This post concerns some tidbits I found concerning the Ontario regulatory environment surrounding wind turbines and thus is pretty wonkie (and boring unless you have a particular interest in the subject matter). I normally wouldn’t even post on this, but I found enough bothersome details that I figured I should take the time.
The Green Energy Act removed most local oversight of wind projects, but both the Province (Ontario) and the Federal Government (Canada) still have oversight of these projects. Both levels of government have established environmental standards that must be met before they approve projects. Both levels have procedures for following up on the environmental effects (mostly bird and bat kills) of projects post construction. You can get my version of the history of Wolfe Island during the pre-construction environmental screenings by visiting my companion web site, amherstislandwindinfo.com.
Post-construction, for major projects, the two levels plus some outside interests come together to create the PCFP (the Post Construction Followup Plan). Wolfe Island’s first “final” PCFP (part 1 and part 2) came out in May 2009 just as the project was beginning operation. The second “final” PCFP came out in February 2010. The PCFP’s are nominally project-specific, although if you look at the document properties of the WI PCFP’s you find they were originally written for the Port Alma project and probably mostly copied and pasted for WI. One of the main purposes of the PCFP is to establish the mortality and disturbance thresholds above which the agencies must be notified.
In addition to the PCFP, both levels of government have also published guidelines for how the wind and bird and bat studies are to be conducted. At the Provincial level the controlling agency is the Ministry of Natural Resources, or MNR. At the Federal level it’s Environment Canada, or EC. They include: The MNR’s Guidelines for Birds, MNR’s Guidelines for Bats, EC’s Guidance for Environmental Assessment, and EC’s Recommended Protocols. These would include, as an example, standards for how carcass searches are to be done.
You’d think the thresholds would be set at a point where the overall population of the birds and bats wouldn’t be affected. You’d be wrong. From the Feb 2010 PCFP:
NRCan, EC, and MNR will be immediately informed if the projected annual mortality level of all birds, including raptors, at Wolfe Island, derived from three consecutive weeks of surveys, is greater than or equal to 11.7 birds/MW. In the context of the Wolfe Island EcoPower® Centre, this means that NRCan, EC and MNR will be contacted if 134 bird fatalities are noted over a consecutive three-week period. In other words, if this rate of mortality was continued for the duration of one year, the annual bird mortality at the facility would equal the highest bird mortality rate observed to date in North America.
So the threshold has been set so it isn’t passed until WI becomes the most prolific killer of birds in North America, for WI some 2315 birds/year, regardless of what effects it might have on the local population. For raptors:
…,if this rate of mortality [0.09] was continued for the duration of one year, the annual raptor mortality at the facility would equal the highest raptor mortality rate observed to date in North America, outside California.
So now we’re down to just the most prolific killer outside California, for WI 18 raptors/year, again without regard to the effects on the local population. And bats:
…is greater than or equal to 12.5 bats/MW/year, or high incidence of bat mortality such that projected annual mortality rate would approach significance levels according to MNR’s Guideline to Assist in the Review of Wind Power Proposals: Potential Impacts to Bats and Bat Habitats.
The bat threshold appears to be more reasonably calculated, equating to 2475 bats/year for WI (which seems like a big number for mammals that are long-lived and don’t reproduce quickly), but when you look at the most recent (March 2010) MNR Bat Guideline you find:
A threshold approach will be used to identify and mitigate potential negative environmental effects resulting from the operation of wind turbines (i.e. bat mortality events), before they become significant.
A threshold of 10 bats per turbine per year has been established by this Guide. This threshold (10
bats/turbine/year) has been determined based on bat mortality reported in surveys throughout Ontario and comparison with jurisdictions across North America.
Oops. 12.5 bats/MW/year is almost 3 times 10 bats/turbine/year. Will the PCFP be changed to reflect this apparently new lower limit? Certainly Transalta is not volunteering to follow the lower threshold (860 for WI) in their reporting.
I mentioned in my posting on WI Report #2 that I didn’t put a great deal of emphasis on mortality, preferring instead to worry about loss of habitat, as discussed below. Part of my reluctance to embrace the mortality numbers is knowing how they are generated. In WI Report #3, the annual mortality figures start with the number of bodies (c) found which then gets raised by three factors: (1) Percentage of area surveyed (Ps), (2) Scavenger removal (Sc) and (3) Searcher effectiveness (Se). These three factors each range from a value of 1.0 to 0.0, with c being divided by each of the three factors to produce the adjusted body count (C). In the case of WI’s Report #2, for example, 180 bats were found. The three factors were applied and the adjusted total was 1270, which is what made the papers around the world. But note how small changes in the body count or the factors can produce large changes in the reported count.
