To: Ministry of Environment…

To: Ministry of Environment, Conservation & Parks

Re: White Pines Wind Project Termination in PEC, ERO #013-3835 / Draft Regulation (DR) & Draft Technical Closure Document (DTC)

The proposed project, though incomplete, has created considerable damage to an area south of Royal Road, an area paradoxically deemed environmentally sensitive by an environmental review tribunal prior to the hasty attempt to complete the project, even prior to final approval.

The greatest of all concerns has been for the disregard for water, both surface water and well water. The access road to the substation was built adjacent to a lot line and underwent extensive excavations of limestone and drainage changes that have impacted our pond along side it (police reports attest to how even trespass occurred to change water course). In the end, water has been redirected from draining directly into a pond which maintained otters and beavers along with turtles as a natural habitat.

A huge pile of debris sits adjacent to the access road and must be removed and surface water drainage to the pond will have to be re-established, such that access road would have to be removed adjacently to facilitate water flow directly as previous.

Further south, culverts were placed which are far too small and have been backed up with water prior to the wet season and must be removed along with the obstacle of the access road which was built far above the former lay of the land and hinders free flow of water as previous - a stream in season that passed along lot line and onto our property and adjacent to our well and for over a century for livestock and to spray crops, etc.

Blandings Turtles were identified in these wetlands prior to construction and it is an infringement of their habitat to not remove and restore to original the built up area. Further, it compromises the natural course of water to our well.

The actual location of the substation is of great concern, it is only a short distance from the adjacent lot line and its construction involved weeks of limestone fracturing, which may have compromised ground water flow from our well, to the extent which will be known only in extreme dry periods, for a well that has never been in its history this is potentially of great concern.
The materials above the substation site are not just obstructions to views which must be removed (such as posts, electrical transmission hardware, etc) but includes transformers, the oil and contents of which are notoriously long term sources of careful scrutiny and maintenance to prevent environmental consequences / contamination and of course must be removed in their entirety and safely.

Again, the impact of the substation site potentially on water, especially our well, could be catastrophic! The potential environmental concerns long term must be thoroughly prevented by removal of all materials, confirmed by a third party, now or the consequences in the future will have far greater costs and liability.

Termination should deem this project of no future consequential impact so the roads affecting drainage to the pond and stream must be removed along with all materials at the substation location with no exceptions!.

Re: DTC 4.2.1, 4.31. 4.41 etc. “Unless the Company and the landowner have a written agreement that provides for another arrangement…” This wording would preclude removal of the concrete foundations for the substation, or removal of the new access roads or removal of the other materials and must be corrected so that as per decommissioning can be effected and remedy be made now, especially considering water course changes, well infringement and Blandings Turtle habitat changes all affected on our property as a result of work literally on the other side of the fence.
Re: changes to ground water / surface water flow to our pond, stream, well all have been affected and can only be remedied by access road removal and typographical changes remedied to original to facilitate water movement.

Compensation in lieu of correction would not allow for our pond’s water levels, nor the security of our well water or Blandings Turtle habitat to be restored and pose considerable long term costs of monitoring our well water indefinitely into the future.

Hence, DTC site Restoration 5.1.1 – The company shall (a) where natural features have been disturbed by construction or closure activities restore the natural features previously found in the project location and the 120 m Zone of Investigation to the state that existed before the construction and closure of the facility started and (b) preserve the current natural features found in the project location and the 120 m zone of investigation that have been disturbed by construction.

Re: DTC 6, Storm Water Management, Erosion and sediment Control & Surface Water Monitoring – Assessment of water bodies formerly were done when conditions were driest and were not as result reflective of true impact on water flow or map of water bodies. As a result alterations to topography have impacted our land’s water resourced literally across the fence from an access road.

DTC 6.13 – The company shall ensure that closure activities are located a minimum of thirty (30) meters from the high water mark of water bodies - This last comment would completely exclude the access road to substation as it is completely through wetlands and was placed over sensitive area to begin with, and directly affects our well, stream, and pond as well as influencing their water levels and poses long term contamination / monitoring issues which must be resolved or compensated and also cause huge back up water on other side of culverts under road. “Wells and ground water” should be added to DTC 6.1 Damage and Impacts and DTC 6.11 Storm Water Pollution.

Lastly, the anemometer tower on the land south of Royal Road must be removed as there will be neither need for it nor anyone taking responsibility to maintain it after termination of this project.