REA Review For Dumais

Review of Draft REA Reports and Documents
Big Thunder Wind Park
Horizon Wind Inc.
Prepared by the Nor’Wester Mountain Protection Committee.
August 30, 2010
1
Table of Contents
Foreword and Acknowledgements ................................................................................................... iii
1. Introduction ................................................................................................................................ 1
2. Background ................................................................................................................................ 2
2.1 Nor’Wester Mountain Escarpment Protection Committee ................................................ 2
2.2 Approval Requirements and Expectations ......................................................................... 3
2.3 EA process ......................................................................................................................... 3
2.4 REA process....................................................................................................................... 3
2.5 Transition Process .............................................................................................................. 5
3. Review of REA Reports............................................................................................................. 6
3.6 General ............................................................................................................................... 6
3.7 Environmental Study Report (ESR)................................................................................... 6
3.7.1 ESR Chapter 1 Project Summary............................................................................... 6
3.7.2 ESR Chapter 2 Project Description............................................................................ 7
3.7.3 ESR Chapter 3 Scope of the Assessment ................................................................... 8
3.7.4 ESR Chapter 4 Agency Consultation ......................................................................... 9
3.7.5 ESR Chapter 5 Public Consultation ........................................................................... 9
3.7.6 ESR Chapter 6 First Nations Consultation .............................................................. 11
3.7.7 ESR Chapter 7 Environmental Characteristics ........................................................ 11
3.7.8 ESR Chapter 8 Assessment of Environmental Effects, Mitigation Requirements,
and Residual Effects ................................................................................................................ 14
3.7.9 ESR Chapter 9 Follow-up Measures........................................................................ 28
3.7.10 ESR Chapter 10 Summary of Mitigation, Effect Management and Monitoring
Commitments ........................................................................................................................... 29
3.7.11 ESR Chapter 11 Project Advantages and Disadvantages ........................................ 29
3.7.12 ESR Chapter 12 Conclusion .................................................................................... 30
3.7.13 ESR Chapter 13 References ..................................................................................... 30
3.8 ESR Appendix A Agency Correspondence ..................................................................... 31
3.9 ESR Appendix B Technical Specifications ..................................................................... 31
3.10 ESR Appendix C Public Consultation ............................................................................. 32
3.11 ESR Appendix D First Nation Consultation .................................................................... 33
3.12 ESR Appendix E Avian Impact Assessment Report ....................................................... 33
3.13 ESR Appendix F Bat Monitoring Report......................................................................... 34
3.14 ESR Appendix G Archeological Impact Report .............................................................. 34
3.15 ESR Appendix H Rare Terrestrial Species ...................................................................... 35
3.16 ESR Appendix I Areas of Natural and Scientific Interest ............................................... 35
3.17 ESR Appendix J Radio Communication, Radar, and Seismoacoustic Impact Assessment
35
3.18 ESR Appendix K Shadow Flicker Analysis Results........................................................ 36
3.18.14 ESR Appendix K Incomplete report .................................................................... 37
3.18.15 ESR Appendix K Inconsistency with ESR Report .............................................. 37
3.18.16 ESR Appendix K Data Issues .............................................................................. 37
3.19 Project Description Report ............................................................................................... 38
3.20 Design and Operations Report ......................................................................................... 43
3.21 Construction Plan Report ................................................................................................. 45
3.22 Decommissioning Report................................................................................................. 46
3.23 Consultation Report ......................................................................................................... 48
i
3.24 Natural Heritage Records Review Report........................................................................ 48
3.25 Natural Heritage Site Visit Report ................................................................................... 49
3.26 Environmental Noise Impact Report ............................................................................... 50
3.27 Visual Impact Assessment Report ................................................................................... 53
3.28 Maps................................................................................................................................. 54
4. Summary of Comments ........................................................................................................... 56
5. Review Conclusions and Recommendations ........................................................................... 57
APPENDIX A Draft REA Initial Comments (as provided to Horizon August 24, 2010) Pages 1- 69
APPENDIX B Summary of Review Recommendations ................................................. Pages 1 - 11
APPENDIX C LETTER OF January 4, 2010 from MNR - Peregrine Falcon…...……….Page 1 - 3
List of Tables
Table 1 Environmental Study Report Initial Comments Summary ................................................... 6
Table 2 Consultation Initial Comments Summary........................................................................... 32
Table 3 Inconsistencies between ESR and Appendix K .................................................................. 37
Table 4 Project Description Report Initial Comments Summary .................................................... 38
Table 5 Design and Operations Report Initial Comments Summary .............................................. 43
Table 6 Construction Plan Report Initial Comments Summary ...................................................... 45
Table 7 Decommissioning Plan Report Initial Comments Summary .............................................. 47
Table 8 Natural Heritage Site Visit Initial Comments Summary .................................................... 49
Table 9 Environmental Noise Impact Report Initial Comments Summary ..................................... 51
Table 10 Visual Impact Assessment Initial Comments Summary................................................... 53
Table 11 Maps Initial Comments Summary .................................................................................... 54
List of Acronyms
ANSI Area of Natural or Scientific Interest
BTWP Big Thunder Wind Park
CanWEA Canadian Wind Energy Association
EA Environmental Assessment
ESR Environmental Study Report
FWFN Fort William First Nation
LP Limited Partnership
MOE Ministry of Environment
NavCan Navigation Canada
NMEPC Nor’Wester Mountain Escarpment Protection Committee
OPA Ontario Power Authority
PDR Project Description Report
PPS Provincial Policy Statement
REA Renewable Energy Approval
TB Technical Bulletin
WTG Wind Turbine Generator
ii
Foreword and Acknowledgements
This review of the proposed Big Thunder Wind Park draft REA reports represents a significant
accomplishment for a grassroots community group, the Nor’Wester Mountain Escarpment
Protection Committee, in two important ways; first, the group is all volunteers who found time to
become involved and contribute to this review and, second, many members of the group only met
for the first time this year, yet were able to come together to work as a team.
The REA process is still being developed and implemented even at the time of this review. The
Green Energy and Green Economy Act regulations passed just over a year ago have resulted in a
cascade of changes to policies, guidelines and programs in environmental and energy planning,
and public consultation. The changes can be difficult to comprehend for project developers, who
have an entire government office to assist them (the Renewable Energy Facilitation Office), but
almost impossible for the average person.
The proponent (project developer) driven process that has been implemented, without direct MOE
oversight or involvement during planning, relies on the project developer to interpret the advice
and guidance documents. For developers with significant and varied experience in power project
planning, allowing interpretation provides the ability to tailor the process somewhat to the project,
and still provide meaningful consultation and public involvement, and a fair and open process.
Perhaps because of the changing regulatory and approvals processes, or perhaps because the new
REA process was not strictly adhered to in this case, this project is seen by many in the community
as not providing meaningful public consultation, nor an open process.
This review provides comments and advice on the reports in an effort to improve them, and ensure
they meet the MOE technical bulletin guidance documents which the proponent committed to
meeting at the Aug 5th and 24th open houses. There are 412 comments from an initial assessment of
the reports, which were provided to the proponent August 24th. This review document appends
those comments, and provides further review based on additional assessment and considering the
proponents statements and information at the August open houses. This review document used the
initial and further reviews to develop 139 specific recommendations.
This review is the result of dedicated efforts and community teamwork. It involves months of
volunteer work by many people from the NMEPC. The contributions included formal review of
sections of various reports and appendices, working on the database of 412 initial comments
(Appendix A), as well as many informal comments and discussions.
It is hoped that this review will be useful in the efforts to improve the REA report documents, the
planning and public consultation processes, and ultimately the project, should it proceed.
Nor’Wester Mountain Escarpment Protection Committee
iii
NMEPC Review of draft REA reports for proposed Big Thunder Wind Park
1. Introduction
This document is a review of the draft REA reports issued by Horizon Wind in May 2010 as part
of the REA approvals process. The draft REA reports include the ESR report, and appendices, the
Project Description Report (PDR), and the Design and Operations Plan, Construction Plan and
Decommissioning Plan Reports.
The review was carried out by various members of the NMEPC and the public over the period
from June to August 2010. There was no paid consultant or professional contribution to this
review; it was entirely carried out by average people, members of the public who volunteered
significant time over the summer.
The review was comprised of two approaches. The initial approach was to document the issues and
concerns in a database noting the page, chapter and section number. This information is included
in Appendix A. The issues and concerns were identified by comparing the draft REA documents
against the MOE Technical Bulletins, as well as considering what a reasonable person would
expect. This approach was confirmed as reasonable by statements at the August 5th and 24th, 2010
open houses in Thunder Bay and Neebing where a Horizon representative answered a question in
open public forum that the final reports would meet the MOE Technical Bulletins.
The second approach to the review was to critique the documents and note comments outside the
data base. This part of the review was more of a holistic approach, looking for issues and concerns
from as wider context. These comments formulated much of the text in the body of the review.
There may be overlap in the database comments and the comments in the body of the text.
The background section provides a brief overview of the NMEPC, and the various approvals
process. The ‘transition’ provisions and the implications are also discussed
The draft REA report review is comprised firstly of the ESR review. The ESR review includes
review of the various chapters and appendices in varying levels of detail. Where volunteers had the
time and interest, there is more detailed review. The review of the REA reports follows the ESR
review. Each report is compared against its applicable Technical Bulletin. For each report (ESR
and REA reports) there is a summary table provided which collates the database of REA comments
included as Appendix A. The comments are categorized, including missing information,
misleading information and minor infractions, and a short description added. This is to assist
others in identifying what each comment relates to, and how it could be remedied.
In each section, recommendations as specific direction or advice to the proponent or MOE is

provided identified in bold and italics. These are based on the review, and are made to address
various deficiencies or issues. These recommendations are summarized after the review, and
further, overall recommendations are provided.
Readers of the report should keep in mind limitations of this review. It was prepared by average
people, in their spare time, without the benefit of paid professionals. There were obvious resource
issues and the review was not able to cover all the various reports, appendices and manufacturer’s
data sheets in a level of detail which a regulator or paid professional might. Further review and
information could be identified following submission of this report.
1
2. Background
2.1 Nor’Wester Mountain Escarpment Protection Committee
The Nor’Wester Mountain Escarpment Protection Committee (NMEPC) is a local grassroots group
of citizens. It was formed in the fall of 2009 when many area residents first learned about this
project proposed on a mountain close to their homes. Although the proponent has identified that
direct notice was sent to all area residents, many of those immediately adjacent had no knowledge
of the project until November 2009 when the NMEPC contacted them. On August 5, a Horizon
representative further stated that everyone within 120 m of the project, including electrical lines,
had been directly notified.
Residents were shocked to learn of this project (especially since it was signed 3 years prior behind
closed doors without their knowledge on city owned land) as it was a threat to a previously well-
protected watershed area containing protected peregrine falcons, rare to the area Sugar Maple
trees, a cold water Lake Trout lake, sensitive groundwater recharge area, and an area upon which
development was discouraged. Many residents hike the trails within the area and enjoy the
benefits of this pristine environment close up and from afar.
Industrial sized wind turbines have increased dramatically in height, and power and sound output
in recent years. They have been developed closer to people, and many documents and research
have suggested adverse health and environmental effects due to their presence, especially when
located close to homes and in sensitive areas. There were significant concerns and questions raised
by the local community regarding this project, and its specific proposed sites.
From the fall of 2009 until summer 2010, there has been no significant public consultation by the
proponent. What the local residents were provided with was a media campaign and public relations
program. Certainly the proponent and its local consultants (Firedog Communications and Mr S.
Wright) would have been aware of the many meetings, open houses, City Council deputations,
demonstrations, newspaper articles, and editorials. These external consultants or Horizon itself had
ample opportunity to directly engage the public to provide information and address concerns. The
public concern or activity is not reasonably reflected in the Renewable Energy Approvals (REA)
reports. Questions regarding the proposed project and the specific studies were directed to the
proponent. But still there was no reasonable public consultation.
MOE must review the project and consultation from September 2009 to August 2010 to
determine whether reasonable attempts were made to engage and consult with the public.
Should it be determined that there was a failure to consult appropriately, the proponent must be
required to develop and carry out a consultation program satisfactory to MOE before any REA
report is prepared.
MOE must review the direct notifications made in this project to determine if they satisfy the
requirements. Failure to provide appropriate notification should be considered a significant
flaw in the process, for which the public should not suffer.
2
MOE must require the proponent to include in its REA reports sufficient and detailed
description of the ongoing public and community concerns. Also, the proponent should identify
how it has addressed specific individual and community concern.
2.2 Approval Requirements and Expectations

