Comment ID: 210830 These…

Comment ID: 210830

These comments are prepared after review of the “Draft Site Plan Report” for the Otter Creek Wind Farm LP (the latest version posted on the company website). The noise assessment report points out a conspicuous fact about the justice (equal gain and pain) from this proposed development. The assessment identifies 8 participating receptors within 2000 metres of the nearest wind turbine, while there are 1488 non-participating residents within the same radius, who will receive the adverse impacts. The Draft Site Plan Report notes that the tip of the 12 proposed turbines (Enercon E-141) will stand some 199.5 metres above the terrain. Applying the assessment of whether a penalty for a “concave ground” situation would occur, the quoted section from the Ontario guidelines (section 6.4.10 d) points out that a penalty would only apply if the depth of the concave depression between the wind turbine (at 199.5 metres hall, and a receptor’s home, at typically less than 3 metres for a 1 story home) would require a depression deeper than 1.5 x [199.5m – 3m]/2 or 147.4 metres existed. This means the Ontario regulations would only require a correction in the event of a depression nearly 3 times as deep as the Niagara Gorge. Given that residents at the K2 wind farm have noted that winds in the direction where they pass over a concave depression under 10 metres are more bothersome in their annual monitoring of wind turbine annoyance demonstrates how ineffective the Ontario Regulations are at protecting citizens. Equally, there are other aspects of the Ontario Regulations for wind turbine siting that have been demonstrated as ineffective. Citizens have filed many (freedom of information requests show the number is in the thousands) complaints based on: -sleep deprivation (identified in many studies as having adverse health effects) -tonal noise (resulting in no action by Ontario regulators for periods of years, even when identified by third party monitoring) -cyclical noise, that makes a 40 dBA average value meaningless -noise levels far above background values Demonstration is clear through complaints filed by citizens that the regulation based on a time averaged value of 40 dBA is not effective at protecting citizens, Submissions to the Environmental review Tribunal that projects will exceed even this 40 dBA value have been struck from testimony on the statement on the basis that a wind operator is required to demonstrate compliance with the regulations. However, the Enbridge Underwood project has been collecting data for nearly 10 years since the turbines first started up without having enough data to show if the turbines are in compliance Equally, three separate assessments have been unable to collect sufficient data to show the single Enercon – E-48 turbine (about 34 percent in diameter or 11.5% in area of the proposed Enercon E-141 turbines in the Otter Creek array) is compliant and it continues to operate even though hundreds of complaints have been filed. Approval of the Otter Creek wind farm should not be granted according to the Ontario Renewable Energy Approvals guidelines as they have been shown to be ineffective at protecting citizens. Statements that a review by the Ontario Chief Medical Officer in 2010 found no “direct” link between wind turbines and adverse health are meaningless, as the impact is known, and demonstrated to be the indirect effect on health caused by noise based annoyance that results in sleep deprivation, a fact that has been identified in peer reviewed scientific papers.