterfowl, waterbirds, passerines and bats are particularly vulnerable to displacement from critical habitats and collision mortality. Government and developers have downplayed the negative environmental footprint of wind turbines. However, as developments proliferate, post construction monitoring points to unforeseen cumulative effects and many looming

4 The Irish Electricity Supply Board (ESB) National Grid study of installed wind power in Ireland (2004) concluded: “The evidence shows that as the level of wind capacity increases, the CO2 emissions actually increase as a direct result of having to cope with the variation of wind-power output”. Similar reports corroborating this conclusion include the Tallinn Technical University study (2003), the Rhine-Westphalia Institute for Economic Research study (2009), and the Bentek study (2011). Advice to the Ontario government from The Ontario Power Authority (OPA), Integrated Power System Plan, (October, 2007) warned that the use of wind turbines “would result in higher greenhouse gas emissions”.

environmental concerns. Ontario’s Green Energy Act with its inadequate regulations and guidelines governing the siting of renewable energy installations is urgently in need of revision. Better information on the effects of industrial wind turbines must be obtained through rigorous study and the precautionary principle of the Bergen Agreement adhered to before further construction proceeds and incalculable irreversible damage is done to Ontario’s natural heritage.

References

Barrios, L., and A. Rodriguez. 2004. Behavioural and environmental correlates of soaring bird mortality at on-shore wind turbines. Journal of Applied Ecology. 41:72-81.

Bennet, P., and B. McBee. 2011. The Wind Power Paradox: Bentek Market Alert.

Crowder, A.A., and J.M. Bristow. 1988. The future of waterfowl habitats in the Canadian lower Great Lakes wetlands. Journal of Great Lakes Research. 14:115-127.

Dennis, D.G.,, G.B. McCullough, N.R. North, and R.K. Ross. 1984. An updated assessment of migrant waterfowl use of Ontario shorelines of the southern Great Lakes. Pages 37-42in Waterfowl Studies in Ontario, S.G. Curtis, D.G. Dennis and H. Boyd, editors. Canadian Wildlife Service Occasional Pape No 54.

Desholm, M. 2006. Wind farm related mortality among avian migrants – a remote sensing study and model analysis. Ph.D. Thesis, National Environmental Research Institute, Denmark.

Everaert, J., and E. Kuijken. 2007. Wind turbines and birds in Flanders (Belgium): Preliminary summary of the mortality research results: Belgian Research Institute for Nature and Forest.

Frondel, M., N. Ritter, C. Vance, F. Scheffer, and C. Schmidt. 2009. Economic impacts from the promotion of renewable energies: The German experience. Final Report: Rheinisch- Westfälisches Institut für Wirtschaft sforschung (Rhine-Westphalia Institute for Economic Research).

Herdendorf, C.E. 1992. Lake Erie coastal wetlands: an overview. Journal of Great Lakes Research. 18:533-551.

Irish Electricity Supply Board (ESB). 2004. Impact of Wind Power Generation in Ireland on the Operation of Conventional Plant and the Economic Implications: ESB National Grid.

Kingsley, A., and B. Whittam. 2005. Wind Turbines and Birds: A Background Review: Environment Canada / Canadian Wildlife Service, 81 pages.

Kunz, T., E. Arnett, W. Erickson, A. Hoar, G. Johnson, R. Larkin, M. Strickland, R. Thresher, and M. Tuttle. 2007. Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses: Journal of Wildlife Management 71:2449–2486; DOI: 10.2193/2007-270.

Liik, O., R. Oidram, and M. Keel. 2003. Estimation of real emissions reduction caused by wind generators: Tallinn Technical University, Estonia.

Manville, A.M. 2005. Bird strikes and electrocutions at power lines, communication towers, and wind turbines: state of the art and state of the science – next steps toward mitigation: Proceedings 3rd Internatl. Partners in Flight Conference. USDA Forest Service Gen. Tech. Rep. PSW-GTR-191, Vol. 2: 1051-1064.

Ontario Power Authority (OPA). October 2007. Integrated Power System Plan.

Petrie, S.A. 1998. Waterfowl and Wetlands of Long Point Bay and Old Norfolk County: Present Conditions and Future Options for Conservation. Unpublished Norfolk Land Stewardship Council Report. Long Point Waterfowl, Port Rowan, Ontario.

Petrie, S.A., S. Badzinski, and K.L. Wilcox. 2002. Population trends and habitat use of Tundra Swans staging at Long Point, Lake Erie. Waterbirds: 25:143-149.

Petrie, S.A., and K.L. Wilcox. 2003. Migration chronology of Eastern Population Tundra Swans. Canadian Journal of Zoology. 81: 861-870.

Prince, H.H., P.I. Padding, and R.W. Knapton. 1992. Waterfowl use of the Laurentian Great Lakes. Journal of Great Lakes Research. 18:673-699.

Schummer, M. L. 2005. Comparisons of resource use by Buffleheads, Common Goldeneyes and Long-Tailed Ducks during winter on northeastern Lake Ontario. Ph.D. Dissertation. University of Western Ontario. London, Ontario.

Stewart, G. B., and A.S. Pullin. 2004. Effects of wind turbines on bird abundance; Systematic Review No.4: Centre for Evidence-based Conservation, University of Birmingham, England, 49p.

Questions Arising from the

Auditor General’s 2011 Report on Renewable Energy Initiatives

(Chapter 3 Ministry of Energy: Electricity Sector—Renewable Energy Initiatives)

Compiled by Keith Stelling, MA, MNIMH, Dip Phyt, MCPP

Central Bruce-Grey Wind Concerns Ontario

18 January, 2012

Table of contents

Summary: ...... 5

Detailed findings of the Auditor General’s investigations ...... 7

1. Wind and solar will add significant additional costs to electricity bills ...... 7

2. The government claim of 1% rise in electricity costs for renewable energy was inaccurate ...... 8

3. $169 million in 2010 and $296 million in 2011 would need to be recovered from electricity

ratepayers for the cost of connecting renewable energy ...... 8

4. Ontario consumers were not informed of true costs of green energy ...... 9

5. The government was warned in 2007 that new wind power would create higher Green House

Gas (GHG) emissions ...... 11

6. Minister added $4.4 billion to FIT contract payments against O.P.A. advice ...... 12

7. Was the Samsung agreement made without economic or business case analysis and neither OEB

nor OPA was consulted? ...... 14

8. Normal due diligence process not followed; no formal Cabinet approval ...... 15

9. Electricity ratepayers may have to pay $150 to $225 million a year to renewable energy

generators not to produce electricity ...... 15

10. Backup: Consumers have to pay twice for intermittent renewable energy ...... 16

11. Cost and environmental impact of backup not analyzed ...... 17

12. The extent of the backup requirement has been underestimated ...... 19

13. Closing coal plants will require an increase of 5,000 MW of gas-fired generation ...... 20

14. Minister suspended independent assessment that would ensure decisions were economically

prudent and cost-effective ...... 20

15. Billions committed to renewable energy without evaluating impact ...... 21

16. Despite anticipated surpluses, renewable energy generators will get paid even though Ontario

does not need their electricity ...... 22

Loss of oversight and transparency in decision making ...... 23

17. Ministerial directives bypassing OPA and OEB lead to loss of transparency, economic prudence

and cost effectiveness ...... 23

18. Many directions related to the procurement and pricing of renewable energy have been issued

since 2008 in the absence of an approved IPSP, and the OEB has had no oversight role ...... 24

19. There has been a lack of independent oversight on the reasonableness of FIT prices ...... 26

20. If the IESO instructs wind generators to shut down under a surplus-power situation, the

generators still get paid ...... 29

21. There has been inadequate assessment of the potential costs of curtailing renewable energy . 30

22. Adding more renewable energy would result in curtailment cost of paying renewable

generators for not producing electricity from $150 million to $225 million a year ...... 31

23. The lack of correlation between electricity demand and intermittent renewable energy has

created operational challenges, including power surpluses and the need for backup power ...... 31

24. Surplus base load generation caused by renewable energy will add more costs for electricity

ratepayers ...... 33

25. In 2010, 86% of wind power was produced on days when Ontario was already in a net export

position...... 33

26. Export customers paid only about 3¢/kWh to 4¢/kWh for Ontario power; electricity ratepayers

of Ontario paid more than 8¢/kWh for this power to be generated ...... 34

27. From 2005 to the end of our audit in 2011, Ontario received $1.8 billion less for its electricity

exports than what it actually cost electricity ratepayers of Ontario ...... 35

28. The IESO requested that nuclear generators shut down or reduce electricity supply 205 times in

2009 and 13 times in 2010 ...... 36

29. Recommendation 5: Assess the operational challenges and the feasibility of adding more

intermittent renewable energy into the system ...... 36

Socio-economic Impacts ...... 37

30. Promised “green” jobs have not been produced and existing jobs may be lost because of higher

electricity prices ...... 37

31. A majority of the jobs will be temporary ...... 38

32. Analysis should consider both job-creation and job-loss impacts, and experiences of other

jurisdictions with similar renewable energy initiatives ...... 38

Environmental Concerns ...... 40

33. Estimated reduction in greenhouse gases did not take into account the continuing need to run

fossil-fuel backup ...... 40

Health Concerns ...... 42

34. CMOH report questioned...... 42

35. Academic research chair has produced no report ...... 42

36. Ministry of Energy should measure impact of backup facilities and provide objective research on

potential health effects of wind power ...... 43

Summary:

With comprehensive and detailed evidence gathered independently from inside the Ministry

of Energy-- much of it previously unavailable to the public-- the Auditor General’s Report

unambiguously challenges both the rationale and implementation of the Green Energy Act.

The Act has been promoted as a mechanism for cutting greenhouse gas emissions,

increasing job opportunities, and creating a competitive business environment. However the

Auditor General’s investigators found little evidence that these objectives have been or

would be realized. Instead it suggests that the escalating electricity costs resulting from the

addition of solar and wind power to the grid with their extravagant feed-in-tariffs are having

the opposite effect.

The report emphasizes “that wind and solar renewable power will add significant

additional costs to ratepayers’ electricity bills”. (89)1 However there will be additional

costs because “wind and solar are not as reliable and require backup from alternative

energy-supply methods such as gas-fired generation”. (89) Nevertheless, the public

was led to believe increased costs would be minimal (1%). Surveys indicated that people

were willing to pay only up to 5% more for renewable electricity.

1 The number in brackets following a quotation indicates the page number in the report. Quotations from the report are printed in serif font. The report can be found at: http://www.auditor.on.ca/en/reports_en/en11/2011ar_en.pdf

The Auditor’s Report is © Queen's Printer for Ontario. However, the Office of the Auditor General supports the diffusion and sharing of information. The materials on this site may be downloaded, displayed, printed, and reproduced for non-commercial purposes only, provided that the materials remain unaltered, the source is acknowledged, and Crown copyright is recognized.

The report indicates that the escalating increase of electricity prices will continue to gain momentum as rising costs for backup, connection of renewable energy projects, spilling hydro and nuclear, and payments to renewable energy producers not to produce electricity increase. The negative implications of increased electricity costs on employment and the economy in general further challenge the practicality of the Green Energy Act. The Auditor questions whether the estimate of the number of jobs that the government claims have been created by the Act is accurate and asks why those that are being lost are not being accounted for.

However the report goes beyond assessing the financial liability of imprudent expenses and overly generous feed-in-tariffs offered to energy producers. “No comprehensive business- case evaluation was done to objectively evaluate the impacts of the billion-dollar commitment. Such an evaluation would typically include assessing the prospective economic and environmental effects of such a massive investment in renewable energy on future electricity prices, direct and indirect job creation or losses, greenhouse gas emissions, and other variables”. (89) Alarmingly, decisions continue to be made piecemeal without overall cost and effectiveness evaluation. The investigators found that “the ministry’s internal audit service team . . . had not recently conducted any audit work on renewable energy initiatives”. (88)

The government’s adamant contention that there are no adverse health effects from industrial wind turbines is also questioned by the Auditor General who notes that the report by Ontario’s Chief Medical Officer of Health “was questioned by environmental groups, physicians, engineers, and other professionals, who noted that it was merely a literature review that presented no original research and did not reflect the situation in Ontario”. (119-120)

Even more worrying, is the lack of appropriate oversight and transparency. Decisions have

been made by ministerial directive and directions, relying largely on the opinion of a single

inexperienced minister, while circumventing both the recommendations regarding feasibility

by expert energy professionals in the Ontario Power Authority (OPA) and frustrating the

responsibility for oversight by the Ontario Energy Board (OEB) to ensure that renewable

energy resources are obtained in a cost-effective manner.

Detailed findings of the Auditor General’s investigations

1. Wind and solar will add significant additional costs to electricity bills

“Wind and solar renewable power will add significant additional costs to ratepayers’

electricity bills. Renewable energy sources such as wind and solar are also not as

reliable and require backup from alternative energy-supply methods such as gas-

fired generation”. (89)

“The government was well aware that its renewable energy initiatives meant higher

costs”. (89) However, the government assumed “that this was a more-than-

acceptable trade-off given the environmental and health benefits, as well as the

anticipated job-creation benefits”. (89) Nonetheless, the government failed to assess

“the prospective economic and environmental effects of such a massive investment in

renewable energy on future electricity prices, direct and indirect job creation or

losses, greenhouse gas emissions, and other variables”. (89)

QUESTION: Why is the government continuing its massive investment in renewable energy without a responsible business practice assessment of costs and benefits?

2. The government claim of 1% rise in electricity costs for renewable energy was inaccurate

“In May 2009, when the Green Energy and Green Economy Act (Act) was passed,

the Ministry said the Act would lead to modest incremental increases in electricity

bills of about 1% annually—the result of adding 1,500 MW of renewable energy under

a renewable procurement program called the Feed-in Tariff program and

implementing conservation initiatives. In November 2010, the Ministry forecast that

a typical residential electricity bill would rise about 7.9% annually over the next five

years, with 56% of the increase due to investments in renewable energy that would

increase the supply to 10,700 MW by 2018, as well as the associated capital invest-

ments to connect all the renewable power sources to the electricity transmission

grid”. (89)

QUESTION: Was it willful blindness or incompetence on the part of Former Energy and Infrastructure Minister George Smitherman when he told the CTV on April 6, 2009: “Any additional costs to consumers will be minimal. Residents can expect their electricity bills to increase about one per cent per year”?

QUESTION: Was Premier McGuinty’s statement to the Legislature on February 26, 2009 that “renewable energy will have only a minimal impact on electricity bills” knowingly incorrect in an attempt to mislead the legislature and the public, or was it based on less than the due diligence expected of the leader of the province?

3. $169 million in 2010 and $296 million in 2011 would need to be recovered from electricity ratepayers for the cost of connecting renewable energy

“Hydro One files applications with the OEB to seek approval to recover the costs of

transmission and distribution charges on electricity bills. Its most recent distribution

rate application estimated that investments of $169 million in 2010 and $296 million

in 2011 would need to be recovered from electricity ratepayers for the cost of

connecting renewable energy to the distribution systems and modernizing the

electricity grid”. (115)

4. Ontario consumers were not informed of true costs of green energy

“Based on our analysis of OPA data, renewable energy contracts will contribute

significantly to increases to the Global Adjustment (GA). . . . The total GA is expected

to increase tenfold province-wide, from about $700 million in 2006 to $8.1 billion in

2014, when the last coal-fired plants are phased out. Almost one-third of this $8.1

billion is attributable to renewable energy contracts”. (94)

“The OPA indicated that consumers have to be advised, through appropriate

channels, of the expected electricity-price increases arising from a large number of

contracts to buy green energy at fixed rates that are significantly higher than market

prices. However, a number of consumer surveys conducted by the government in

spring and fall 2010 indicated that although consumers generally supported

renewable energy, they were for the most part unaware of its impact on prices.

Specifically:

• An OPA survey showed that only 14% of respondents thought renewable energy

would lead to electricity price increases, while 60% disagreed that “green energy

sources like wind and solar are too expensive and unreliable.”

• Ministry surveys found that only a minority of respondents linked recent price

increases to the cost of renewable energy, although many respondents did say that

they were prepared to pay “modest” increases for renewable electricity”.

• Hydro One surveys found that consumers supported spending to connect renewable

energy to the power grid, but were less inclined to support electricity bill increases

associated with these investments. About half said they were willing to pay for such

investments, but only 27% would agree to an increase in their electricity bills of more

than 5%”. (94)

“In November 2010, the Ministry’s Long-Term Energy Plan (LTEP) included

electricity-price forecasts based on the effects of all investments in Ontario’s

electricity system. According to the LTEP, a typical residential electricity bill would

rise about 7.9% annually over the next five years, with 56% of the increase due to

investment in new, cleaner renewable energy that would increase the supply to

10,700 MW by 2018 as well as the associated capital investments to connect

renewable power sources to the transmission grids”. (94-95)

“We also noted that although the LTEP and the related pamphlet did inform the

public that renewable energy would increase their electricity bills, the cost impact of

renewable energy by sector was not disclosed in detail”. (95)

“Figure 4: Monthly Electricity Charge Related to Renewable Energy in

Different Sectors (Source of data: Ministry of Energy) (95)

Assumed Renewable Energy Related Charge Electricity ($) Consumption

2018 Economic Sector Examples (kWh/month) (Actual) (Projected) residential n/a 800 2 31 small commercial convenience store, 12,000 38 500 small dry cleaner, restaurant, small retail store large commercial supermarket, 130,000 385 5,000 shopping mall, large office building, hotel industrial paper and pulp, 61,200,000 200,000 2,400,000 automobile,

mining, cement, iron and steel manufacturing, chemical products, petroleum (i.e., refineries)

“In addition to the forecasts in the Ministry’s LTEP and contained in Figure 4, in

April 2010, the OEB completed an analysis predicting that a typical household’s

annual electricity bill will increase by about $570, or 46%, from about $1,250 in 2009

to more than $1,820 by 2014. More than half of this increase would be because of

renewable energy contracts”. (95-96)

5. The government was warned in 2007 that new wind power would create higher Green House Gas (GHG) emissions

“The OPA was designated as the province’s energy planner, responsible for

submitting long-term plans to the Ontario Energy Board (OEB) for approval.

However, the first long-term energy plan put forward by the OPA since its creation in

December 2004 has not been approved by the OEB. Although the OPA did spend

$10.7 million to develop its first energy plan, which it submitted to the OEB for

review in 2007, the government suspended the OEB’s review of the plan in 2008. In

2010, the Ministry released its own Long-Term Energy Plan to provide the OPA with

sufficient context on the government’s policy priorities and targets to guide it in its

planning. From the public’s perspective, this could lead to some ambiguity as to

which entity is responsible for electricity planning in Ontario”. (89-90)

QUESTION: Why did the government suspend the OEB’s review of the plan in 2008 after spending $10.7 million for its development? Was it because the OPA warned the government that wind generation would result in higher greenhouse gas emissions?

The OPA Integrated Power System Plan, (October, 2007) analyzed a “high wind power” scenario for the province, and concluded:

“Since wind generation has an effective capacity of 20% compared to 73% for hydroelectric generation, additional generation capacity with better load- following characteristics would need to be installed”.

“This needed capacity will likely have to be obtained by installing additional gas-fired generation. Thus, in addition to incurring further capital costs for the gas generation installation, higher gas usage would be expected to make up for the reduced amount of renewable energy from wind compared to that from hydroelectric generation or this alternative. Therefore, this alternative would result in higher greenhouse gas emissions. Wind and solar power will never be more than a niche supplier of power in Ontario.”

6. Minister added $4.4 billion to FIT contract payments against O.P.A. advice

“Earlier procurement programs for renewable energy included competitive bidding

and the Renewable Energy Standard Offer Program (RESOP), which were both very

successful and achieved renewable generation targets in record time. In particular,

RESOP received overwhelming responses. It was expected to develop 1,000 MW over

10 years, but it exceeded this target in a little more than one year. Although

continuing the successful RESOP initiative was one option, the Minister directed the

OPA to replace RESOP with a new Feed-in Tariff (FIT) program that was wider in

scope, required made-in-Ontario components, and provided renewable energy

generators with significantly more attractive contract prices than RESOP. These

higher prices added about $4.4 billion in costs over the 20-year contract terms as

compared to what would have been incurred had RESOP prices for wind and solar

power been maintained. The Ministry indicated that replacing RESOP with FIT

successfully expedited its renewable energy program and promoted Ontario’s

domestic industry”. (90)

“Many other jurisdictions set lower FIT prices than Ontario and have mechanisms to

limit the total costs arising from FIT programs. The OPA made a number of

recommendations to lower Ontario’s pricing structure. We were advised that the

government opted for price stability to maintain the investor confidence required to attract capital investment to Ontario until the planned two-year review of the FIT program could be undertaken”. (90) 2

QUESTION: What could have prompted the Energy Minister to silence his advisors in October 2009 when “in a letter to the OPA, Mr. Smitherman personally seized control of the agency. ‘I write pursuant to my authority as the Minister of Energy and Infrastructure, in order to exercise the statutory powers of ministerial direction which I have in respect of the Ontario Power Authority. . . I direct you to develop a feed-in tariff (FIT) program’”.3 Was this the result of the lobbying by the industry?

QUESTION: Was Mr Smitherman’s use of ministerial direction in the interests of Ontario’s electricity consumers?

2 The Auditor’s report adds further examples of proposed changes:

“• In March 2009, before the passage of the Green Energy and Green Economy Act, the OPA proposed a reduction of 9% to FIT prices for electricity generated from ground-mounted solar projects, in line with similar practices in some other jurisdictions. This could have reduced the cost of the program by about $2.6 billion over the 20-year contract terms. The government did not apply this reduction. The Ministry informed us that such a predetermined price reduction ran counter to the government’s goals of maintaining policy and price stability for the initial two- year period”.

“• In February 2010, the OPA recommended cutting the FIT price paid for power from microFIT ground-mounted solar projects after the unexpected popularity of these projects at the price of 80.2¢ per kilowatt hour (kWh), the same price as was being paid for rooftop solar projects, became apparent. This price would provide these ground-mounted solar project developers with a 23% to 24% after-tax return on equity instead of the 11% intended by the OPA. The recommended price cut was not implemented until August 2010. In the five months from the time the OPA recommended the price cut in February 2010 to the actual announcement in July 2010, the OPA received more than 11,000 applications from developers. Because the government decided to grandfather the price in order to maintain investor confidence, all of these applications, if approved, would qualify for the higher price rather than the reduced one. We estimated that, had the revised price been implemented when first recommended by the OPA, the cost of the program could have been reduced by about $950 million over the 20-year contract terms”. (90)

3 “Ontario's iron-fisted energy model” Terence Corcoran, Financial Post, October 01, 2009.

7. Was the Samsung agreement made without economic or business case analysis and neither OEB nor OPA was consulted?

“The Ministry negotiated a contract with a consortium of Korean companies to build

renewable energy projects. The consortium will receive two additional incentives

over the life of the contract if it meets its job-creation targets: a payment of $437

million (reduced to $110 million, as announced by the Ministry in July 2011 after

the completion of our audit fieldwork) in addition to the already attractive FIT

prices; and priority access to Ontario’s electricity transmission system, whose cap-

acity to connect renewable energy projects is already limited. However, no economic

analysis or business case was done to determine whether the agreement with the

consortium was economically prudent and cost-effective, and neither the OEB nor

the OPA was consulted about the agreement. On September 29, 2009, the ongoing

negotiations with the consortium were publicly announced, and Cabinet was briefed

on the details of the negotiations and the prospective agreement in October 2009.

The formal agreement was signed in January 2010”. (90-91)

QUESTION: Was it determined whether or not Samsung had sufficient experience in building wind turbines, and if not, is the Ontario taxpayer subsidizing the research and development costs of a Korean company?4

4 “Samsung Heavy industries (SHI) was established in 1974 and has become the second largest ship manufacturer in the world with an exclusive focus on shipbuilding, offshore floaters, digital devices for ships, and construction and engineering concerns. It was reported in March of 2009 that Samsung was thinking about moving towards wind turbine production. With the recent drop in vessel orders, the company needs a new source of work and revenue. SHI is looking for a new plant site, where the company plans to build a production plant for producing 200 wind turbines, with capacities of 2.5 MW and 5 MW. SHI is aiming to build about 500 units by 2015”. (Renewable Energy News, May 25 2009) http://www.renewbl.com/2009/05/25/samsung-heavy-industries-turning-towards- wind-turbine-production.html

QUESTION: Who signs a contract (after receiving an offer from only one source) that commits Ontario to pay $20 billion over a 20 year period for an intermittent power source, much of which will have to be sold at cost because it is produced during times of surplus base load generation? 5 Can we not expect our government to apply the same diligence to spending our money as we would- and would we not at least get competitive bids?

8. Normal due diligence process not followed; no formal Cabinet approval

“However, we noted that the normal due diligence process for an expenditure of this

magnitude had not been followed. For large projects such as the consortium

agreement, we expected but did not find that a comprehensive and detailed economic

analysis or business case had been prepared. According to the Ministry, the decision

to enter into the agreement with the consortium was made by the government.

Although the Cabinet was briefed about the agreement, the Ministry indicated that

there had been no formal Cabinet approval because it was not required”. (108)

QUESTION: Why was no economic or business case analysis done to determine whether the agreement with the Korean consortium was economically prudent and cost-effective, and why was neither the OEB nor the OPA consulted about the agreement?

9. Electricity ratepayers may have to pay $150 to $225 million a year to renewable energy generators not to produce electricity

“Given that demand growth for electricity is expected to remain modest at the same

time as more renewable energy is being added to the system, electricity ratepayers

may have to pay renewable energy generators under the FIT program between $150

million and $225 million a year not to generate electricity”. (91)6

5 2000 MW Wind x 20 years x 8760 hrs/yr x $140 per MWh x 28% CF = $13.7 billion 500 MW solar x 20 years x 8760 hrs/yr x $469 per MWh x 15% CF = $6.2 billion

6 Compare this with another which makes the IESO calculation appear to be very low: $225 Million for 2500 hours a year of non production corresponds only to 666 MW of wind generation. We are headed to over 7000 MW of wind, and it will mostly be

QUESTION: Does the government not have a responsibility to exercise economic prudence on behalf of electricity consumers? Why have contracts not stipulated that electricity be paid for only when it is needed?

