I appreciate the opportunity…

I appreciate the opportunity to submit comments and concerns regarding this proposal. I am a citizen of North Stormont. I attended and participated as a witness in the recent Environmental Review Tribunal (ERT) process pertaining to the NationRise Wind project. The Conservative government promised us that if we voted for them, "Help is on the way". We helped you to get your majority but we are still waiting for help in return. NationRise IS PRE-CONSTRUCTION. Yet somehow it is still moving forward AND this proposal would grandfather it under the old rules leaving our municipality and our citizens without any democratic rights. We are being stripped of the basic human right to enjoy good health and the peaceful enjoyment of our properties that we worked very hard to establish. This is NOT in the public interest and it is NOT what was promised.

It also very important to note that there was a lot of information provided at the ERT by our experts and witnesses. Information that was NOT provided or included in the proponent's documentation or investigations. The Chair of the Tribunal acknowledged these were very valid concerns in her final ruling - but dismissed us anyhow based on the restrictive rules of the tribunal process. Also of note, the Ministry's OWN EXPERT WITNESS testified that he had many concerns with this project and that he felt the proponent had "tried to get away with" cutting corners. He did not feel their investigations or risk assessments were sufficient. He prepared a list of concerns and a list of recommendations to the Ministry - conditions he felt should be factored into the approval process. The Ministry chose to ignore his concerns and he confirmed under oath that NONE OF HIS RECOMMENDATIONS MADE IT INTO THE REA AS CONDITIONS. The government, under the Liberals, chose to ignore their own experts and approve. As the ERT brought all of this extra information to light but the tribunal chose to allow the REA to stand as is, the current government, under the Conservatives, will be opening itself up to LIABILITY when and if the concerns raised throughout the ERT process come to pass. The Liberal government chose to ignore the obvious concerns with this project - and if the REA is not revoked by the new government knowing what they know now as a result of the ERT, they will be equally complicit and open to LIABILITY.

The following was prepared by a fellow citizen in our Township and, with his permission, I am adding it here as it accurately reflects my concerns as well.

In General:
 Thank you for the opportunity to comment. The Repeal of the GEA and restoration of planning authority to municipalities going forward is welcomed in general. Grandfathering of existing negative aspects IS NOT in the public interest and perpetuates significant harm to the detriment of the current government and the citizens who voted for change.
 When the terms UNNEEDED, UNWANTED, HARMFUL, INEFFECTIVE AND EXTREMELY COSTLY apply to any renewable energy project then citizens must rely on governmental regulations to protect them. This proposal is harmful to citizens of Ontario and NOT in the public interest.
 It would be advantageous for the policy, regulations and laws, to reflect exactly what “renewables” mean in legislative and real terms for the people of Ontario. For example, I have heard that hydro electric generation / water source was removed from the definition of renewables by the former government yet what could be more green and cost effective than already paid-for and in place hydro electric generation?
Continued Applicability:
 The PC party has been my party and that of the majority of residents of SD&G since elected into power in this riding in 2011. ERO 13-4265 applicability to pre-construction projects targets SD&G specifically and unfairly as Nation Rise Wind Project is the only existing LRP1 pre-construction project. It is a project with outdated noise guidelines and a highly conditional REA due to known gaps and shortcomings rushed through in the last days of the former liberal government. As such it is not in the public interest to grandfather it until the issues are addressed and current standards applied.
 There is a huge distinction between industrial wind and solar farms and those for home use. There is no conceivable justification to exempt those for home use from municipal planning and control and even less so for industrial scale projects such as Nation Rise Wind Farm which is solely for the benefit of a large multinational corporation and against the public interest of all people of Ontario; in particular the voters within SD&G, North Stormont Township and our MPP.
 This ERO is to the detriment of, and against the public interest of those already living under Industrial Wind Turbines. It goes against the core themes of what Progressive Conservative Party MPP’s have been saying and promising since 2009, while in opposition.
 The PC government election platform promised to cancel all-preconstruction projects. It was a commitment to integrity and the voice of the people. To do otherwise will reduce PC Party political integrity to the level of that of the former government and also risk human and livestock health thereby exposing the current government to liability from knowingly grandfathering outdated noise regulations from 2008 that have been recognized as inadequate and have since been updated by Canadian and International Standards bodies.