The MOE identifies its requirements (needs) and expectations (wants) for studies and reports in
many forms. These can include needs identified in regulations or Directors orders, or wants
identified in guidelines, bulletins, or direct correspondence with proponents. Sometimes the
guidelines can become requirements, based on specific project or proponent considerations. The
application of the requirements is normally absolute. For expectations, there is considerable
leeway in application. An experienced proponent with a good track record and no significant
project concerns may not have to satisfy all the expectations, while others may have to.
2.3 EA process
The Environmental Assessment process is a regulatory requirement that applied to industrial wind
power projects until 2009. The EA process is one that includes identification of impacts, and
mitigation. It examines impacts from an environmental, economic, and social perspective. Public
consultation and involvement is an integral part of the process. The EA process was developed
over the last 40 years, primarily as a response to problems with large scale developments and
public concerns.
With the introduction of the Green Energy and Green Economy Act the EA process was no longer
to be used for industrial wind power developments. A new process, called the REA process was
developed and used.
2.4 REA process

The REA process, requirements, and guidelines are still in development. The REA process is in
some ways similar to the EA process, in that there are still investigations into environmental
impacts, and mitigation. There is also a public consultation and regulatory approval process.
Generally the REA process as we understand it is as follows,

Site investigation and notice of project.
o Proponent identifies a site that looks promising for development
o Proponent issues a notice in the newspaper etc to identify it is considering
developing a project in a specific area
o Basic information is gathered to identify whether the project is feasible and what
the potential impacts might be
o Proponent could begin engaging local stakeholders to exchange information
Development of Project Description Report
o Basic background information gathered
o Identification of environmental, social and technical issues and information
o Identification of project technical components (tower and turbine types, heights etc)
o Identification of alternatives or a proposed project layout
o Issue of Project Description Report
Project Description Report Open Houses
o First opportunity for public to see project and potential impacts
3
o Opportunity for public to provide missing information (correct errors / omissions)

o Chance for proponent to identify further opportunities or issues regarding project
o Important step to ensure project reasonably considers public input
Development of Draft REA reports (Operation, Construction, Decommissioning etc)
o More detailed information gathered
o Detailed assessments of impacts developed
o Issue of Draft REA reports
o MOE does not normally review these reports
Draft REA Open Houses
o Opportunity for public to see project in detail, after input from PDR
o Opportunity for public to identify issues, missing information etc
o Opportunity for proponent to identify further opportunities and issues regarding the
specific project proposal and details
Development of Final REA reports
o Proponent takes input from draft REA open houses and revises project and reports
as necessary
o If significant changes to project or reports are made, new draft REA reports could
be developed with open houses
Issue of Final REA reports to MOE
o MOE reviews against regulations and technical bulletins
MOE Decision
o MOE can approve, deny, or approve with conditions, the project
o Decision can be appealed
Appeals Process
o There is a short appeals process (15 or 30 days)
o There is limited grounds on which to appeal , essentially unless permanent harm
will be caused and can be proven there is little ability to successfully appeal
o Once appeals process, or time limit has expired, the final REA approvals is
provided
REA approvals
o After appeals process expired, and assuming decision was approve, or approve with
conditions
o REA approvals provides for most provincial approvals, but not federal if required
o Specific local approvals ie water crossings may still be required
But the REA process is an approvals process not an assessment process. Its goal is to speed up and
streamline the approvals. Minimum setbacks are included in the process, to provide (in theory)
separation from sensitive features, such as water course and people. The use of setbacks relieves
the proponent from investigating potential impacts for some concerns. There is no requirement to
identify alternatives. There is no requirement to mitigate impacts (use of setbacks is enough).
A positive feature of the REA process is the Technical Bulletins. These are guidance documents
which the MOE has issued (in draft March 2010) to provide detailed and specific direction to
proponents. The bulletins clearly identify information requirements and expectations. Should these
bulletins be adhered to in a meaningful way, project information will be collected, collated and
communicated clearly to the public and regulators.
4
At the open house Aug 5, 2010 in Thunder Bay, a representative of BTWP project clearly stated
that they would meet the MOE technical bulletin requirements. (This can be confirmed by
reviewing the videotape of the proceedings made by Horizon)
The proponent must be required to satisfy its public commitment of August 5th and 24th, 2010
and fully meet the requirements of the MOE Technical Bulletins for all the REA reports.
2.5 Transition Process

Because the project was already started before the REA process was developed, it was termed a
‘transition project’ and special provisions apply. This was to provide projects in various stages of
development some credit for work and consultation already completed. It was not intended to
reduce the opportunities for real involvement of the public
Apparently, the MOE decision to provide this special provision to the BTWP was made in the fall
of 2009. The decision was made based on information provided by Horizon Wind to MOE. At that
time MOE was apparently not aware of the growing public concern regarding this project, and
made a decision that previous open houses in 2008 and 2009 for BTWP sufficiently satisfied the
Project Description Report open house requirements.
Since the decision to provide the transition project special provision (no first open house) there
have been a number of issues that would indicate the special provisions be revoked. These include,
Initial open houses (2008 and 2009) did not provide specific information as normally
provided with a PDR open house (turbine types, sizes, manufacturer)
Previous open houses did not indicate electrical connections, roads, or site information
Project changed significantly since fall of 2009 (turbine locations moved twice, and project
now includes electrical connections)
Significant public concern and requests for information and consultation since fall 2009
Public was not informed of special provisions by proponent or regulator until spring 2010
The proponent must identify to the public in the draft REA documents what special provisions
apply outside the normal process. This is specifically the ‘transition project’ provisions.
The August 4, 5, 23, 24 open houses must be considered as the PDR (first) open houses. The
information presented at prior open houses was general and non specific. The changes in the
project and lack of consultation since 2009 are significant. The proponent must update and
revise the draft REA reports, reissue draft REA reports based on the first real public input. After
reissuing the draft REA documents the proponent must then have draft REA open houses.
5
3. Review of REA Reports

3.6 General
The reports were reviewed by a number of people and comments assembled into this report. Many
of the specific comments are in the attached Appendix A. These comments are included as the
reviewers input, without editing. There are obvious grammatical and spelling issues, but the
comments should provide sufficient detail to indicate what the issue is. If additional information is
needed, it is suggested to go to the report section and read the relevant part of the report, at which
time the issue often becomes apparent to the reader even without the REA review comment. If
further clarification is required, it is suggested to contact the NMEPC who will have the original
reviewer clarify.
Overall, the review found that there was significant duplication between the various REA reports,
and that there was significant missing information. There were many instances where the
reviewers were expecting more detailed information, but it was not provided. This was most
apparent for identifying the rationale for why decisions were made to located project components,
or why turbines were relocated multiple times.
3.7 Environmental Study Report (ESR)

In general the environmental study had a number of issues. The information in Appendix A
provides specific location and description of some issues. The total number of comments provided
in Appendix A is 412, and these comments were provided t oHorizon Wind Inc on August 24,
2010. Table 1 Environmental Study Report Initial Comments Summary below summarizes the
issues found related to the ESR report. For the ESR report there were 130 issues, of which almost
half were identified as missing information. This is significant as the ESR should provide clear and
complete information regarding the environmental features, effects, mitigation and remaining
effects.
Report Type of issue Number of issues (Total=130)

General ESR Minor infractions 17
Missing information 64
Misleading information 17
False information 7
REA conflicts 5
Process inadequacies 19
Credibility 1
Table 1 Environmental Study Report Initial Comments Summary
3.7.1 ESR Chapter 1 Project Summary

This section indicates that the project is 27 MW, but fails to identify that a total of 79.5 MW has
been applied for from the OPA for power supply contracts. This should be identified in the project,
as it is the same proponent, with the same name for the projects (Big Thunder Wind Park Alpha
through Gamma). This is further neglected at the Project Titles section, where the specific project
names (as named on applications to OPA) should be included
6
The regulatory regime is described, but it neglects to identify the special transition provisions, nor
how they affect public involvement and opportunities for input
The proponent information is identified, although Ms. Nguyen position and authority within the
company is not provided. It is likely that Ms Nguyen does not have the authority to bind the
company, and a more senior employee/ officer should be identified
The authors of the screening report are identified, although many of the REA reports and portions
of the ESR include limitations and qualifications. It is difficult to understand how the authors of
some of the reports can be listed with a primary role, and then limit the reliance on their reports.
Further, there are others involved in the project, whose roles should be clearly communicated, such
as Foghorn Renewable Energy, Big Thunder Wind Park Limited partnerships, and Horizon Energy
Legacy Group.
The proponent must address the 10 comments as included in Appendix A related to the ESR
chapter 1.
The proponent must clarify the project relationship and names relative to the large number of
projects known as Big Thunder Wind Park.
The proponent must clarify the nature and relationship of all parties involved in development of
the project.
The proponent must clearly communicate the special transition provisions and how that impacts
public opportunities for involvement.
3.7.2 ESR Chapter 2 Project Description

The project description identifies the proponent as Horizon Wind Inc., but the nature of the
relationship of other parties (as noted in chapter 1 review above) should be clearly identified and
communicated.
The use of only selected parts of the Provincial Policy Statement (PPS) should not occur. The PPS
should not be used piecemeal, and ignoring other relevant policies is not appropriate
The purpose of the project is also to provide the proponent with a business opportunity. The true
nature of the project purpose was apparent during open house questions when the proponent
advised that it could not move turbines away from people because it would make the project
uneconomic.
Current land use description ignores the land use associated with the electrical lines. The lines are
part of the project undertaking.
The description of the wind turbine fails to disclose that the manufacturer data sheet sound power
(and perhaps other information) is estimates, and that no actual turbines of this type have been
constructed. This is an important piece of information which has is missing from the project
description.
7
Electrical tap lines are discussed, but the existing capacity as per Thunder Bay Hydro is only 3 to 4
MW as per Thunder Bay Hydro website. Which turbines will be connected initially, and how the
others will be connected is unclear. Given that there is only an OPA contract for 16.5 MW, it is
unclear how various parts so the project will connect, where, and in what stages.
The nature and status of the FWFN land claim is vague. The land proposed for the development
was part of the historical claim, but this is ignored.
Much of Section 2.6 is from the Construction and operations reports. Including them here is
irrelevant and only increases the size of the report
chapter 2
The proponent must identify and clarify the nature and involvement of all parties involved in
project development.
The proponent must include in the purpose that its objective is to make money. If not, the
proponent should not identify economics as rationale for turbine location, or rationale for not
implementing certain mitigation.
The proponent must clearly disclose that the tower and turbine information is estimated and that
no tower and turbine of this type has been constructed.
The proponent must clearly identify the electrical connections, land uses associated, the turbines
and schedule for various stages, and how potential stages of the project will be incorporated, for
3 MW, 16.5 MW, 27 MW and other stages to 79.5 MW.
The proponent must clearly identify how the First Nations and Métis have been consulted, and
how their land claims and use of lands could be impacted.
3.7.3 ESR Chapter 3 Scope of the Assessment

This chapter reveals a significant issue with this project. The project identifies that issues were
scoped through consultation. It also identifies that local residents were consulted and that the
professional judgment of the assessment team was used. Unfortunately, the results of that process
to scope issues, and identify the importance of issues, and why some are not addressed is not part
of the report. This leaves readers and the public wondering why and how some issues are
addressed and others not. Specifically the significant concerns of the local residents regarding
noise, health issues, flicker, property value impacts and visual impacts have been discounted and
not addressed. The results of scoping should be clearly provided, perhaps with maps and figures to
identify preferred area, and exclusion zones. The entire process of moving from a large study area
to specific sites should be clear, with the rationale and decision making provided.
The provincial screening criteria identified as table 3-1 is suggested as part of the screening
criteria. These are criteria used for projects as part of the environmental assessment process, to
8
screen out those projects with minimal anticipated impacts. Use of these criteria for this project
does not seem appropriate. This screening process does not address the specific issues raised by
the community. How these screening criteria are used in the scoping process is not adequately
identified.
The study area is identified as determined through a combination of professional judgment and
experience with predictable effects. This is completely deficient in details that would be expected
to be known and communicated to the public. This is the very heart of decision process regarding
locating of turbines. If the proponent cannot identify how the study area and turbines are located,
or based all its decisions on professional judgment and experience, then this entire study and
project should be denied.
chapter 3
The proponent must clearly identify how it scoped issues, and how consultation and professional
judgment were used in the scoping and turbine locating process.
The proponent must clearly communicate the process it used to determine the study area, and
turbine locations. The rationale for identify locations must be known, and without this
information any evaluation and comments by the public or regulators is irrelevant.
3.7.4 ESR Chapter 4 Agency Consultation

The agency consultation identifies that a transition process was to apply to this project.
Unfortunately, the specific transition provisions are not identified, nor are the impacts on agency
and public consultation.
Appendix A includes agency correspondence. Unfortunately determining the consultation process

and status is difficult without some collation and tabulation of consultation and status.
chapter 4
The proponent must identify the specific transition provisions and how agency consultation has
been impacted.
The proponent must clearly identify the dates, nature, and status of agency consultations. This
should be summarized in tabular format.
3.7.5 ESR Chapter 5 Public Consultation