10. Backup: “Consumers have to pay twice for intermittent renewable energy”

“Renewable energy sources such as wind and solar provide intermittent energy and

require backup power from coal- or gas-fired generators to maintain a steady,

reliable output. According to the study used by the Ministry and the OPA, 10,000

MW of electricity from wind would require an additional 47% of non-wind power,

typically produced by natural-gas-fired generation plants, to ensure continuous

supply”. (91)

“Operational Challenge: Backup Power Requirement”

“To maintain reliability, there is always a need for backup power generation in the

event that a generator must shut down unexpectedly. However, intermittent

renewable energy sources such as wind and solar require fast-responding backup

power and/or storage capacity to keep the supply of electricity steady when the skies

are cloudy or the wind dies down. The OPA informed us that because viable large-

scale energy storage is not available in Ontario, wind and solar power must be backed

up by other forms of generation. This backup power is generated mainly from natural

gas, because coal will be phased out by the end of 2014”. (113)

“The IESO confirmed that consumers have to pay twice for intermittent renewable

energy—once for the cost of constructing renewable energy generators and again

for the cost of constructing backup generation facilities, which usually have to keep

running at all times to be able to quickly ramp up in cases of sudden declines in

produced during times of surplus. The cost will be well over 225 million per year, and will be more likely 10 times higher each year.

sunlight levels or in wind speed. The IESO confirmed that such backups add to

ongoing operational costs, although no cost analysis has been done”. (113)

QUESTION: Why has the government not carried out any cost analysis of the ongoing operational costs for back up of wind and solar energy?

QUESTION: Are consumers not paying three times: once to the wind generators either to produce or not produce; once to the other generators such as nuclear or hydro that "spill"; and potentially a third time to sell the surplus at a negative price; i.e. we pay others to take the surplus off our hands?

11. Cost and environmental impact of backup not analyzed

“The backup requirements have cost and environmental implications”. (113)

“The use of gas-fired backup generation will reduce the net contribution of renewable

energy to environmental protection, as indicated by studies from other jurisdictions

(see the “Environmental and Health Impacts” section later in this report)”. (113)

“Despite these concerns, the cost and environmental impacts of such backup

generation capacity were not formally analyzed to ensure that this information would

be available to policy decision-makers”. (113)

QUESTION: Why has the government not investigated the negative environmental footprint of gas fired backup generation?

A succession of energy ministers through Mr Duncan, Mr Phillips, Mr Smitherman, Mr Phillips again (after Mr Smitherman left abruptly), Mr Duguid and now Mr Bentley keep telling us we need wind to shut down dirty coal to protect the health of Ontarians. The main reason that "coal generation is "dirty" is that the government has resisted installing filters that would remove particulate and SO2 ... at much lower cost than building the new system and shutting down coal. However more polluting open-cycle gas plants running less efficiently on standby7 are needed

7 “There are two classes of gas turbine: Open Cycle Gas Turbine (OCGT) and Combined Cycle Gas Turbine (CCGT). OCGT has lower capital cost, higher operating costs, uses more gas and produces more greenhouse emissions than CCGT per MWh of electricity

to back up the wind turbines. They cause more health problems than the coal units when outfitted with modern pollution control. According to the Suzuki Foundation:

“Possibly more troubling are the emissions of fine particulates from gas-fired power plants. Though particulate emissions are about one-tenth what they are for coal power, the U.S. Environmental Protection Agency estimates that 77% of particulates from a natural gas plant are dangerously small. These fine particulates have the greatest impact on human health because they bypass our bodies’ natural respiratory filters and end up deep in the lungs. In fact, many studies have found no safe limit for exposure to these substances”. 8

QUESTION: Was the following information which appeared on the Ontario Ministry of Energy and Infrastructure web site intentionally designed to confuse the public or did it represent the failure of the minister to understand his portfolio:

“There are a number of unique advantages to wind power: Electricity generation from wind farms reduces the emission of carbon dioxide by 99 per cent over coal-fired electricity plants and by 98 percent over natural gas”. “Wind and solar projects will displace 40 megatonnes of carbon dioxide compared to what would be emitted by equivalent gas-fired generation. That's equivalent to removing every single car off Ontario roads for one year”.

generated. OCGT follows load changes better than CCGT. CCGT has higher capital cost and needs to run at higher power and run for longer to be economic. CCGT is more efficient so it uses less gas and produces less greenhouse emissions. CCGT produces electricity at less cost than OCGT for capacity factors above about 15%”.

• “If wind generation is available the power produced is highly variable and unscheduled so it needs to be backed up by OCGT. Although OCGT is called up to back up for wind, the energy produced by wind actually displaces CCGT generation mostly”.

• “Because wind energy is variable, unreliable and cannot be called up on demand, especially at the time of peak demand, wind power has low value”. – Peter Lang. Cost and Quantity of Greenhouse Gas Emissions Avoided by Wind Generation. http://www.windaction.org/documents/20052

Combined cycle gas plants (efficiency around 70%) need to be operating at a power over about 50% to be able to vary their load up the last 50%, while simple cycle (open cycle) gas turbines (efficiency about 35%) can run from low load to high load, but use twice as much gas to do so. Thus, if combined cycle generators are needed to back up 7000 MW of wind, you would need them already running at 7000 MW to be able to load the top 7000 MW. Thus wind plus gas = 14,000 MW, and make up all of the Ontario base load, leaving no room for nuclear.

8 From the Suzuki Foundation web site: http://www.davidsuzuki.org/Climate_Change/Energy/Fossilfuels/naturalgas.asp

—Ontario Ministry of Energy and Infrastructure web site.

QUESTION: Why does the government continue to mislead the public regarding the real environmental footprint of wind energy?

12. The extent of the backup requirement has been underestimated

“The only analysis on backup power that the Ministry cited was a study done by a

third party engaged by the OPA as part of its 2007 IPSP development. The study

noted that 10,000 MW of wind would require an extra 47% of non-wind sources to

handle extreme drops in wind. We noted that the third party who carried out this

study also operated an Ontario wind farm, raising questions about the study’s

objectivity”. (113-114)

QUESTION: Why did the government claim that 10,000 MW of wind would require only an extra 47% of non-wind sources as backup relying only on the opinion of an Ontario wind development operator when it had already been informed of the German electricity distributor E-on Netz “Wind report 2005” which stressed in its introductory summary:

“Wind energy is only able to replace traditional power stations to a limited extent. Their dependence on the prevailing wind conditions means that wind power has a limited load factor even when technically available. It is not possible to guarantee its use for the continual cover of electricity consumption. Consequently, traditional power stations with capacities equal to 90% of the installed wind power capacity must be permanently online in order to guarantee power supply at all times”.

(More recently, some experts have indicated that wind must be backed up 100%).

“We noted that: Prior to the passage of the Green Energy and Green Economy Act in

2009, the Ministry did not quantify how much backup power would be required. It

was not until February 2011 that the Minister issued a new supply-mix directive that

asked the OPA to consider backup options, such as converting coal-fired plants to

gas-fired operation, importing power from other jurisdictions, and developing

storage systems. The OPA has not yet made any recommendations to the Ministry”.

(113)

QUESTION: When will those recommendations be available to the public?

13. Closing coal plants will require an increase of 5,000 MW of gas-fired generation

“The government has committed to closing all coal-fired plants by the end of 2014.

Ontario is on track to meet this commitment. Of the 19 units operated at five coal-

fired plants across Ontario in 2003, the Ministry indicated that eight units had been

closed since that year and two more were to be shut down later in 2011. As a result of

these closures, the installed capacity of coal-fired generation in Ontario has been

decreasing. It is anticipated that more than 7,500 MW of coal-fired installed capacity

in 2003 will be replaced by nuclear power from refurbished plants and an increase of

about 5,000 MW of gas-fired generation, with the balance coming from new

renewable energy sources”. (92-93)

QUESTION: Why does the government continue to mislead the public by saying that wind is shutting down coal? Wind is not shutting down coal because wind can fall to 0 when the system is at peak.

14. Minister suspended independent assessment that would ensure decisions were economically prudent and cost-effective

“The OEB’s review and approval process of the OPA’s first IPSP, submitted in August

2007, was suspended the following year at the direction of the Minister, who asked

the OPA to revise the IPSP. The suspension of the independent regulator’s review

meant that there would be no independent assessment to ensure that decisions were

made in an economically prudent and cost-effective manner”. (96)

QUESTION: Why did the government assume there was no need for independent assessment to ensure that decisions were made in an economically prudent and cost-effective manner?

15. Billions committed to renewable energy without evaluating impact

“Although the Ministry consulted with stakeholders in developing the supply-mix

directives, the LTEP, and the Green Energy and Green Economy Act, billions of

dollars were committed to renewable energy without fully evaluating the impact, the

trade-offs, and the alternatives through a comprehensive business-case analysis.

Specifically, the OPA, the OEB, and the IESO acknowledged that:

• no independent, objective, expert investigation had been done to examine the

potential effects of renewable-energy policies on prices, job creation, and greenhouse

gas emissions; and

• no thorough and professional cost/benefit analysis had been conducted to identify

potentially cleaner, more economically productive and cost-effective alternatives to

renewable energy, such as energy imports and increased conservation”. (97)

QUESTION: Why has no independent, objective, expert investigation been done to examine the potential effects of renewable-energy policies on prices, job creation, and greenhouse gas emissions?

QUESTION: Why has no thorough and professional cost/benefit analysis been conducted to identify potentially cleaner, more economically productive, and cost- effective alternatives to renewable energy, such as energy imports and increased conservation?

QUESTION: Why did the ministry ignore comments received which identified concerns with their path?

16. Despite anticipated surpluses, renewable energy generators will get paid even though Ontario does not need their electricity

“According to the OPA, Ontario’s electricity generation capacity has been much

higher than demand in recent years. Electricity demand has declined since 2005 due

to the economic downturn, conservation, and declines in the auto, pulp, and paper

industries, while supply increased mainly because of the addition of renewable

energy and gas-fired resources. The OPA noted that demand is expected to remain

flat or decline due to continued conservation efforts and uncertain or slow economic

recovery, while supply is expected to increase as a result of significantly more

renewable energy coming on-line”. (98)

“Our analysis of actual and projected data from the IESO and the OPA shows that

from 2005 to 2025, installed and effective capacity will continue to exceed both

average demand and peak demand”. (99)

“The OPA did advise us that Ontario will face significant energy uncertainty beyond

2015 as a result of the increasing supply of renewable energy, the phasing out of coal

by the end of 2014, and the refurbishment of nuclear units. Ontario will experience a

temporary supply reduction from 2016 to 2020, when all coal-fired plants will be

closed and some nuclear units will be taken out of service for refurbishment. The

expected increase in renewable energy sources such as wind and solar will not

effectively address the temporary supply reduction. According to the OPA, renewable

energy sources are not always available during peak demand periods due to their

intermittency and low effective capacity”. (99)

QUESTION: Are we at risk of blackouts for four years? Actually it is worse than that. The "plan" replaces coal with gas, and shuts down the coal. The "plan" refuses to refurbish Pickering Nuclear Generating Station, and commits instead to build new nuclear, but the Minister then refused the bid made and did not direct the OPA

to pursue further bids. We are going to be very short on days the wind does not blow.

“An OEB analysis completed in April 2010 also concluded that, by 2016, electricity

supply will far exceed demand. Despite these anticipated surpluses, renewable

energy generators who have contracts with the OPA will get paid even though

Ontario does not need their electricity”. (99-100)

Loss of oversight and transparency in decision making

17. Ministerial directives bypassing OPA and OEB lead to loss of transparency, economic prudence and cost effectiveness

“Even after the breakup of the former Ontario Hydro, Ontario’s electricity sector

continued to have a system of checks and balances in place with two expert agencies

playing key roles—the OPA as energy planner and the OEB as regulator. This

arrangement was intended to ensure that decisions are made transparently and

objectively; that consumers get reliable, affordable, and sustainable power; and that

any energy plan is economically prudent and cost-effective. With the Green Energy

and Green Economy Act, 2009 (Act) giving the Minister the authority to direct

certain aspects of planning and procurement of electricity supply through ministerial

“directives” and “directions,” the frequent exercise of this authority has created some

ambiguity regarding the original mandates of the OPA and the OEB from the

planning and oversight perspective”. (100)

18. Many directions related to the procurement and pricing of renewable energy have been issued since 2008 in the absence of an approved IPSP, and the OEB has had no oversight role

“The OEB is an independent regulatory agency mandated to protect the interests of

consumers with respect to the price, adequacy, reliability, and quality of electricity

service. It is also responsible for promoting economic efficiency and cost-

effectiveness in the generation, transmission, and distribution of electricity. Under

the Green Energy and Green Economy Act, 2009 (Act), the OEB was also given a

new objective: the promotion of renewable energy, including the timely connection of

renewable energy projects to transmission and distribution systems”.

The ministerial direction-making authority has limited the OEB’s ability to carry out

its regulatory and oversight role on behalf of consumers with respect to renewable

energy. The OEB advised us that other than the review of the IPSP, it has no

oversight responsibility over any procurement of renewable energy, which has

become an increasingly important part of Ontario’s electricity-supply mix. Because

the OEB has not yet approved any IPSP, it has had no oversight role with respect to

renewable energy since the creation of the OPA in 2004. Had the OEB’s review and

approval responsibilities with respect to the OPA’s first IPSP not been suspended, the

impact of any ministerial directions would have been analyzed as part of the OEB’s

review of the IPSP. Many directions related to the procurement and pricing of

renewable energy have been issued since 2008 in the absence of an approved IPSP,

and the OEB has had no oversight role whatsoever. A report in 2009 by the

Environmental Commissioner of Ontario raised concerns that the OEB will not be

able to examine the economic prudence and cost-effectiveness of any electricity-

related initiatives introduced through ministerial directions in the absence of an

approved IPSP”. (101)

QUESTION: When will oversight on behalf of consumers be returned to the OEB and the OPA?

“Although the OEB has played an oversight role in the connection of renewable energy to the grid by evaluating construction, expansion, and reinforcement projects of transmission and distribution systems, its limited involvement in reviewing the procurement and pricing of renewable energy has limited the effectiveness of its normal role in protecting the interests of consumers with respect to prices and overall cost-effectiveness in the electricity sector. For example, in December 2007 the

Minister directed the OPA to enter into contracts for certain hydro projects that would have the “potential to add a new supply of clean, renewable power at an acceptable price to Ontario ratepayers.” In January 2010, the OPA was advised that the estimated cost for one of these projects had increased substantially, from $1.5 billion to $2.6 billion, and there was no guarantee that the cost would not continue to rise. Given the estimated $1.1-billion cost increase, the OPA expressed concerns about whether the project would provide value for ratepayers. In February 2010, at the OPA’s request, a direction was issued by the Minister, who acknowledged the cost overrun but instructed the OPA to proceed anyway. The direction noted that the

Minister was satisfied that the project remained consistent with government priorities. The Ministry informed us that under the existing regulatory and legislative framework, the OEB would not have had any oversight role with respect to this particular project”. (101)

“RECOMMENDATION 2

“To ensure that senior policy decision-makers are provided with sound information on which to base their decisions on renewable energy policy, the Ministry of Energy and the Ontario Power Authority should work collaboratively to conduct adequate analyses of the various renewable energy implementation alternatives so that

decision-makers are able to give due consideration to cost, reliability, and

sustainability”. (102)

QUESTION: When does the government intend to implement this recommendation?

19. There has been a lack of independent oversight on the reasonableness of FIT prices

“In recent years, renewable energy has often been procured through standard-offer

and non-competitive processes in response to ministerial directions. Prices for

renewable energy, especially under the FIT program, have been between two and 10

times higher than those of conventional energy sources, such as nuclear, natural gas,

and coal. Generators of renewable energy will be paid guaranteed prices over the

contract terms, which range from 20 years for electricity from wind, solar, and

bioenergy, to 40 years for hydroelectricity”. (102)

“The OPA indicated that the competitive process usually provides the best value and

is the preferred option, barring other policy priorities, to ensure that contracted

prices are cost-effective and reflect current market costs”. (102)

“• There was minimal documentation to support how FIT prices were calculated to

achieve the targeted return on equity, because of the numerous changes to the

financial model and assumptions used by the OPA”. (104)

“• There has been a lack of independent oversight on the reasonableness of FIT

prices. Although the OEB has historically been mandated to oversee and approve

electricity prices, it has no role or legislative responsibility to review or approve FIT

prices”. (104)

“Revision of FIT Prices

“By July 2010, less than a year after the launch of FIT, the OPA had received more than 16,000 applications, about 13,500 of which were for ground-mounted solar projects. According to the OPA, this overwhelming response highlighted the unexpected popularity of microFIT ground-mounted solar projects at the price of

80.2¢/kWh, the same price that was being paid for rooftop solar projects. The original FIT price of 80.2¢/kWh would provide developers of these ground-mounted solar projects with a 23% to 24% after-tax return on equity instead of the 11% intended by the OPA. Therefore, in July 2010 OPA proposed cutting the price by about 27%, from 80.2¢/kWh to 58.8¢/kWh”. (105)

“The proposed price cut brought a strong response during a 30-day round of consultations. Many developers objected to the proposed 58.8¢/kWh price and demanded that the OPA grandfather the 80.2¢/kWh price for those applications already filed. In August 2010, the OPA issued a more modest price cut of about

20%—to 64.2¢/kWh instead of 58.8¢/kWh—and agreed to pay 80.2¢/kWh for all applications received by the OPA up to then, including those still awaiting approval.

“The OPA applied the price cut only to new applications in order to ensure price and policy stability and prevent any potential lawsuits. We also noted that the price cut had limited impact because it was not done in a timely way. Specifically:

• The OPA had proposed since February 2010 that immediate action be taken to reduce the FIT price for ground-mounted solar projects. The OPA informed us that the price cut was not announced until July 2010, five months later, because the government needed time to analyze the situation. Due to this delay, the OPA received more than 11,000 applications from February to June 2010, all of which qualified for the full price rather than the reduced one because of the decision to grandfather the price in order to maintain investor confidence”. (105)

QUESTION: Is this an example of developers making energy policy in the absence of OPA’s ability to ensure that contracted prices are cost-effective and reflect current market costs?

“In addition, we noted that the revised price of 58.8¢/kWh originally proposed by the

OPA would have provided developers with an 11% after-tax return on equity intended for all renewable energy projects. However, the revised price went from 58.8¢/kWh to 64.2¢/kWh without adequate documentation to support how the OPA arrived at the higher price. The OPA indicated that 64.2¢/kWh was a reasonable price based on justifications provided by developers and other stakeholders. We estimated that, had the OPA been successful in making the price cut to 58.8¢/kWh when it was initially recommended, electricity ratepayers would have saved about $950 million over the

20-year contract terms, while developers would still have received their 11% after-tax return”. (105)

QUESTION: Why did the Minister defer to developers and other stakeholders demanding more than a generous and reasonable 11% after-tax return which would have saved electricity ratepayers $950 million?

“• The initial FIT prices proposed by the OPA in March 2009, prior to the passage of the Green Energy and Green Economy Act, included an automatic 9% drop in the contract price for every 100 MW of power contracted from ground-mounted solar projects. However, the OPA informed us that the Minister removed this adjustment, fearing that it would discourage manufacturing investments and hamper the development of renewable energy. We estimated that if this adjustment had been implemented as first proposed, the cost of the FIT program could have been reduced by about $2.6 billion over the 20-year contract terms”. (106)

QUESTION: Can the Minister explain why he felt electricity ratepayers could afford to pay an extra $2.6 billion given the already deteriorating economic climate?

“• The absence of caps or limits to the number of contracts signed under Ontario’s

FIT program led to the current oversubscription. The OPA informed us that it

designed the FIT program at a time when no long-term energy plan was in place and

it was unsure about the quantities”. (106)

QUESTION: Is there a long-term energy plan now?

“One of the top-priority issues identified by the OPA was the significant reduction in

the cost of solar technologies—about 50% since 2009—as the technology matured

and improved. The OPA specifically recommended reducing FIT prices for solar

projects to reflect current market conditions and introducing a plan to signal further

price reductions in future. However, the OPA informed us that no decision had been

forthcoming regarding its concern about the very generous prices being offered to

investors in renewable energy projects”. (107)

QUESTION: Why has the Ministry failed to take into account the fact that the cost of solar technologies has been reduced by 50% since 2009 even though the OPA has expressed concerns about the very generous terms being offered to investors in renewable energy projects?

20. If the IESO instructs wind generators to shut down under a surplus-power situation, the generators still get paid

“Reducing renewable power can be an efficient way to reduce supply. Wind

generators can be brought on-line or off-line quickly—an ideal characteristic to

address surpluses. Although this helps to address the degree to which the electricity

system is overloaded, it may not result in cost savings because if the IESO instructs

wind generators to shut down under a surplus-power situation, the generators still

get paid under the FIT program”. (113)

“According to the OPA, a new IPSP will assess the operational challenges of surplus

power and backup requirements. At the time of our audit, the new IPSP was still

under development”. (114)

QUESTION: Will the Ministry be deleting this provision in its review of the FIT contracts in order to save electricity ratepayers well over $225 million a year? (See below)

21. There has been inadequate assessment of the potential costs of curtailing renewable energy

“A situation called curtailment occurs when the Independent Electricity System

Operator (IESO) instructs generators to reduce all or part of their output in order to

mitigate an oversupply of electricity. Compared to other renewable energy contracts

such as RES and RESOP, the FIT contract has a unique feature that offers renewable

energy generators an “Additional Contract Payment” to compensate them for any

revenue lost as a result of curtailment instruction. Accordingly, electricity ratepayers

still have to pay renewable energy developers even when those generators are not

producing electricity during periods of curtailment”. (107)

“The IESO has not yet curtailed renewable energy generators under the FIT program

because no FIT projects have been on-line, and therefore no “Additional Contract

Payment” has been triggered or included in electricity bills to date. However, the

OPA and the IESO acknowledged that when more renewable energy projects under

the FIT program are added to the grid, the power surplus will grow and such

curtailments will be likely (see “Operational Challenge: Surplus Power” later in this

report)”. (107)

“There has been inadequate assessment of the potential costs of curtailing renewable

energy, even though there is a strong likelihood of curtailment in the future for these

energy sources. For example, the OPA has performed several scenario analyses, but

none included the impact of curtailing renewable energy. The OPA indicated that its

plans are based on situations where supply equals demand, but not where there are

surpluses and where the curtailment of renewable energy may be required”. (107)

QUESTION: Why have the costs of curtailment not been estimated in the cost of renewable energy? Why have electricity consumers been burdened with this unique feature of the FIT contract?

22. Adding more renewable energy would result in curtailment cost of paying renewable generators for not producing electricity from $150 million to $225 million a year

“The OPA also noted that the calculation of curtailment costs depends on a number

of factors and assumptions that could be very volatile. The only analysis on

curtailment we found was done by the IESO in 2009. It estimated that the

substantial addition of renewable energy would result in curtailment of between

2,000 and 2,500 hours per year and that the cost of paying renewable generators for

not producing electricity could range from $150 million to $225 million a year.

However, these projections were based on 2008 data and we were advised that no

updated projections had been done since then”. (107)

QUESTION: Since this estimate refers to an excess of only 666MW, and in reality the excess will be well over that, when can we expect updated projections?

23. The lack of correlation between electricity demand and intermittent renewable energy has created operational challenges, including power surpluses and the need for backup power

“We analyzed the performance of all wind farms in Ontario in 2010 based on IESO

data. Although the average capacity factor of wind throughout the year was 28%, it

fluctuated seasonally, from 17% in the summer to 32% in the winter. It also fluctuated daily, from 0% on summer days, when electricity demand was high, to

94% on winter days, when demand was lower”. (111)

“Our analysis also indicated that wind output was out of phase with electricity demand during certain times of day. For example, during the morning hours, around

6:00 a.m., wind output usually decreased just as demand was ramping up.

Throughout the day, demand remained high but wind output typically dropped to its lowest level for the day. During the evening hours, around 8:00 p.m., when demand was ramping down, wind output was rising, and it remained high overnight until early morning. This somewhat inverse relationship between daily average wind output and daily average demand was particularly pronounced in the summer and winter months”. (111)

“The OPA has recognized that the lack of correlation between electricity demand and intermittent renewable energy has created operational challenges, including power surpluses and the need for backup power generated from other energy sources. The

IESO has been working through its Renewable Integration Project to mitigate these challenges by engaging stakeholders and establishing technical working groups to discuss design principles, forecasting, and future markets for renewable energy”.

(111)

QUESTION: Figure 10, on page 111 of the Auditor General’s report indicates that the OPA and IESO show that wind has a "capacity contribution" of only 11% during system peak, and actual experience shows it is often well less than that, as low as 0 MW from all Ontario wind generators during system peak some days. At what point does this lack of correlation between availability and demand make wind energy economically unviable? Is it not imprudent to carry on adding wind energy to the grid before such analysis has been completed?

24. Surplus base load generation caused by renewable energy will add more costs for electricity ratepayers

“The IESO informed us that increasing the proportion of renewable energy in the

supply mix has exacerbated a challenge called surplus base-load generation (SBG), a

power oversupply that occurs when the quantity of electricity from base-load

generators is greater than demand for electricity. Base-load generators are designed

to run at a steady output 24 hours a day to meet the constant need or minimum

demand for electricity. Ontario’s base-load fleet includes nuclear units, certain hydro

stations, and intermittent renewable energy sources such as wind. The IESO

informed us that Ontario did not have any SBG days from 2005 to 2007, but

experienced four such days in 2008, 115 days in 2009, and 55 days in 2010. The jump

in SBG days was attributed to several factors, including an increase in wind power

and a drop in electricity demand”. (111-112)

“Given that electricity demand is expected to remain relatively flat for at least the

next few years as more renewable energy comes on-line, there will almost certainly

be more SBG days in the years to come, creating operational challenges and costs

that will ultimately be borne by electricity ratepayers”. (112)

QUESTION: How many surplus base-load days were experienced in 2011?

25. In 2010, 86% of wind power was produced on days when Ontario was already in a net export position.

“In 2008, the IESO forecast that, because most generators cannot ramp wind power

up or down in response to demand, SBG hours will increase significantly over the

next decade. The vast majority of new renewable energy in the next few years is

expected to come from wind generators, which typically have their highest output

overnight and early morning, when SBG events are more prevalent.