 The Minister has an obligation to act in the public interest; which may not necessarily be in the best interests of a specific commercial entity operating in violation of, or in the absence of measurable controls. The large number of unresolved complaints due to Industrial Wind Turbines clearly demonstrates that allowing ‘projects under review’ to continue under the old terms of the Green Energy Act would clearly not be in the public interest.
 Similar to mercury, tobacco, asbestos, thalidomide, lead; There is evolving awareness of the harmful effects of industrial wind turbines as applicable to EMF, stray voltage, infrasound and low frequency sound on human and animal health and the natural environment. There are thousands of unresolved complaints yet the amount of unmeasured and unregulated low frequency and infrasound grows proportionally larger with turbine size and height. It would be negligent, rash and imprudent to allow any construction to proceed until the root cause of these issues become clear.
 Existing industrial wind turbines were forced on unwilling hosts and residents without any sort of a plebiscite, referendum or agreement from the community. Approval of ERO 13-4265 and the proposed transition regulations places the Ministry of Municipal Affairs and Housing in a position of responsibility for continued harm and on notice of legal liability on most existing issues and from those deemed pre-construction yet allowed to proceed.
 More critically, it condones the harmful prior government policies in the case of pre-construction projects grandfathered under the old GEA siting, setback and outdated noise guidelines, before they are even built.
 It is not the responsibility of the Ministry of Municipal Affairs and Housing to oversee renewable energy projects nor to respond to citizen complaints from Industrial Wind Projects, nor is it equipped to do so, yet by sponsoring this ERO 13-4265 it moves significant accountability and legal liability from the MECP to the Ministry of Municipal Affairs and Housing, if approved.
 Problems with turbines also need to be addressed by aggressive enforcement of existing approvals and regulations by the Ministry of the Environment, Conservation and Parks. Stop orders should be issued against all turbines generating adverse effects for residents. Low frequency or infrasound effects must be considered in determination of adverse effects.
 Night time noise needs to have a hard upper limit (no more than 35dba) for a single occurrence, ergo, no averaging over time or flexibility based on wind speed as it is the impulsive nature of noise that disturbs sleep and threatens health.
 This must be supported with measurements, tools, standards and technology to adequately address residents’ complaints including and in particular for low frequency and infrasound.
 No new or in-process projects must be allowed until INDEPENDENT verifiable controls are in place.
 The MECP must establish tools, training and protocols to measure and assess low frequency and infrasound impacts especially within homes NOW in order to help resolve outstanding complaints of in operation projects.
 No new construction can be allowed to proceed before the tools, training, and protocols are established and proven effective by resolving in-operation complaints.
 Victims should be removed immediately from toxic environments as you would do with any health or environmental concern until the root cause is identified and remedied. The perpetrator should compensate the victim through an escrowed account managed by the Ministry
 The wind industry is unregulated and unlicensed. Resolving complaints expeditiously must be a condition of an annual license to operate for existing projects and a standard condition of all future contracts.
 Stop orders must be issued against all non-compliant turbines under at least two scenarios.
o (1) triggered by periodic but random measurement by the MECP, or
o (2) if generating complaints due to adverse effects for residents.
 Any non-action due to claimed frivolous or vexatious complaint must be fully documented and justified in a public forum and reported to the AG, forming a part of their regular reports.
 Considering the high number of outstanding complaints over a long period spanning decades, there appears to be a pressing need for an independent arm’s-length Industrial Wind Turbine Ombudsman established to manage and resolve Ontarians complaints and concerns.
o The Office must be able to make binding decisions, protect citizens from arbitrary lawsuits by proponents, assess and award costs to affected residents in order to correct the huge imbalance in financial and legal resources between residents and local opposition groups and those of multinational proponents supported by industry lobbyists.
o First priority would be those wind turbine operating under the old GEA
o New construction including those deemed holding a REA but pre-construction cannot allowed to proceed until this safeguard to the public interest in place and functional
 In the case of recently approved yet pre-construction projects, the revised Wind Turbine Noise Guidelines must reflect the most current Canadian and International standards – (currently IEC/CSA 61400-11, 2013) rather than allowing the option to use the outdated Wind Turbine noise guidelines from 2008, over a decade ago, which were identified as inadequate to protect human health & the natural environment.