Similar to comments on agency consultation, the impact of transitional project status is not
identified, and the impacts on opportunities for public involvement are not identified.
The public consultation identifies that area landowners and residents must be involved.
Unfortunately for this entire project this has not occurred. More specifically since late 2009 the
9
proponent has avoided contact with area residents. During Thunder Bay City Council deputations,
Horizon representatives left early, and refused to stay even when requested by a member of the
public. This could be interpreted as indicating a lack of concern for resident’s issues and no desire
for involvement. The entire first paragraph indicates what should happen for public consultation;
unfortunately this did not occur. What is later described as consultation are actually the minimum
notification requirements as required by regulation, not true consultation.
The methodology section indicates that public consultation was comprised of 2 public meetings
and responses to inquiries. There is no mention or acknowledgement of the significant public
concerns since the fall of 2009, and that there has been no specific measures taken to consult in
response. In fact, the proponent has avoided contact and consultation, preferring to use public
relations and a media campaign to try to sway public opinion.
The sections on activities is missing a number of activities including Horizon presentations and
letters to City Council in 2009 and 2010, as well as the significant number of public
demonstrations, deputations to councils, editorials, news articles, and letters to the editor. The
majority of the news media and letters to the editor were opposed in some form to the project or
specific turbine locating. The existence and activities of the Nor’Wester Mountain Protection
Committee was totally ignored.
The open house descriptions identify that there was no specific information or maps related to
turbine locating, or locating decisions provided at the open houses. This was also the case for the
August 2010 open houses, where no project area maps of sufficient size (ie table size) were
available. This is significant relative to the REA consultation process and the first (project
description report) open houses. Under the REA process the first open house must have the site
specific and generator information. The response to questionnaires fails to acknowledge that as the
project proceeded, the support for the project declined.
The response to correspondence is lacking in detail and information. There should be a table of
questions and answers provided; with the names of the questioner removed (these can be replaced
with generic descriptions such as ‘resident’).
The table 5-3 is has little value. To identify that issues were addressed in specific sections does not
clearly identify to the public how there issues were addressed. It merely sends the reader on a
search through various reports. A clear communication of issue, and resolution, preferably in a
table format, would make it clear to all how issues were addressed.
Overall, this section of the report provides little detail upon which the public or a regulator could
assess the public consultation. It lacks detail, and totally ignores the significant community based
activities which occurred since the fall of 2009. The appendix that supports this section is also
insufficient; refer to review of ESR Appendix A.
chapter 5
The proponent must identify the specific transition provisions and how public consultation is
impacted.
10
The proponent must acknowledge that since public concerns became apparent last fall (2009) it
has not engaged in any real public consultation.
The proponent must halt its process, engage the public meaningfully, and address the concerns.
Suggested methods would be standard consultative tools such as working groups, stakeholder
focus sessions, and meeting directly with potentially impacted residents. This could begin
immediately.
The proponent must acknowledge and describe the significant public and media concerns and
events, especially since fall of 2009. Also, the proponent should explain its response to the
concerns.
The first open houses did not have specific turbine locating information. The proponent should
not be provided the free pass on the first (PDR) open houses. The proponent must hold open
houses further to its first real set of open houses in August
The proponent must provide more information, preferably in a tabular form, identifying how
written, email, and phone questions were responded to.
The proponent must identify how issues raised were addressed, and not merely provide report
section to refer to. Provided in a tabular form this would communicated clearly how issues were
addressed.
3.7.6 ESR Chapter 6 First Nations Consultation

This section is less than one half page in length. Given the significant and historical ties to the
lands on which this project is located, this is surprising.
The section identifies that the details will be provided in the final REA applications. This is
unacceptable with respect to providing appropriate comment and consultation on the draft REA
reports. The review for the final documents is short and there is not sufficient opportunity to
review entire new reports. The activities to date should be presented to provide the public and First
Nations and Métis people the opportunity to review and evaluate the activities to date.
The First Nations Consultation section and the corresponding Consultation Report are missing
from the draft REA report. The proponent must issue the missing section and Consultation
Report, as part of the draft REA, with 60 days notice and open house to follow. Not including
this information was the choice of the proponent, but the public and First Nations deserve to
have this information at the draft report stage.
3.7.7 ESR Chapter 7 Environmental Characteristics

This entire chapter is an interesting combination of significant amounts of general information, and
small amounts of site specific information. The site specific importance, location, and distribution
of environmental characteristics are important, as well as the relevance to this project. They should
be adequately and clearly addressed and communicated.
11
Turbine locating decisions would obviously require that environmental concerns be identified
geographically but none of this information is included. Site maps identifying where the areas of
concern are located would assist the public and regulators in understanding the process, but these
are not included. This brings into question the entire process, and evaluation of impacts and
mitigation, because the project should attempt to minimize overall impact on the environment.
The hydrogeology section fails to identify that the area is a high groundwater recharge area, and a
sensitive aquifer. This combined with fractured rock groundwater is not addressed as it relates to
this project. At the August 23, 2010 open houses the Horizon Wind Inc., Vice President, identified
that there would be a lot of blasting, sufficient to provide almost enough gravel for the entire
projects roads and pads. The potential for impacts on the rock (unknown fragility or
characteristics) and groundwater networks is not addressed or acknowledged.
Climate and wind information presented is general and of little value. Climate normal monthlies
are far too general, and obviously the minimum night time winter temperatures would be important
to mechanical equipment operation. Whether these turbines will function is the extreme low
temperatures in the area are a concern. The preferred wind over the area close to the only wind test
tower has been identified as a reason to locate the turbines close to the cliff edge. There is no data
supplied to support this assertion, and it is difficult to understand how wind at 140 meter heights,
on top of 200 meter cliffs would vary so drastically in the a space of a few hundred meters
laterally. There is no indication of how the wind patterns over the area were determined, and the
only information provided is an average wind speed and direction.
Socioeconomic conditions information is general and does not provide sufficient detail regarding
the area in the vicinity of the project. Data regarding the number of people in Ontario is irrelevant.
The current land use ignores the significance of the land uses adjacent to the project as desirable
rural and estate residential areas. The reason they are desirable is the natural beauty and quiet area.
The proximity to residential areas is downplayed and the proximity of significant estate residential
areas of Broad Oaks and Mount Forest are ignored.
The tourism section is missing information and evaluation regarding the role the natural state of
the Nor’Wester Mountains plays in the important tourism industry. The Nor’Wester hotel relies on
use of its facility with the natural scenic backdrop for weddings and graduations – loss of which
will occur with the present development - this is not acknowledged. The general information
provided does not sufficiently address the local importance of the visual and quiet aspects of the
Nor’Westers. The information provided includes irrelevant generic information about Thunder Bay
theater and golf, yet ignores the Fort William Golf and Country Club which is in closer proximity.
This tourism section appears to be sourced from local tourist brochures, rather than relevant site
and project specific information.
Existing noise levels in the area are described, but the impacts of the proposed project are ignored.
Archeological assessments area described, with a stage 2 assessment proposed before construction.
The recommendation of the Ministry of Culture is identified in the report as prior to construction.
Actually, the Ministry of Culture identified that a stage 2 assessment should be completed far
enough in advance to account for delays. There is a significant difference between the statement in
12
the REA draft ESR 7.9.4 and the letter from Ministry of Culture. The proponent should be
undertaking surveys far enough in advance to account for delays. Perhaps the surveys should be
far enough in advance to allow for alteration of road or turbine locations should information or
artifacts be found..
Recreation areas do not adequately describe the existing use of the areas as trails and hiking, the
potential uses with various tourism and recreation developments. The existing Loch Lomond ski
facility, and the presently closed Big Thunder Sports Park (reopening has been subject of call fro
proposals in 2010) should be clearing and adequately described. The impacts on these uses are not
addressed.
Safety issues fail to address the significant and important tissue of ice throw. The proximity of the
local ski area and the locating of turbines immediately (180 metres) above residences increase the
likelihood of ice throw. The proximity of snowmaking equipment is not acknowledged. The
section identifies that the roads will be gated to prevent unauthorized entry, but other parts of the
report indicate public will have access. This should be clearly communicated in the report as the
access roads will cross and be located on ski trails and hiking trails.
The Visual Landscape section has 3 lines of text. This is inadequate based on the importance that
the local community, residents and business place on the unadulterated natural landscape. The
proposed project would drastically alter the visual landscape and this is ignored entirely. The local
community has identified these concerns.
The proponent must provide clear information, on legible maps to show the location of all
environmental characteristics and information used in locating turbines and roads.
The proponent must acknowledge the groundwater significance of the area, and provide more
detailed information regarding potential impacts of its construction and operation activities on
the rock stability, groundwater network, and aquifer.
The proponent must indicate the distribution of wind over the area, and how this was
determined. Because the proponent is using the wind distribution as rationale for turbine
location this information is required.
The proponent must acknowledge that the area in the vicinity of the proposed project is a
residential area, valued for its proximity to the natural beauty of the Nor’Westers and the quiet
of the area.
The proponent must revise its tourism section to acknowledge and describe the local tourism
and the significance of the local vista and the quiet nature of the area on local tourism.
The proponent must include a description of how the proposed facility will impact noise levels.
The sound power levels and the impacts on people, and properties must be clearly
communicated.
The proponent must acknowledge that the Ministry of Culture recommends a stage 2
archeological assessment far enough in advance to account for delay. It would be prudent to
13
conduct the stage 2 assessment as early as possible to allow for relocation of turbines, roads and
electrical lines as necessary.
The proponent must acknowledge and describe the existing and potential recreation uses in
more detail, and describe the impacts of the proposed facilities on those uses.
The proponent must describe the potential safety issues related to ice formation and throw
relative to the ski facility, and residences especially immediately below and adjacent to the
proposed turbines.
The proponent must acknowledge and describe fully the visual landscape and its importance to
the community. This is perhaps one of the most common issues raised, and relates to property
values, enjoyment of property, the local economy, and tourism.
3.7.8 ESR Chapter 8 Assessment of Environmental Effects, Mitigation

Requirements, and Residual Effects
This chapter was reviewed in detail, as the identification of effects and mitigation is critical. The
review identifies the relevant section of the report, so that it is easier to identify the source of the
comments.
ESR 8.1 Level of impact after mitigation measures

Criteria used to assess level of effect after mitigation appears to be based on a resource model.
This model may be appropriate for some effects, but for many of the effects identified in this
chapter it seems inappropriate. This model does not adequately address the distribution of impacts,
as some residents are impacted severely, while on a broader scale the impact is much less severe.
ESR 8.1 The proponent should provide a more detailed and descriptive identification of level of
effect. The effect before and after mitigation should be quantified wherever possible.
ESR 8.2 .1 General Construction Activities – Environmental

This section is deficient in identification of activities, environmental components affected,
potential effects, mitigation, and residual effects.
The activities should describe the specific construction activities in sufficient detail to
understand what the impacts are.
The environmental components would also include dust and air quality
Potential effects should include runoff and siltation, impacts of large equipment etc.
Mitigation measures refer to other reports for details of various activities. That
information should be included here. Mitigation is provided in general terms, such as
defensive driving practices, where specific mitigation for specific issues would be of
value.
14
Residual effects are identified as localized and short lived. Who and how long they are
affected would be important and should be identified.
Importance of effects is noted as minimal. How this was determined, and on what basis
this decision was made is important. The importance of effects to nearby residents or
business may be important.
The proponent must rewrite section ESR 8.2.1 to fully address the missing activities,
environmental components, potential effects, mitigation measures and residual effects.
ESR 8.2.2 General Construction Activities – Social Economic

The activities should describe the specific construction activities in sufficient detail to understand
what the impacts are. How these activities are relevant to socio economic is not understood
The environmental components only identify socio economic issues that may be interpreted as
only positive. There must be more detail here to more clearly understand what the environmental
component considered actually is.
Potential effects are only identified as positive. The positive spin put on this issue borders on the
absurd, with more than a half page listing of trades possibly employed in wind farm construction,
operation and decommissioning (although this sections is only construction). This is misleading
and incorrect. There must be potential negative effects, such as loss of business due to traffic,
noise, visual disruption.
Mitigation measure identifies none. This totally ignores that there might be negative effects.
Residual effects are identified as positive. Again, by ignoring possible negative effects, the public
is not properly informed.
Specifically the proponent must clearly identify potential negative effects which have been
totally ignored.
ESR 8.2.3 Surveying and Siting