Since the prevalence of SBG events could threaten the reliability of the electricity

system, the IESO has been taking action to ease the power surplus. However, there

are technical difficulties and cost implications of these actions. Among them:

• Storing surplus power is difficult because of the seasonal nature of renewable

energy and the need for unrealistically large storage capacity.

• Exporting surplus power is, according to the OPA and the IESO, a common and

preferred way to mitigate power surpluses. Since 2006, Ontario has been a net

exporter. The IESO indicated that although it is difficult to quantify, the increase in

renewable energy has led to an increase in exports and put downward pressure on

export prices. We noted that:

• In 2010, 86% of wind power was produced on days when Ontario was already in a

net export position”. (112)

QUESTION: If in 2010 only 14% of the wind energy that was produced was available when it was needed, why were electricity ratepayers burdened with the obligation to pay for production of wind energy so that it can be exported at below cost and sometimes it actually costs to export it? (See below)

QUESTION: What percent of wind energy was produced in 2011 when Ontario was already in a net export position?

26. Export customers paid only about 3¢/kWh to 4¢/kWh for Ontario power; electricity ratepayers of Ontario paid more than 8¢/kWh for this power to be generated

“The price Ontarians pay for electricity and the price Ontario charges its export

customers—which are determined by the interaction of supply and demand in the

electricity market—have in recent years been moving in opposite directions.

Although export customers paid only about 3¢/kWh to 4¢/kWh for Ontario power,

electricity ratepayers of Ontario paid more than 8¢/kWh for this power to be gener-

ated. . . .” (112)

27. From 2005 to the end of our audit in 2011, Ontario received $1.8 billion less for its electricity exports than what it actually cost electricity ratepayers of Ontario

“• Based on our analysis of net exports and pricing data from the IESO, we estimated

that from 2005 to the end of our audit in 2011, Ontario received $1.8 billion less for

its electricity exports than what it actually cost electricity ratepayers of Ontario”.

(112)

QUESTION: What actually did it cost us considering that sometimes we had to pay to export electricity?

“• A study in September 2009 also noted that Denmark, which relies heavily on wind

power, has been faced with a similar situation and exported large amounts of surplus

power to Norway and Sweden in order to balance domestic supply with demand”.

(112)

QUESTION: The government was warned of the situation in Denmark where electricity consumers end up subsidizing the electricity exported to adjacent jurisdictions in the CEPOS Report (see below) which was brought to the Minister’s attention in 2009. Is it the government’s policy to subsidize American energy consumers at the cost of Ontario residents?

QUESTION: Although government ministers have claimed that export and import rates balance out, the Auditor General’s observation that supply and demand in the electricity market have in recent years been moving in opposite directions, appears to contradict these claims. Will the Ministry be investigating this issue and when will a realistic cost accounting be available to the public?

“• Reducing hydro power can be done by diverting, or spilling, water from hydro gen-

erators. The IESO informed us that although the magnitude and timing of spill

activities have not been well documented, Ontario spilled water to reduce electricity

supply on 96 days in 2009 and 10 days in 2010. Because the overall cost to produce

hydro power is often lower than that of all other types of power, reducing hydro

power to “make room” for wind and solar power is an expensive mitigation strategy

to reduce surplus power, particularly as hydro, wind, and solar power are all

considered renewable energy sources”. (112-113)

QUESTION: What is the magnitude of the spill activities in 2011? When will this information be available to the public?

28. The IESO requested that nuclear generators shut down or reduce electricity supply 205 times in 2009 and 13 times in 2010

“Reducing nuclear power is viewed as a last resort because nuclear units are designed

to run constantly and produce at maximum capacity. Ramping nuclear units up and

down involves significant costs and can lead to equipment damage. If a nuclear unit

is shut down, it typically takes 48 to 72 hours to restart it. With nuclear energy

accounting for the majority of Ontario’s electricity, such downtime is risky and costly.

The IESO requested that nuclear generators shut down or reduce electricity supply

205 times in 2009 and 13 times in 2010”. (113)

QUESTION: How many times were nuclear reactors shut down in 2011?

QUESTION: Why is government policy jeopardizing the reliability and efficiency of our nuclear fleet when wind production could easily be terminated?

29. Recommendation 5: Assess the operational challenges and the feasibility of adding more intermittent renewable energy into the system

“RECOMMENDATION 5

“To ensure that the stability and reliability of Ontario’s electricity system is not

significantly affected by the substantial increase in renewable energy generation over

the next few years, the Ontario Power Authority should continue to work with the

Independent Electricity System Operator to assess the operational challenges and the

feasibility of adding more intermittent renewable energy into the system, and advise

the government to adjust the supply mix and energy plan accordingly”. (114)

QUESTION: When can the public expect to see an accurate assessment of this issue?

Socio-economic Impacts

“The Green Energy and Green Economy Act, 2009 (Act) was intended to support

new investment and economic growth in Ontario through the creation of a strong

and viable renewable energy sector”. (117)

“The Ministry said the Act is expected to support over 50,000 direct and indirect jobs

over three years in transmission and distribution upgrades, renewable energy, and

conservation. We questioned whether the job projection information was presented

as transparently as possible”. (117)

30. Promised “green” jobs have not been produced and existing jobs may be lost because of higher electricity prices

“Recent public announcements stated that the Green Energy and Green Economy

Act, 2009 was expected to support over 50,000 jobs, about 40,000 of which would

be related to renewable energy. However, about 30,000, or 75%, of these jobs were

expected to be construction jobs lasting only from one to three years. We also noted

that studies in other jurisdictions have shown that for each job created through

renewable energy programs, about two to four jobs are often lost in other sectors of

the economy because of higher electricity prices”. (91)

31. A majority of the jobs will be temporary

“We questioned whether the job projection information was presented as

transparently as possible. For example:

• A majority of the jobs will be temporary. The Ministry projected that of the 50,000

jobs, about 40,000 would be related to renewable energy. Our review of this

projection suggests that 30,000, or 75%, of these jobs would be construction jobs and

would last only from one to three years, while the remaining 10,000 would be long-

term jobs in manufacturing, operations, maintenance, and engineering. However, the

high proportion of short-term jobs was not apparent from the Ministry’s public

announcement”. (117)

32. Analysis should consider both job-creation and job-loss impacts, and experiences of other jurisdictions with similar renewable energy initiatives

“• The 50,000-job projection included new jobs but not those jobs that would be lost

as a result of promoting renewable energy. Experience in other jurisdictions suggests

that jobs created in the renewable energy sector are often offset by jobs lost as a

result of the impact of higher renewable energy electricity prices on business,

industry, and consumers. . . . In addition, the closure of Ontario’s coal-fired plants

by the end of 2014 will lead to job losses, but these were not factored into the

Ministry’s job projections. Ontario Power Generation, which operates the coal-fired

plants, informed us that the extent of job losses depended on the Ministry’s plan:

about 2,300 jobs would be lost if the Ministry closed all coal-fired plants, but 600 of

these could be saved if certain coal-fired plants are converted to biomass or gas-fired

operation”. (117-118)

“In particular, Ontario’s FIT program was modeled on the FIT programs in Germany and Spain, and their job-related experiences could well be relevant to Ontario. For example, we noted the following studies conducted over the past three years:”

“• A 2009 study conducted in Germany noted that job projections in the renewable energy sector conveyed impressive prospects of gross job growth but omitted such offsetting impacts as jobs lost in other energy sectors and the drain on economic activity caused by higher electricity prices. The study found that the cost of creating renewable-energy-related jobs was up to US$240,000 per job per year, far exceeding average wages in other sectors”. (118)

“• A 2009 study conducted in Spain found that for each job created through renewable energy programs, about two jobs were lost in other sectors of the economy”. (118)

“• A 2009 study conducted in Denmark noted that a job created in the renewable sector does not amount to a new job but, rather, usually comes at the expense of a job lost in another sector. The study also found that each job created under renewable energy policies cost between US$90,000 and US$140,000 per year in public subsidies—or about 175% to 250% of the average wage paid to manufacturing workers in Denmark”. (118)

“• A 2011 study conducted in the United Kingdom (after the FIT program was launched in Ontario) reported that about four jobs were lost elsewhere in the economy for every one new job in the renewable energy sector, primarily because of higher electricity prices”. (118)

“In November 2010, similar concerns were raised about the Ontario job projections in a report by the Task Force on Competitiveness, Productivity and Economic

Progress of the Rotman School of Management at the University of Toronto. The report noted that it is unclear what the jobs estimate includes, because it has offered neither a definition of green jobs nor a transparent calculation of how the 50,000 figure was arrived at. The report also said that it is unclear whether the 50,000

estimate is a gross or net number of jobs. The report further noted that even if

50,000 new jobs were created, the higher energy costs attributable to renewable

energy might result in job losses elsewhere in the economy, particularly in industries

that use large quantities of energy. Another recent study in Canada estimated that

each new job to be created as a result of renewable energy programs would cost

$179,000 per year”. (118)

“RECOMMENDATION 7: To ensure that the provincially reported estimate of jobs

created through the implementation of the renewable energy strategy is as objective

and transparent as possible, the analysis should give adequate consideration to both

job-creation and job-loss impacts, as well as job-related experiences of other

jurisdictions that have implemented similar renewable energy initiatives”. (118)

QUESTION: When can the public expect some transparency and objectivity in ministerial announcements on this subject?

Environmental Concerns

33. Estimated reduction in greenhouse gases did not take into account the continuing need to run fossil-fuel backup

“The Ministry indicated that renewable energy will help reduce greenhouse gases by

displacing gas-fired generation. However, as noted earlier, any significant increase in

intermittent renewable energy requires backup power by either coal- or gas-fired

plants because wind and solar power have relatively low reliability and capacity. In

Ontario’s case, because coal-fired plants are being phased out by the end of 2014, this

backup will need to come from gas-fired plants. Although gas-fired plants emit fewer

greenhouse gases than coal-fired plants, they still contribute to greenhouse gas

emissions. Our review of experiences in other jurisdictions showed that the original estimated reduction in greenhouse gases had not been reduced to take into account the continuing need to run fossil-fuel backup power-generating facilities. For instance:

• A 2008 study in the United Kingdom found that power swings from intermittent wind generation need to be compensated for by natural-gas generation, which has meant less of a reduction in greenhouse gases than originally expected.

• A 2009 study in Denmark noted that although the country is the world’s biggest user of wind energy, it has had to keep its coal-fired plants running to maintain system stability.9

• The German government also had to build new coal-fired plants and refurbish old ones to cover electricity requirements that could not be met through intermittent wind generation”. (119) 10

9 In September 2009, “Wind Energy, the case of Denmark” was published by the Danish Center for Politiske Studier (CEPOS). The report warned: “The very fact that the wind power system, that has been imposed so expensively upon the consumers, cannot and does not achieve the simple objectives for which it was built, should be warning to the energy establishment, at all levels, of the considerable gap between aspiration and reality”.

10 The October 2009 report of the Rhine-Westphalia Institute for Economic Research (one of Germany’s leading economic research institutions), analyzed the German renewable energy technology promotion experience. The report concluded: “Although Germany’s promotion of renewable energy is commonly portrayed in the media as setting ‘a shining example’, we would instead regard the country’s experience as a cautionary tale of massively expensive environmental and energy policy that is devoid of economic and environmental benefits”. “Wind turbines and solar panels have produced no environmental benefit in Germany

in terms of lowering of CO2 emissions that would not have been produced by other plans already in effect. Frondel, Dr. Manuel; Ritter, Nolan; Vance, Prof. Colin, Ph.D., Scheffer, Fabian; & Schmidt, Prof. Christoph. Economic impacts from the promotion of renewable energies: The German experience. Final Report. Rheinisch-Westfälisches Institut für Wirtschaft sforschung (Rhine-Westphalia Institute for Economic Research) October 2009. http://www.instituteforenergyresearch.org/germany/Germany_Study_-_FINAL.pdf

“The Ministry has not yet quantified how much backup power will be required from

other energy sources to compensate for the intermittent nature of renewable energy,

and accordingly has no data on the impact of gas-fired backup power plants on

greenhouse gas emissions”. (119)

Health Concerns

34. CMOH report questioned

“In recent years, there have been growing public-health concerns about wind

turbines, particularly with regard to the noise experienced by people living near wind

farms. In May 2010, Ontario’s Chief Medical Officer of Health issued a report

concluding that available scientific evidence to date did not demonstrate a direct

causal link between wind turbine noise and adverse health effects. However, the

report was questioned by environmental groups, physicians, engineers, and other

professionals, who noted that it was merely a literature review that presented no

original research and did not reflect the situation in Ontario. We also noted that only

a limited number of renewable generators were in operation in Ontario when the

report was prepared in spring 2010, a few months after the launch of the FIT

program”. (119-120)

35. Academic research chair has produced no report

“One of the provisions of the Act was the establishment of an academic research chair

to examine the potential effects of renewable energy generators on public health. In

February 2010, an engineering professor from the University of Waterloo was

appointed to this position but, as of July 2011, there had been no report on the

results of any research conducted to date”. (120)

QUESTION: When can we expect a report from the academic research chair?

QUESTION: What are the qualifications of an engineering professor specializing in solar energy to assess medical problems?

36. Ministry of Energy should measure impact of backup facilities and provide objective research on potential health effects of wind power

“RECOMMENDATION 8

“To ensure that renewable energy initiatives are effective in protecting the

environment while having minimal adverse health effects on individuals, the

Ministry of Energy should:

• develop adequate procedures for tracking and measuring the effectiveness of

renewable energy initiatives, including the impact of backup generating facilities, in

reducing greenhouse gases; and

• provide the public with the results of objective research on the potential health

effects of renewable wind power”. (120)

QUESTION: Does the government’s failure to act on the issues detailed in the Auditor General’s report necessitate a full public enquiry?

Industrial Wind Turbines and Health: Wind Turbines Can Harm Humans if too close to Residents1

A summary of some of the peer reviewed articles and conference papers, abstracts and citations, regarding impairment of health and wind turbines2

Compiled by Carmen Krogh, BScPharm April, 2012 3 ______Wind Turbine Acoustic Investigation: Infrasound and Low-Frequency Noise A Case Study Stephen E. Ambrose, Robert W. Rand and Carmen M. E. Krogh DOI: 10.1177/0270467612455734 Bulletin of Science Technology & Society published online 17 August 2012 http://bst.sagepub.com/content/early/2012/07/30/0270467612455734

Bio: Robert W. Rand has more than 30 years of experience in industrial noise control, environmental sound and general acoustics. A Member INCE since 1993, he runs a small business providing consulting, investigator, and design services in acoustics.

Bio: Carmen M. E. Krogh, BScPharm, provided research and reference support. She is a retired pharmacist with more than 40 years of experience in health. She has held senior executive positions at a major teaching hospital, a professional association, and Health Canada. She was former Director of Publications and Editor-in-Chief of the Compendium of Pharmaceutical and Specialties (CPS), the book used in Canada by physicians, nurses, and other health professions for prescribing information on medication.

Abstract Wind turbines produce sound that is capable of disturbing local residents and is reported to cause annoyance, sleep disturbance, and other health-related impacts. An acoustical study was conducted to investigate the presence of infrasonic and low-frequency noise emissions

1 Excerpted from Case Nos.: 10-121/10-122 Erickson v. Director, Ministry of the Env ironment Environmental Review Tribunal, Decision, p 207 “This case has successfully shown that the debate should not be simplified to one about whether wind turbines can cause harm to hu mans. The evidence presented to the Tribunal de monstrates that they can, if facilities are placed too close to residents. The debate has now evolved to one of degree.” 2 This summary focuses on published literature 2010 to March 2013 associated with risks to health. References are not intended to be exhaustive. 3 Any errors or omissions are unintended

1 from wind turbines located in Falmouth, Massachusetts, USA. During the study, the investigating acousticians experienced adverse health effects consistent with those reported by some Falmouth residents. The authors conclude that wind turbine acoustic energy was found to be greater than or uniquely distinguishable from the ambient background levels and capable of exceeding human detection thresholds. The authors emphasize the need for epidemiological and laboratory research by health professionals and acousticians concerned with public health and well-being to develop effective and precautionary setback distances for industrial wind turbines that protect residents from wind turbine sound. ______Falmouth, Massachusetts wind turbine infrasound and low frequency noise measurements Stephen E. Ambrose, Robert W. Rand and Carmen M. E. Krogh Invited paper presented at Inter-noise 2012m New York City, NY

Bio: Stephen E. Ambrose has more than 35 years of experience in industrial noise control. Board Certified and Member INCE since 1978, he runs a small business providing cost- effective environmental noise consulting services for industrial and commercial businesses, municipal and state governments, and private citizens. Bio: Robert W. Rand has more than 30 years of experience in industrial noise control, environmental sound and general acoustics. A Member INCE since 1993, he runs a small business providing consulting, investigator, and design services in acoustics.

Abstract Falmouth, Massachusetts has experienced non-predicted adverse acoustic and health impacts from an industrial wind turbine (IWT) sited close to neighbors. The public response from this quiet rural area has been very vocal for a majority of homeowners living within 3000-ft. Complaints have ranged from the unexpectedly loud with constant fluctuations and the non- audible pressure fluctuations causing a real loss of public health and well-being. Early research indicates that both the IHC and OHC functions of the ear receive stimulation during moderate to strong wind speeds. This research presents a challenge to noise control and health professionals to determine the causal factors for the adverse public health impacts. This case study will present sound level and analyzed measurement data obtained while living in a house 1700-ft from an operating IWT during moderate to strong hub height wind speeds. There was a strong correlation with wind speed, power output and health symptoms.

2 ______Sleep disturbances and suicide risk: A review of the literature. Rebecca A Bernert and Thomas E Joiner Neuropsychiatr Dis Treat. 2007 December; 3(6): 735–743. PMCID: PMC2656315 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2656315/

Acknowledgments This work was supported, in part, by a grant from the National Institute of Mental Health to Rebecca A Bernert and Thomas Joiner (1 F31 MH080470-01) and by the John Simon Guggenheim Foundation.

Abstract A growing body of research indicates that sleep disturbances are associated with suicidal ideation and behaviors. This article provides a critical review of the extant literature on sleep and suicidality and addresses shared underlying neurobiological factors, biological and social zeitgebers, treatment implications, and future directions for research. Findings indicate that suicidal ideation and behaviors are closely associated with sleep complaints, and in some cases, this association exists above and beyond depression. Several cross-sectional investigations indicate a unique association between nightmares and suicidal ideation, whereas the relationship between insomnia and suicidality requires further study. Underlying neurobiological factors may, in part, account for the relationship between sleep and suicide. Serotonergic neurotransmission appears to play a critical role in both sleep and suicide. Finally, it remains unclear whether or not sleep-oriented interventions may reduce risk for suicidal behaviors. Unlike other suicide risk factors, sleep complaints may be particularly amenable to treatment. As a warning sign, disturbances in sleep may thus be especially useful to research and may serve as an important clinical target for future suicide intervention efforts. ______Relevance and applicability of the Soundscape concept to physiological or behavioural effects caused by noise at very low frequencies which may not be audible Bray, Wade, Acoustical Society of America 164th Meeting, Kansas City, MO 22‐26 October, 2012, 2aNS6

Abstract: A central tenet of the Soundscape concept is that humans immersed in sonic environments are objective measuring instruments (New Experts), whose reports and descriptions must be taken seriously and quantified by technical measurements. A topic category in acoustics meetings of recent years is “Perception and Effects of Noise.” There is growing evidence from the field, and from medical research, that the ear’s two‐part transducer activity involving inner hair cells (IHC, hearing, velocity sensitive) and outer hair cells (OHC, displacement‐sensitive) may, through demonstrated OHC activation and neural signals at up to 40 dB below the audibility threshold, produce behavioral and physiological effects as reported by a growing number of people. The Soundscape concept centering on human responses, New Experts, is as important and applicable to responses to effects from sound

3 as it is to responses to directly audible sound. In a wider sense, this is a new sound quality and psychoacoustic issue. ______The Noise from Wind Turbines: Potential Adverse Impacts on Children's Well-Being Arline L. Bronzaft Bulletin of Science Technology & Society 2011 31: 256, DOI: 10.1177/0270467611412548. http://bst.sagepub.com/content/31/4/291

Bio: Dr. Arline L. Bronzaft is a Professor Emerita of Lehman College, City University of New York. She serves on the Mayor’s GrowNYC, having been named to this organization by three previous Mayors as well. Dr. Bronzaft is the author of landmark research on the effects of elevated train noise on children’s classroom learning; has examined the impacts of airport- related noise on quality of life; and has published articles on noise in environmental books, academic journals and the more popular press. In 2007, she assisted in the updating of the New York City Noise Code.

Abstract Research linking loud sounds to hearing loss in youngsters is now widespread, resulting in the issuance of warnings to protect children’s hearing. However, studies attesting to the adverse effects of intrusive sounds and noise on children’s overall mental and physical health and well-being have not received similar attention. This, despite the fact that many studies have demonstrated that intrusive noises such as those from passing road traffic, nearby rail systems, and overhead aircraft can adversely affect children’s cardiovascular system, memory, language development, and learning acquisition. While some schools in the United States have received funds to abate intrusive aircraft noise, for example, many schools still expose children to noises from passing traffic and overhead aircraft. Discussion focuses on the harmful effects of noise on children, what has to be done to remedy the situation, and the need for action to lessen the impacts of noise from all sources. Furthermore, based on our knowledge of the harmful effects of noise on children’s health and the growing body of evidence to suggest the potential harmful effects of industrial wind turbine noise, it is strongly urged that further studies be conducted on the impacts of industrial wind turbines on their health, as well as the health of their parents, before forging ahead in siting industrial wind turbines. ______Wind turbine syndrome: fact or fiction? Review Article A Farboud, R Crunkhorn, A Trinidade The Journal of Laryngology & Otology, 1 of 5. ©JLO (1984) Limited, 2013 doi:10.1017/S0022215112002964

Abstract Objective: Symptoms, including tinnitus, ear pain and vertigo, have been reported following exposure to wind turbine noise. This review addresses the effects of infrasound and low frequency noise and questions the existence of ‘wind turbine syndrome’.

4 Design: This review is based on a search for articles published within the last 10 years, conducted using the PubMed database and Google Scholar search engine, which included in their title or abstract the terms ‘wind turbine’, ‘infrasound’ or ‘low frequency noise’. Results: There is evidence that infrasound has a physiological effect on the ear. Until this effect is fully understood, it is impossible to conclude that wind turbine noise does not cause any of the symptoms described. However, many believe that these symptoms are related largely to the stress caused by unwanted noise exposure. Conclusion: There is some evidence of symptoms in patients exposed to wind turbine noise. The effects of infrasound require further investigation. There is ample evidence of symptoms arising in individuals exposed to wind turbine noise. Some researchers maintain that the effects of wind turbine syndrome are clearly just examples of the well known stress effects of exposure to noise, as displayed by a small proportion of the population. However, there is an increasing body of evidence suggesting that infrasound and low frequency noise have physiological effects on the ear. Until these effects are fully understood, it is impossible to state conclusively that exposure to wind turbine noise does not cause any of the symptoms described. The effects of infrasound and low frequency noise require further investigation.

______Wind Turbine Noise John P. Harrison Bulletin of Science Technology & Society 2011 31: 256, DOI: 10.1177/0270467611412549 http://bst.sagepub.com/content/31/4/256

Bio: Dr. John P. Harrison has expertise in the properties of matter at low temperatures with emphasis on high frequency sound waves (phonons). For the past 5 years he has studied wind turbine noise and its regulation. He has presented invited talks on the subject at 3 conferences, including the 2008 World Wind Energy Conference.

Abstract Following an introduction to noise and noise regulation of wind turbines, the problem of adverse health effects of turbine noise is discussed. This is attributed to the characteristics of turbine noise and deficiencies in the regulation of this noise. Both onshore and offshore wind farms are discussed. ______Editorial: Wind turbine noise Christopher D Hanning and Alun Evans British Medical Journal, BM J2 012;344 doi: 10.1136/ bmj.e1527 (8 March 2012) www.bmj.com

Bio: Christopher Hanning, BSc, MB, BS, MRCS, LRCP, FRCA, MD is an honorary consultant in sleep medicine Sleep Disorders Service, University Hospitals of Leicester, Leicester General Hospital, Leicester, UK

5 Dr Chris Hanning is Honorary Consultant in Sleep Disorders Medicine to the University Hospitals of Leicester NHS Trust, UK. He retired in September 2007 as Consultant in Sleep Disorders Medicine.

After initial training in anaesthesia, he developed an interest in Sleep Medicine. He founded and ran the Leicester Sleep Disorders Service, one of the longest standing and largest services in the UK. He was a founder member and President of the British Sleep Society

His expertise in this field has been accepted by the civil, criminal and family courts. He chairs the Advisory panel of the SOMNIA study, a major project investigating sleep quality in the elderly, and sits on Advisory panels for several companies with interests in sleep medicine.

Bio: Alun Evans, is an epidemiologist, Centre for Public Health, Queen’s University of Belfast, Institute of Clinical Science B, Belfast, UK

Except from BMJ web site:

Seems to affect health adversely and an independent review of evidence is needed.

The evidence for adequate sleep as a prerequisite for human health, particularly child health, is overwhelming. Governments have recently paid much attention to the effects of environmental noise on sleep duration and quality, and to how to reduce such noise. However, governments have also imposed noise from industrial wind turbines on large swathes of peaceful countryside.

The impact of road, rail, and aircraft noise on sleep and daytime functioning (sleepiness and cognitive function) is well established. Shortly after wind turbines began to be erected close to housing, complaints emerged of adverse effects on health. Sleep disturbance was the main complaint. Such reports have been dismissed as being subjective and anecdotal, but experts contend that the quantity, consistency, and ubiquity of the complaints constitute epidemiological evidence of a strong link between wind turbine noise, ill health, and disruption of sleep.

The noise emitted by a typical onshore 2.5 MW wind turbine has two main components. A dynamo mounted on an 80 m tower is driven through a gear train by … ______Literature Reviews on Wind Turbines and Health : Are They Enough? Brett Horner, Roy D. Jeffery and Carmen M. E. Krogh Bulletin of Science Technology & Society 2011 31: 399. DOI: 10.1177/0270467611421849 http://bst.sagepub.com/content/31/5/399

6 Bio: Brett Horner, BA, is a certified management accountant and has held senior manager positions in international business consulting groups. He has provided information technology consulting and accounting/auditing services to a wide variety of clientele. He has dedicated over 2 years reviewing and analyzing references on the subject of industrial wind turbines and reported health effects.

