Zeljko Romic Senior Program…

Zeljko Romic
Senior Program Support Coordinator
Minister of the Environment, Conservation and Parks
Environmental Assessment and Permissions Division
Client Services and Permissions Branch
135 St. Clair Avenue West 1st floor
Toronto, ON
M4V 1P5
Dear Mr. Romic
Re: EBR 013-3835, Technical Requirements for the Closure of the White Pines Wind Facility

The draft Technical Requirements say that the existence of a written agreement between the Company and the landowner may allow some of the components of the White Pines Wind Farm to remain at the sites after the closure or decommissioning has been completed.

The Wpd original Decommissioning Plan did not include the provision for any components to remain with the exception of the access roads, electrical distribution/collector lines and the possibility of below grade wind turbine foundations.

The original Decommissioning Plan was created prior to the identification during the Environmental Review Tribunal (ERT) hearings and the decision by that ERT panel that the access roads, crane pads and turbine foundations will cause serious and irreversible harm to Blanding’s turtles. To overcome this threat, stringent mitigation measures were required at all project sites (where there will be wind turbine foundations, access roads, crane pads, transformer foundations) during the life of the project.

The Technical Requirements only call for the Company to continue these mitigation measures while closure activities are still ongoing .

It is highly improbable that the mitigation measures would be continued after the completion of the closure. Allowing these components to remain after decommissioning will cause serious and irreversible harm to the Blanding’s turtle.

Modify the Technical Requirements to ensure that all of the project components identified to be a threat to a Species at Risk be dismantled and removed from the project location. These components are the access roads, crane pads, wind turbine foundations (above grade).

It is essential that the access roads and crane pads be removed. Turbine and turbine transformers foundations must be removed to below grade. All wind turbine components should be removed from the location and their value realized by salvaging and use at another location, recycling or sold for scrap.

Section 7 of the Regulations should be the modified to include sections from the Environmental Effects Monitoring Plan 2.0 Post Construction Monitoring Plan 2.2.5 Natural Habitat and 3.0 Adaptive Management Program 3.2.2 Habitat. Section 7. (2) (a) of the Regulations should be revised – (a) monitor natural features, agricultural land and road allowances affected by the construction and closure of the facility.

In addition to the wind energy project components listed above there is a Meteorological Tower (MET) which is part of the White Pines Wind Energy Project but was not included in the REA. WPD originally erected two (2) MET towers to be associated with the project. One tower has been removed . One tower remains . The tower and cables that associated with the tower are a hazard to birds and should also be dismantled, lowered and removed from the project location. The removal of the MET tower should be added to the Technical Requirements Schedule A 1. (1) 2.

All of the access roads and crane pads, within the project area, are located in or adjacent to Blanding’s turtle habitat and bird staging and/or nesting areas.The wind turbines, foundations, access roads and crane pads should be dismantled, removed and the sites restored during the non-active period for Blanding’s turtles (October 16 to April 14) and before the main bird migration period.