This section is reasonably developed and there are no comments at this time.
ESR 8.2.4 Land Clearing

potential effects, mitigation, and residual effects. In many respects this deficiency is related to the
project activities and effects from electrical lines of the proponents’ site, and along the upgraded
electrical lines into Fort William.
15
what the impacts are. Additional information related to upgraded electrical lines into Fort William
should be added. Maps and diagrams would clarify what and where the activities would occur.
The environmental components should include runoff and siltation.
Potential effects are identified as destruction and alteration of habitat. That is too general and the
potential effects should be linked to the environmental component. New access is identified as a
positive effect, although that may not be accurate. There is no mention of loss of use of ski/hike
trails.
Mitigation measure identifies natural revegetation and replanting. That is post construction.
Mitigation for the specific effects, by component should be identified. The limitation of public
access is contrary to the benefit of increased access – it can’t be both increased and prevented at
the same time
Residual effects are identified as some reduction and alteration of wildlife habitat with no details,
or project life. Unfortunately this is a vague and general statement that provides no real
information regarding the scope or duration of effects. The project will last 25 to 45 years, the
duration of the Horizon/City contract.
Specifically the proponent must clearly identify the residual effects in more detail and that they
will last 25 to 45 years.
ESR 8.2.5 Road Construction/ Modification

There should be maps and profiles of roads, including cut and fill areas and location of trails.
There should be identification of the visual impacts and scarring of the mountainside to build and
maintain roads in this rugged and steep terrain.
potential effects, mitigation, and residual effects. There are no existing roads, only ski trails
The activities should describe the specific road construction activities in sufficient detail to
understand what the impacts are.
The environmental components do not address loss of trails or visual impacts
Potential effects are only identified related to some environmental components. The effects on the
ski trails will be devastating. There will be permanent loss of use and destruction of trails. The
impact of the wide roads and clearing up the side of the mountain is ignored.
Mitigation measures fail to identify whether or how roads or turbines will be relocated should
archeological finds be made. Mitigation for loss of trials and visual impacts is not addressed.
Residual effects are identified as localized and short lived. This is not accurate for the trail system
and visual impacts- these are long lived and essentially permanent.
16
Specifically the proponent must clearly identify environmental components and potential
negative effects related to the Big Thunder ski and hiking trails destruction, and the significant
visual impacts.
ESR 8.2.6 Water Crossings

Addition of maps and diagrams to this section would assist with understanding the nature and
extent of water crossings.
This section ignores the water crossing associated with the upgraded transmission/ electrical lines
to Fort William.
The proponent must rewrite section ESR 8.2.6 to include the water crossing into Fort William.
Specific information and description should be included.
ESR 8.2.7 Delivery of Equipment

The activities should describe the specific equipment delivered and the size of truck. There are
many varied sizes and weights, many of which are over size or over eight. Without this
information it is not possible to understand the potential impacts.
The environmental components should also identify socio economic issues, as the additional truck
traffic, and road closures will impact local businesses.
Potential effects are only identified in general terms. The nature of road closures, how often, and
for how long should be identified.
Mitigation measure identifies defensive driving practices, and delivery times. More detail and
information about how mitigation would reduce impacts would be useful.
Residual effects are identified as localized and short lived. The specific impacts, and affected
business and residents would be useful.
Specifically the proponent must clearly identify the types and sizes of vehicles and impacts on
roads and local residents and businesses.
ESR 8.2.8 Foundation Construction

17
The activities should describe the specific foundation construction activities in sufficient detail to
understand what the impacts are. The depth and diameter of foundations, and how rock will be
excavated is important missing information.
The list of environmental components is missing the identification and description of

‘groundwater’ and ‘safety of residents’ who live below the cliffs. This area is a sensitive
groundwater area, and the locating of turbines in proximity to the cliff edges on fragile rock should
ensure the potential impacts are adequately addressed.
Potential effects are missing what might happen to groundwater or the mountain rock structure.
With the indication from August 23rd open house where a Horizon representative indicated that
most of the site rock will come from foundation excavation, it is expected that there will be a lot of
blasting and rock excavation.
Mitigation measures ignore mitigation for groundwater impacts, or for prevention of rock slides
and failures
Residual effects could be devastating and long term. Groundwater impacts would be extremely
difficult to mitigate, and any loss of integrity of the rock structure would result in significant
impacts to local residents and businesses.
environmental components, potential effects, mitigation measures and residual effects, and to
account for the possible impacts to groundwater and to the integrity of the mountain rock
structure.
ESR 8.2.9 Tower and Turbine Assembly and Installation

The activities should describe the specific activities in sufficient detail to understand what the
impacts are. How these activities are carried out, and with what equipment and what impacts is not
well described.
The environmental components should include ‘birds’ as these cranes and turbine parts are large
and tall. Impacts on birds in this context should be addressed.
Potential effects are only identified in general terms as disruptive. The specific effects and on what
component should be identified.
Mitigation measure identifies that area will be returned as close as possible to original condition.
This statement is unclear. Will the areas be top soiled, and trees planted?
Residual effects are identified as none anticipated. This does not correspond to mitigating back to
original condition.
18
environmental components, potential effects, mitigation measures and residual effect, and to
identify the specific mitigation required to return sites to original condition
ESR 8.2.10 Interconnections

what the impacts are. The stringing of lines and connections should be included
The environmental components should include impacts on birds, bats, and wildlife and noise
impacts.
Potential effects are only identified as related to archeology. There must be potential negative
effects, such as impacts on birds, bats and wildlife.
Mitigation measure identifies only mitigation for archeology. The impacts to wildlife etc could be
based on time of year and construction methods.
Residual effects are identified as none anticipated. This should include potential loss of habitats
and disruption to habitats.
Specifically the proponent must clearly identify potential negative effects on wildlife.
ESR 8.2.11 Water Crossings – Electrical Tap Lines

what the impacts are. This section refers to the water assessment report, but should discuss
activities here also
The environmental components should be more specific. The Kaministiquia River is home to a
walleye fishery and Lake Sturgeon
Potential effects should include disruption to fish spawning or migrations.
Mitigation measures should include timing the construction activities to avoid sensitive time
periods.
Residual effects are identified as localized and short lived. Depending on impacts to fisheries this
should be reviewed.
19
environmental components, potential effects, mitigation measures and residual effects, and to
incorporate the fisheries concerns in the Kaministiquia River
ESR 8.2.12 Switching Station Construction

what the impacts are. The size of excavations and equipment necessary should be identified.
The environmental components should include groundwater and wildlife, birds, etc.
Potential effects should include potential to disrupt groundwater or rock integrity, as well as
wildlife habitat.
Mitigation measures should include time of construction to reduce impacts on wildlife, how
groundwater will be protected, and any special considerations for rock structures.
Residual effects could be long term if groundwater impacted. The impacts on wildlife and birds
would likely be short lived
Specifically the proponent must clearly identify additional environmental components and
potential negative effects.
ESR 8.3.1 Wildlife Disturbance (birds)

Impacts on birds will likely be significant. The area is known as an area for peregrine falcons and
birds of prey. Local residents attest to significant numbers of waterfowl migrating in the area.
The wind turbines proposed in this area are very large with significant blade lengths. In fact these
turbine models have not yet been constructed anywhere. The interaction between birds, especially
birds or prey and wind turbines is often lethal to the bird. Numerous articles and information is
available in this regard, including Globe and Mail, June 10, 2010 ‘Wind farm turbines proving
deadly for birds, bats’.
The proponent has a project site 17,000 acres in size. Surely there are reasonable areas within
those 17,000 acres to locate turbines away from cliffs where falcons nest and hunt.
The proponent must identify in section ESR 8.31 why they cannot relocate turbines away from
cliff face, within the 17,000 acre study area. Movement of turbines away from area would be
best mitigation for potential effects. The precautionary principle should be applied and turbines
moved as far as possible from peregrine falcon potential nest areas, given the project life of 25
to 45 years.
20
ESR 8.3.2 Wildlife disturbance (bats)

The only comment provided at this time is that there are impacts on bats and potential impacts
should be clearly identified with mitigation. Numerous articles and information is available in this
regard, including Globe and Mail, June 10, 2010 ‘Wind farm turbines proving deadly for birds,
bats’.
ESR 8.3.3 Noise effects

Identifies all points of reception used are residences. Vacant properties should have been modeled
with potential residences. This missing information was identified to proponent and should have
been corrected
Does not identify that the manufacturer specification includes tonal effect, and no tonal effect
assumed for study
Does not identify that sound predicted is just below 40 dB, and there could be more or less noise in
reality. Should have identified mitigation and proposed action should noise be higher
A significant issue is that with noise impacts, is that there is a night time operation identified by
the manufacturer to reduce noise. This mitigation measure was not identified (or acknowledged).
Mitigation measure identified was that turbines were relocated south away from residences. This is
partially true, but turbines have been relocated multiple times in the since fall 2009, both towards
and way from homes.
Mitigation measures should have identified possible reduced noise operation, or locating turbines
farther away.
This section of the report is deficient. For identification of mitigation, it fails to identify that there
are a limited number of turbines (4 to 6) that are the source of most of the noise to residences,
mitigation regarding manufacturers reduced noise operation is ignored, and other possible
operational modes are not identified. The data used to identify the noise impacts is questionable,
noise receptors (vacant lots) are missing, the use of estimated manufacturer data, and ignoring
other manufacturer data (tonality K of 2 dB)
The proponent must rewrite section ESR 8.3.3 of the report to fully address the potential
mitigation and uncertainty regarding estimated manufacturer’s data.
The proponent must rewrite ESR 8.3.3 of the report to fully describe the mitigation measures
available including manufacturers reduced noise night time operation mode, as well as the
rationale for the mitigation to be used (and not used ) in this project (i.e. turbine location, blade
size, turbine height etc). Reference the ‘Environmental Noise Study Appendix K’ for more
specific recommendations regarding the noise study
ESR 8.3.4 Land Use and the Local Economy

21
The activities identifies only ‘wind turbine operation’ this is too general and the specific activities
of the project related to operation should be identified.
Environmental components affected ignores potential use of the land as ski and hiking trails, the
use of the vistas in the local tourist and hotel economy, the vistas importance as part of the
gateway to Thunder Bay, impacts on the local ski hill, use of Loch Lomond (coldwater fishery),
use of area as hunting area for First Nations or Métis, or any specific employment components.
Potential effects only identifies positive effects in general terms, 3 new jobs, tax base and lease
payments. There should be more information available and provided.
Potential effects not identified are costs to Thunder bay Hydro to connect the project, road upgrade
costs for the City of Thunder bay or MTO, loss of jobs from ski hill or hotel closures/reduced use,
loss of use of millions of dollars of XC ski trails, impact of no trespassing zones in area, or impacts
on local homeowners property values. The lack of any negative impacts identified is a concern.
A project that has been marketed as having 75 million $ of benefits to the community should have
more specific information identified. General information on benefits, while tending to downplay
the negative impacts does not provide the public with an accurate assessment of ‘land use and local
economy’.
Mitigation measures identifies that no mitigation is required. Based on the report only providing
limited and positive impacts this is not surprising, but certainly there will some actual or potential
negative impacts. Mitigation for impacts should include specific and detailed mitigation to reduce
potential effects as identified above. These include proponent paying for all or part of the electrical
connection and off site road upgrade costs, rerouting construction roads to stay away from ski
trails, relocating turbines away from ski and trail areas, allowing access across roads and project
site, and relocating turbines to reduce property value devaluation.
Residual effects are noted as providing a positive effect on the community. There is no evaluation
of the quantity of that effect ort how it would be determined. The residual effect for the above
noted negative potential effects should be included
environmental components, potential effects, mitigation measures and residual effects. There
must be more detail and negative effects must be identified and considered.
ESR 8.3.5 Landscape

Environmental Component affected only identifies landscape. The visual impact of the turbines
will affect the social portion of the environment. The impact of the turbines on the landscape will
22
impact the local community and the City of Thunder Bay who place high value on the natural
beauty of the area. The environmental component should be expanded to include the broader
definition of environment including the social impacts. The development of the project itself has
already caused significant environmental effects on the community with the formation of a local
citizens group opposed to the project proposed. This section should be revised to include the
impacts of the turbines on the local community, and the City.
The mitigation measures identify that turbines were moved further away from nearest residences as
a result of input from the public. Actually the turbines had been moved multiple times, some away
from and some towards residences. The actual reasons for moving turbines from one location to
another have not been clearly identified, and statements identifying why turbines were moved
should be supported by information in the ESR to detail rationale for turbine locating, and
relocation.
Further mitigation regarding paint color and lighting is of little use. Turbine manufacturer’s paint
turbines in standard colors, and lighting is required as per regulations. This is not mitigation.
Turbine colors and lighting are not identified, and should be to properly assess the supposed
mitigation.
The mitigation of moving turbines back further is totally ignored. This is an important mitigation
measure, as the available property to the proponent is 17,000 acres, yet it has sited its turbines at
the closest location to existing built up areas. Mitigation regarding smaller turbines has been totally
ignored. Smaller turbines would obviously reduce the visual impacts.
Residual effects are noted that turbines will remain visible to residents. There should be some
measure of how visible and to how many residences. The purported mitigation from moving
turbines should be identified. There should be clear and more detailed information regarding the
specific residual effects.
Importance of effects is noted as low. This completely ignores the obvious concerns which remain
in the community. Numerous deputations and public concerns have been made to Horizon and the
City in this regard. It is not appropriate for the proponent to identify this as a low importance
effect.
The proponent must rewrite Section ESR 8.3.5 Landscape to fully address the missing activities,
must be more detail, and mitigation measures must be identified and considered.
ESR 8.3.6 Tourism

