Comments on: New regulation…

Comments on: New regulation under the Environmental Protection Act to close the White Pines Wind Project, ERO number 013-3835.

General Comment:

1. I support this legislation, and most of the proposed regulation to decommission the White Pines Wind Project.

Specific comments dealing with road stream crossing between Turbine 1 and 2, at 43.923108° N, -77.097059°. These comments are made based on my professional expertise as a fisheries and habitat biologist:

2. During construction of the White Pines Wind Project a culvert was placed at the stream crossing at this location (43.923108° N, -77.097059°). This stream crossing exists on the historic farm lane. The lane and crossing will likely continue to be used for the farm after the White Pines Wind Project is closed. I recommend retaining this culvert to minimize further impacts to aquatic organisms and habitat. Rainbow trout and white suckers migrate from Lake Ontario to spawn in this stream. Although not documented by OMNRF, I have recorded video and photos of juvenile and spawning adult rainbow trout in this stream.

OMNRF and OMAFRA have spent thousands of dollars to update farm culverts at stream crossings in Prince Edward County. It would be a shame to spend money to remove the culvert in question when the people of Ontario are paying to have others replaced.

3. Likewise, the electrical cable should be left in situ at the stream and in the appropriate buffer zone on either side to minimize impacts to aquatic organisms and habitat.

4. The stream was illegally dammed with straw bales downstream of the culvert when the farm lane was reconstructed. The REA does not allow such infractions. These bales should be removed before winter. Currently, they are not causing serious impact because this portion of the stream is dry. It runs underground due to the karst geology, and emerges about 140 m east. However, during high flow, especially spring runoff the surface channel has streamflow. At that time, I expect the straw dam to initially hold back silt (it is supposed to be a silt trap), and then, the dam will fail, allowing the silt to move downstream in a deleterious glut. One does not need to wait for the completion of this ERO to remove this illegal dam.

Specific comment dealing with deconstruction of the White Pines Wind Project relative to Blanding’s turtles:

5. The White Pines Wind Project is detrimental to the survival of Blanding’s turtles, especially in the current location, because these local populations are smaller and more at risk than those along the south shore. I my opinion as a professional biologist, the total impact of the project on Blanding’s turtles outweighs the increased risks associated with deconstruction. Accordingly, timing restirctions for work in Blanding’s turtle habitat should be waived, and deconstruction of the White Pines Wind Project should be completed as fast as possible.

6. Some of the road gravel should be retained to create Blanding’s turtle nesting habitat. This should be done under the direction of OMNRF Blanding’s turtle experts. This could help to mitigate impacts of the project on Blanding’s turtle populations.