Bio: Roy D. Jeffery, MD, is a rural family physician and a clinical preceptor for the University of Ottawa and the Northern Ontario Medical Schools. He practices rural medicine with special interests regarding geriatric home care and rural health. He has the distinction of being awarded the Ontario Family Physician of the Year–Northern Division in 2008.

Bio: Carmen M. E. Krogh, BSc Pharm, is a retired pharmacist with more than 40 years of experience in health. She has held senior executive positions at a major teaching hospital, a professional association, and Health Canada. She was a former director of Publications and editor-in-chief of the Compendium of Pharmaceutical and Specialties, the book used in Canada by physicians, nurses, and other health professions for prescribing information on medication.

Abstract Industrial wind turbines (IWTs) are a new source of community noise to which relatively few people have yet been exposed. IWTs are being erected at a rapid pace in proximity to human habitation. Some people report experiencing adverse health effects as a result of living in the environs of IWTs. In order to address public concerns and assess the plausibility of reported adverse health effects, a number of literature reviews have been commissioned by various organizations. This article explores some of the recent literature reviews on IWTs and adverse health effects. It considers the completeness, accuracy, and objectivity of their contents and conclusions. While some of the literature reviews provide a balanced assessment and draw reasonable scientific conclusions, others should not be relied on to make informed decisions. The article concludes that human health research is required to develop authoritative guidelines for the siting of IWTs in order to protect the health and welfare of exposed individuals. ______Wind Turbine Infra and Low-Frequency Sound: Warnings Signs That Were Not Heard Richard R James DOI: 10.1177/0270467611421845 Bulletin of Science Technology & Society published online 15 December 2011 http://bst.sagepub.com/content/early/2011/11/07/0270467611421845

Bio: Richard R. James, Institute of Noise Control Engineering, has been actively involved in the field of noise control since 1969, participating in and supervising research and engineering projects related to control of occupational and community noise. He has performed extensive acoustical testing and development work for a variety of complex environmental noise problems using both classical and computer simulation techniques. Since 2006, he has been involved with noise and health issues related to industrial wind turbines.

7 Abstract Industrial wind turbines are frequently thought of as benign. However, the literature is reporting adverse health effects associated with the implementation of industrial-scale wind developments. This article explores the historical evidence about what was known regarding infra and low-frequency sound from wind turbines and other noise sources during the period from the 1970s through the end of the 1990s. This exploration has been accomplished through references, personal interviews and communications, and other available documentation. The application of past knowledge could improve the current siting of industrial wind turbines and avoid potential risks to health. ______Wind Turbines Make Waves: Why Some Residents Near Wind Turbines Become Ill Magda Havas and David Colling Bulletin of Science Technology & Society 2011 31: 414. DOI: 0.1177/0270467611417852 http://bst.sagepub.com/content/31/5/369

Bio: Magda Havas, PhD, is an associate professor at Trent University where she teaches and conducts research on the biological and health effects of electromagnetic and chemical pollutants. She received her BSc and PhD at the University of Toronto and did postdoctoral research at Cornell University on acid rain and aluminum toxicity.

Bio: David Colling has applied his electrical engineering studies at Ryerson Polytechnical Institute and his specialized training in electrical pollution to conduct electrical pollution testing for Bio-Ag on farms, homes, and office buildings. Some of the homes tested are located in the environs of industrial wind turbines.

Abstract People who live near wind turbines complain of symptoms that include some combination of the following: difficulty sleeping, fatigue, depression, irritability, aggressiveness, cognitive dysfunction, chest pain/pressure, headaches, joint pain, skin irritations, nausea, dizziness, tinnitus, and stress. These symptoms have been attributed to the pressure (sound) waves that wind turbines generate in the form of noise and infrasound. However, wind turbines also generate electromagnetic waves in the form of poor power quality (dirty electricity) and ground current, and these can adversely affect those who are electrically hypersensitive. Indeed, the symptoms mentioned above are consistent with electrohypersensitivity. Sensitivity to both sound and electromagnetic waves differs among individuals and may explain why not everyone in the same home experiences similar effects. Ways to mitigate the adverse health effects of wind turbines are presented. ______Industrial Wind Turbine Development and Loss of Social Justice? Carmen M.E. Krogh Bulletin of Science Technology & Society 2011 31: 321, DOI: 10.1177/0270467611412550, http://bst.sagepub.com/content/31/4/321

8 Bio: Carmen M. E. Krogh, BScPharm is a retired pharmacist with more than 40 years of experience in health. She has held senior executive positions at a major teaching hospital, a professional association and Health Canada. She was a former Director of Publications and Editor-in-chief of the Compendium of Pharmaceutical and Specialties (CPS), the book used in Canada by physicians, nurses and other health professions for prescribing information on medication.

Abstract This article explores the loss of social justice reported by individuals living in the environs of industrial wind turbines (IWTs). References indicate that some individuals residing in proximity to IWT facilities experience adverse health effects. These adverse health effects are severe enough that some families have abandoned their homes. Individuals report they welcomed IWTs into their community and the negative consequences were unexpected. Expressions of grief are exacerbated by the emotional and physical toll of individuals’ symptoms, loss of enjoyment of homes and property, disturbed living conditions, financial loss, and the lack of society’s recognition of their situation. The author has investigated the reported loss of social justice through a review of literature, personal interviews with, and communications from, those reporting adverse health effects. The author’s intention is to create awareness that loss of social justice is being associated with IWT development. This loss of justice arises from a number of factors, including the lack of fair process, the loss of rights, and associated disempowerment. These societal themes require further investigation. Research by health professionals and social scientists is urgently needed to address the health and social impacts of IWTs operating near family homes. ______WindVOiCe, a Self-Reporting Survey: Adverse Health Effects, Industrial Wind Turbines, and the Need for Vigilance Monitoring Carmen M.E. Krogh, Lorrie Gillis, Nicholas Kouwen, and Jeffery Aramini Bulletin of Science Technology & Society 2011 31: 334, DOI: 10.1177/0270467611412551, http://bst.sagepub.com/content/31/4/334

Bio: Carmen M. E. Krogh, BScPharm is a retired pharmacist with more than 40 years of experience in health. She has held senior executive positions at a major teaching hospital, a professional association and Health Canada. She was a former Director of Publications and Editor-in-chief of the Compendium of Pharmaceutical and Specialties (CPS), the book used in Canada by physicians, nurses and other health professions for prescribing information on medication.

Bio: Ms Lorrie Gillis is the process administrator for the WindVOiCe health survey. Ms Gillis volunteers her time and ensures the processes for administering the protocols are maintained.

Bio: Dr. Nicholas Kouwen is a Distinguished Professor Emeritus in the Department of Civil and Environmental Engineering of the University of Waterloo, Waterloo, Ontario, Canada. He is a registered Professional Engineer (Ontario) and a Fellow of the American Society of

9 Civil Engineers. His field of expertise is in hydraulic and hydrological modelling and is currently involved in studies dealing with the impact of climate change on water availability.

Bio: Dr. Jeff Aramini is a public health epidemiologist with expertise in the investigation of health concerns using epidemiological principles. DVM and M.Sc. from the University of Saskatchewan; Ph.D. from the University of Guelph. Former senior epidemiologist with Health Canada/Public Health Agency of Canada. Currently, President and CEO of an organization that addresses public health, patient care, public safety and information management for clients in government, industry and academia.

Abstract Industrial wind turbines have been operating in many parts of the globe. Anecdotal reports of perceived adverse health effects relating to industrial wind turbines have been published in the media and on the Internet. Based on these reports, indications were that some residents perceived they were experiencing adverse health effects. The purpose of the WindVOiCe health survey was to provide vigilance monitoring for those wishing to report their perceived adverse health effects. This article discusses the results of a self reporting health survey regarding perceived adverse health effects associated with industrial wind turbines. ______Wind turbines can harm humans: a case study Carmen ME Krogh, Roy D Jeffery, Jeff Aramini, Brett Horner Paper presented at Inter-noise 2012, New York City, NY

Bio: Brett Horner, BA, is a certified management accountant and has held senior manager positions in international business consulting groups. He has provided information technology consulting and accounting/auditing services to a wide variety of clientele. He has

10 dedicated over 2 years reviewing and analyzing references on the subject of industrial wind turbines and reported health effects.

Abstract In Canada the Ontario Government has adopted wind energy as a renewable energy source. Our research in Ontario documents some individuals living in the environs of wind turbines report experiencing physiological and psychological symptoms, reduced quality of life, degraded living conditions, and adverse social economic impacts. Some families have abandoned their homes or negotiated financial agreements with wind energy developers. Wind turbine noise is a reported cause of these effects; however, some commentators suggest sound from wind turbines does not pose a risk of any adverse health effect in humans. These competing claims can confuse authorities responsible for establishing noise guidelines. An Ontario Environmental Review Tribunal considered a wide body of evidence including expert testimony and found wind turbines can harm humans if placed too close to residents. Risks must be understood to ensure guidelines protect human health. Evidence including peer reviewed literature, case reports, freedom of information documents and expert testimony will be presented which support the conclusion that wind turbines, if placed too close to residents, can harm human health. ______Wind turbine noise perception, pathways and effects: a case study Carmen ME Krogh, Roy D Jeffery, Jeff Aramini, Brett Horner Paper presented at Inter-noise 2012, New York City, NY

11 dedicated over 2 years reviewing and analyzing references on the subject of industrial wind turbines and reported health effects.

Abstract In Ontario Canada wind turbines are being sited close to humans. Wind turbine noise is perceived to be more annoying than other equally loud sources of sound. This annoyance can contribute to stress related health impacts. An Ontario government commissioned report concludes a nontrivial percentage of exposed persons will be impacted. Our research documents some Ontarians living in the environs of wind turbines report experiencing physiological and psychological symptoms, reduced quality of life, degraded living conditions, and adverse social economic impacts including a loss of social justice. In some cases the effects resulted in families abandoning their homes. Others have negotiated financial agreements with wind energy developers. An Ontario Environmental Tribunal considered a wide body of evidence including expert witness testimony and found that wind turbines can harm humans if placed too close to residents. Peer reviewed literature, case reports, freedom of information documents and expert testimony will be presented which support the conclusion that noise perception via the indirect pathway can result in serious negative effects. ______Annoyance can represent a serious degradation of health: wind turbine noise a case study Carmen ME Krogh, Roy D Jeffery, Jeff Aramini, Brett Horner Paper presented at Inter-noise 2012, New York City, NY

12 Bio: Brett Horner, BA, is a certified management accountant and has held senior manager positions in international business consulting groups. He has provided information technology consulting and accounting/auditing services to a wide variety of clientele. He has dedicated over 2 years reviewing and analyzing references on the subject of industrial wind turbines and reported health effects.

Abstract Annoyance is often discounted as a health concern. Wind turbine noise is perceived to be more annoying than other equally loud sources of sound. The Ontario government commissioned a report which concludes a non-trivial percentage those exposed to wind turbine sound will be highly annoyed which can be expected to contribute to stress related health impacts. Our research in Ontario, Canada documents some individuals living in the environs of wind turbines report experiencing physiological and psychological symptoms, reduced quality of life, degraded living conditions, and adverse social and economic impacts. Some families have abandoned their homes or negotiated financial agreements with wind energy developers. An Ontario Environmental Review Tribunal considered a wide body of evidence including expert testimony and found wind turbines can harm humans if placed too close to residents. Evidence including peer reviewed literature, case reports, freedom of information documents and expert testimony are presented which support the conclusion that annoyance can represent a serious degradation of health. ______Effects of insufficient sleep on circadian rhythmicity and expression amplitude of the human blood transcriptome Carla S. Möller-Levet, Simon N. Archer, Giselda Bucca, Emma E. Laing, Ana Slak, Renata Kabiljo, June C. Y. Lo, Nayantara Santhi, Malcolm von Schantz, Colin P. Smith, and Derk-Jan Dijk Published online before print February 25, 2013, doi:10.1073/pnas.1217154110 PNAS (Proceedings of the National Academy of Sciences) February 25, 2013 201217154 http://www.pnas.org/content/early/2013/02/20/1217154110

13 Abstract Insufficient sleep and circadian rhythm disruption are associated with negative health outcomes, including obesity, cardiovascular disease, and cognitive impairment, but the mechanisms involved remain largely unexplored. Twenty-six participants were exposed to 1 wk of insufficient sleep (sleep-restriction condition 5.70 h, SEM = 0.03 sleep per 24 h) and 1 wk of sufficient sleep (control condition 8.50 h sleep, SEM = 0.11). Immediately following each condition, 10 whole-blood RNA samples were collected from each participant, while controlling for the effects of light, activity, and food, during a period of total sleep eprivation. Transcriptome analysis revealed that 711 genes were up- or down-regulated by insufficient sleep. Insufficient sleep also reduced the number of genes with a circadian expression profile from 1,855 to 1,481, reduced the circadian amplitude of these genes, and led to an increase in the number of genes that responded to subsequent total sleep deprivation from 122 to 856. Genes affected by insufficient sleep were associated with circadian rhythms (PER1, PER2, PER3, CRY2, CLOCK, NR1D1, NR1D2, RORA, DEC1, CSNK1E), sleep homeostasis (IL6, STAT3, KCNV2, CAMK2D), oxidative stress (PRDX2, PRDX5), and metabolism (SLC2A3, SLC2A5, GHRL, ABCA1). Biological processes affected included chromatin modification, gene-expression regulation, macromolecular metabolism, and inflammatory, immune and stress responses. Thus, insufficient sleep affects the human blood transcriptome, disrupts its circadian regulation, and intensifies the effects of acute total sleep deprivation. The identified biological processes may be involved with the negative effects of sleep loss on health, and highlight the interrelatedness of sleep homeostasis, circadian rhythmicity, and metabolism. ______Low-frequency noise from large wind turbines Henrik Møller and Christian Sejer Pedersen Section of Acoustics, Aalborg University, Fredrik Bajers Vej 7-B5, DK-9220 Aalborg Ø, Denmark, Acoustical Society of America [DOI: 10.1121/1.3543957] J. Acoust. Soc. Am. 129 (6), June 2011 PACS number(s): 43.50.Rq, 43.28.Hr, 43.50.Cb, 43.50.Sr [ADP] Pages: 3727–3744

Abstract As wind turbines get larger, worries have emerged that the turbine noise would move down in frequency and that the low-frequency noise would cause annoyance for the neighbors. The noise emission from 48 wind turbines with nominal electric power up to 3.6 MW is analyzed and discussed. The relative amount of low-frequency noise is higher for large turbines (2.3– 3.6 MW) than for small turbines ( 2 MW), and the difference is statistically significant. The difference can also be expressed as a downward shift of the spectrum of approximately one- third of an octave. A further shift of similar size is suggested for future turbines in the 10- MW range. Due to the air absorption, the higher low-frequency content becomes even more pronounced, when sound pressure levels in relevant neighbor distances are considered. Even when A-weighted levels are considered, a substantial part of the noise is at low frequencies, and for several of the investigated large turbines, the one-third-octave band with the highest level is at or below 250 Hz. It is thus beyond any doubt that the low-frequency part of the spectrum plays an important role in the noise at the neighbors.

14 ______Toward a Case Definition of Adverse Health Effects in the Environs of Industrial Wind Turbines: Facilitating a Clinical Diagnosis Robert Y. McMurtry Bulletin of Science Technology & Society 2011 31: 316, DOI: 10.1177/0270467611415075, http://bst.sagepub.com/content/31/4/316

Bio: Dr. Robert Y. McMurtry is the former Dean of Medicine for the University of Western Ontario. He was a member of the Health Council of Canada for 3½ years and a member and special advisor to the Royal Commission under Roy Romanow on the future of health care in Canada. Dr. McMurtry was a visiting Cameron Chair to Health Canada for providing policy advice to the Minister and Deputy Minister of Health. He was the Founding and Associate Deputy Minister of Population & Public Health, Canada. Dr. McMurtry also sat on the National Steering Committee on Climate Change and Health Assessment. Presently Dr. McMurtry is Professor (Emeritus) of Surgery, University of Western Ontario.

Abstract Internationally, there are reports of adverse health effects (AHE) in the environs of industrial wind turbines (IWT). There was multidisciplinary confirmation of the key characteristics of the AHE at the first international symposium on AHE/IWT. The symptoms being reported are consistent internationally and are characterized by crossover findings or a predictable appearance of signs and symptoms present with exposure to IWT sound energy and amelioration when the exposure ceases. There is also a revealed preference of victims to seek restoration away from their homes. This article identifies the need to create a case definition to establish a clinical diagnosis. A case definition is proposed that identifies the sine qua non diagnostic criteria for a diagnosis of adverse health effects in the environs of industrial wind turbines. Possible, probable, and confirmed diagnoses are detailed. The goal is to foster the adoption of a common case definition that will facilitate future research efforts. ______Effects of industrial wind turbine noise on sleep and health Nissenbaum, Michael A., Aramini, Jeffery J., Hanning, Christopher D. Noise & Health, September-October 2012, Volume 14, p243 www.noiseandhealth.org

Bio: Dr. Michael A. Nissenbaum received his undergraduate education at McGill University in Montreal and completed medical school at the University of Toronto. He specialized in diagnostic imaging and completed his residency at McGill University. He received a Fellowship from the University of California. Currently, Dr. Nissenbaum is certified by the Royal College of Physicians of Canada, and American Board of Radiology. He is a radiologist at the Northern Maine Medical Center, Fort Kent, Maine. Previous positions include Junior Faculty at Harvard University and Associate Director of MRI at a major Harvard teaching hospital.

15 Bio: Dr. Jeff Aramini is a public health epidemiologist with expertise in the investigation of health concerns using epidemiological principles. DVM and M.Sc. from the University of Saskatchewan; Ph.D. from the University of Guelph. Former senior epidemiologist with Health Canada/Public Health Agency of Canada. Currently, President and CEO of an organization that addresses public health, patient care, public safety and information management for clients in government, industry and academia.

Bio: Dr Chris Hanning is Honorary Consultant in Sleep Disorders Medicine to the University Hospitals of Leicester NHS Trust, UK. He retired in September 2007 as Consultant in Sleep Disorders Medicine. After initial training in anaesthesia, he developed an interest in Sleep Medicine. He founded and ran the Leicester Sleep Disorders Service, one of the longest standing and largest services in the UK. He was a founder member and President of the British Sleep Society. His expertise in this field has been accepted by the civil, criminal and family courts. He chairs the Advisory panel of the SOMNIA study, a major project investigating sleep quality in the elderly, and sits on Advisory panels for several companies with interests in sleep medicine.

Abstract Industrial wind turbines (IWTs) are a new source of noise in previously quiet rural environments. Environmental noise is a public health concern, of which sleep disruption is a major factor. To compare sleep and general health outcomes between participants living close to IWTs and those living further away from them, participants living between 375 and 1400 m (n= 38) and 3.3 and 6.6 km (n = 41) from IWTs were enrolled in a stratified cross- sectional study involving two rural sites. Validated questionnaires were used to collect information on sleep quality (Pittsburgh Sleep Quality Index — PSQI), daytime sleepiness (Epworth Sleepiness Score — ESS), and general health (SF36v2), together with psychiatric disorders, attitude, and demographics. Descriptive and multivariate analyses were performed to investigate the effect of the main exposure variable of interest (distance to the nearest IWT) on various health outcome measures. Participants living within 1.4 km of an IWT had worse sleep, were sleepier during the day, and had worse SF36 Mental Component Scores compared to those living further than 1.4 km away. Significant dose-response relationships between PSQI, ESS, SF36 Mental Component Score, and log-distance to the nearest IWT were identified after controlling for gender, age, and household clustering. The adverse event reports of sleep disturbance and ill health by those living close to IWTs are supported. ______Properly Interpreting the Epidemiologic Evidence About the Health Effects of Industrial Wind Turbines on Nearby Residents Carl V. Phillips Bulletin of Science Technology & Society 2011 31: 303, DOI: 10.1177/0270467611412554, http://bst.sagepub.com/content/31/4/303

Bio: Dr. Carl V. Phillips is a consultant and author specializing in epidemiology, science- based policy making, and communicating scientific concepts to the public. He spent most of

16 his career as a professor of public health and now works in litigation support, scientific advising, and grant-supported research. He blogs at ep-ology.blogspot.com, which provides links to his other writings.

Abstract There is overwhelming evidence that wind turbines cause serious health problems in nearby residents, usually stress-disorder type diseases, at a nontrivial rate. The bulk of the evidence takes the form of thousands of adverse event reports. There is also a small amount of systematically gathered data. The adverse event reports provide compelling evidence of the seriousness of the problems and of causation in this case because of their volume, the ease of observing exposure and outcome incidence, and case-crossover data. Proponents of turbines have sought to deny these problems by making a collection of contradictory claims including that the evidence does not “count,” the outcomes are not “real” diseases, the outcomes are the victims’ own fault, and that acoustical models cannot explain why there are health problems so the problems must not exist. These claims appeared to have swayed many nonexpert observers, though they are easily debunked. Moreover, though the failure of models to explain the observed problems does not deny the problems, it does mean that we do not know what, other than kilometers of distance, could sufficiently mitigate the effects. There has been no policy analysis that justifies imposing these effects on local residents. The attempts to deny the evidence cannot be seen as honest scientific disagreement and represent either gross incompetence or intentional bias. ______Jerry Punch, Rick James and Dan Pabst Wind-Turbine Noise What Audiologists Should Know Audiology Today, July/August 2010

Authors: Jerry Punch, PhD, Richard James, BME and Dan Pabst, BS are with the Department of Communicative Sciences and Disorders, Michigan State University, East Lansing, Michigan, US

Conclusion Our purpose in this article has been to provide audiologists with a better understanding of the types of noise generated by wind turbines, some basic considerations underlying sound-level measurements of wind-turbine noise, and the adverse health effects on people who live near these turbines. In future years, we expect that audiologists will be called upon to make noise measurements in communities that have acquired wind turbines, or are considering them. Some of us, along with members of the medical profession, will be asked to provide legal testimony regarding our opinions on the effects of such noise on people. Many of us will likely see clinical patients who are experiencing some of the adverse health effects described in this article. As a professional community, audiologists should become involved not only in making these measurements to corroborate the complaints of residents living near wind-turbine projects but also in developing and shaping siting guidelines that minimize the potentially adverse health effects of the noise and vibration they generate. In these ways, we

17 can promote public health interests without opposing the use of wind turbines as a desirable and viable alternative energy source. ______Occupational Health and Industrial Wind Turbines: A Case Study Robert W. Rand, Stephen E. Ambrose, and Carmen M. E. Krogh Bulletin of Science Technology & Society 2011 31: 359DOI: 10.1177/0270467611417849 http://bst.sagepub.com/content/31/5/359

Bio: Robert W. Rand is a principal author with over 30 years of experience in industrial noise control, environmental sound, and general acoustics. A member of the Institute of Noise Control Engineering since 1993, he runs a small business providing consulting, investigator, and design services in acoustics.

Bio: Stephen E. Ambrose is a principal author with over 35 years of experience in industrial noise control. A member of the Institute of Noise Control Engineering since 1978, he runs a small business providing cost-effective environmental noise consulting services for industrial and commercial businesses, municipal and state governments, and private citizens.

Bio: Carmen M. E. Krogh, BScPharm, who provided health-related research and reference support, is a retired pharmacist with more than 40 years of experience in health. She has held senior executive positions at a major teaching hospital, a professional association, and Health Canada. She was a former Director of Publications and Editor in Chief of the Compendium of Pharmaceutical and Specialties (CPS), the book used in Canada by physicians, nurses, and other health professions for prescribing information on medication.

Abstract Industrial wind turbines (IWTs) are being installed at a fast pace globally. Researchers, medical practitioners, and media have reported adverse health effects resulting from living in the environs of IWTs. While there have been some anecdotal reports from technicians and other workers who work in the environs of IWTs, little is known about the occupational health sector. The purpose of this case study is to raise awareness about the potential for adverse health effects occurring among workers. The authors propose that there is a need for research regarding occupational worker exposure relating to IWTs. ______Responses of the ear to low frequency sounds, infrasound and wind turbines. Alec N. Salt and T.E. Hullar, Department of Otolaryngology, Washington University School of Medicine, St. Louis, MO, 63110, USA. Hearing Research 2010 Sep 1; 268(1-2):12-21. Epub 2010 Jun 16

Abstract Infrasonic sounds are generated internally in the body (by respiration, heartbeat, coughing, etc) and by external sources, such as air conditioning systems, inside vehicles, some industrial processes and, now becoming increasingly prevalent, wind turbines. It is widely assumed that infrasound presented at an amplitude below what is audible has no influence on the ear. In this review, we consider possible ways that low frequency sounds, at levels that

18 may or may not be heard, could influence the function of the ear. The inner ear has elaborate mechanisms to attenuate low frequency sound components before they are transmitted to the brain. The auditory portion of the ear, the cochlea, has two types of sensory cells, inner hair cells (IHC) and outer hair cells (OHC), of which the IHC are coupled to the afferent fibers that transmit "hearing" to the brain. The sensory stereocilia ("hairs") on the IHC are "fluid coupled" to mechanical stimuli, so their responses depend on stimulus velocity and their sensitivity decreases as sound frequency is lowered. In contrast, the OHC are directly coupled to mechanical stimuli, so their input remains greater than for IHC at low frequencies. At very low frequencies the OHC are stimulated by sounds at levels below those that are heard. Although the hair cells in other sensory structures such as the saccule may be tuned to infrasonic frequencies, auditory stimulus coupling to these structures is inefficient so that they are unlikely to be influenced by airborne infrasound. Structures that are involved in endolymph volume regulation are also known to be influenced by infrasound, but their sensitivity is also thought to be low. There are, however, abnormal states in which the ear becomes hypersensitive to infrasound. In most cases, the inner ear's responses to infrasound can be considered normal, but they could be associated with unfamiliar sensations or subtle changes in physiology. This raises the possibility that exposure to the infrasound component of wind turbine noise could influence the physiology of the ear. ______Responses of the Inner Ear to Infrasound Alec N. Salt and Jeffery T. Lichtenhan Fourth International Meeting on Wind Turbine Noise Rome, Italy, 12-14 April 2011

Bio: Alec N. Salt received his PhD from the University of Birmingham, UK, in 1977 and has been actively involved in research into the physiology of the ear for over 35 years.