The environmental component is identified solely as ‘recreation’. There should be more detail
about what specific environmental component is being discussed. For instance there is hiking,
23
cross county skiing, and snowmobiling in the area. There may be hunting and fishing. There is
downhill skiing. There is significant potential for that area if left as a natural area for future use as
a recreational area.
Potential effects are limited to visibility and road construction. Obviously the project will have
significant other effects including noise from turbines and construction, cut and fill from
construction, limited access during and after construction, possible ice throws on area users, and no
trespassing zones.
Mitigation measures are related to painting and lighting (see section ESR 8.3.6 for comments) and
modifying roads to maintain ski trail high and low points. There is no discussion regarding
locating of access roads to reduce impacts on trails, or how roads will not be compatible with ski
trails. This section ignores the potential mitigation of relocating turbines and roads to eliminate or
minimize impacts on recreational users.
Residual effects are noted as turbines remaining visible and that ski trails will remain accessible
and topography preserved. The proposed project appears t o actually utilize the present trail system
for its access roads, and the trail network will be useless once severed by roads maintained year
round.
The importance of the effects is identified as low. This statement does not correspond to the high
importance that the people of Northwestern Ontario, Thunder Bay, and South Neebing place on
outdoor recreational activities.
The proponent must rewrite Section ESR 8.3.5 Recreation to fully address the missing activities,
must be more detail and mitigation measures must be identified and considered. There must be
recognition of the residual effects of the roads, noise and visual impacts on recreational uses in
the area.
ESR 8.3.8 Property values

of the project related to operation should be identified. For instance, property value and time on
market has already been impacted by the proposal and planning activities of a wind farm.
The environmental component is identified as property values. There should be a more clear
identification that this is a social environment component.
Potential effects identify that often residents surrounding a wind farm express concerns regarding
local property values, and then provides a full page of various studies seemingly proving that
property values are not impacted. There is no identification of the significant concerns raised for
this specific project, by local residents, or how this specific area would or would not be impacted.
This area is one that has significant natural beauty, and is the primary reason local residents
identify as affecting the decision to locate there. The area is away from the City downtown, and
24
removal of the natural and unadulterated aspect of the mountains will certainly impact decisions to
locate there, and thus property values.
No mitigation measures are identified. There are mitigation measures.

The obvious mitigation measure would be compensation direct to property owners from the
proponent or the City (landowner). Other mitigation includes relocating turbines to reduce the
property value impacts, reducing the size and noise levels of the turbines, or not building turbines
at all.
Residual effects are identified as not expected to have significant impact on property values. We
do not know what is significant to the proponent, as the proponent will not be bearing the cost of
property value decline. This section should clearly identify what anticipated property value losses
would be, and on what basis. Without this it is merely speculation and conjecture, upon which no
one should rely.
Importance of effects is noted as minimal. Of course to the proponent the importance is minimal as
they will not suffer. For local residents, who will solely bear any possible property value loss, it
will be important.
The proponent must rewrite Section ESR 8.3.8 Property values to fully address the missing
activities, environmental components, potential effects, mitigation measures and residual effects.
There must be some discussion of this specific area, and potential for property value loss as the
areas’ main attraction to buyers is the natural beauty and the lack of noise.
ESR 8.3.9 Public Safety

Environmental component affected identifies only safety. The nature of this section is that it really
only deals with ice throws, so perhaps a more accurate description and component should be
identified.
Potential effects concentrate solely on ice throws. There are obviously other aspects of public
safety associated with the project, such as electrical contact, climbing/ fall from heights, fire, blade
throw and a turbine failing or falling. These other potential effects and how they relate to the
various stages of construction should be identified. For ice throws, the information presented is
primarily general in nature and does deal sufficiently with the specific project. For instance the
proximity of snowmaking equipment and a ski facility is not addressed. The wind direction, speed
and risk to turbines should be identified and discussed. The risk of ice throws is downplayed, and
the concern from local residents who live 600 feet below the mountain the turbines are located
regarding farther ice throws is not addressed. The risk associated from multiple turbines (ie the site
specific risk based on 18 turbines) is not addressed. There should be site specific information and
evaluation of the potential for ice accretion.
25
Mitigation measures are identified as sensors to detect ice buildup. The manufacturer data sheets
do identify ways to try to identify ice buildup including imbalance and power loss measurements.
These methods rely on ice building up and a period of imbalance and power loss before blades are
stopped. There will still be ice buildup, and potential for ice throw.
Mitigation is also identified as posting signs. This will mitigate neither ice throws nor public safety
(the risk will be the same, people will just be more aware).
Mitigation not discussed includes moving turbines away from human activities and residences ,
using a more sophisticated system of observation, data collection and sensing to detect conditions
which ice forms in and shutting down at those times, having exclusion zones which the public
cannot enter,
The proponent must rewrite Section ESR 8.3.9 Public Safety to fully address the missing
activities, environmental components, potential effects, mitigation measures and residual effects.
There must be some discussion of the various public safety risks and mitigation. Mitigation
measures including moving turbines away from homes should be considered given the
potentially disastrous impacts of ice throw, blade throw, or turbine failing.
ESR 8.3.10 Aeronautical Obstruction

The activities section identifies only ‘wind turbine operation’ this is too general and the specific
activities of the project related to operation should be identified.. For instance, risk to airplane
during construction from cranes would be different than during operation when the structures are
lit.
Environmental component is identified as safety. Perhaps more details here regarding how this is
an environmental component is warranted.
Potential effects do not identify any potential effects, merely that they are a risk to low flying
aircraft. The nature of the risk and how they would be impacted would be useful. If the potential
effect is actually that an aircraft might fly into a turbine or blade then that should be clearly
identified. The potential for low flying aircraft to use the area does not appear to have been
investigated. The area is close to an airport with a flight school, part of the flight path used by large
aircraft at higher altitudes for approach to the airport, and an area where small aircraft including
helicopters are often seen. None of these are identified of addressed
Mitigation measures identify that lights will be used on the turbines. This will assist with nighttime
warnings. Locating turbines away from the area, using smaller turbines, or not building turbines at
this site are mitigation measures not addressed.
Residual effects are identified as none. But pilots will no longer be able to use that area. This
should be clearly noted.
26
The proponent must rewrite Section ESR 8.3.10 Aeronautical Obstruction to clearly identify the
potential effects, and possible mitigation including turbine relocation and smaller turbines.
ESR 8.3.11 Electromagnetic Radiation

No comment at this time
ESR 8.3.12 Radio Communication and Radar

Mitigation measures do not identify how any effects which are apparent after turbines are in
operation will be mitigated. These measures could include limiting or stopping operation of
turbines altogether, or compensating the affected homeowner/ party.
The proponent must clearly identify in Section ESR 8.3.11 radio Communications and Radar
how any effects apparent during operation will be mitigated, and what will be the criteria used
to determine if mitigation is ‘necessary’
ESR 8.3.13 Visual Effects – Shadow Flicker

A significant issue with the Shadow Flicker study and results is that in the ESR report the
mitigation ignores the fact that only 3 turbines are the cause of modeled flicker. One obvious
mitigation measure ignored would be to relocate these turbines and remove all shadow flicker.
This could be assessed for moving turbines before construction and after. Another method to
mitigate flicker is to have a shutdown programmed for the specific turbines at the times when sun
causes flicker. The impact of this on power production should be minimal considering the minimal
estimated hours per year of flicker
The proponent must rewrite section ESR 8.3.13 to fully address mitigation for shadow flicker,
including shutdown operation modes, and movement of turbines (pre and post construction).
ESR 8.3.14 Human Health
This section ignores the concerns raised by local residents. This should be clearly recognized, and
identified as an issue. The information sent to City Council and available to the proponent was not
considered or included in the report. The information that local residents have provided should be
directly addressed, especially where that information conflicts with the information included in this
section.
Mitigation measures ignore the obvious mitigation of relocating turbines to an area where shadow
flicker, noise and potential for human interaction is reduced or minimized. The use of the
manufacturers night time reduced noise operation is ignored. The use of shut down modes in times
of high sound transmission is ignored. The use of smaller lower power turbines is ignored. The
mitigation that could be used once turbines are erected is ignored (ie reduced power operation).
27
The residual effects and importance of these effects is minimized. While the proponent will not
have to live in the area, it is easy to identify effects as minimal.
The proponent must rewrite section ESR 8.3.14 Human Health to consider and evaluate
information brought forward by concerned residents. Ignoring this information is not right. The
mitigation, including shutdown operation modes, and movement of turbines (pre and post
construction, reduced turbine/ tower size, lower power operation and shut down modes must be
included.
Summary of review of Chapter ESR 8
In general this chapter provides a weak review of environmental effects and mitigation. Many
sections only have a cursory identification of environmental components, impacts and mitigation.
Provision of information in tabular format so that the effect and relevant mitigation is obvious
would be useful. Clear and easy communication of the information would help in understanding
and assign impacts.
The proponent must summarize the information in chapter ESR 8 in tabular format to clearly
present the environmental effects and mitigation
3.7.9 ESR Chapter 9 Follow-up Measures

The objectives of the monitoring program do not correlate with those identified in the
Methodology. The methodology identifies that the program will collect data, verify mitigation
measures effectiveness, verify compliance, and provide information for continued improvement –
these seem to be objectives. The 9.3.2 objectives appear to be overall objectives of the project
locating /construction and operations activities. The report alternatively uses environmental
effects, valued ecosystem components and should be clear on what it will monitor and why.
The section environmental effects monitoring systems says nothing. Readers may be unsure of
what system is referred to, an ISO management system, and information system, or the specific
monitoring system for each effect. Similarly for management structures- there is no specific or
relevant information provided.
The programs plans and procedures are simply summaries of supposed programs, although there is
no program for operation and maintenance or decommissioning. There are reports that identify the
activities associated with these,. If these are actual programs they should be properly described,
and documented as programs. These sections are essentially irrelevant.
The monitoring section fails in most cases to provide sufficient quantity or quality of information
to adequately describe the monitoring. There is no monitoring identified for noise, groundwater,
fish and fish habitat, radio communication, property values, or local economy. Many of these are
actually identified in Chapter 10 as having monitoring, yet they are ignored here. Where
monitoring is described (3 requirements), the report fails to identify fully how the monitoring will
collect data, verify mitigation, measure effectiveness, verify compliance, or provide information
for continued improvement.
28
The proponent must review their monitoring objectives to ensure that they are relevant to its
methodology, and monitoring activities.
The proponent must define what environmental effects monitoring systems and management
structures are. These sections have general descriptions of how the proponent will supposedly be
environmentally responsible and refer to other reports without sufficient information in this
report.
The entire section follow-up measures dealing with monitoring must be reviewed and completed
to identify properly the objectives and monitoring consistent with the environmental effects and
the entire report. In its present form it lacks detail and consistency, and does not provide
sufficient information to evaluate whether the monitoring activities and program.
3.7.10 ESR Chapter 10 Summary of Mitigation, Effect Management and

Monitoring Commitments
The summary section is only a table, without any discussion. It was good to see information
presented simply without irrelevant and general discussion.
This section describes effects, mitigation and monitoring grouped by ecosystem components. This
grouping was done in section ESR 8.8 and ESR 8.9. The grouping here tends to simplify the
effects, and does not identify which mitigation or monitoring applies when multiple effects are
within a single component. It is important to understand how each potential effect (or group) will
be mitigated and what the monitoring is. There is no indication of monitoring for most of the
effects, and where monitoring is indicated the commitments should a problem occur is not
identified.
The proponent must identify clearly how each effect is mitigated and the monitoring. Should
monitoring identify problems the commitments to address the problems must be identified. This
was done verbally in open houses for some effects, for instance which if noise is above 40 dB at
a receptor, the farm (or offending turbines) will be shut down.
3.7.11 ESR Chapter 11 Project Advantages and Disadvantages