How are these factors determined? Well, it depends. Sometimes trials are run, with dead birds being placed in the field and checking to see how many were (a) found or (b) scavenged. Sometimes past history from other projects (Melancthon was mentioned) is used. Sometimes they are estimated. In the case of raptors, the body count was 12 and then adjusted to 13. Two of the factors were estimated to be 1.0 and the third was pretty close to that. It should be obvious that the opportunity for gaming the numbers exists and would have to be pretty tempting – especially when your employer wants you to come up with the lowest numbers that won’t be questioned.
Along the same lines, what area is searched? The standard seems to be a 50m radius from the base of the turbine, based on a report that 85%+ of the bodies landed within that distance from the turbine. I was curious what size turbines that figure came from, but I couldn’t find it. Turbine blades keep getting longer and longer and WI’s are almost that long now.
Another significant portion of the PCFP concerns habitat disturbance, which to me is the most important consideration. There are 4 classes of birds whose habitat is checked, but no bats. Apparently if bats disappeared from WI it would go unnoticed by the authorities. You’d think that a significant decrease in overall density would be the most obvious measure of habitat disturbance, and (again!) you’d be wrong. Depending on the class, the criterion changes. As an example, for raptors (about which I care the most) it reads:
A potentially significant decline of wintering raptors will be defined by an absence of raptors in 50% or more of the areas observed to support raptors during pre-construction surveys.
So if the overall population simply goes down by a factor of, for example, 3 (like it has at WI) that doesn’t count. It should be obvious that the above definition allows a fair amount of gaming. You can imagine who defines the “areas”.
The third major part of the PCFP is what happens if any of the thresholds (either mortality or disturbance) are exceeded. For exceeding bird mortality thresholds, the mitigations include:
- initiation of research
- increasing survey frequency
- increasing reporting frequency
- adding behavioural or movement surveys
Doesn’t that make you feel better? Finally:
After exhausting reasonable efforts to determine the cause of mortality, as determined through discussions with the Parties, and if unanticipated potentially significant adverse environmental effects persist that cannot be mitigated by managing those factors, CREC is committed to implementing technically and economically feasible operational mitigation that includes blade feathering and, if necessary, shutdown of problematic WTGs.
I can’t remember when I’ve seen more conditions than in the above paragraph. Given that the reporting is only for 3 years (of which one year’s reporting is now complete), I’d bet the clock would run out before any real mitigation actions take place. At WI the raptor mortality has been above the threshold since Report #2, and low vole count, not turbines, is listed as the reason.
Excess bat mortality also gets a similar round of studies, followed by:
- CREC may consider retrofitting problematic WTGs with ultrasonic deterrent devices or similar-purpose device. Such devices are being studied or developed by third parties, and CREC would consider the possibility of utilizing this type of technology when or if it is commercially viable, available, and demonstrated effective
- increase of rotor “cut-in” wind speed of specific WTGs, as bats are more active at lower wind speeds
Note that shutting down turbines, while a theoretical possibility, is the absolute last step, unlikely to ever come to pass within the 3 year lifetime of the PCFP, regardless of the harm to the bat populations.
For bird habitat disturbance the mitigation depends on the class of bird. As an example, again for raptors, the list includes:
- expand survey
- mitigation banking
- land donation
- financial contribution
Note that trying to save WI’s superior raptor habitat is not even in the list. This list is section 3.3 in the February 2010 PCFP so you can take a look at it in case you don’t believe me. Of all the evasions of responsibility these documents contain, this one bothers me the most.
Note that there is no mitigation for bat habitat disturbance, as there is no threshold for reporting it.
This has been a long posting. If I knew how to shorten it while retaining its flavor, I would. It is apparent that these documents are all an exercise in public relations, designed to supply the appearance of doing something while planning on not doing anything at all. We’ll get a chance to see how serious the authorities are about at least the raptors. As I mentioned above, the threshold for raptor mortality has been surpassed and as a result, finally, in Report #3:
The raptor and vulture mortality rate is higher than the notification threshold of 0.09 raptors/MW
identified in the Follow-up Plan. In accordance with the Follow-up Plan, TransAlta and the MNR
have initiated discussions regarding adaptive management. Raptor behavioural studies are
underway involving surveys during four peak mortality periods, and will continue across late
summer and late fall, 2010 and spring, 2011.
Meanwhile, the clock is ticking. Two more years and they’re home free.