Bio: Dr. Lichtenhan is from the Eaton-Peabody Laboratory, Massachusetts Eye & Ear Infirmary, Boston Massachusetts and the Department of Otology & Laryngology, Harvard Medical School, Boston, Massachusetts.

Abstract: Unweighted sound measurements show that wind turbines generate high levels of infrasound. It has been wrongly assumed that if subjects cannot hear the infrasound component of the noise then they cannot be affected by it. On the contrary, the mammalian ear is highly sensitive to infrasound stimulation at levels below those that are heard. Most aspects of responses to infrasound are far from well established. Measurements made within the endolymphatic system of the cochlea show responses that become larger, relative to measurements made in perilymph, as frequency is lowered. This suggests that endolymphatic responses to infrasound are enhances in some manner. For high-frequency sound, acoustic stimuli in the ear are summed. In contrast, the inner ear’s responses to infrasound are suppressed by the presence of higher frequency stimuli. The complexity of the ear’s response to infrasound leads us to the conclusion that there are many aspects that need to be better understood before the influence of wind turbine noise on the ear can be dismissed as insignificant.

19 ______Infrasound From Wind Turbines Could Affect Humans Alec N. Salt and James A. Kaltenbach Bulletin of Science Technology & Society 2011 31: 296, DOI: 10.1177/0270467611412555 http://bst.sagepub.com/content/31/4/296

Bio: Alec N. Salt received his PhD from the University of Birmingham, UK, in 1977 and has been actively involved in research into the physiology of the ear for over 35 years.

Bio: James A. Kaltenbach received his PhD from the University of Pennsylvania in 1984. He specializes in the neurobiology of hearing disorders and is currently the Director of Otology Research at the Cleveland Clinic.

Abstract Wind turbines generate low-frequency sounds that affect the ear. The ear is superficially similar to a microphone, converting mechanical sound waves into electrical signals, but does this by complex physiologic processes. Serious misconceptions about low-frequency sound and the ear have resulted from a failure to consider in detail how the ear works. Although the cells that provide hearing are insensitive to infrasound, other sensory cells in the ear are much more sensitive, which can be demonstrated by electrical recordings. Responses to infrasound reach the brain through pathways that do not involve conscious hearing but instead may produce sensations of fullness, pressure or tinnitus, or have no sensation. Activation of subconscious pathways by infrasound could disturb sleep. Based on our current knowledge of how the ear works, it is quite possible that low-frequency sounds at the levels generated by wind turbines could affect those living nearby. ______Perception-based protection from low-frequency sounds may not be enough Alec N. Salt and Jeffery T. Lichtenhan Invited paper presented at Inter-noise 2012, New York City, NY

Bio: Alec N. Salt, Department of Otolaryngology, Washington University School of Medicine, St. Louis, MO,received his PhD from the University of Birmingham, UK, in 1977 and has been actively involved in research into the physiology of the ear for over 35 years.

Acknowledgements This work was supported by grant R01 DC001368 from the NIDCD, National Institutes of Health. We thank Jared Hartsock and Ruth Gill for their assistance with the experiments.

Abstract Hearing and perception in the mammalian ear are mediated by the inner hair cells (IHC). IHCs are fluid-coupled to mechanical vibrations and have been characterized as velocity sensitive, making them quite insensitive to low-frequency sounds. But the ear also contains more numerous outer hair cells (OHC), which are not fluid coupled and are characterized as displacement sensitive. The OHCs are more sensitive than IHCs to low frequencies and

20 respond to very low-frequency sounds at levels below those that are perceived. OHC are connected to the brain by type II afferent fibers to networks that may further attenuate perception of low frequencies. These same pathways are also involved in alerting and phantom sounds (tinnitus). Because of these anatomic configurations, low-frequency sounds that are not perceived may cause influence in ways that have not yet been adequately studied. We present data showing that the ear’s response to low-frequency sounds is influenced by the presence of higher-frequency sounds such as those in the speech frequency range, with substantially larger responses generated when higher-frequency components are absent. We conclude that the physiological effects of low-frequency sounds are more complex than is widely appreciated. Based on this knowledge, we have to be concerned that sounds that are not perceived are clearly transduced by the ear and may still affect people in ways that have yet to be fully understood. ______Public Health Ethics, Legitimacy, and the Challenges of Industrial Wind Turbines: The Case of Ontario, Canada Martin Shain Bulletin of Science Technology & Society, 2011 31: 256 DOI: 10.1177/0270467611412552, http://bst.sagepub.com/content/31/4/346

Bio: Martin Shain S.J.D. is trained in law and social sciences. He is principal and founder of the Neighbour at Work Centre® and assistant professor at the Dalla Lana School of Public Health, Occupational and Environmental Health Division, University of Toronto.

Abstract While industrial wind turbines (IWTs) clearly raise issues concerning threats to the health of a few in contrast to claimed health benefits to many, the trade-off has not been fully considered in a public health framework. This article reviews public health ethics justifications for the licensing and installation of IWTs. It concludes that the current methods used by government to evaluate licensing applications for IWTs do not meet most public health ethical criteria. Furthermore, these methods are contrary to widely held fundamental principles of administrative law and governmental legitimacy. A set of decision-making principles are suggested to address this situation that are derived from existing and emerging legal principles in Canada and elsewhere. These include the Precautionary Principle, the Least Impactful Means (Proportionality) Test, and the Neighbor Principle. ______

Daniel Shepherd, David Welch, Kim N. Dirks, and David McBride, (March 2013), Do Quiet Areas Afford Greater Health-Related Quality of Life than Noisy Areas? International Journal of Environmental Research and Public Health, ISSN 1660-4601 http://www.mdpi.com/1660-4601/10/4/1284

Authors: Daniel Shepherd 1,*, David Welch 2, Kim N. Dirks 2 and David McBride 3

21 1 School of Public Health, Auckland University of Technology, Auckland 1142, New Zealand 2 School of Population Health, The University of Auckland, Auckland 1142, New Zealand; E-Mails: [email protected] (D.W.); [email protected] (K.N.D.) 3 Department of Preventative and Social Medicine, University of Otago, Dunedin 9054, New Zealand; E-Mail: [email protected] * Author to whom correspondence should be addressed; E-Mail: [email protected]

Abstract: People typically choose to live in quiet areas in order to safeguard their health and wellbeing. However, the benefits of living in quiet areas are relatively understudied compared to the burdens associated with living in noisy areas. Additionally, research is increasingly focusing on the relationship between the human response to noise and measures of health and wellbeing, complementing traditional dose-response approaches, and further elucidating the impact of noise and health by incorporating human factors as mediators and moderators. To further explore the benefits of living in quiet areas, we compared the results of health-related quality of life (HRQOL) questionnaire datasets collected from households in localities differentiated by their soundscapes and population density: noisy city, quiet city, quiet rural, and noisy rural. The dose-response relationships between noise annoyance and HRQOL measures indicated an inverse relationship between the two. Additionally, quiet areas were found to have higher mean HRQOL domain scores than noisy areas. This research further supports the protection of quiet locales and ongoing noise abatement in noisy areas

Shepherd, Daniel; McBride, David; Welch, David; Dirks, Kim; Hill, Erin Wind turbine noise and health-related quality of life of nearby residents: a cross sectional study in Ne w Zealand Presented at the Fourth International Meeting on Wind Turbine Noise, Rome, 2011 http://otago.ourarchive.ac.nz/handle/10523/2260 24/03/2013

Abstract: Hearing allows humans to detect threats in the environment and to communicate with others. However, unwanted sound has the capacity to evoke reflexive and emotional responses, and can act a stressor. The World Health Organisation classifies noise as an environmental pollutant that degrades sleep, quality of life and general health. Previous research provides evidence of a relationship between wind turbine noise and both annoyance and sleep disturbance. However, wind turbines are a relatively new source of community noise, and as such their effects on health have yet to be fully described. We report a study exploring the effect of wind turbine noise on health and wellbeing in a sample of New Zealand residents living within two kilometres of a wind turbine installation. Our data provide evidence that wind turbine noise can degrade aspects of health-related quality of life and amenity. On this evidence, wind turbine installations should be sited with care and consideration with respect to the communities hosting them.

22 ______Mitigating the Acoustic Impacts of Modern Technologies: Acoustic, Health, and Psychosocial Factors Informing Wind Farm Placement Daniel Shepherd and Rex Billington Bulletin of Science Technology & Society 2011 31: 389 DOI: 10.1177/0270467611417841 http://bst.sagepub.com/content/31/5/389

Bio: Daniel Shepherd has a PhD in psychoacoustics and holds a lectureship at the Faculty of Health, AUT University. As an environmental psychologist, he researches the psychological response to noise from both individual and social perspectives.

Bio: Dr. Rex Billington is a research health psychologist at AUT University after 18 years with the World Health Organization including directorships in Mental Health and the Global Program on AIDS.

Abstract Wind turbine noise is annoying and has been linked to increased levels of psychological distress, stress, difficulty falling asleep and sleep interruption. For these reasons, there is a need for competently designed noise standards to safeguard community health and well- being. The authors identify key considerations for the development of wind turbine noise standards, which emphasize a more social and humanistic approach to the assessment of new energy technologies in society. ______Evaluating the impact of wind turbine noise on health related quality of life by Daniel Shepherd, David McBride, David Welch, Kim N. Dirks, Erin M. Hill Noise & Health, September-October 2011, 13:54,333-9 DOI: 10.4103/1463-1741.85502 www.noiseandhealth.org

Abstract We report a cross-sectional study comparing the health-related quality of life (HRQOL) of individuals residing in the proximity of a wind farm to those residing in a demographically matched area sufficiently displaced from wind turbines. The study employed a nonequivalent comparison group posttest-only design. Self-administered questionnaires, which included the brief version of the World Health Organization quality of life scale, were delivered to residents in two adjacent areas in semirural New Zealand. Participants were also asked to identify annoying noises, indicate their degree of noise sensitivity, and rate amenity. Statistically significant differences were noted in some HRQOL domain scores, with residents living within 2 km of a turbine installation reporting lower overall quality of life, physical quality of life, and environmental quality of life. Those exposed to turbine noise also reported significantly lower sleep quality, and rated their environment as less restful. Our data suggest that wind farm noise can negatively impact facets of HRQOL.

23 Acknowledgements: We are grateful to our colleagues and others whose reviews substantially improved the manuscript. We are especially grateful for the thorough review undertaken by Professor Rex Billington, who as the WHO Director of Mental Health in the 1990s oversaw the development of the WHO’s program into quality of life, health and the environment. ______Numerical simulation of infrasound perception, with reference to prior reported laboratory effects. M.A.Swinbanks Presented at Inter-noise 2012, New York City, NY

Abstract In earlier presentations, the author has argued that conventional assessments of the perception of infrasound based on mean (rms derived) sound energy levels underestimate the importance of the associated crest factor of very low frequency sound pressure variations. By simulating the dynamic response of the ear at levels close to the hearing threshold, it is apparent that infrasound may be perceptible at lower levels than those based on long time constant rms assessment. In particular, it will be shown that the existence of a finite threshold of audibility, together with the added presence of low level higher frequency noise in the first critical band (i.e. below 100Hz), can imply the perception of infrasound at significantly lower levels than has hitherto been acknowledged. The results of simulations will be compared to independently reported effects which have been observed in laboratory testing by other researchers.

Conclusion (excerpt) The dBG levels for the wind-turbine infrasound inside the house are 10-15dB lower than the Chen test signal which gave rise to adverse effects after only 1 hour. But since there is an 8dB increase in sensitivity for 10% of young adults, it is clear that these infrasonic wind turbine levels could be expected to become a problem after several hours of exposure. ______The Problems With ''Noise Numbers'' for Wind Farm Noise Assessment Bob Thorne Bulletin of Science Technology & Society 2011 31: 262 DOI: 10.1177/0270467611412557, http://bst.sagepub.com/content/31/4/262

Bio: Bob Thorne, MSc, PhD, is the principal consultant of Noise Measurement Services Pty Ltd, Brisbane, Australia. He holds a PhD from Massey University, New Zealand, in health science and is an environmental health research associate in the Institute of Food, Nutrition and Human Health at Massey University. His research work involves using advanced specialized technology for intrusive noise assessment, and a specific application is personalized sound reinforcement for hearing assistive devices.

24 Abstract Human perception responds primarily to sound character rather than sound level. Wind farms are unique sound sources and exhibit special audible and inaudible characteristics that can be described as modulating sound or as a tonal complex. Wind farm compliance measures based on a specified noise number alone will fail to address problems with noise nuisance. The character of wind farm sound, noise emissions from wind farms, noise prediction at residences, and systemic failures in assessment processes are examined. Human perception of wind farm sound is compared with noise assessment measures and complaint histories. The adverse effects on health of persons susceptible to noise from wind farms are examined and a hypothesis, the concept of heightened noise zones (pressure variations), as a marker for cause and effect is advanced. A sound level of LAeq 32 dB outside a residence and above an individual’s threshold of hearing inside the home are identified as markers for serious adverse health effects affecting susceptible individuals. The article is referenced to the author’s research, measurements, and observations at different wind farms in New Zealand and Victoria, Australia.

MULTI-MUNICIPAL WIND TURBINE WORKING GROUP COMPRISED OF ELECTED OFFICIALS AND CITIZENS FROM MUNICIPALITIES IN BRUCE , D U F F E R I N , G R E Y , H U R O N , P E R T H , AND WELLINGTON COUNTIES

Mark Davis, Deputy Mayor, Arran-Elderslie, Co-Chair

1925 Bruce Road 10, Box 70, Chesley, ON NOG 1L0 519-363-3039 Fax: 519-363-2203 [email protected] 15 March, 2013

Hon. Bob Chiarelli Minister of Energy 4th Floor, Hearst Block, 900 Bay Street Toronto, ON M7A 2E1 [email protected]

Dear Minister Chiarelli;

THIS IS A FORMAL REQUEST THAT YOU ADDRESS MUNICIPAL CONCERNS OVER WIND TURBINES

You may be aware of reports (in The Economist and the U.K. Guardian) of Bulgarian demonstrators burning their electricity bills because of skyrocketing electricity price increases (14%). Bulgaria’s government has since resigned (20 February) after failing to diffuse the discontent of consumers who are outraged over the 200% profits of foreign owned renewable electricity producers when the high cost of connecting renewables to the grid is paid by consumers. The Bulgarian caretaker government has now appointed an international auditor to conduct a full analysis of the country's energy sector.

In Ontario, our rural electricity rates have already risen 15% per year since 2009 when Minister Smitherman assured us renewables would cause only a 1% rise per year. Foreign multinational energy producers are profiting handsomely from our unrealistic feed-in- tariffs which are contributing to grim economic repercussions for Ontario.

The communities represented in our group host one-third of the operating wind turbines in Ontario. We are targeted for the installation of many more. For over five years we have been attempting to share with your government what we have learned from delegations and presentations by affected citizens, economists and electricity generation professionals. Along with 91 municipalities, we have repeatedly asked for a stop to the frenzied approval and contract issuing process still continuing despite known health, economic and wildlife issues and doubtful climate benefits. We have seldom had even the courtesy of an acknowledgment of our letters.

It must be clearly stated: we are not, “willing host communities”. Our constituents are fully aware of the problems with industrial wind turbines.

The current surplus of available electricity provides an excellent opportunity to pause the approvals process so that we can get this right.

Minister Chiarelli, as you know, your appointment follows a string of short term, inexperienced incumbents from Ministers Smitherman, Phillips, Duguid, through Bentley. Serious mistakes have been made in the energy portfolio. Unless they are addressed urgently, the damage will be long term, crippling and irreversible. Here is our list of issues which require immediate attention:

The awarding of contracts and issuing of Renewable Energy Approvals for wind facilities must immediately cease. The Ontario Power Authority must be directed to inform interested parties at once that no further applications for the development of wind facilities shall be accepted until after the following actions have been completed:

 The Ministry of the Environment must complete a review of the Regulations for Renewable Energy Approvals and reissue the Regulations to ensure protection of citizens and the environment from both direct and indirect health and safety concerns, with a progress update within 12 months.

 The Ontario Power Authority must address the recommendations made in the 2011 Annual Report of the Auditor General with respect to Renewable Energy initiatives and power pricing. This will include a review of the pricing of Renewable Energy contracts to consider the value of the supplied power in terms of availability when needed; competitiveness; impact of power pricing on the Ontario economy; as well as the impact of the generating method on the environment including humans, wildlife, and land area usage.

 Amendments must be made to the Green Energy Act (2009) deleting exemptions for renewable energy projects from environmental legislation, restoring municipal jurisdiction under the Planning Act and reversing the onus on citizens to prove that health and environment are being harmed by such projects.

The accompanying document will give you a fresh perspective to understand the situation you face as Minister of Energy. It provides data and rationale for the actions we require. You will see why wind energy facilities are not replacing coal; that there is often an almost perfect mismatch between wind production and demand; that since wind has to be backed up with more emission producing natural gas generation CO2 emissions tend to increase; that price increases in rural Ontario electricity rates are already creating crippling economic problems resulting in many job losses; that noise regulations are inadequate; and that as even more wind energy is added to the grid, the resulting destabilization from

2 repetitive steam reject derating is causing serious concerns for the safety of our nuclear fleet.

We look forward to your expeditious reply as these are indeed serious issues, for which you have the responsibility to act. We have copied this letter to a number of respected media journalists and you may want to copy your response to them also as we believe we have clearly identified the problem, and the solution, and the public deserves to hear your response.

Respectfully,

Mark Davis, Co-Chair, MULTI-MUNICIPAL WIND TURBINE WORKING GROUP

CC: Hon. Kathleen Wynne, Premier and Minister of Agriculture Hon James Bradley, Minister of the Environment Hon David Orazietti, Minister of Natural Resources Serge Imbrogno, Deputy Minister of Energy Journalist – Christina Blizzard - Toronto Sun Journalist – John Spears - Toronto Star Journalist – Scott Miller - CTV 2 News Network Journalist – Dave Seglins - CBC News Network Journalist – Karen Howlett - Globe and Mail Journalist – Terrance Corcoran - National Post Broadcaster – Dale Goldhawk - 740 Radio

MULTI-MUNICIPAL WIND TURBINE WORKING GROUP

Attachment to letter to Minister of Energy

There is no rational basis for adding more wind generators to the Ontario electrical system: it will threaten grid stability, make electricity unaffordable, increase CO2 emissions and increase the harm already being done to citizens, communities, significant wildlife habitats and the Ontario economy.

Introduction

Wind turbines are being justified on the basis of arguments that do not relate to actual experience. Adverse impacts from wind turbines are not being mitigated by the current inadequate regulations.

On March 14th, 2013, Minister of Natural Resources, David Orazietti, stated in a letter: “Expanding clean and renewable sources of energy is key to the government's plan to phase out coal-fired generation, mitigate climate change, create green jobs and support technological innovation in renewable energy.”

Ministry of Energy staff must also take responsibility for these statements. They are not true. This document examines the issues and demonstrates why they must be addressed.

Directives from the Minister of Energy to the Ontario Power Authority call for the installation of yet more wind powered generators without learning from the adverse experience with existing wind facilities.

The Long Term Energy Plan calls for 10,700 MW of new renewable generation (mostly wind generators) to be installed by 2018.1

Adverse experience has already arisen from the operation of 876 wind powered generators in Ontario connected to the bulk electrical system. It is imperative for the ministry to learn from this adverse experience to prevent recurrence before adding more wind energy.

1. Wind is not replacing coal fired generation

FIGURE 1 – WIND IS NOT REPLACING COAL FIRED GENERATION

1 This target was revised to 2015 with the release of the Feed in Tariff Review in 2012, (to allow a further increase) in 2013. The Ontario Power Authority identifies 2015 MW as “wind facilities” in commercial operation, with nearly twice as much, 3776 MW, already under development, for a total wind capacity of 5791 MW by 2015.

Figure 1 is derived from IESO and predecessor Ontario Power Generation and Ontario Hydro reports. It makes it clear that coal generation dropped from 40 TWh in 2003 to 4 TWh in 2012, not because of a new policy of “expanding renewable sources of energy,” but as a result of:  the restart of nuclear units that was already in progress in 2003 and improved performance of other nuclear units, (~ 20 TWh increase in nuclear output from 2003 to 2012);  the addition of natural gas fired generators (~ 10 TWh increase from 2003 to 2012);  and a reduction in the Ontario demand of about 15 TWh due to the economic setback since 2006. The tiny 4 TWh contribution from wind generators is barely visible on the chart and contribution from solar utility generation is invisible.

2. Wind is not available when needed

Wind energy introduces serious grid-management issues. Wind is not effective for displacing coal because wind energy availability is mismatched to demand.

There is often an almost perfect mismatch between wind production and electrical system

demand in Ontario.

FIGURE 2. WIND IS NOT AVAILABLE WHEN NEEDED

A careful study of the actual performance of the wind turbines shows that they are chronically not available when coal fired units are needed to be run, during hot summer days and cold crisp winter ones. Figure 2 shows winter and summer examples of the fact that in any season, there are periods of highest Ontario electrical demand when wind turbines are just not available, while there are periods of low Ontario demand when an excess of generation from wind turbines is forcing non carbon emitting hydro and nuclear generators to derate.

3. Adding intermittent wind output increases CO2 emissions

FIGURE 3 – INCREASING WIND OUTPUT TYPICALLY INCREASES COAL UNITS ON LINE FOR BACKUP

Figure 3 shows further evidence of the mismatch between wind turbines and demand. It also demonstrates that experience gained with operating the existing wind turbines shows that in reality wind turbines are forcing non carbon emitting generating sources to be less efficient, thereby unnecessarily increasing the warming of the atmosphere, discharging steam without generating electricity, or spilling water, while actually requiring on line excess capability of coal fired generators to be connected to the grid to provide back up for when the wind generators drop in output.

This is happening with the current wind turbine penetration of 1726 MW on the IESO monitored system and 2015 MW in commercial operation (as identified by the Ontario Power Authority) in total and a further 3776 MW already under OPA contract yet to be added to the system.

When this magnitude of wind generation is added, either base load nuclear units will be forced off line, which will require carbon emitting gas fired units to take up the slack when wind output falls, as it invariably does; or the wind generators will be paid to shut down. The IESO has estimated that will cost consumers an additional $200 million a year. There is no rational basis for continuing to add more wind to the Ontario system.

4. Operating wind turbines increased the need for coal fired generators on the system

Further study of Figure 3 shows that during a typical 10-day monitored period in January 2013, when wind turbines are in operation, the IESO monitored system typically increases the amount of coal fired generation connected to the system, but not loaded, to be able to accommodate for the drops in wind output that the system must anticipate.

Examination of the operating experience of the actual wind turbine generators in Ontario in 2012 and early 2013, shows that there have been at least 100 times when the wind generation has dropped by equal or greater to 25% in a 4 hour period, with drops of over 50% in a 4 hour period occurring. Having 5791 MW of operating wind turbines by 2015, as planned by ministry policy will result in drops of over 3000 MW in system output in short time periods, often at the same time as the electrical system load is increasing.

5. The present Energy Ministry policy will further increase the required operation of fossil fueled generation in Ontario, not reduce it.

If the final coal units are taken off line, or if the wind penetration increases, the Ontario system will require extensive derating of hydro generators to be able to maintain an available (but unloaded) operating margin for the anticipated drop in wind outputs as experienced, with the shortfall for the held back hydro generators filled by gas fired generation. The path being

followed by the policy driven by the Ministry of Energy will increase the required operation of fossil fueled generation in Ontario, not reduce it. It will not be possible to maintain this operating reserve by operating gas units, as the majority of gas fired units installed are combined cycle generators that are loaded to over 70% in output for stable operation, leaving inadequate reserve for the 5791 MW of wind generation scheduled to be in service by 2015 (according to the OPA website).

6. Price increases in rural Ontario electricity rates are creating crippling economic problems Government support and the 20 year contract price for wind generation at much higher than the average electricity price has resulted in a rapid increase in Ontario electricity prices to consumers. The “Clean Energy Benefit” 10% reduction of consumer electricity prices is only masking the increasing price, resulting in an increase in the Ontario Debt that will need to be repaid, at a time the debt has already increased to unprecedented levels.

FIGURE 4 – PRICE INCREASES IN RURAL ONTARIO ELECTRICITY PRICE

It is clear from the publicly available data that the plan the Ministry of Energy is following is becoming disastrous to the Ontario economy. Already, the “all-in” price of peak generated electricity for rural customers is increasing by over 15% a year as shown in Figure 4. That is certainly nowhere near the 1% per year originally promised when the Green Energy and Green Economy Act was introduced, nor the 3.5% per year when the Ontario Long Term Energy Plan was published two years ago.

With price increases of this magnitude, Ontario is under high risk of losing the remaining high energy consuming industries we have. In every community, small industries, and even commercial enterprises for which energy for refrigeration is a major cost, (such as grocery stores, apple orchards, ice cream factories, cheese factories, and farmers with dairy coolers) are suffering. We have already lost a number of industries and commercial enterprises for which energy is a major component because they have moved to locations with lower energy prices (for example Xstrada, Stoney Creek Dairy, and Ben and Jerry’s Ice Cream).

Consider the remaining major manufacturers in Ontario. Honda in Alliston, Toyota in Woodstock, GM in Oshawa, Ford in Oakville, and Chrysler in Windsor are major Ontario businesses that consume significant quantities of electricity to operate assembly lines operating in an environment where the Ontario base electrical prices are nearly double the prices in the United States where these firms already have other assembly plants.

The table below compares the price for electricity for a rural consumer in Ontario, to the price for electricity for the rural consumer in various American states which are home to the US auto assembly plants. Even though there may be special arrangements to price electricity lower for industry, this simply means most Ontario electricity consumers will share even more of the burden.

These Ontario plants are at risk when the Ontario electricity price continues to rise. These companies must respond to shareholders, and the threat to relocate production to other existing plants is very real.