 I fail to understand why this PC Government has NOT halted proceedings on Nation Rise as it is still pre-construction nor why Romney Wind LRP1 is proceeding construction despite a major announcement of cancellation of over 750 other projects . Politicians cannot continue to ignore mounting evidence of health concerns and the negative impact on the environment, as a result of industrial wind farms. In my view, a complete moratorium should be issued on all new applications for renewable energy, as well as those applications pre-construction or under present review. This would allow for extensive and much-needed research, a complete cost-benefit analysis and time to put protective regulations, standards, guidelines, tools, processes and procedures’ into place while focus in placed on renegotiating and resolving issues with those presently in operation.
 Industrial scale wind and solar have been forced on unwilling municipalities, residents and neighboring landowners in Ontario by dint of government contracts with proponents, government regulation and without any form of compensation.
A Guiding Principle. - Affected municipalities and non-participating landowners should not themselves have to directly pay for the decisions of government in which they had no choice and should be compensated, if resulting from a governmental policy decision deemed in the greater good.
o Despite the questionable parameters and resultant findings of the now aging study performed several years ago by MPAC; a study done at the behest of the former liberal government, realtors confidently attest that in their experience there are 10 – 30% typical losses in value for properties located within and adjacent to an industrial wind project. In addition, I am personally aware of a number of lawsuits for non-disclosure of wind projects and of a signed letter by one elderly couple who had to take a significant reduction in an already negotiated home sale merely because of the buyer became aware just before final signature of a potential though not yet approved REA.
o Research done in 2016 by the partnership of Clarkson University and Nanos Research on U.S properties with a view of Wolfe Island wind turbines showed an overall property value loss of 15 per cent for homes “with a view” of the turbines. Older research done by Ontario real estate appraiser Ben Lansink in 2012 found a more dramatic reduction for properties closest to turbines, an average loss of 37 per cent.
University of Guelph associate professor Richard Vyn found a property value loss in communities opposed to wind power projects of 8.98 percent for houses within 2 km of turbines, and 8.62 per cent for properties within 4 km, post-construction of turbines. Lesser reductions were found in communities non-opposed but that can also be attributed to lack of public awareness and biased promotion by proponents and vested interests.
For the Nation Rise power project in North Stormont, there are 828 properties within less than 1,500 metres of turbines according to the wind power developer, Portugal-based EDP, and approximately 2,500 residences within 2 to 5 km of the turbines, according to community group Concerned Citizens of North Stormont. The houses within 1,500 metres of a turbine in the “Nation Rise” project could see a loss of $21.8 million using professor Vyn’s estimate, $37 million according to Clarkson-Nanos, or as much as $91 million in losses using Mr. Lansink’s calculations.
Given the above, the financial cost from lost opportunity due to businesses, non-profits, and residents that will not want to relocate to communities in the vicinity of industrial wind farms or loss of tax base from successful future appeals or even those who quietly move away either abandoning their homes or selling at a reduced cost is not easily calculable but estimated to be in the many hundreds of millions, well beyond any possible compensation to renegotiate or cancel agreements with proponents.
 The Ministry of Municipal Affairs and Housing must be prepared to compensate municipalities for this loss plus the very real cost of dealing with complaints, administration, proponents impacts to infrastructure, and local residents, especially if approving projects that are pre-construction at this time and even more so if grandfathering outdated regulations and noise models.
 The Ministry of Municipal Affairs and Housing, if approving this ERO 013-4265, must be prepared to compensate residents and owners for the very real cost of value to property, livelihood and quiet enjoyment of property.
Major Changes or Expansion:
 The scope of restoration of municipal authority is too narrow. Municipal controls must apply to ANY expansion of scope, location or upgrading or replacement of turbine components or repowering as well as any construction of roadways, access ways or transport of materials needed for any purpose, including routine maintenance or repairs.
 Any expansion or upgrading or replacement of turbine components or repowering as well as any construction of roadways, access ways or transport of materials needed for any purpose, including routine maintenance or repairs must consider then current noise, environmental and setback requirements with current applicability of O:reg 359/09
 The existence of municipal regulations for any changes in scope, expansion, location, upgrading, repowering or major repairs must be a mandatory requirement so that decisions are well thought out and considered, so as to not have orphans, precedents and exceptions that cannot be regulated in future.
 As such, Municipalities with citizens that want renewable energy would be incented to establish regulations as a priority and those that do not are protected from undue pressure