Project advantages identify many advantages in broad and general terms that are irrelevant to this
specific project area, or the people impacted. For instance the economy of Ontario is too broad a
recipient of construction value, the local areas (Thunder Bay and even northwestern Ontario’s)
benefit would be more relevant. Many of the advantages do not appear to have been discussed or
identified in any detail in the report, and if provided here should be clearly and fully described
within the report. For instance, decreased reliance on fossil fuel energy, when the energy mix in
the area is almost entirely Hydroelectric, and when wind power operates it will require a backup
online should the wind power change suddenly. There is no examination of the impacts
specifically of this project on the electrical system operation or how a 27 MW station will result in
decreased reliance on fossil fuel (coal, natural gas, oil) in this region.
The project disadvantages downplay or ignore the disadvantages. The use of ambiguous terms
such as ,some area’, ‘small amount’, ‘will change’, and ‘may be discouraged’ in this section leads
readers to conclude these disadvantages are minimal or irrelevant. There should be sufficient
29
description to allow readers to determine themselves the significance. There are missing
disadvantages that have been raised by the public for months, or years. For instance potential
property value declines, potential health impacts, admitted noise annoyance issues, loss of the trail
system (by roads, limited access, and noise), loss of significant sugar maple tree areas and loss of
future use of the land for other purposes.
The proponent must revise the project advantages and disadvantages to provide information
relevant to this project, and fully describe the actual and potential disadvantages, especially
those that the public have raised. This includes loss of sugar maples, and potential property
value losses and health impacts.
3.7.12 ESR Chapter 12 Conclusion

The description of the process followed indicates that the project followed the Environmental
Assessment process. This is not correct; the Environmental Assessment process was not followed.
The project started under the Environmental Assessment process, and finished with the REA
process, but followed neither fully. This section fails to identify the transition provisions and how
that has impacted the process and reduced opportunities for public involvement (no PDR open
house).
The list of features is provided, whereas a list of environmental components would be better.
Perhaps they are the same, but the use of the word feature, without further describing how each
feature is impacted leaves it up to readers to interpret for themselves. The identification that the
project will have very few net negative effects on the environment ignores the concerns and issues
raised by local residents and stakeholders. The proponent must acknowledge this as at least
potential negative impacts and that to the recipients of these negative effects the considered to be
significant.
The proponent must fully and accurately describe the regulatory requirements, how they
changed during the project, how this project does not satisfy the full REA process, and the
impacts on opportunities for public involvement.
The proponent must acknowledge that there are potential negative impacts identified by local
residents and stakeholders, and that they consider the residual effects significant.
3.7.13 ESR Chapter 13 References

This section should be updated, and reflect all the referenced reports and material used in the draft
REA / ESR reports. It would be useful to have references numbered and cross referenced so that
readers could easily identify the source of data and information within the reports
There are missing references. For example

P 58 indicates that the Monarch butterfly is listed by the COSEWIC as Special Concern,
but this does not have a date, and the only list indicated as referenced is for the rare plants
database
p59 indicates that the Ontario Breeding Bird Atlas Surveys (2001 to 2005) which is not
in the references
p 61 references a source Environment Canada, 2008 which is not in references
30
pp 62- 64 references a source as Statistics Canada, 2006 Census of Canada, but this is not
n references
There are references that are so general they are of no value, they do not point to the information
that the report might have used, for instance,
Ontario Power Authority. 2006. http://www.powerauthority.on.ca. Retrieved March 10,
2006
This website has significant amounts of information, and a general website does not direct the
reader to where specific information referenced is. Also, the date of the reference appears so old it
is irrelevant. There have been significant updates to the process since 2006, including a complete
change in energy approvals process, FIT updates, and awarding of energy contract offers.
The proponent must update the references section to clearly identify the source material. Use of
tables and numbered cross references would greatly assist readers and reviewers in confirming
sources.
3.8 ESR Appendix A Agency Correspondence

Agency correspondence is presented as a collection of newspaper notices, letters and emails. It is
unclear how the various items apply, or fit into the process. It is unclear as to the status of various
agency requirements, for instance the Canadian Environmental Assessment Act application (Feb
13, 2008 J. Chan to N. Nguyen).
The various proponents involved is difficult to rationalize, with some letters addressed to people
without companies, and some letters to previously unknown companies (i.e. Foghorn Renewable
Energy). The role of these various companies and people is not identified within the project
documents, or in this appendix.
A table identifying correspondence by agency, including date and issue/resolution would clarify
what the various items relevance is. Without context the collection of items is only serves to
confuse.
The proponent must identify the role of the various companies and people involved in the project
and agency consultation. Without this, the public cannot be sure of whether the agency contacts
are relevant and appropriate to this project.
The proponent must identify the various agency correspondences in a table, and correlated how
they relate to the various elements of the project. A clear path of agency consultation and issue
resolution would benefit the public in understanding the process and status of agency
consultation.
3.9 ESR Appendix B Technical Specifications

This appendix is identified in the appendix as a technical specifications report. In fact, it is a
collection of data sheets from the manufacturer. The source of the data sheets and a responsible
person to attest to the accuracy and validity of information is not provided. For other data sheets in
another part of the report, the data sheets have a different person identified as the release Ing, and a
different date.
31
The second last page (unnumbered) and possibly added to the specifications identifies that the
Vensys 82 will be measured directly after erection of the first turbines. The ‘report’ should clearly
identify that the data is based on estimates, and not measured or actual data
The last page of the specifications identify that the Vensys 82 has no significant tonality. This is
used in the noise studies to justify 0db tonal penalty. But in other pages, there is a tonal coefficient
kT of 2 dB. The letter regarding the noise guarantee is a persona letter on Vensys stationary to the
proponent. Without identification of who the author and guarantor is, and on what specific basis
the claim is made, this letter should not be relied upon.
The proponent must provide technical specifications based on actual data, or clearly identify
that the data is estimated. Use of estimated data in noise studies should include a sensitivity
analysis to account for possible estimation errors.
The proponent must provide additional information related to tonality. Reliance on a single
letter with a statement from an unknown representative of the manufacturer is not appropriate.
3.10 ESR Appendix C Public Consultation

The information contained in Appendix A provides detailed comments by page on the report, and
is summarized in Table 2 Consultation Initial Comments Summary. The comments in Appendix A
indicated that there were 43 specific issues identified with the report, of which 40 were considered
‘credibility’ issues. The credibility is directed at the report itself and whether all information is
presented fully and completely, whether any information has been omitted, and whether the public
can rely on the credibility of the report.
Report Type of issue Number of issues (Total = 43)

Consultation rpt Minor infractions
False information
REA conflicts
Process inadequacies
Credibility 40
Table 2 Consultation Initial Comments Summary
Public Consultation is presented as a collection of newsletters and information sheets (likely from
open houses). There is no indication on the sheets as to the source, or relevance to consultation.
Without identifying how the various newsletters are relevant to public consultation, this section is
confusing and of little value.
There seems to be an incomplete collection of news articles and public consultation related
material. There was significant public concern and numerous direct contacts with the proponent;
newspaper articles, media releases, editorials, letters to the editor, and presentations to council.
These were primarily opposed to the project of turbine locations, and the proponent should include
these. It is not appropriate to only include information or articles that support its project, and
ignore others.
32
The proponent must address the 43 comments as included in Appendix A related to the
Consultation
The proponent must identify the various public related correspondences, articles, and
information in a table, and correlate how they relate to the various elements of the project. A
clear path of public consultation and issue resolution would benefit the public in understanding
the process and how the public concerns have been addressed (or not addressed).
The proponent must acknowledge the significant community concern and identify specifically
what was done in that regard. Whatever specific actions taken and the results should be clearly
documented
3.11 ESR Appendix D First Nation Consultation

This appendix is empty. There is a note that correspondence will be documented in the
consultation report with final REA Application.
This does not seem acceptable from the point of view of identification of consultation in the draft
for public comment. Also, consultation and identifying what has happened is more than just
correspondence. There should be sufficient identification of the activities and how the project has
identified and addressed the concerns of First Nations
The proponent must provide a proper First Nations Consultation report, identifying more than
simply correspondence. The consultation report should identify the contacts, issues, mitigation
and residual effects associated with First Nations related concerns.
3.12 ESR Appendix E Avian Impact Assessment Report

This report was not reviewed in detail and further comment will follow.
From a general review it was noted that

Chapter one introduction is merely a copy of other introductions and provides no relevant
information on this report. It would be useful to have further description or introduction of
this report in the Introduction
Regional geology ignores the hydrogeological aspects. This area is a significant recharge
area for groundwater and a cold water lake.
The proposed protocol for the site was developed and agreed to by Environment Canada in
2008. Given that the report was issued in 2010, and there may have been changes to avian
species level of concern since 2008, the present applicability of this protocol should be
confirmed. A number of local residents have identified that any development on their
properties adjacent to the Nor’Wester Mountains must be undertaken with special
provisions to protect peregrine falcon habitat is not addressed.
General habitat characteristics do not identify the large number of cliffs.
The bird survey locations (figure 3.1 June 2009) were limited to specific sites which appear
to have been determined previously as turbine locations. This suggests that the turbine
33
locations were determined as early as June 2009, and that other information regarding
moving turbines in response to community concerns in late 2009/early 2010 should be
questioned.
The nesting period results in a commitment to do forest clearing outside of May 24 to July
23. This mitigation is not identified in the ESR chapter 8.9, table 8-6, 8.2.4 land clearing.
The peregrine falcon and nesting area issue identifies consultation with MNR is ongoing.
This should be clearly identified with risk to project and impacts on this environmental
component. How these issues will be mitigated, or that it is outstanding, could not be
located in the ESR chapter 8.9
The proponent must ensure that mitigation for identified effects is included in the
appropriate activities in the ESR, where issues are outstanding these should be clearly
identified in all relevant sections of the ESR, and that all information is up to date and
complete.
3.13 ESR Appendix F Bat Monitoring Report

This report was not reviewed and comments on this report will be provided at a later date
3.14 ESR Appendix G Archeological Impact Report

This report was not reviewed in detail, and further comments will be forwarded at a later date.
The following comments are provided at this time,

The report identifies the location as Municipality of Blake, although other information in
the REA reports identifies it as Neebing Municipality. This raises concerns whether the
assessment was done for the correct location.
The report identifies the area has high potential regarding archeological evidence.
The description of use of the area does not acknowledge that the Fort William First nation
is located adjacent to the subject property, that the area was subject to land claim
previously, or that the Nor’Wester Mountains and Mount MacKay adjacent to the site was
of special significance to native peoples.
The report does not acknowledge the presence of the historical Fort William, fur trading
and historical and current presence of Métis.
The report dos not identify that Loch Lomond is a clear cold water lake with fresh water
and lake trout. This would have been good areas for people to live.
Conclusions and recommendations identify that a Stage 2 Archeological assessment be
undertaken before final design phase in order to maximize opportunities to avoid
archeological heritage features. Apparently the present proposal is to do the Stage 2
assessments as the project is constructed
The attached letter from Ministry of Culture (should be in agency consultation) identifies
that stage 2 assessment should be completed far enough in advance to account for delays.
The proponent must confirm the location of the assessment, and ensure that the input of First
Nations and Métis peoples are included.
34
ESR Appendix G. The proponent must undertake a stage 2 archeological assessment before
final design and location or turbines and roads, as per its own consultant and Min of Culture
recommendations. To finalize turbines and roads before the stage 2 assessment risks damaging
heritage features during construction and the entire project viability.
3.15 ESR Appendix H Rare Terrestrial Species


This appendix is merely a set of tables listing information regarding terrestrial species as
indicated in ESR 7.4. This would be satisfactory, except that ESR 7.4 provides no further
information, assessment or interpretation of this data as it relates to this project. Without
this included in the ESR, it should be located here.
The tables are identified as table 13-1 through 13-6. It is not known whether this means that
this is only part of a series of chapters, this being the 13th. This should be corrected.
The proponent must ensure that the relevance of the data listed in this appendix, to the specific
project and potential impacts is identified. This could be in the appendix or more appropriately
in the ESR.
3.16 ESR Appendix I Areas of Natural and Scientific Interest

This appendix is a single page, identifying the ANSI.
There is no reference to the source of the page of information
There is no indication on the map of the relative location of the proposed turbines
The relevance of the ANSI, and whether similar areas (without designation) exist in the
project area is not identified or discussed
ESR Appendix I. The proponent must identify the source, and date of the information sheet
which describes the ANSI.
The proponent must identify the location of proposed turbines on a map which includes the
ANSI.
The proponent must discuss the important scientific and natural features, and whether these
exist elsewhere in the project area and how they will be impacted, and mitigation measures.
3.17 ESR Appendix J Radio Communication, Radar, and

Seismoacoustic Impact Assessment

Section 3.5 suggests that post construction mitigation measures are included in a
RABC/CanWEA document. These mitigation measures, how determined if required and
who will pay should be clearly identified.
35
Pre construction surveys should be undertaken before anything is built to ensure that any
changes can be properly attributed to its cause.
Includes an appendix of parties contacted. They are all agencies, with no residences. Also,
2 of the parties have pending concerns, and one listed as no concerns (NavCan) identified
in agency consultation ‘possible concerns’
Recommendations clearly identify potential for degraded signal quality for area residents.
These residents should be individually contacted and advised of potential impacts.
The qualifications and limitations section is worrisome. It clearly states that the report
cannot be relied upon by anyone other than the proponent. How a member of the public can
use the report and rely on it to understand the project and assess the potential impacts is not
clear. Without a report upon which the information and analysis can be relied upon, there is
in essence, no report.
The proponent must ensure that mitigation measures and implementation criteria are clearly
communicated and agreed to before any construction begins.
The proponent must carry out surveys of the status of existing reception of potentially impacted
residences. Potentially impacted residences should be contacted individually before any turbine
sites are finalized.
The proponent must clearly identify the status of agency consultation, and specifically what
concerns were, and how satisfied.
3.18 ESR Appendix K Shadow Flicker Analysis Results