EXISTING ASSEMBLY PLANT ONTARIO RURAL PRICE PER ONTARIO AUTO ASSEMBLY FOR THIS MANUFACTURER IN KWH / US STATE PRICE PER KWH PLANT THIS STATE Toyota – Woodstock Kentucky (also Texas) 23.0/8.7 = 2.6

Honda – Alliston Ohio (also Indiana) 23.0/10.5 = 2.2

GM Car – Oshawa Kansas City. KA 23.0/10.2 = 2.3

GM Truck – Oshawa Lansing, Mi 23.0/12.5 = 1.8

Ford – Oakville Michigan 23.5/12.5 = 1.8

Chrysler – Windsor Michigan 23.0/12.5 = 1.8

(ONTARIO RURAL PRICE BASED ON AN AVERAGE 750 KWH CONSUMPTION FOR A RURAL CONSUMER TO GENERATE AN “ALL-IN” PRICE

INCLUSIVE OF ENERGY, DELIVERY, REGULATORY COST, DEBT RETIREMENT, AND HST.

US STATE “ALL-IN” ELECTRICITY PRICE FROM WEBSITE, HTTP://WWW.TARGETMAP.COM/VIEWER.ASPX?REPORTID=9037 BASED ON US ENERGY

INFORMATION AGENCY DATA).

7. Economic benefits of the Green Energy act have not materialized

The Green Energy and Economy Act (2009), was passed by the Ontario Legislature with a goal of sparking growth in renewable sources of energy, including wind powered generators. It was stated that 50,000 new jobs would be created in the first three years-- a goal that has come nowhere near achievement in spite of favourable supporting conditions.

The rhetoric about green energy creating jobs in Ontario will soon be overwhelmed by the reality of a far greater magnitude of lost jobs.

As for creating technological innovation in Ontario, the high value parts of wind turbines are built outside Ontario, while only the physically large components such as blades and towers will be made in Ontario. These are short lived jobs, not sustainable jobs, and will evaporate as soon as the turbines are erected. Shipping these components out of Ontario to the United States is very unlikely due to their size, and the fact that industries are already producing towers and blades in the US, close to the users.

8. Regulations are not protecting citizens

It is now clear that current regulatory setbacks are not large enough.

Installation of wind turbines in our municipalities is too close to public roadways, and too close to the homes of citizens. There has not been adequate attempt made to avoid significant wildlife habitat which is now being degraded. Our citizens are suffering, our community cohesiveness has been badly damaged, and our economic well being is deteriorating due to the policies implemented by your ministry.

The current regulations for Renewable Energy Approvals of wind turbines have permitted a 100 metre tall industrial wind turbine to be installed as close as 210 metres from homes of unwilling non-participating neighbours in one of our communities, and the regulations are routinely being used to propose setbacks of wind turbines over 150 metres tall as close as 60 metres from neighbouring lot lines, or the travelled portion of provincial and municipal roads. These regulations are not protecting citizens.

The Regulations made under the Renewable Energy Approvals permit wind turbines as close as blade length plus 10 metres to public roadways, and to the lot lines of neighbours by means of a trivial assessment that provides inadequate protection to citizens from ice throw, blade failures, and wind turbine tower collapse. All of these have already occurred in Ontario, and the

inadequate setbacks risk citizens from these failure modes, in spite of formal identification of public safety concerns by qualified professionals.

Freedom of Information Act requests have disclosed that staff of the Ministry of the Environment have formally identified this problem: “MOE Provincial Officers have attended at several of the complainants residences and have confirmed that despite the noise emissions apparently complying with the applicable standard – C of A (Air) limits, that the noise emissions are, in fact causing material discomfort to the residents in and around their homes”. This demonstrates that the standards of the Regulations made under the Renewable Energy are not adequate to protect the public.

The basis for the setback to homes is flawed because it does not consider the “quality” of sound of the wind turbines. It does not assess C-weighted measurement of the sound intensity, and ignores the cyclical nature of both the amplitude and frequency modulation of the sound. This noise is more noticeable and more of a nuisance. It is noise the WHO links to adverse health effects, a concern for public health and environmental health.

9. Regulations must consider more than A-weighted measurement of sound

The Ministry of the Environment has continued to approve wind turbines up to 150 metres tall, producing a known to be annoying cyclical sound level, with predominant low frequency components, as close as 210 metres to offsite residences from a single turbine 100 metres in height, under 400 metres to residences impacted by multiple turbines in close proximity, and as close as 550 metres in current approvals. Regulations require only 40 dBA in rural communities or 45 dBA in other communities, neglecting the special characteristics of cyclic, amplitude and frequency modulated sound, the predominant low frequency component of wind turbine sound, or the intrusiveness of sound levels that increase at night in areas of very low background, in spite of concerns identified by citizens and qualified professionals.

The World Health Organization (Europe), report “Burden of Disease from Occupational Noise – Quantification of healthy life years lost in Europe” (2011) begins, “This publication summarizes the evidence on the relationship between environmental noise and health effects, including cardiovascular disease, cognitive impairment, sleep disturbance, tinnitus, and annoyance.” All are indirect health effects. The WHO Report concludes, “There is sufficient evidence from large- scale epidemiological studies linking the population exposure to environmental noise with adverse health effects. Therefore, environmental noise should be considered not only as a cause of nuisance but also as concern for public and environmental health.”

In the light of new research from the Medical Officer of Health for Grey-Bruce, it is clear that the Report “The Potential Health Impact of Wind Turbines,” issued by the Chief Medical Officer of Health, (2010) which considered the effects only of direct health effects from noise such as hearing loss, can no longer be used by proponents or the government as an excuse to ignore health concerns since it failed to address more serious indirect health effects from environmental noise from wind turbines, as identified by the World Health Organization, and failed also to interview actual patients.

Citizens in nearly all municipalities where wind turbines have been installed have identified health issues that have arisen since the wind turbines commenced operation.

Using more recent information than was available in 2010, the Grey-Bruce MOH report found that in all 18 of the observed peer reviewed studies of people living around industrial wind turbines, health issues of varying levels occurred in every situation. In 3 of the studies, they noted a dose response i.e. the closer to a turbine the greater the negative health occurrence. It called for greater setbacks from human habitations.

10. Amendments are needed to sections of the Green Energy Act (2009)

The Green Energy and Green Economy Act (2009) took away planning authority from local municipalities to reject applications to install wind turbines in the local municipalities. The current Premier has stated that wind turbine installations would preferentially be installed in “willing communities”. Over 90 Municipal and County Councils in the majority of municipalities where wind turbines have already been installed and where planned have passed resolutions calling for or supporting a moratorium on further development of wind turbines showing they are not “willing host communities” at least until questions regarding health and safety are resolved. However the policy introduced with the Feed In Tariff Review gives municipalities only the chance to approve the turbines, not to reject them.

Amendments must be made to the Green Energy Act (2009) deleting exemptions for renewable energy projects from environmental legislation, restoring municipal jurisdiction under the Planning Act and reversing the onus on citizens to prove that health and environment are being harmed by such projects.

Conclusion:

It is clear that the installation of wind turbines in our municipalities has done harm to our citizens, our community well being, and to our economic welfare. We have had repeated deputations to councils from citizens identifying harm done to them personally. These people are our neighbours and upstanding citizens of our communities. They are neither “crack-pots” nor “malcontents.” We have demonstrated to you that claims that wind turbines are shutting down coal fired generators are false. We have demonstrated that claims for advantages of job creation are false, and in fact, rapidly rising electricity prices are threatening the economic well being of our communities, and Ontario as a whole. We have shown that regulations are inadequate to protect the public from known risk factors. Immediate action is required to

address these concerns. As Minister of Energy you have the authority and it is your responsibility. We await your response.

From: [email protected]

Sent: July 17, 2013 9:01 AM

To: [email protected]

Subject: OPA/IESO - Siting of Energy Projects

On behalf of the Chartwell-Maple Grove Residents Association I would like to thank you for coming to Oakville to hear our concerns and suggestions.

We fully support the initiatives proposed by C4CA, particularly those that pertain to the need for legislation to define setbacks and other siting requirements. Investigating best-practices worldwide would be a good place to start.

Our recommendations are very much in line with those of C4CA, and are focussed on the principles of transparency and engagement:

The first priority on any project should be to ensure the health and safety of citizens and protect the environment. Coordination between different levels of government (federal, provincial, municipal) and different provincial departments (Energy, Health, etc.) is sorely lacking and very much needed.

Communication and engagement with communities and citizens must begin at a much earlier stage, must be genuine, and must be ongoing. The establishment of a Citizens Advisory Group was a suggestion by many.

There is a need for a governing body, or organization that more closely monitors energy needs, and has the flexibilty and authority to adjust plans on an ongoing basis. It was clear to many that there was no real need for the Oakville plant, yet the process just rolled on in oblivion.

Lastly, we ask for transparency and accountabilty at all stages of the process. Without this, the process will not be improved.

Thank you once again for your interest in our concerns. We look forward to hearing from you about the changes you will be proposing.

Daniela Morawetz

President, CMGRA

Sent from my BlackBerry device on the Rogers Wireless Network

CITY HALL P.O. BOX 400 70 COLLIER STREET BARRIE, ONTARIO TEL. (705) 792-7900 L4M 4T5 FAX (705) 739-4265 www.barrie.ca

THE CORPORATION OF THE CITY OF BARRIE Mayor’s Office “Committed to Service Excellence”

July 18, 2013

Regional Planning and Infrastructure Siting Dialogue Ontario Power Authority 120 Adelaide St. West, Suite 1600 Toronto, ON M5H

Dear Sirs,

Re: Regional Energy Planning and Siting in Ontario

This letter is in reply to the June 13, 2013 e-mail invitation from the Ontario Power Authority (OPA) to “Join the Conversation” by providing recommendations to be used by the Ontario provincial government to establish a stakeholder engagement process to support the development of future regional energy plans and site new energy infrastructure.

It is my understanding that the OPA and the Independent Electricity System Operator (IESO) have been directed by the Minister of Energy to work together to develop recommendations for a new, integrated regional energy planning process that would focus on improving how large energy infrastructure projects are sited in Ontario.

I understand also that the Minister requested, among other things, that recommendations developed by the OPA and IESO contain concrete proposals, which feature transparent mechanisms for seeking input from municipalities, Aboriginal communities and other stakeholders in the development of regional energy plans; and include processes for ensuring that municipalities are engaged in the siting of large energy infrastructure projects which could include generation, transmission and transformation facilities.

As the Mayor of Barrie, a current municipal Shareholder of PowerStream Inc., (PowerStream), the second largest electricity distributor in the Province and Board member of PowerStream, I believe my perspective on the siting of large energy infrastructure projects in Ontario may be helpful.

Letter to Ontario Power Authority July 18, 2013

The Places to Grow Act, 2005 and its concomitant Regulations identified Simcoe County within the Ontario Government’s Greater Golden Horseshoe growth plan area as an area where an integrated and co-ordinated approach to planning is to be carried out. Barrie is located in Simcoe County.

Barrie’s Growth Management Strategy is designed to recognize Barrie’s designation as the only urban growth centre in Simcoe County. Among other things, Barrie’s Growth Management Strategy is being used to guide and direct urban land needs within the City of Barrie for the next 20 years. Over the next two decades, Barrie is forecasted to experience significant population and employment growth. The City’s current urban area is now approaching build-out and if development is to continue, higher density growth must be accommodated within the City’s built-up areas. At the same time, new greenfield development on the City’s limited remaining designated areas and within an expanded urban boundary must be strategically planned and phased, in a manner consistent with Provincial policy direction which supports the City of Barrie Official Plan.

To help ensure that Barrie fulfills its role as an anchor urban node in Central Ontario, the Province adjusted the City’s boundary and added land to the City through the Barrie-Innisfil Boundary Adjustment Act, 2009. This legislation extended the southern boundary of Barrie to include 2,335 hectares (5,770 acres) of land previously in the Town of Innisfil.

Engagement of Municipalities in Energy Planning and Siting Processes

I fully endorse the belief that there is high value in having municipalities and other stakeholders more directly involved in regional planning1. As indicated in the foregoing discussion, the City of Barrie is in the process of implementing its Growth Management Strategy which is governed, in part, by provincial planning and direction.

Moreover, the Ontario Energy Board (OEB) has recently adopted an integrated approach to distribution system planning that requires LDCs, such as PowerStream, to engage appropriate stakeholders. LDC applications to the OEB for distribution system investments, including regionally planned infrastructure, have to demonstrate that the related distribution services are provided in a manner that responds to the regional planning process. Indeed, the Process for Regional Infrastructure Planning in Ontario, prepared by the Planning Process Working Group and adopted by the OEB contemplates a point of broader engagement at the project level for infrastructure investments that are the result of a Regional Infrastructure Plan2.

1 Regional Sessions Presentation, Stakeholder Engagement: Regional Planning and Siting in Ontario An Introduction, available on the OPA’s website 2 Planning Process Working Group Report to the Board: The Process for Regional Infrastructure Planning in Ontario, Revised May 17, 2013, Page 23 Letter to Ontario Power Authority July 18, 2013

Several approaches to stakeholder engagement for regional planning and siting in Ontario are proposed by the OPA and IESO in their Regional Sessions Presentation: siting boards; government site selection; multi-stage competitive procurement; individual EA for all large generation; and community funds for hosts. I believe that, depending on the facility and location within the province, each of these approaches may have more merit than others for a given investment.

I appreciate the opportunity to provide comments on the Ontario Government’s energy planning and siting processes, in particular to stress the importance and relevance to the City of Barrie.

Please contact my office if you require further information or have any questions.

Sincerely,

Jeff Lehman Mayor, City of Barrie Director, PowerStream

City Hall, 426 Brant Street, P.O. Box 5013 Burlington, Ontario L7R 3Z6

July 15, 2013

Regional Planning and Infrastructure Siting Dialogue c/o Ontario Power Authority 120 Adelaide St. West Suite 1600 Toronto, ON M5H 1T1

RE: Regional Electricity Planning Process – Comments from City of Burlington

The City of Burlington is responding to the request for comments and suggestions from the OPA and IESO related to the Regional Electricity Planning Process, contributing to the recommendations that the OPA and IESO will make to the Minister of Energy to improve municipal and community engagement in the Regional Electricity Planning Process and the siting of large energy projects.

As you are aware, community energy planning is top of mind for the City of Burlington at this time. We have just finalized a draft plan in partnership with Burlington Hydro, making it available for a community engagement process for feedback on the proposed goals, objectives, actions and targets. There are five areas of focus in the plan, including: Behaviour Change & A Culture of Conservation; Energy Efficiency; Energy Generation & Security; Land Use & Growth; and Transportation. It is an integrated approach to how energy is consumed, conserved and generated in Burlington, with recommended incremental and transformative actions to improve the energy network.

The City and Burlington Hydro were the lead agencies on the development of the plan, with support and guidance from a group of community stakeholders, with representation by: the local school boards and hospital, Burlington Economic Development Corporation, Union Gas, Halton Region, BurlingtonGreen, Burlington Sustainable Development Committee, the Ontario Power Authority, the Royal Botanical Gardens, McMaster University and a local business. The advice and support provided by this group was invaluable and served to strengthen the overall plan. The attached comments are based on lessons learned through this process as well as the City’s long standing experience in land use planning, environmental assessments, and community engagement processes.

The City would like to thank the OPA and IESO for the opportunity to contribute to this consultation process for consideration as part of the recommendations to be made to the Minister of Energy for potential improvements to the Region Electricity Planning Process and the siting of large energy infrastructure projects. We look forward to further discussion with the OPA and IESO regarding the comments provided.

Yours truly,

Sent via email

Allan Magi, P.Eng. Executive Director Corporate Strategic Initiatives cc: Bruce Krushelnicki, Director, Planning & Building Department, City of Burlington Andrea Smith, Manager of Policy, Planning & Building Department, City of Burlington Gerry Smallegange, President & CEO, Burlington Hydro Inc. Attachment to Letter: Regional Electricity Planning Process – Comments from City of Burlington

City of Burlington Comments on the Regional Electricity Planning Process:  Generally, more time for the consultation process regarding Regional Energy Planning and Siting in Ontario would be appreciated.  The graphic provided within the Discussion Guide dated June/July 2013 for the Regional Electricity Planning Process identifies the need for collaboration among the LDCs, municipalities, Aboriginal communities and the OPA. We recommend that municipal engagement be in the broadest sense of the term and more aptly termed community engagement.  The Regional Electricity Planning Process should be publicly accountable and transparent, particularly if new generation or transmission lines are being considered and recommended, and that the broad community be engaged in the process. To focus community engagement at the end of the process for the siting of large energy infrastructure projects is far too late, particularly when it comes down to one or two sites. The community needs to understand and possibly be involved in the decision- making to get to that point.  Given the above comment, it is imperative that the community be engaged in the needs identification and that the problem and opportunity statements are clearly defined.  Alternatives should also be clearly defined with consideration of local, sustainable solutions and conservation options.  It has been noted that through the consultation process, the terms ‘electricity’ and ‘energy’ have been used interchangeably. The City would support a truly ‘integrated’ energy planning process, one that is not just focused on electricity but one that includes community or district energy systems to improve the generation and delivery of thermal (heating and cooling) energy.  The OPA and IESO should work with local municipalities on community engagement opportunities to help improve the process and scope it appropriately.  Reports related to Regional Electricity Planning Processes and project siting should be publicly available and presented to municipal councils as part of their regularly scheduled meetings, allowing public delegations.  The City supports local community energy planning and, where a local plan exists, it should be taken into consideration during the Regional Electricity Planning Process.  It is recognized that smaller communities may lack the capacity to undertaken a community energy plan. In these cases, the OPA and IESO may have a role in supporting these communities.  It was pointed out in the consultation process that regional electricity planning boundaries do not match up with municipal boundaries. This is also true with conservation authorities. Each conservation authority ‘board of directors’ includes municipal representation. A similar model could be considered for the regional electricity planning area.  All of the possible approaches to enhance engagement in the regional electricity planning process and to improve integration of municipal planning and regional energy planning, listed on p.4 of the Discussion Paper, are supported.

City of Burlington Comments on the Siting of Large Energy Infrastructure Projects:  As noted above, it is important that the Regional Electricity Planning Process be open and transparent so that the community understands the decision making process to get to this point of siting large infrastructure projects. As part of the open and transparent process, data related to energy mapping, infrastructure capacity, energy needs etc. should be provided to the community as it becomes available.  There should be more effort to engage the public during the screening of options and sites earlier in the process. Again, as noted above, the point where a site is finally selected is really too late for a robust community engagement process.  The OPA should consider undertaking an environmental screening process when considering proposals for the different options/sites with a public consultation components, before selecting the final option. The environmental screening process would consider pros and cons, local considerations, environmental impacts, as well as other factors. It would also provide rationale for the recommended option/site.  Consideration of a community based siting board could be an interesting option to assist in the process with local representation. Rules and responsibilities would have to be clearly defined. As noted above, the conservation authority model could be considered.  Requesting proposals for willing community hosts is another potential solution, but runs the risk of not having municipalities volunteer as willing hosts in the specific ‘energy’ region that is under review.

City of Guelph Recommendations to OPA/IESO Consultation on Siting Large Power Generation in Ontario July 15, 2013

Guelph’s Community Energy Initiative.

The City of Guelph’s Community Energy Initiative (CEI) calls for a 50% reduction in per capita energy use and 60% reduction in greenhouse gas emissions by 2031 – while growing in population by 50,000. The plan has aggressive targets in the areas of peak demand reduction, local generation and conservation/efficiency. The CEI is a long term local policy document that aims be fully integrated into municipal policy and programming with formalized community engagement.

Municipalities are increasingly in a position to offer real and tangible solutions to provincial electrical generation and distribution challenges in constricted areas such as the Kitchener-Waterloo-Guelph- Cambridge region.

A copy of the Executive Summary of the Community Energy Initiative is attached.

The City of Guelph is a founding member of QUEST (Quality Urban Energy Systems of Tomorrow) and shares their position. The submission from the City of Guelph is consistent with many of the recommendations made by QUEST.

Integrated planning processes, with shared knowledge of local growth and energy system requirements and collaboration between the province, municipalities, utilities and other community and energy stakeholders, will enable better discussions and decisions about what mix of energy resources are required and desirable to meet future needs, how they should be delivered and in what applications they should be used. An integrated, collaborative approach will ensure that our communities are resilient, adaptable, and have the capacity to deliver more energy services while at the same time minimizing environmental impacts.

Recommendations:

The City of Guelph recognizes that, for municipalities and their communities to play a credible and valuable role in Provincial-level regional energy planning, there must be clear framework for engagement and standards for participation. We therefore offer the following recommendations.

1. A Consistent, Integrated, and Horizontal Policy Framework: We applaud the Province in acknowledging a municipal role in energy planning. There is an opportunity to enshrine this acknowledgement through provincial policies that consider all energy needs, not just electricity:

50% of municipal energy end-use is in the form of heat. Local thermal distribution systems can efficiently and cleanly address this demand while providing local generation solutions through distributed Combined Heat and Power systems. This is a win-win for both local and provincial challenges.

Places to Grow legislation does not currently address energy and therefore does not adequately set the framework for Provincial support for local integrated energy systems. Further, aligning the Provincial Policy Statement to explicitly consider all forms of energy siting will provide municipalities with a mandate to get involved and incorporate siting into local planning processes.

2. Interministerial coordination and collaboration: Energy and land-use planning issues do not fit neatly within any one Ministerial or agency mandate – true horizontal government coordination will be required to address these issues – the ministries of energy, infrastructure, municipal affairs, economic development, environment, and transportation as well as agencies like the OPA and IESO all have a shared mandate and responsibility for these issues.

3. Clear rules and process: Communication and education regarding the process needs to be a priority, with clarity on the rules and process. Municipal capacity building will be required (for example to inform municipal planners about energy planning, and municipal planning education for energy and utility planners). There needs to be a clear understanding of the roles and responsibilities of various organizations responsible for energy planning in order to facilitate collaboration.

4. Engagement early and often: Instead of having required community engagement at the end of the siting process, introduce required engagement at the beginning of the siting process to determine the type, location and size of energy infrastructure. Community leaders and groups should be encouraged to provide input and act as informal liaisons between the broader community and those with formal input to the planning process – this includes consumer groups, the business community, aboriginal representatives and other community leaders and representatives

5. Municipal Role: Municipalities make all kinds of decisions that impact energy use, including land use planning, and investment in transportation, water and waste infrastructure. Municipalities should therefore have a formal role to play in the energy planning process. LDCs and utilities are critical players in the process but they do not in all cases represent municipal interests. Municipalities require additional resources and capacity to engage in community energy planning.

The City of Guelph recognizes that the local generation and conservation/efficiency targets embodied in the Community Energy Initiative need to seen as reliable and deliverable to electricity supply and distribution planners. We therefore recommend that the Municipal Energy Plans currently be considered as supportable by the Ministry of Energy be evolved into compliance based plans that provide assurance and credibility to the electricity planning process.

Garforth International llc Energy Productivity Solutions

City of Guelph Community Energy Plan  CITY OF GUELPH COMMUNITY ENERGY PLAN

  Final Report dated 16th March 2007

Prepared For Guelph Community Energy Plan Consortium Community Energy Plan

Garforth International llc Garforth International llc Energy Productivity Solutions Energy Productivity Solutions

City of Guelph Community Energy Plan   CITY OF GUELPH  OMMUNITY NERGY LAN C E P 11 Boshart Way, Toledo, Ohio 0, USA

 Page   Final Report dated 16th March 2007

Prepared For Guelph Community Energy Plan Consortium

Garforth International llc Final Report dated 3rd April 2007 Energy Productivity Solutions Prepared For  Guelph Community Energy Plan Consortium 

11 Boshart Way, Toledo, Ohio 0, USA Page  Garforth International llc Garforth International llc Energy Productivity Solutions Energy Productivity Solutions City of Guelph Community Energy Plan City of Guelph Community Energy Plan   ACKNOWLEDGEMENTS 2. EXECUTIVE SUMMARY The team preparing the recommended CEP would like to acknowledge the efforts made by the following groups, individuals, and organizations that have made invaluableFor over contributions two centuries, to the the ready availability of low cost energy has allowed the world’s development of the Community Energy Plan. industrialized countries to achieve unprecedented levels of well being and prosperity. Recent Guelph Community Energy Plan Consortiumdramatic increases in costs and price volatility are putting the spotlight globally on how Co-chairs effectively we use energy. The rapid growth of China and India is putting further pressure on Art Stokman, President, Guelph Hydro Electric Systems Inc. the world’s energy supplies and climate. Despite its plentiful energy resources, Canada is Janet Laird, Director, Environmental Services Department, Cityincreasingly of Guelph exposed to the full force of the global energy market pressures and can look Consortium Liaison forward to energy costs trading upwards combined with pricing uncertainty. Martin Lavictoire, Conservation and Efficiency Technician, CityThe of evidence Guelph is growing that the human use of energy is causing greenhouse gas emissions Representatives that are beginning to have significant effects on the climate. Recent opinion polls indicate that Astrid Clos, Guelph and District Homebuilders’ Association this is now viewed as the most critical issue for most Canadians, underlined by the renewed Karen Farbridge, Office of VP Research, University of Guelphpolitical / Mayor commitment to meet international greenhouse gas emissions targets. Ken Hammill, Friends of Guelph Mike Krewski, Channel Account Manager, Commercial/IndustrialOver Markets,half of the Union world’s Gas population lives in cities, and in Canada that proportion is closer to 0%. John Loncar, Account Manager, Commercial/Industrial marketing,Of all Unionthe energy Gas used in Canada, over half is for buildings, homes, and transportation within Janette Loveys Smith, Manager Community Development, Citycities. of Guelph Homes and buildings use over 0% of all energy in the country and consume more than Craig Manley, Manager, Community Design and Developmenthalf Services of all theDepartment, electricity. Cities are increasingly recognizing that the quality of life and City of Guelph competitiveness will in part be driven by how effectively they manage the use of their energy Don McLaughlin, Director, Maintenance & Energy Services, andPhysical water Resources, resources. University of Guelph Guelph’s leaders recognized the growing importance of effective management of energy and Gillian Maurice, Sustainability Coordinator, Physical Resources,water University to the economyof Guelph and environment, and in 00 formed a Consortium to proactively Peter Rodway, Wellington Catholic District School Board develop a community energy plan. The Consortium represents all facets of the community Charles Simon, Architect & Planner, Architecture Planning Researchincluding the administration, academia, business, the gas and electric utilities, and other Ian Smith, President, Guelph Chamber of Commerce community groups. In 00, the Consortium decided to formalize a long-term Community Tom Smith, Chief of Operations, Upper Grand School BoardEnergy (now with Plan the (CEP) Grand whichRiver would guide the city’s energy future for years to come. The CEP Conservation Authority) team had a balanced mix of local and global expertise ensuring the plan incorporated the best Robert Cameron, Manager of Plant Operations, Upper Grandelements School Boardof urban energy management from around the world. Rick Thompson, Board Member, Guelph Hydro Electric Systems Guelph, with its current population of 11,000, plus an additional 1,000 students during the Andrew Lambden, Guelph Development Association academic year, is a thriving town well situated in the “Golden Triangle”, an area to the west of Toronto that is attracting significant growth. Guelph’s population is expected to grow to Individual Acknowledgements 10,000, probably within its current boundaries, supported by significant commercial and industrial development. The participation and assistance provided by a large number of individuals and organizations who in various ways have given both their time and knowledge to assistIn rough the CEP numbers, project the has growth will add about 0,000 homes and somewhere between 00,000 been invaluable. and 00,000 square meters of non-residential construction, along with significant industrial growth. Participation in CEP Planning Meetings Dan Amyot, GIS Supervisor, Guelph Hydro Electric SystemsTo support this growth, the city has made a commitment to implement an energy plan that will Laura Bailey, Councilor, City of Guelph ensure the long-term competitiveness and environmental performance of the city. The Guelph Peter Cartwright, Manager of Economic Development Services,CEP City was of developed Guelph to be much more than an inspirational statement. It was created very much Lloyd Cummins, Department Head, Energy & Utilities, Physicalwith Resources, implementation University in mind. of For this reason the team looked at success stories from the USA, Guelph Canada and Europe to adopt the best ideas that had clearly worked elsewhere. All of these Janice Folk-Dawson, President of CUPE Local 1, Universitysuccess of Guelph stories underlined the need to take a long-term, multi-decade view and to have Peter Henderson, VP of Finance, Guelph Hydro Electric Systemscommunity leadership that ensured long-term, consistent implementation of the basic strategies Kathleen Hyland, Facilities Coordinator, Family Housing, Universityyear after of Guelphyear. Another key element was to see the energy supply of the city as an integrated whole.

11 Boshart Way, Toledo, Ohio 0, USA 11 Boshart Way, Toledo, Ohio 0, USA  Page  Garforth International llc Garforth International llc Energy Productivity Solutions Energy Productivity Solutions City of Guelph Community Energy Plan City of Guelph Community Energy Plan   ACKNOWLEDGEMENTS The overall vision of the CEP is simple: The team preparing the recommended CEP would like to acknowledgeGuelph the efforts will create made a by healthy, the reliable and sustainable energy future by continually increasing the following groups, individuals, and organizations that have made invaluableeffectiveness contributions of how we to use the and manage our energy and water resources development of the Community Energy Plan. This vision is supported by five goals that focus on the CEP’s role in attracting quality Guelph Community Energy Plan Consortiuminvestment, in ensuring reliable and affordable energy, in reducing environmental impacts, in Co-chairs enhancing Guelph’s competitiveness, and in aligning public investment with the CEP. Each has Art Stokman, President, Guelph Hydro Electric Systems Inc. recommended long-term measurements detailed in the plan. Janet Laird, Director, Environmental Services Department, City• ofGuelph Guelph will be the place to invest, supported by its commitment to a sustainable energy future Consortium Liaison Martin Lavictoire, Conservation and Efficiency Technician, City• ofGuelph Guelph will have a variety of reliable, competitive energy, water, and transport services available to Representatives all Astrid Clos, Guelph and District Homebuilders’ Association • Guelph energy use per capita and resulting greenhouse gas emissions will be less than the current Karen Farbridge, Office of VP Research, University of Guelph / Mayorglobal average Ken Hammill, Friends of Guelph Mike Krewski, Channel Account Manager, Commercial/Industrial• Guelph Markets, will Union use less Gas energy and water per capita than comparable Canadian cities John Loncar, Account Manager, Commercial/Industrial marketing,• All Union publicly Gas funded investments will visibly contribute to meeting the other four CEP goals Janette Loveys Smith, Manager Community Development, City of Guelph Craig Manley, Manager, Community Design and DevelopmentSuccessful Services deliveryDepartment, of these goals brings tangible financial and other benefits to residents, local City of Guelph business, the city administration, developers and builders, banks and investors, and the energy Don McLaughlin, Director, Maintenance & Energy Services, suppliers.Physical Resources, University of Guelph Guelph was an early pioneer in the development of community energy solutions by being a key Gillian Maurice, Sustainability Coordinator, Physical Resources,player University in developing of Guelph municipal energy distribution in Ontario 100 years ago. Taking the lead for Peter Rodway, Wellington Catholic District School Board the next 100 years is entirely consistent with this tradition. Today the city covers about ,000 Charles Simon, Architect & Planner, Architecture Planning Researchkm. The population of 11,000 is estimated to grow by at least % per year to approximately Ian Smith, President, Guelph Chamber of Commerce 10,000 by 01. Residential growth will be from a mixture of redevelopment in some older Tom Smith, Chief of Operations, Upper Grand School Boardareas, (now with and thenew Grand development River on greenfield sites. Industrial and commercial developments are Conservation Authority) planned in six areas around the city. Robert Cameron, Manager of Plant Operations, Upper Grand School Board Rick Thompson, Board Member, Guelph Hydro Electric SystemsToday, Guelph uses a total of ,00 gigawatt hours of equivalent energy (GWh ) from Andrew Lambden, Guelph Development Association e fuels of all types, or . megawatt hours of equivalent energy (MWhe) for every inhabitant of the city. If the heat wasted in the production of electricity for the city is Individual Acknowledgements included, the total rises to , GWhe or .1 MWhe /capita. This is the energy The participation and assistance provided by a large number of individualsdirectly and consumed organizations in the cities buildings, vehicles, and industries, and does not include who in various ways have given both their time and knowledge to assistenergy the usedCEP projectin ships, has airplanes, long-haul freight or other transportation. In general, the been invaluable. Guelph CEP focuses on the energy directly used in the city as this can be more easily influenced by community action. In 00 a total of 19. million cubic meters of water Participation in CEP Planning Meetings was pumped and treated. Lost water totaled approximately 1 percent of all water Dan Amyot, GIS Supervisor, Guelph Hydro Electric Systems Laura Bailey, Councilor, City of Guelph pumped. The average daily water demand was ,9 cubic meters. Peter Cartwright, Manager of Economic Development Services, City of Guelph Lloyd Cummins, Department Head, Energy & Utilities, Physical Resources, University of Guelph  Janice Folk-Dawson, President of CUPE Local 1, University of Guelph 2 Peter Henderson, VP of Finance, Guelph Hydro Electric Systemshttp://guelph.ca/uploads/ET_Group/waterworks/Waterworks_Summary_Report_00.pdf Kathleen Hyland, Facilities Coordinator, Family Housing, University of Guelph  11 Boshart Way, Toledo, Ohio 0, USA 11 Boshart Way, Toledo, Ohio 0, USA   Garforth International llc Garforth International llc Energy Productivity Solutions Energy Productivity Solutions City of Guelph Community Energy Plan City of Guelph Community Energy Plan   ACKNOWLEDGEMENTS The team preparing the recommended CEP would like to acknowledge the efforts made by the following groups, individuals, and organizations that have made invaluableThis use contributions is comprised to the of 0-0 litres per equivalent population per day for household use, development of the Community Energy Plan. with the balance being used by commerce and industry. Guelph’s climate, with over , heating degree days compared to only 10 cooling degree Guelph Community Energy Plan Consortium days, puts a high demand on space heating, and the plan addresses the heating alternatives in Co-chairs some detail. Art Stokman, President, Guelph Hydro Electric Systems Inc. Janet Laird, Director, Environmental Services Department, CityThe of CEP Guelph was developed using the following priorities: Consortium Liaison • Maximize the energy and water efficiency for buildings, vehicles and industry Martin Lavictoire, Conservation and Efficiency Technician, City• of Maximize Guelph use of heat generated in electricity generation and existing industrial processes Representatives • Incorporate as many renewable energy sources as feasible Astrid Clos, Guelph and District Homebuilders’ Association • Team with the existing electricity and gas networks to avoided wasteful duplication of assets Karen Farbridge, Office of VP Research, University of Guelph / Mayor Ken Hammill, Friends of Guelph Cities that systematically implement these principles year after year typically have energy levels Mike Krewski, Channel Account Manager, Commercial/Industrialat least Markets, half of Union the current Gas levels of Guelph, with all the associated economic and environmental John Loncar, Account Manager, Commercial/Industrial marketing,benefits Union that Gasthis brings. Janette Loveys Smith, Manager Community Development, City of Guelph On the first priority, efficiency, detailed assessments were made of the present ,000 homes Craig Manley, Manager, Community Design and Development Services Department, and 1. million m non-residential buildings by age and energy use. The needs for the future City of Guelph industrial energy use and transport fuels use were similarly assessed. Don McLaughlin, Director, Maintenance & Energy Services, Physical Resources, University of Guelph Following these priorities, the CEP recommendations are: Gillian Maurice, Sustainability Coordinator, Physical Resources, University of Guelph Peter Rodway, Wellington Catholic District School Board Use efficiency to create at minimum all the energy needed to support the growth Charles Simon, Architect & Planner, Architecture Planning Researchof the residential sector Ian Smith, President, Guelph Chamber of Commerce It is feasible to add about 0,000 homes with no net increase in energy needs and this is the Tom Smith, Chief of Operations, Upper Grand School Boardrecommended (now with the Grandtarget. River Ontario recently passed stringent new energy efficiency building codes Conservation Authority) that will be fully in force by 01. The CEP is recommending that the city explore incentives Robert Cameron, Manager of Plant Operations, Upper Grandand School other Board approaches to immediately implement the full code. This alone, combined with Rick Thompson, Board Member, Guelph Hydro Electric Systemsenergy efficiency requirements on major residential renovations creates all the energy needed Andrew Lambden, Guelph Development Association for growth. From 01 onwards, the CEP is recommending a steady annual improvement in energy Individual Acknowledgements efficiency of about 1% per year, which by 01, would be a level that aligns with global best practice from Scandinavia and Germany. The participation and assistance provided by a large number of individuals and organizations who in various ways have given both their time and knowledge to assistUse theefficiency CEP project to create has all the energy needed to support the growth of the been invaluable. commercial and institutional sectors Participation in CEP Planning Meetings Similarly, all the energy needed to support the entirety of the growth of commercial and Dan Amyot, GIS Supervisor, Guelph Hydro Electric Systemsinstitutional buildings energy needs can be met by the same combination of immediate Laura Bailey, Councilor, City of Guelph implementation of the new codes and efficient renovation. Peter Cartwright, Manager of Economic Development Services,Adopt City an of Guelphenergy performance labeling scheme for buildings as a voluntary Lloyd Cummins, Department Head, Energy & Utilities, Physicalinitiative Resources, for the University city, teamed of with Natural Resources Canada and a local Guelph mortgage bank, to act as a pilot for the whole of Canada to gain about 5% Janice Folk-Dawson, President of CUPE Local 1, University of Guelph Peter Henderson, VP of Finance, Guelph Hydro Electric Systemsincremental delivered efficiency Kathleen Hyland, Facilities Coordinator, Family Housing, UniversityThe CEP of isGuelph recommending that all new and existing buildings have an Energy Performance (EP) Certificate that guarantees the building’s energy consumption in normal operation at the

11 Boshart Way, Toledo, Ohio 0, USA 11 Boshart Way, Toledo, Ohio 0, USA   Garforth International llc Garforth International llc Energy Productivity Solutions Energy Productivity Solutions City of Guelph Community Energy Plan City of Guelph Community Energy Plan   ACKNOWLEDGEMENTS time the building is sold or even rented. There is no Canadian EP Certification at present. It is the subject of much discussion at a Federal level in Canada, and the recommendation is to offer The team preparing the recommended CEP would like to acknowledgeGuelph the effortsas a national made bypilot. the following groups, individuals, and organizations that have made invaluable contributions to the development of the Community Energy Plan. The recommendation is to model around an emerging approach being discussed in Canada that is an amalgam of the Canadian Energy Guide and the European Union approach. Guelph Community Energy Plan Consortium Co-chairs The experience in other jurisdictions is that this stimulates somewhat higher quality buildings Art Stokman, President, Guelph Hydro Electric Systems Inc. and a certain amount of “efficiency competition” between developers. Janet Laird, Director, Environmental Services Department, CityAdd of toGuelph Guelph’s attractiveness for quality industrial investment by offering world Consortium Liaison class tailored energy services and achieve annual investment growth rates higher Martin Lavictoire, Conservation and Efficiency Technician, City of Guelph than the underlying population growth, with no overall increase of the primary Representatives Astrid Clos, Guelph and District Homebuilders’ Association energy needed to serve the first fifteen years of growth. Karen Farbridge, Office of VP Research, University of GuelphIncreasingly, / Mayor industrial investors are looking at energy services as a key part of their decision on Ken Hammill, Friends of Guelph where to invest. The CEP is recommending developing tailored energy services for selected Mike Krewski, Channel Account Manager, Commercial/Industrialindustrial Markets, development Union Gas areas that not only deliver gas and electricity, but also selectively deliver John Loncar, Account Manager, Commercial/Industrial marketing,other energyUnion Gasforms such as compressed air, process steam heating and cooling, etc. Janette Loveys Smith, Manager Community Development, CityMeet of GuelphGuelph’s growing transport requirements while reducing the transportation Craig Manley, Manager, Community Design and Development Services Department, energy use by 25%, using sensitive urban design, effective alternative transport City of Guelph Don McLaughlin, Director, Maintenance & Energy Services, options,Physical Resources, and encouraging vehicle efficiencies. University of Guelph Transport fuels collectively represent 0% of all the energy used in Guelph, and account for a Gillian Maurice, Sustainability Coordinator, Physical Resources,huge University % of all of the Guelph greenhouse gas emissions caused by the city. The CEP recommends a Peter Rodway, Wellington Catholic District School Board multi-pronged approach that includes various measures to encourage more efficient vehicles, Charles Simon, Architect & Planner, Architecture Planning Researchurban design that reduces vehicle journeys, and focused attention on appropriate competitive Ian Smith, President, Guelph Chamber of Commerce mass transit. Tom Smith, Chief of Operations, Upper Grand School BoardMany (now ofwith these the Grandmeasures River were already being developed in detail in Guelph’s wider transport and Conservation Authority) urban planning. The CEP is underlining the importance of their success to meeting the overall Robert Cameron, Manager of Plant Operations, Upper Grandenergy School and Board climate change goals. Rick Thompson, Board Member, Guelph Hydro Electric Systems Andrew Lambden, Guelph Development Association Incrementally create energy distribution architecture in Guelph that will allow the majority of the city to be served with fuel choices that optimize cost, availability, and environmental impact long into the future. Individual Acknowledgements Over the coming years major changes will happen in energy and environmental legislation, fuel The participation and assistance provided by a large number of individualsavailability, and theorganizations viability of emerging alternative energy technologies and their relative costs. To who in various ways have given both their time and knowledge to assistbe able the toCEP achieve project maximum has benefit from these changes, the CEP is recommending a stepwise been invaluable. development of district heating networks covering the higher density areas of the city to supply Participation in CEP Planning Meetings space heating and domestic hot water. These networks also provide an efficient and economic Dan Amyot, GIS Supervisor, Guelph Hydro Electric Systemsway to distribute heat from a variety of existing and new energy sources. Laura Bailey, Councilor, City of Guelph In evaluating benchmark cities such as Mannheim or Copenhagen, we find that a common Peter Cartwright, Manager of Economic Development Services,feature City of of these Guelph very efficient and reliable energy and water systems was the existence of all Lloyd Cummins, Department Head, Energy & Utilities, Physicalenergy Resources, services University being supplied of by a single company. This avoids the inefficient use of primary Guelph fuel, and allows a rational integration of alternative energy sources. The CEP is recommending Janice Folk-Dawson, President of CUPE Local 1, Universitythis ofapproach. Guelph Peter Henderson, VP of Finance, Guelph Hydro Electric Systems Kathleen Hyland, Facilities Coordinator, Family Housing, University of Guelph

11 Boshart Way, Toledo, Ohio 0, USA 11 Boshart Way, Toledo, Ohio 0, USA   Garforth International llc Garforth International llc Energy Productivity Solutions Energy Productivity Solutions City of Guelph Community Energy Plan City of Guelph Community Energy Plan   ACKNOWLEDGEMENTS Within fifteen years, at least a quarter of Guelph’s total energy requirement will be The team preparing the recommended CEP would like to acknowledgecompetitively the efforts made sourced by the from locally created renewable resources following groups, individuals, and organizations that have made invaluableThe challenge contributions around to climate the change will increasingly turn the focus on renewable fuels as a development of the Community Energy Plan. viable and essential way to reduce greenhouse gas emissions. Currently the economic value of Guelph Community Energy Plan Consortiumgreenhouse gas reductions is zero, but this is likely to change as various market mechanisms come into force. Co-chairs Art Stokman, President, Guelph Hydro Electric Systems Inc. The CEP is strongly recommending a target to install the equivalent of a “Thousand Roofs” of Janet Laird, Director, Environmental Services Department, Citysolar of photovoltaicGuelph electricity. Consortium Liaison The heat demand of the area makes it a natural fit for integrating bio-mass heat sources Martin Lavictoire, Conservation and Efficiency Technician, City of Guelph combined with district heating to provide about 10% of the base load heat needs through the Representatives winter. The local wind quality makes energy from turbines marginal under the current Astrid Clos, Guelph and District Homebuilders’ Association technology. Last but not least, the growing need to find environmentally acceptable ways to Karen Farbridge, Office of VP Research, University of Guelph / Mayor manage municipal waste merits a rigorous assessment of the waste-to-energy potential. Ken Hammill, Friends of Guelph Mike Krewski, Channel Account Manager, Commercial/IndustrialTarget Markets, – At Union least Gas 30% of Guelph’s anticipated electricity requirements will be John Loncar, Account Manager, Commercial/Industrial marketing,associated Union Gas with Combined Heat and Power (cogeneration) by 2031. Janette Loveys Smith, Manager Community Development, City of Guelph Craig Manley, Manager, Community Design and DevelopmentAs Servicesthe city’s Department, energy evolves to include more district energy, it begins to include small and City of Guelph medium scale combined heat and power installations. Today Guelph’s 1, GWh annual Don McLaughlin, Director, Maintenance & Energy Services, electricityPhysical Resources, use in reality uses ,0 GWhe of fuel, the difference being lost as heat, creating non- University of Guelph productive costs and significant greenhouse gas emissions. By implementing CHP within larger Gillian Maurice, Sustainability Coordinator, Physical Resources,developments, University ofmuch Guelph of this heat can be effectively captured and used, creating major cost and Peter Rodway, Wellington Catholic District School Board environmental benefits. The CEP recommendation is to proactively seek CHP projects with a Charles Simon, Architect & Planner, Architecture Planning Researchtotal electric capacity in the to 100 MW range with a comparable level of heat recovery. Ian Smith, President, Guelph Chamber of Commerce Tom Smith, Chief of Operations, Upper Grand School BoardGuelph (now with will the reduceGrand River the magnitude of the summer grid electrical peak by at least Conservation Authority) 40% by 2031 to avoid the need for investment in new electrical infrastructure to Robert Cameron, Manager of Plant Operations, Upper Grandserve School the Board growth of the city Rick Thompson, Board Member, Guelph Hydro Electric SystemsOne of the consequences of growing prosperity and the norms of new construction is the Andrew Lambden, Guelph Development Association increasing use of air-conditioning, even though climatically there is relatively little need. The result is very high electrical demands for a few hours a day during the summer months. This Individual Acknowledgements peak drives substantial investments in underutilized generation, transmission and distribution assets by the electric utility. The participation and assistance provided by a large number of individuals and organizations who in various ways have given both their time and knowledge to assistThe cumulativethe CEP project effect has of many of the preceding measures including efficiency, cogeneration, been invaluable. heat recovery and solar PV will moderate and reduce the peak. Participation in CEP Planning Meetings Guelph will systematically create an integrated energy metering, billing and Dan Amyot, GIS Supervisor, Guelph Hydro Electric Systemsmanagement network across the entire city to allow cost-effective management of Laura Bailey, Councilor, City of Guelph all energy forms Peter Cartwright, Manager of Economic Development Services, City of Guelph Lloyd Cummins, Department Head, Energy & Utilities, PhysicalThe Resources, energy breakthroughs University of foreseen by the CEP arise as a result of seamless integration of Guelph energy efficiency along electrical, gas and district heating networks, with a flexible and, over Janice Folk-Dawson, President of CUPE Local 1, Universitytime, of changing Guelph mix of renewable and non-renewable energy sources. Such an approach Peter Henderson, VP of Finance, Guelph Hydro Electric Systemsrequires a high degree of management and data sharing across the different parts of the system Kathleen Hyland, Facilities Coordinator, Family Housing, Universityto deliver of maximumGuelph benefit. The recommendation is to establish a common data management and metering architecture within the city.

11 Boshart Way, Toledo, Ohio 0, USA 11 Boshart Way, Toledo, Ohio 0, USA   Garforth International llc Garforth International llc Energy Productivity Solutions Energy Productivity Solutions City of Guelph Community Energy Plan City of Guelph Community Energy Plan   ACKNOWLEDGEMENTS Guelph will implement large area high-efficiency Scale Projects that accelerate The team preparing the recommended CEP would like to acknowledgeprogress the efforts towards made by a the successful implementation of the CEP by creating early following groups, individuals, and organizations that have made invaluablesuccess contributions and developing to the a deep pool of community expertise development of the Community Energy Plan. All too often, CEPs fail to deliver due to a lack of sufficient scale and early success. The Guelph Community Energy Plan ConsortiumConsortium was committed to make sure that did not happen in Guelph. As a result, the CEP is Co-chairs recommending implementing neighborhood energy plans in relatively large, but bounded areas Art Stokman, President, Guelph Hydro Electric Systems Inc. of the city. Janet Laird, Director, Environmental Services Department, CityThe of plan Guelph is calling for the early identification and implementation of Scale Projects. Some Consortium Liaison specific ideas are included as part of the CEP, and include various business and industrial Martin Lavictoire, Conservation and Efficiency Technician, Cityareas, of Guelph the greenfield mixed use developments targeted for the south of the city, the University of Representatives Guelph Campus as a whole, and the revitalization of the St. Patrick’s Ward. These are offered Astrid Clos, Guelph and District Homebuilders’ Association as viable examples of potential Scale Projects. Karen Farbridge, Office of VP Research, University of Guelph / Mayor Ken Hammill, Friends of Guelph The CEP also recommends elements that will ensure long-term successful implementation. Mike Krewski, Channel Account Manager, Commercial/IndustrialMany Markets, Federal, Union Provincial Gas and local programs exist and the CEP is recommending the city John Loncar, Account Manager, Commercial/Industrial marketing,maintain Union information Gas and offer assistance to capture as many of these resources as possible. Janette Loveys Smith, Manager Community Development, CityThe of Consortium Guelph clearly recognizes that some of the measures proposed will require adjustment Craig Manley, Manager, Community Design and Developmentor interpretationServices Department, of regulatory or other legal constraints, and is committed to clear these kinds of City of Guelph market barriers wherever possible. Since many of these challenges will be of interest beyond Don McLaughlin, Director, Maintenance & Energy Services, Guelph,Physical theResources, CEP is suggesting that Guelph can be a national prototype as these market and University of Guelph regulatory structures emerge. A high priority in this area will be to establish the market Gillian Maurice, Sustainability Coordinator, Physical Resources,framework University of a of municipal Guelph energy service organization that is structured to ensure the highest Peter Rodway, Wellington Catholic District School Board reliability, least cost and least environmental impact energy services of all types. Charles Simon, Architect & Planner, Architecture Planning ResearchGuelph’s elected officials, business community, financial institutions, neighborhood groups, Ian Smith, President, Guelph Chamber of Commerce utilities, architects, developers, construction industry, academia and the city administration are Tom Smith, Chief of Operations, Upper Grand School Boardclearly (now with committed the Grand to theRiver vision, goals, recommended actions and progress of the CEP as a key Conservation Authority) measure of Guelph’s overall success in becoming a world class city in which to live, work and Robert Cameron, Manager of Plant Operations, Upper Grandplay. School Board Rick Thompson, Board Member, Guelph Hydro Electric Systems Andrew Lambden, Guelph Development Association In support of this, the CEP is recommending community and neighborhood groups be instrumental in ensuring Scale Projects are sensitively implemented and the energy and environmental goals are fully achieved. The CEP also presents an amazing opportunity for the Individual Acknowledgements University of Guelph and other colleges to build on the city’s commitment to the CEP by developing specialist areas of study, training and research such that Guelph will become a The participation and assistance provided by a large number of individualscenter ofand excellence organizations on the theory and practice of sustainable urban development. who in various ways have given both their time and knowledge to assist the CEP project has been invaluable. The goals that the CEP has established are intentionally very aggressive and are generational in nature. The CEP is strongly recommending the city put in place a regular reporting system to Participation in CEP Planning Meetings track the progress towards the goals and to share best practices with the community, both Dan Amyot, GIS Supervisor, Guelph Hydro Electric Systemsthrough conventional and electronic media, and as a regular topic at City Council Meetings. Laura Bailey, Councilor, City of Guelph Peter Cartwright, Manager of Economic Development Services,Guelph City isof already Guelph blessed with a number of commercial, non-profit and general interest groups Lloyd Cummins, Department Head, Energy & Utilities, Physicalas wellResources, as individuals University working of towards sustainability, energy efficiency and alternative energy in Guelph some way. The CEP made a first step to create an inventory of some of these resources, and Janice Folk-Dawson, President of CUPE Local 1, Universitythis ofshould Guelph be the basis of a developing resource database. Peter Henderson, VP of Finance, Guelph Hydro Electric SystemsDespite the anticipated growth of the population and increase in economic activity, the overall Kathleen Hyland, Facilities Coordinator, Family Housing, Universityfuel use of required Guelph by the city to deliver all its energy service will actually decrease from today’s total of , GWhe to ,1 GWhe in 01. This represents a decrease of greenhouse gas 11 Boshart Way, Toledo, Ohio 0, USA 11 Boshart Way, Toledo, Ohio 0, USA   Garforth International llc Garforth International llc Energy Productivity Solutions Energy Productivity Solutions City of Guelph Community Energy Plan City of Guelph Community Energy Plan   ACKNOWLEDGEMENTS emissions, currently at an estimated 1 tonnes per inhabitant, to about tonnes. This is still some distance from the ambitious goal, but at a level that is clearly putting Guelph among the The team preparing the recommended CEP would like to acknowledgetop energythe efforts performers made by in the the world. following groups, individuals, and organizations that have made invaluable contributions to the development of the Community Energy Plan. At the same time, Guelph will take its place as one of the most competitive and attractive cities in Ontario and Canada, with a core energy productivity expertise that will be sought out around Guelph Community Energy Plan Consortiumthe world. Co-chairs Art Stokman, President, Guelph Hydro Electric Systems Inc. Janet Laird, Director, Environmental Services Department, City of Guelph Consortium Liaison Martin Lavictoire, Conservation and Efficiency Technician, City of Guelph Representatives Astrid Clos, Guelph and District Homebuilders’ Association Karen Farbridge, Office of VP Research, University of Guelph / Mayor Ken Hammill, Friends of Guelph Mike Krewski, Channel Account Manager, Commercial/Industrial Markets, Union Gas John Loncar, Account Manager, Commercial/Industrial marketing, Union Gas Janette Loveys Smith, Manager Community Development, City of Guelph Craig Manley, Manager, Community Design and Development Services Department, City of Guelph Don McLaughlin, Director, Maintenance & Energy Services, Physical Resources, University of Guelph Gillian Maurice, Sustainability Coordinator, Physical Resources, University of Guelph Peter Rodway, Wellington Catholic District School Board Charles Simon, Architect & Planner, Architecture Planning Research Ian Smith, President, Guelph Chamber of Commerce Tom Smith, Chief of Operations, Upper Grand School Board (now with the Grand River Conservation Authority) Robert Cameron, Manager of Plant Operations, Upper Grand School Board Rick Thompson, Board Member, Guelph Hydro Electric Systems Andrew Lambden, Guelph Development Association

Individual Acknowledgements The participation and assistance provided by a large number of individuals and organizations who in various ways have given both their time and knowledge to assist the CEP project has been invaluable. Participation in CEP Planning Meetings Dan Amyot, GIS Supervisor, Guelph Hydro Electric Systems Laura Bailey, Councilor, City of Guelph Peter Cartwright, Manager of Economic Development Services, City of Guelph Lloyd Cummins, Department Head, Energy & Utilities, Physical Resources, University of Guelph Janice Folk-Dawson, President of CUPE Local 1, University of Guelph Peter Henderson, VP of Finance, Guelph Hydro Electric Systems Kathleen Hyland, Facilities Coordinator, Family Housing, University of Guelph

11 Boshart Way, Toledo, Ohio 0, USA 11 Boshart Way, Toledo, Ohio 0, USA   -‐-‐-‐-‐-‐Original Message-‐-‐-‐-‐-‐

From: Heather Stauble [mailto:[email protected]]

Sent: July 16, 2013 4:38 PM

To: [email protected]

Cc: [email protected]; [email protected]

Subject: Recommnedations -‐ Feedback

Regional Energy Planning and Siting in Ontario June/July 2013

Further to your request for specific recommendations, please note the following:

Guiding Principles:

Protection of Health, Environment and Economy

Preliminary questions: That the first questions that should be asked with respect to the any energy proposal are: Do we need it? When do we need it? Does it work? How well? Does it work when we need it? Does it work where we need it? Can it be stored? excess What are the ramifications of production? How much does it cost? What will be the health, environmental and economic impact on the community and the province?