The Shadow Flicker Study as identified in Appendix K of the ESR is actually just a series of
computer model printouts. There is no serious attempt at providing a ‘study’ or analysis with
conclusions, assumptions or limitations. Some of this information is provided in the body of the
ESR 8.3.13.
The main issues with the Shadow Flicker Study are as follows, and are described in following
subsections
Incomplete report
Inconsistency with ESR report
Missing receptors
A significant issue with the Shadow Flicker study and results is that in the ESR report the
mitigation ignores the fact that only 3 turbines are the cause of modeled flicker. One obvious
mitigation measure would be to relocate these turbines and remove all shadow flicker.
The proponent must provide proper study assumptions, model description, interpretation of
results, conclusions and recommendations for the Shadow Flicker study. Without these the
analysis has little value to most readers.
36
The proponent must include in its interpretation of the shadow flicker analysis an indication of
the extent and effects of shadow flicker, as well as the information that only 3 turbine locations
are the source of the identified flicker.
3.18.14 ESR Appendix K Incomplete report

The report has no introduction, assumptions, conclusions or recommendations. The model and
basis for the model are not identified in the report. It is left to the reader to try to decipher the
parameters used in the model from the cryptic information on the model printouts. Also, the report
has no author identified, nor their qualifications.
3.18.15 ESR Appendix K Inconsistency with ESR Report

There are a number of inconsistencies between the ESR main body report section 8.3.13 and the
‘report’ appendix K. These are summarized in Table 3 Inconsistencies between ESR and
Appendix K below,
ESR 8.3.13 Appendix K

Receptors identified as windows in Identifies a single receptor at each building
building
Identifies map included with Appendix K Map is illegible to identify specific
to identify turbines and generators receptors and what the identifying letter is
Identifies shadow flicker maximum at any Identifies 7 homes , all with shadow flicker
residence 1 hour 32 minutes per year (does from 1 hour 35 minutes to 6 hours 40
not identify ‘worst case’) minutes per year worst case
Does not include table shadow flicker by Shadow flicker by turbine indicates only 3
turbine of 18 turbines are case of shadow flicker
Table 3 Inconsistencies between ESR and Appendix K
3.18.16 ESR Appendix K Data Issues

The report utilizes receptors identified as supplied by Horizon Wind, and improved by satellite
imagery. At the August 4th, 2010 open house a Horizon representative identified that the receptors
were ground truthed and verified. The receptors identified do not include vacant properties (as
required for noise studies). The receptors identified area 1 meter square boxes meant to simulate
the home. Obviously the homes area much larger and the receptors are much larger. The use of
property immediately outside the home would also be normal, so use of a receptor the size, shape
and location of the home would be appropriate.
It is recommended that the Shadow Flicker study be remodeled with receptors at existing and
potential homes (vacant lots) and that receptors are modeled at a size and location that
accurately represents the homes.
It is recommended that the Shadow Flicker Study Appendix K be revised to provide sufficient
detail on the model, assumptions, conclusions so that readers can understand the modeling
It is recommended that the proponent identify that moving turbines 5, 8, and 12 would eliminate
all shadow flicker, and identify why these turbines cannot/will not be relocated.
37
3.19 Project Description Report

The Project Description Report was reviewed against the MOE Technical Bulleting One (TB1),
Guidance for preparing the Project Description Report. This was done because a Horizon
representative stated at both the August 5th and 24th 2010 public open house that the REA reports
would meet the technical bulletins.
Technical Bulletin One describes the Project Description Report as a document that is used to
communicate a description of their project, including any negative environmental effects. The draft
version of report is to be developed early in the process, and prior to the draft REA reports. It is the
communication of real and detailed information to the public and an important component of the
REA process.
The review of the Project Description Report for BTWP May, 2010 (no date on report) indicates
that the report is missing a substantial amount of information. The information contained in
Appendix A provides detailed comments by page on the report, and is summarized in Table 4
Project Description Report Initial Comments Summary. The comments in Appendix A indicated
that there are 55 specific issues with the report, primarily related to missing information. That
missing information supports the statement that the Project Description Report as submitted does
not satisfy TB1. Also, there was no draft Project Description Report issued at any time in the
process.
Report Type of issue Number of issues

(Total 55)
Project description Minor infractions 3
False information 4
REA conflicts
Credibility
Table 4 Project Description Report Initial Comments Summary
Further to the comments in Appendix A., following are more comments on the Project Description
report.
The project overview section is missing information. The description of the proponent and its
background does not adequately describe who the various proponents and consultants involved in
the project are or their relationships. For instance there are 5 projects applied for (Big Thunder
Wind Park Alpha through Gamma) by Big Thunder Wind Park LP. There is an overall company
Horizon Energy Legacy Group, with Horizon Wind LP, and Horizon Wind inc. there is a
Consultant MK Ince and Foghorn renewable Energy Inc. The various companies, Group,
Incorporated’s and Limited Partnerships are confusing. The roles, relationships and responsibilities
and liabilities should be completely and fully described. The contact for Horizon has no title
indicated and it appears to be a junior representative, with an email at Big Thunder (not at
Horizon). The proponent’s background in infrastructure type assets is vague, and the reader is
38
unsure of what this refers to, for instance power projects, or roads, or sewers. The approvals
section is silent on the implications of crossing the First Nations lands, or locating the project on
traditional lands formerly subject to land claim.
The project description section is missing data as required in the TB1. Blade sweep area, acoustic
emission data, and sound power frequency should be included here. Some of this information is
included in the ESR, but it is required here. The report neglects to mention important information
such as; that the noise power levels are only estimates, that this particular turbine generator has
never been constructed or measured for sound emissions, that there is a night time reduced noise
operational mode, or that the manufacturer identifies a tonal coefficient of 2 dB.
The project description fails to adequately describe the electrical connections outside of the
immediate turbine area. The electrical lines and equipment including the underwater crossings
should be clearly identified, without errors in connection location descriptions.
The planning activities describe a multi- year consultation process. The description fails to identify
the significant public concerns and opposition since November of 2009. There is a heading for
stakeholder consultation, but there are no activities listed, leaving the reader to conclude there was
no stakeholder consultation. There is no mention or description of technical studies undertaken.
There is no mention of the change in study area or change in turbine locations, or the rationale for
those changes. The description also fails to describe the changing regulatory processes or the
various transition special provisions, how they differed from the full requirements, or the impacts
on the planning and consultation process.
The construction section leaves questions answered.. While realizing it is summary information, it
is difficult to understand the proponent will excavate the foundations for these extremely large
turbines, in an area of volcanic intrusive and diabase rock. The significant issues surrounding
construction and blasting are not addressed. Blasting on top of a plateau or mesa rock formations,
below which residences and a downhill ski facility are located, raises serious concerns. The
interconnection facilitates construction section fails to provide information regarding the
underwater crossing, or how the various phase will be constructed. There is no information about
when or what each interconnection phase (phase of the project) will be comprised of, what
upgrades, what new turbines and lines and where.
The operation and maintenance section should identify the extreme weather events that would
result in shutdown, the temperature ratings and limitations of the turbines, and how the turbines
will be operated when snowmaking operations are on going. The section references ensuring
access to the site year round, but the reader is unsure if this means public access, or restricted
private access. The area is presently available to the public to utilize, so this is important.
Environmental monitoring fails to identify that noise is an issue, especially as turbines, blades and
mechanical equipment ages.
Decommissioning identifies that heavy equipment will be used to remove the foundations,. The
reader could assume that foundations will be removed. Natural regeneration is identified for site
rehabilitation, followed by a time frame of 2 weeks. It is unclear how the site will naturally
regenerate in 2 weeks. This should be corrected tot prevent misunderstanding regarding this
activity.
39
The site plan included is difficult to read and understand. According to a proponent representative,
the site plan should be printed poster size to be properly read. This map should have been included
as a set, in sections, at a scale that could be reasonably read and interpreted.
The project location map identifies what is indicated as the original study area. Many residents
have identified that there was information and mapping provided early in the project (2008 or
2009) that indicated a much smaller study area centered on the Big Thunder Ski facility. The
change in study area, the timing and implications on the process and consultation should be
communicated. The proposed study area map is difficult to read the details, and should include
additional more detailed maps. The maps are also missing the source and information such as
homes.
The current land use fails to describe the significant land use of the project area for the electrical
lines. These lines are part of the project and will follow roads beside homes in various types of
settings (rural, semi rural, and residential), under a river, across a railroad yard, and through forest.
The description of First Nations interests has simple and obvious errors. The name and date of the
treaty appear to be incorrect. The ongoing land claim, and traditional use of the land on which the
project is located is not described. The data provided for the reserve statistics is old, and recent
data is readily available. There is no description of the Métis or the historical and present interest
in the area.
The description of nearest residences is wrong. It fails to identify the residences closest tot the
turbines in the City of Thunder Bay. It is difficult to understand if these are simple errors, or
indicative of a deeper lack of understanding of the area. The significant number of homes in the
Broad Oaks and Mount Forest and Caspian Road subdivisions is ignored. These are the areas
which have identified themselves as significantly concerned since 2009. Unfortunately, the
proponent failed to meet with them or acknowledge their concerns.
The proximity to significant sites provides information on sites that appear to be located far and
away, alongside sites close to and within the project area. The sites that are impacted are only
generally described, without any useful detail. The impacts of the proposed project on these sites
are ignored, but should have been an important part of this section.
Project Environmental features section identifies the sites on mountains 430 to 450 metros
elevation. This would suggest to a reader that they are 430 m tall, upon which 140 m structures
would not be significant. In fact the mountains are approximately 200 meters in height, with
elevation of 430 to 450 metros above sea level. Structures 140 meters on top of 200 meter
mountains are significant. Loch Lomond as a significant cold water lake and the area as a
significant and sensitive groundwater recharge area is ignored. The geology is only nominally
described and implications on this project are ignored.
The vegetation only discussed maples in the context of Squaretop Mountain, and ignores the
significant stands of Sugar Maple over the entire study area. These Sugar maples are rare to
Northwestern Ontario, and re perhaps beyond the range they are normally found.
40
The impact on peregrines is not discussed, and the location of turbines close to the cliffs, when
there was significant study area (17,000 acres) within which to locate is not discussed. Impacts on
birds are indicated as ‘taken seriously by the proponent and has been carefully studied and
considered’. Unfortunately no where in the report (or any of the REA reports) is it identified how
the birds are considered specifically in locating turbines or roads. This is a common observation,
where the report identifies that something is carefully considered, but the manner and to what
extent considered is never identified. Identification of mitigation is not the same as consideration.
The bats and aquatic environment sections are not commented on here. Refer to Appendix A
The requirements for fish, fish habitat, and navigable waters are not commented on here. Refer to
Appendix A.
The environmental effects section would be anticipated to be one of the most significant and
detailed. It is actually one of the shortest and most general. The archeological assessment section
fails to acknowledge that it is recommended to perform stage 2 assessments early enough in the
project to avoid delays. Also, it is not understood what the phrase ‘construction will only occur on
areas cleared of any archeological concerns’. This appears to indicate that concerns will be
removed physically, perhaps by earthmoving equipment. Natural heritage features fails to identify
the natural heritage feature of the mountain range itself, and impacts on the visual character. No air
odor or dust emissions are identified, although it is expected that construction will result in
significant activity including blasting. The dust and compressive air blast will be an effect. The
noise section fails to identify that the noise study uses estimated data on turbines never measured
for noise, that the modeling resulted in noise just below MOE limits, and that over time noise
increase due to mechanical wear and physical injury to blades. This noise section also fails to
identify tonal effects, and the use of night time reduced noise operations as per manufactures. The
noise section fails to identify that it is primarily between 4 and 6 of the 18 turbines that are the
cause of noise concerns as per the modeling. The visual impacts section ignores the significant
concerns raised for 6 months before the report was written. The visual impacts on the local
residents have been identified as a significant issue, as the main reason to live in an area away for
the City is the areas natural beauty and vista. The photomontages referred to include areas so far
removed the turbines are insignificant and the sky/cloud colors and photo quality masks the
turbines. The impact of the significant roads up the mountain area ignored and should be included.
The impact of flicker by only 3 turbines is ignored. Land use describes not restricting use, but
other wind farm operators use no trespassing zones, and there have been conflicting verbal
promises/interpretations, both limiting and allowing full access. The land use section fails to
address the effect of the roads destroying the exiting trails; loss of these trails will mean that the
closed sports park will likely never be viable.
The public health and safety section ignores the many concerns raised by the public regarding
potential health impacts of turbines. Whether the proponent agrees or not, these should be
acknowledged. Also the health impacts of ice throw, turbine self destruction, fires, lightning strike,
and the noise in the area (generators are 105 dB) is not included or discussed. The report indicates
there are no protected areas, although there is an ANSI.
Conclusions in this report could easily be mistaken for the introduction, or perhaps part of a
promotional brochure. They provide no specific or useful conclusions related to the information
provided in the report, or for this project.
41
The proponent must address the 55 comments as included in Appendix A related to the PDR .
The proponent must revise and update its Project Description section to fully describe all the
various legal entities and their relationships. The proponent’s background relevant to wind
power development must also be more fully described relevant to this project.
The proponent must provide additional information and description of the electrical facilities
which are off the immediate generator site, but still part of the project.
The proponent must revise the project data to include the information regarding estimated data,
reduced noise modes, tonal noise, and that no turbines of this particular model have ever been
constructed
The proponent must revise the planning section to fully address the changes in regulations, and
the project consultation process.
The proponent must revise the planning section to acknowledge and address the significant
public concerns, describe its stakeholder consultations in detail, and the specific impacts on the
project, planning and consultation
The proponent must revise its construction section to address the potential difficulties and issues
surrounding foundation installation in complex rock structures above residences. The
interconnection facilities need to be properly described so that each phase of the project and its
timing is understood.
The operations and maintenance section must clearly identify what are the operational
constraints and how operation will be impacted during snowmaking at the ski hill. The public
access tot the site is suggested as year round and this should be confirmed.
The proponent must clarify and include additional information regarding decommissioning.
The proponent must provide clear maps in sufficient detail for the study area, and project site
and layout. How these maps and areas, and layouts were revised over the project should also be
indicated.
The current land use, First Nations interests, proximity to residential and significant sites
sections have significant errors and omissions. The proponent must fully address the identified
errors and omissions, and describe these land uses and the impacts of the proposed project on
them
The proponent must revise the environmental features section to adequately address the
identified deficiencies including peregrine falcons, maple sugar trees, and geological features.
The proponent must clearly identify how the environmental features and impacts were
specifically considered in the decisions used to locate turbines, roads and electrical lines. This is
perhaps one of the most significant omissions in the entire report
42
The proponent must revise the environmental effects section to adequately address the identified
deficiencies including the natural heritage, noise, visual, and land use concerns. This section
should fully identify effects, specifically for this project.
The proponent must provide a conclusions section that has substance. The significant
environmental features, impacts, and mitigations would be a good start.
3.20 Design and Operations Report