Recommendations:In light of the legal actions threatened and initiated by proponents towards the public, municipalities and other bodies:

• That proponents who use legal intimidation directed at members of the public, municipalities, conservation authorities or the province be removed from consideration for approval by the province or municipalities.

In light of Supply and Demand information from IESO over recent years,

• That consideration be given to NOT offering any further OPA contracts.

Furthermore:

• That consideration should be given to staying any further approvals until the following conditions are in place: • The government has the ability to properly assess low frequency noise and infrasound • The government has the information to enable the safe siting of REA projects based on a health study, and the proper tools ( LFN test), a full review of recent peer reviewed science and existing setbacks in other jurisdictions • Demonstrated community and municipal support of the projects • Application and compliance to greater minimum setbacks to all noise receptors for projects based on the cumulative number of turbines proposed within a proposed area • Application and compliance to environmental setbacks set out in O. Reg 359-‐09 prior to November 2, 2012 • Increased capacity of the Ministry of the Energy, Environment and Natural Resources to fully review all applications and requisition peer review reports on all aspects of the projects. • Re-‐instatement of full individual environmental assessments • Require Low Frequency Noise, Infrasound and Audible Noise Reports on all projects with proposed turbines included in the assessments. • Require compliance to noise levels • Develop and implement mitigation measures -‐ to shut projects that are exceeding noise levels off during periods when noise is in excess of stated maximum levels and where there are consistent reports of adverse health conditions.

Going forward:

• That OPA/FIT NOT offer any further OPA/FIT contracts • That the public, municipalities and conservation authorities be informed of possible projects BEFORE any contracts are signed or offered to private landowners. • That proponents be required to provide detailed information and reports to the Municipal Council and the Community and consult BEFORE any contracts or offers are signed between landowners and/or OPA. • That there be OPA and Ministry of Energy and Environment personnel in attendance at all public consultations for energy projects. • That there be a greater focus on conservation • Reduce demand on grid by promoting small, personal energy generation and retrofitting through grants directly to businesses, home and building owners, municipalities for retrofitting, appliance replacement, self generation subject to health, safety, planning and environmental legislation and bylaws. • Focus on small -‐ self generating systems with planning and environmental review and controls to reduce reliance on grid, create small scale, local jobs and manufacturing. • Look at alternate, less intrusive forms of energy • That strong, demonstrated and informed community support be a condition of approval for energy projects. • That strong, demonstrated and informed municipal support be a condition of approval for energy projects. • That the intent of other provincial legislation, such as the Oak Ridges Moraine Act and Plan, be respected in its entirety. • That the Province recognize the public concern with respect to health concerns and peer reviewed research conducted on industrial wind projects • That the province increase setbacks to a minimum of 2 km to property lines for turbines up to 1.5 MW • Application and compliance to greater minimum setbacks to all noise receptors for projects based on the cumulative number of turbines proposed within a proposed area • Application and compliance to environmental setbacks set out in O. Reg 359-‐09 prior to November 2, 2012 • That the province amend regulation O reg 359-‐09 to provide for a minimum of 2km setbacks to the adjoining property line for turbines of 1.5MW • That O. Reg 359-‐09 be amended to reflect greater setbacks for larger turbines and based on the cumulative number of proposed turbines; and that proponents adhere to these setbacks without exception • That a low frequency noise testing protocol be developed, peer reviewed, approved and accredited before any more wind projects are approved. • That audible noise limits be decreased and considered an absolute maximum not to be exceeded. • That municipalities be provided with the resources and authority to request any and all reports deemed necessary to properly review energy projects • That municipalities be re-‐instated with the authority to pass bylaws which they deem necessary to protect their resident's health, environment, infrastructure and economy • That all planning tools and legislative instruments such as the Provincial Policy Statement, Places to Grow, Official Plans be amended to reflect municipalities authority to pass bylaws, request reports, peer reviews, letters of credit and granted the authority to approval and control siting of energy projects within their jurisdiction. • That municipalities be protected from proponents challenging municipal decisions at the Ontario Municipal Board. • That the Conservation Authorities Act be amended to re-‐instate the Conservation Authorities power to allow conservation authorities to deny permits to proponents where conservation efforts are negatively impacted • That Conservation Authorities be protected from their decisions to deny permits to proponents from being challenged • That all large scale energy projects be subject to full individual Environmental Assessments • That all environmental setbacks be re-‐instated and strict compliance to minimum setbacks be required. Rationale: setbacks are there to protect health, environmental and to mitigate against loss of life and economic loss in the -‐ case of hazardous events flooding. These setbacks should apply to energy projects as much as they apply to homes and businesses. The flooding of the Transformer station in Toronto in recent weeks is an excellent example of one reason these setbacks should be applied.... safety in all cases • That the same minimum setbacks apply to participating and nonparticipating landowners. • Planning authority include peer reviewed reports, additional reports, Bylaws re setbacks, health, noise, nuisance, traffic, dust • Community Liaison committees: Communities already have representation via an elected Councillor and MPP epresent to r their interests. Questions arise with respect to accountability; who decides the membership; rules of order; agenda items; budget; transparency; Choice of Chair. • Community Funds for Hosts: Money does not solve the problem. Peer reviewed health studies looked at people who benefited financially and they still got sick. Aramini, Nissenbaum; Grey Bruce Health Unit. Very poorly received at public consultations. • That properties within two kilometers be compensated and insured for lost property values Rationale: If in fact there is no loss, there is no risk and the companies should be prepared to back up this claim with their assets. If the opposite is true, then the project will need to provide compensation to those affected. This is required in other countries. • That municipal tax assessments on neighboring properties is lowered to reflect decreased properties. • No large scale solar or wind on viable farmland – including farmland class 4 – and above in many areas this is the only farmland. Removal of that land from agricultural use, grazing or hay production increases the costs of forage to local farmers who may rely of local, affordable forage crops for livestock. Solar companies have attempted to convince councils that their farmland is not viable when it has been used as grazing or in production for many years. Hundred page soil reports attempt to convince Councils that their land is “muck”. • Don’t sign contracts that have a financial or legal liability attached to them if approval is delayed • Do not develop large scale energy projects on private land • Do not allow community consultation without Ministry staff in attendance • Municipal taxes attributed to energy projects collected by the municipality should be directed into the local community where the projects are located and NOT to the municipality at large. Rationale: In large municipalities, taxes collected by the municipality and directed to an area that is not impacted by a project will increase division within councils as one area benefits at the expense of another area. • Siting Boards: Must be accountable – to public politically, financially, legally and health • Final REA documentation must be available to municipality and general public for the 2nd public meeting. • Allow longer period for full review after public meeting and municipal and public comment. • Public Consultation Report needs to identify attendance at public meetings, concerns and protect the privacy of the community. • Reports being reviewed in at EBR stage need to be available to the general public in hardcopy, at libraries, municipal offoces and on the – internet in all cases ie. wind, solar, biogas, water… • Existing REA submissions should be sent back for proper community review/public meeting operated by MOE prior to any new REA approvals. • Set-‐backs from roads and non-‐participating property lines must be greater to protect public from snow and ice throw, turbine collapse. • Implement routine noise testing based tely immedia after implementation and annually thereafter with results made public and reported to local municipalities. • A centralized provincial-‐level monitoring of noise complaints and tracking of steps taken to resolve the issues. • Formal reporting, testing and mitigation system for noise and electrical complaints. • Larger setbacks for larger turbines • Larger setbacks for multiple turbines • Provision of Fire, EMS by proponents – local Fire and EMS do not have capacity, training or equipment for high elevation escues r or fire • Process to receive, track and follow up on health -‐ summary results reported back through the local Health Boards. • Protection for children of participating landowners who are forced to live in houses that would otherwise considered by MOE to be too close to turbines. • Minimum 2km setback to property lines for schools, daycares, hospitals, nursing homes • Consideration for – predisposed conditions – autistic, seizures, • Rural road infrastructure – impact, costs, environmental • Drainage engineering to review drainage systems affected by the tower sites, roads and transmission lines. • Decommissioning of turbines – environmental, financial and legal responsibility-‐ letters of credit with municipality

Yours sincerely,

Heather Stauble

Councillor

Ward 16

City of Kawartha Lakes

From: Heather Stauble [[email protected]] Sent: Wednesday, July 24, 2013 12:20 PM To: Alexandra McDonough Cc: JoAnne Butler; Sylvia Kovesfalvi Subject: RE: OPA-IESO Regional Engagement Sessions - Draft Summary for Comment Attachments: Key Messages and Detailed Feedback (for comment) comments added.pdf

Follow Up Flag: FollowUp Flag Status: Flagged

Dear Ms. McDonagh,

Please see my previous comments below and your draft summary with additional comments attached.

In light of the short timelines, this is what time permits.

My chief concerns at this point are:

That the protection of human health, community and the local environment including the economic impact of any decisions on all parities be the cornerstones of any decision going forward.

That in the case of wind, a moratorium be called until: greater setbacks reflecting size and numbers of turbines has been implemented; full individual environmental assessments are required and completed; an appropriate low frequency noise test protocol has been developed, completed, peer reviewed and can provide the tools to properly and safely site renewable energy projects; and demonstrated municipal and community support can be assured.

That in the case of other renewables; that siting not conflict with other legislation and the protection of agricultural and water resources; full individual environmental assessments are required and completed; an appropriate tools to properly and safely site renewable energy projects; and demonstrated municipal and community support can be assured.

That municipal input include protection from the OMB and the OEB; the ability to request reports; the power to require financial security to protect the interests of the community and municipality; the power to pass bylaws; appropriate changes to the Provincial Policy Statements, Plans and legislation be supportive of the municipalities authority to make their own decisions.

That the Conservation Authorities Act be restored to allow conservation to be considered under the GEA; that protection be provided from the Mining and Lands Commission; and the Conservation Authorities be provided power to require financial security.

That legislation affected by the Green Energy Act be repealed.

The details on some of these suggestions such as Advisory Committees, Community Benefits to Hosts and Siting Boards are not yet available. I urge you to pause on any further approvals or announcements of new power initiatives and take the care to fully consult and consider that ramifications of the proposed changes.

In the rush to pull these comments together you may be making rash decisions. If there has been nothing else learned from the hurried implementation of the Green Energy Act, we should have learned that "haste makes waste". Real support, not constructed support, is critical to the acceptance and support of any energy project whether it be a gas plant, a wind project or a solar project.

We are currently in a energy surplus situation. There is therefore no need to rush forward and make decisions that place the province or municipalities in a position which carry financial and legal consequences Pausing and saying "No" to future energy projects before further consultation is an option which should be considered.

Yours sincerely,

Heather Stauble Councillor Ward 16 City of Kawartha Lakes

Common Voice Northwest Energy Task Force Please Join the Conversation - Regional Energy Planning and Siting In Ontario Contents • Who we are • Government mandate • Our Region • Regional Planning

History

• Ontario Forestry Coalition

• Forging the Future

• Common Voice Northwest • Series of Task Forces • Energy – 2007 Energy Task Force

• Membership • Operator of Ontario Hydro for NWO • Operator of an Ontario Nuclear Station • 2 Hydro Utility managers • 1 Retired Hydro Utility manager/energy consultant • Electrician • Economic Development Staff and Board Members • Municipal Elected Officials • NOMA • NOACC/Thunder Bay Chamber • NODN Energy Task Force

• Active in: • Integrated Power System Plan – phase 1 and 2 • Ontario Energy Board • IPSP • East West Tie • Regulatory matters • Atikokan GS Conversion • TB GS Conversion • Merging of Local Distribution Companies (LDC) Energy Task Force

• Role • Prime Energy Research Body in the Northwest • Inform on key energy issues: • NOMA • NOACC • City of Thunder Bay • Town of Atikokan • Advisor to Weiler, Maloney, Nelson on behalf of the above organizations ‘the experts up here’

Chris Bentley Minister of Energy

January, 2013 We were not invited! • first invitation to municipalities and other stakeholders • subsequent apology from Colin Anderson • reminder invitation – still no invitation Government Mandate 5.6.1 The Province, working with the Ontario Power Authority and licensed transmission and distribution companies, will identify investment opportunities in Northern Ontario’s transmission and distribution systems to maintain reliability, meet new and growing demands, and accommodate renewable energy generation. Grow North Plan 1110 KM Edmonton 1571 KM

1883 KM Kenora

Wawa Thunder Bay Ottawa

Toronto

Windsor Kenora

Wawa Thunder Bay Ottawa

Toronto

Windsor Kenora

Wawa Kenora

Wawa N.W.O. ELECTRICAL SYSTEM

TRANSMISSION DISTRIBUTION

REQUIREMENTS PLANNING

• vs NEEDS-ANALYSIS PLANNING REQUIREMENTS PLANNING • Starts on the premise that a problem has already been accurately identified and properly understood and that the proposed change will address the problem. •The planning that results involves selection of a process, structure or system that will bring about the change. •The final steps are the efficient implementation of the process, structure or system selected and an assessment as to whether it has been effective in addressing the identified problem.

NEEDS-ANALYSIS PLANNING • Needs-analysis starts with a broad inquiry as to what the end users or beneficiaries of the infrastructure actually need and should reasonably expect to have. • The planning that is involved turns on development of changes that can be expected to address the needs that the users or beneficiaries of the infrastructure have identified.

N.W.O. Experience The distinction between requirements planning and needs-analysis planning is useful because what the Northwest Region has not had, in relation to power system infrastructure development in particular, is adequate needs-analysis planning.

LOADS To 2016 Rubicon 2013 15MW 1250 t/day Cliffs 2016/17 - Open Pit 35 MW - 6-12000 t/day Noront 2016 50 MW 2700 t/day Rainy River 2016 Open Pit 61.2 MW 1250 t/day Osisko 2013 Open Pit 15 MW 1250 t/day Stillwater Open Pit 2014/15 10 MW 2016/27 55 MW 22,000 t/day Goldcorp 2014 60 MW

Claude 2015 15MW Bending Lake 2016 Open Pit 50 MW Treasury 2016 20 MW Northern Iron Open Pit 2016 60 MW LOADS 2017 and Beyond Premier 20 MW Rockex Open Pit 100 MW Panoramic Open Pit 30 MW PC Gold 20 MW REVISED OPA PROJECTIONS SINCE JAN 17 N.W.O. ELECTRICAL SYSTEM

TRANSMISSION DISTRIBUTION

July 15, 2013

Ontario Power Authority and Independent Electricity System Operator

Via email

Re: Ontario Dialogue on Regional Planning and Siting Large Energy Infrastructure

Thank you for the opportunity to present our views on regional planning for electrical power, and how the process for siting large energy infrastructure may effectively be carried out in future.

As a new process is extremely important to rural and small urban Ontario, we fully support a new integrated regional energy planning process that respects character, the contribution and needs of all Ontario communities -‐-‐ not just the large urban centres who are most in need of power.

We fully agree with support and the submission by Wind Concerns Ontario. In addition, we have the following comments, which focus mainly on the arge l wind-‐power generati on projects.

1. The present situation is dictated by the Green Energy Act

The way in which the siting of wind power projects is presently being carried out in Ontario is a disaster for rural Ontario. Huge, high-‐impact projects have been on forced communities by the Green Energy and Green Economy Act (GEA) without consideration of their impact on the local community or the environment.

Regarding the so-‐called “green energy”, it is not possible to "fix" the present process – especially regarding wind power; it is necessary to start with a new one. Clearly none of the following promises have come to fruition with solar and wind power: cleaner reduced carbon dioxide, air to improve health and “save the environment”, thousands of jobs in the province, cost-‐effective alternate energy.

o If anything industrial -‐scale wind development increases carbon dioxide, as -‐ back up energy such as gas is required for this intermittent source. Job increases were over -‐estimated in documents supporting the Green Energy Act by at least an order of . magnitude Those jobs that were created are generally -‐ low tech– even before complying to the World Trade Organization requirement to source parts out of Ontario. In the UK it has been reported that for every “green” job created, five are lost.

o There is strong evidence that more likely than not industrial at wind turbines the current setback defined in the Green Energy Act will negatively harm the health of those living far beyond the Ontario setback. Any setback regulations from any industry must be scientifically based, considering all reports. As such, the setback from wind turbines must be scientifically based, including all the reports since the GEA was made law in September 2009. This includes both peer reviewed and other. In addition setback regulations must start a property lines and not at the middle of a dwelling, in order to protect property rights of the people of Ontario. o The wind proponent should be forced to reimburse for lost property values of nearby properties as a condition of REA. [Denmark has legislation to this effect.]

o The negative effect on economy the of the proposed area in which the IWTs are imposed is not considered and the local municipalities e hav no say. Industrializing tourist communities will destroy the economy of that area. The effect of the turbines as well as the feeder and transmission lines should be considered.

o There is a potential large loss of municipal tax revenue once MPAC is forced to lower assessments on properties near IWTs; this has already occurred on Wolfe Island. This loss of income could have significant effect on affected municipalities.

o Regarding cost-‐effectiveness of solar and wind energy and the Green Energy Act, as Parker Gallant wrote in the Financial Post this month: That Act will cost Ontarians 10 to 20 cancelled gas plants.

Research in the U.K. is showing the life of the large turbines to be significantly shorter than was estimated. How will we rid ourselves of the non-‐functioning turbines? Will the provincial government guarantee their removal? T he municipalities, who had no say in their being built and generally fought keep to them out, should not responsible be for their removal and disposal. Even with Provincial guarantees, there is massive potential liability affecting all taxpayers, the Province budget and its credit rating. Meaningful security (Letter of Credit or equivalent) from the wind proponent is required to avoid a charge to provincial and/or municipal taxpayers. The likelihood of proponents avoiding this responsibility is real; at the time of deconstruction, it may not exist or may have been "sold" to a dummy company without assets.

2. Local zoning and municipal -‐ by laws should be respected (as stated on the “siting” . page)

o The GEA exempts renewable power generation facilities from land use planning control and zoning bylaws, development permit regulations, and official plans. As a result, municipalities have no say in projects. In effect, democracy is removed, especially for rural -‐ and small urban Ontario.

o Municipalities, with their elected officials, must -‐ have decision making power regarding the siting of all industrial projects – certainly including wind and solar projects. A consultative role is totally inadequate. The wind and projects solar have large impacts at the . local level

3. Existence and location of energy projects should be economically viable.

o A business model for each project should be prepared and transparent. This includes the provincial need, cost if given preferred usage, comparative cost to alternate power, transmission line issues, etc.

o Concerns about the economic impact -‐ of large scale wind power generation projects are described in the 2011 report from the Auditor General for Ontario, who said that there had never been a proper -‐ cost benefit analysis or business case study done for wind power generation. 4. An integrated approach to land use must respect preservation of the environment. Recently, the legislative protection f o endangered species that Ontario has created in the last 50 years has been bypassed.

o No industrial development should be permitted on environmentally sensitive land.

o Permits to harm kill, harm and harass endangered species should not be allowed.

5. Setbacks must be appropriate for the safety of people.

o Enforce existing setbacks for turbine clusters. Standards exist but are not enforced.

o Align set-‐backs from property lines and roads with manufacturers recommended safety zones.

o Review general -‐ set backs in context of large turbines. The Ontario setback was chosen when turbines were much smaller and quieter than the present ones. Current “best practice” is 2 kilometers (Australia and Quebec) with some studies suggesting 5 to 10 km deal with low frequency noise/infrasound. As new safety information is constantly generated, the safe setback should be reanalyzed at least annually, and as soon as possible after release of results from new health studies (such as Health Canada, Waterloo).

6. Health complaints must be followed , up following standard s protocol and clear processes.

o Subsequent to adverse health complain ts, formal noise reports are required, made during periods when maximum noise . is likely These should include the measure of low frequency sound as well as that in MOE protocol, effective immediately.

o Results of the noise reports should be compared to the noise model submitted to MOE for project approval.

o If permissible noise levels are exceeded, mitigation is essential.

o Specific consideration of sound sed levels ba on dBC is necessary in order to measure low frequency and infrasound.

o A clear protocol for the handling of health complaints is essential. The health complaints should be received by local health and units, put in a database central by a health body. The health body would ideally be Health Canada in order that health events from across Canada are included.

o Those with health complaints should be consulted directly and be heard by a panel to assess better ways to locate and operate wind projects. All complaints filed should be collated and analyzed. Epidemiological studies to evaluate adverse health effects should be designed and performed by a third party with expertise in the area. Trends, spacial/distance/infrasound etc. relationships should be zed analy and made public.

7. Regional plans defining local electricity needs.

o The short and long term energy requirements of the province must be clear. o The focus should not only be particularly on the situation of large energy projects in the province. More can be achieved through conservation and small projects.

Encourage geothermal, solar etc. on individual buildings – to supply that structure. This will reduce energy demands from the grid. One time building incentives will be far cheaper than long-‐term FIT payments to energy corporations.

Incentives for research into more efficient and small solutions effective storage should be encouraged.

o Imposing all energy generation only in rural areas is not appropriate.

o Large centres have large energy needs. The possibility of all centres to supply a portion of their power should be addressed– e.g., solar and small wind turbines on tall buildings in cities.

o Allow regions to select the approach to fill generation targets. Different types of energy generation are more suited to, and have less economic on impact different areas. If a rural area has a generating station or gas plant that far exceeds its energy demand, there should be no additional energy generation required by that area.

o The regional energy plan should be integrated with /link to the existing municipal/regional planning process. Energy projects need to be developed in context of elements local plans— schools, designated growth areas, tourist areas and environmentally sensitive areas such as major migration routes Important and Bird Areas as ( recommended by Ontario’s Environmental Commissioner).

8. Stakeholder groups to discuss this issue must include rural citizens as well as those in urban centres.

o Live meetings should be held near the communities where turbines are operating, who have experience with the programs, and in those where future turbines have been proposed. This would necessarily include “unwilling hosts”.

9. Clarification is needed regarding which government department(s) and/or agency volved is in in the siting process, including those responsible in the case of a legal challenge and appeal.

10. No new projects should be approved until the new processes regarding Regional Planning and Siting Large Energy Infrastructure are in place.

o As there no are immediate needs for more power, there is no urgency to approve/build new wind-‐power generators. And wind turbines are creating a growing potential liability for the province to fix later, regarding individual property rights, human health, deconstruction costs, municipal tax base, to name a few.

Thank you again for the opportunity to contribute to this dialogue. It comes at a critical time, when energy projects are being imposed on communities against the wishes of the elected local government, without consideration of local needs and economies.

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