The draft Design and Operations Report was reviewed against the MOE Technical Bulleting Four
(TB2), Guidance for preparing the Design and Operations Report. This was done because a
Horizon representative stated at the August 5th and 24th 2010 public open houses that the REA
reports would meet the technical bulletins.
Technical Bulletin Two describes the Design and Operations Report as the principal document
where details of a renewable energy project are presented. The report must present information
clearly, and ensure all information is accurate. If elements of the report are unclear or inaccurate
this may form the basis of MOE determining the application incomplete or not approving the
project.
The review of the Design and Operations Report for BTWP dated May 21, 2010 indicates that the
report is unclear, and is missing information. The information contained in Appendix A provides
detailed comments by page on the report, and is summarized in Table 5 Design and Operations
Report Initial Comments Summary. The comments in Appendix A indicated that there are 74
specific issues with the report, primarily related to missing information. That missing information
supports the statement that the Design and Operations as submitted does not satisfy TB2.

(Total = 74)
Design and Operations Minor infractions 12
False information 3
REA conflicts 3
Credibility 1
Table 5 Design and Operations Report Initial Comments Summary
Further to the comments in Appendix A., following are more comments on the Design and
Operations report.
The Design and Operations report provides general information. It seems to borrow and lend
heavily with other REA reports. For instance, almost all of page 3 is directly from the Project
Description Report (PDR). The Design and Operations report should be further development and
more detailed description, not the same as the PDR. This is perhaps a symptom of the problem
with issuing the PDR and at the same time as the other REA reports, rather than properly following
the REA process.
43
The site plan included is difficult to read and understand. According to a proponent representative,
the site plan should be printed poster size to be properly read. This map should have been included
as a set into sections at a scale that could be reasonably read and interpreted.
There is missing critical information, such as the manufacturers night time mode reduced noise
operation, identification that manufacturer data based on estimated operation (no actual data
available), and that the manufacturer identified a tonal noise component (as well as no significant
tonality)..
The information provided on noise receptors is incomplete. The noise receptors of vacant lots are
missing, as is the ski area educational facilities. The table of noise receptors identifies buildings as
assumed 2 storey residences, with no indication of address or actual building size.
The operation and maintenance section is less than 1 page in length. Given that this is a Design and
Operations report, it would be expected that there would be considerably more detail supplied
regarding operation of the facility. This section is almost worthless, and should identify such items
as whether the turbines will rotate based on wind direction, operational limitations (wind speed,
temperature), how noise relates to wind speed and power output, methods to reduce noise (ie night
time reduced noise mode) etc.
The communication plan section is also essentially worthless. It provides some information of
construction plan updates which is irrelevant to the design and operations. Without understanding
how communications will be carried out, over and above the general information that appropriate
agencies are engaged as required, this section cannot be reviewed.
The environmental effects monitoring section is not clearly laid out. It is difficult to read and
summaries of effects and mitigation would assist greatly. Often the mitigation is not actually
mitigation (such as noise criteria are met at every point of reception). Meaningful mitigation
measures would be those that can be applied during the design or operations stages, such as turbine
relocation to reduce potential noise impacts, or operation in night time reduced noise mode, or
reducing turbine output and noise to reduce impacts. The mitigation should be clearly identified as
to whether it can be applied after turbines are constructed. How potential problems would be
mitigated is not clearly addressed.
The key contact list is deficient. In cases of emergency it should clearly identify what to do in case
of specific emergencies. This site is not within the City of Thunder Bay, but Neebing Municipality
and there is no Municipal contact shown. Neither is there a fire department number indicated for
Neebing Municipality. There should be some locational information posted on each turbine so that
a caller would be able to direct emergency organizations to the correct location. Many of the
contacts seem inappropriate for emergency or regulatory issues, such as the MOE EA coordinator,
MNR district planner (retired) and MCC regional advisor.
Finally, the qualifications and limitations section is worrisome. It clearly states that the report
cannot be relied upon by anyone other than the proponent. How a member of the public can use the
report and rely on it to understand the project assess the potential impacts is not clear. Without a
report upon which the information and analysis can be relied upon, there is in essence no report.
44
The proponent must address the 74 comments as included in Appendix A related to the Design
and Operations Report
The proponent must revise and reissue the draft Design and Operations report, in a format
consistent with the requirements of MOE Technical Bulletin 2, upon which the public can rely
upon. Without the information and detail as required in TB2 the May 2010 draft report should
not be considered sufficiently complete.
3.21 Construction Plan Report

The Construction Plan Report was reviewed against the MOE Technical Bulleting Three (TB3),
Guidance for preparing the Construction Plan Report. This was done because a horizon
representative stated at the August 5th and 24th 2010 public open houses that the REA reports
would meet the technical bulletins.
A key part of TB3 is the purpose as stated on page 1, ‘to describe in sufficient detail project
activities related to the construction phase so that all potential negative environmental effects may
be identified’ and ‘must describe mitigation measures’
The review of the Construction Plan Report for BTWP dated May 18, 2010 indicates that the
report does not meet that purpose. The information contained in Appendix A provides detailed
comments by page on the report, and is summarized in Table 6 Construction Plan Report Initial
Comments Summary. The comments in Appendix A indicated that there are 63 specific issues with
the report, primarily related to missing information. That missing information supports the
statement that the Construction Plan as submitted does not meet the purpose of TB3

(Total issues=63)
construction rpt Minor infractions 6
False information
REA conflicts
Credibility 1
Table 6 Construction Plan Report Initial Comments Summary
Further to the comments in Appendix A., following are more comments on the Construction Plan
report.
The construction plan report provides general information. It seems to borrow and lend heavily
with other REA reports, rather than providing information specific and detailed to the construction
activities.
For instance the construction schedule only provides general information, rather than identifying
specific activities especially on a turbine basis. There is no information provided related to the
electrical transmission line construction, and it is not possible to understand how the construction
45
activities and the equipment might impact the environment. Specific information regarding
locations and amounts of materials and potential effects are not clearly identified
Environmental impacts for construction are not clearly identified, but rather referenced back to the
ESR report. That information should have been clearly indicated in this report, and correlated to
the construction activities. Forcing readers to move between reports does not seem to satisfy the
TB3 purpose of the construction report.
The environmental monitoring section appears to be common with other reports, such as the
decommissioning plan report. The environmental effects monitoring plan is not included, but
rather a reference provided to the Design and Operations report. The monitoring of environmental
effects associated with construction should be separated and included with the construction plan
report.
The conclusions section is really another description of where to find the information in other
reports. The conclusion that the construction will be carried out to minimize negative impacts on
the environment is difficult to understand, given that there is a lack of clear information provided
as to potential negative impacts, mitigation or monitoring in the report. Without specific
information the reader is left having to trust that the statement is true.
Construction Plan report.
The proponent must revise and reissue the draft Construction Plan report, in a format
3.22 Decommissioning Report

The draft Decommissioning Plan Report was reviewed against the MOE Technical Bulleting Four
(TB4), Guidance for preparing the Decommissioning Plan Report. This was done because a
horizon representative stated at the August 5th and 24th 2010 public open houses that the REA
reports would meet the technical bulletins.
The review of the Decommissioning Plan Report for BTWP dated May 18, 2010 indicates that the
report does not meet that purpose. The information contained in Appendix A provides detailed
comments by page on the report, and is summarized in Table 7 Decommissioning Plan Report
Initial Comments Summary. The comments in Appendix A indicated that there are 30 specific
issues with the report, primarily related to missing information. That missing information supports
the statement that the Decommissioning Plan as submitted does not meet the purpose of TB4
46

Decommissioning rept Minor infractions 8
Misleading information
False information
REA conflicts 1
Credibility (comment) 1
Table 7 Decommissioning Plan Report Initial Comments Summary
Further to the comments in Appendix A., following are more comments on the Decommissioning
Plan report.
The decommissioning plan report provides general information. It seems to borrow and lend
heavily with other REA reports, rather than providing information specific and detailed to the
construction activities.
For instance there is reference to removal of main equipment components being recycled and
reused where possible, but how this would happen is not identified. Specific information
regarding locations and amounts of materials and potential effects are not clearly identified.
The report references that the decommissioning will follow standard industry practices effective at
the time of decommissioning. Unfortunately that statement leaves considerable uncertainty around
what is decommissioning.
Environmental impacts for decommissioning are not identified. That information should have been
clearly indicated in this report, and correlated to the decommissioning activities.
The environmental monitoring section appears to be common with other reports, such as the
construction plan report. The environmental effects monitoring plan is not included, but rather a
reference provided to the Design and Operations report. The monitoring of environmental effects
associated with decommissioning should be separated and included with the decommissioning plan
report.
The conclusions section is really another description of where to find the information in other
reports. The conclusion that the decommissioning will be carried out to minimize negative impacts
on the environment is difficult to understand, given that there is little clear information provided as
to potential negative impacts, mitigation or monitoring in the report. Without specific information
the reader is left having to trust that the statement is true.
Decommissioning Plan Report
47
The proponent must revise and reissue the draft Decommissioning Plan report, in a format
3.23 Consultation Report

There was no separate consultation report available for review. There was a section in the ESR
report (chapter 5) and an appendix (ESR Appendix C , Public Consultation).
The proponent must prepare a Consultation report that meets all MOE requirements and
guidelines.
3.24 Natural Heritage Records Review Report

The Natural Heritage Records Review Report, dated May 17, 2010 was reviewed and following
comments were identified.
The introduction is identified as section 2 in the report, but as section 1 in the table of contents.
This appears to be an oversight common to other reports.
The map identified as Figure 2-1 is referred to as having the project area outlined in red. There is
no project or study area indicated on the map. The study area at the beginning of the project was
significantly larger, and should be acknowledged; especially with respect to the records review and
identifying what area was subject to the records review. This is significant as the records review is
for specified areas, often referring to the project or study area indicated on maps.
The map indicated as figure 2-2 identifies that the turbines occupy a small part of the study area
defined in Figure 2-1. Unfortunately Figure 2-1 is supposed to (but doesn’t) outline the project
area, not the study area.
The text refers to various locations and geographic sites, but these sites are not identified on the
maps. Without these sites identified the references to place names is of little value. The place
names and geographic references should be included on the maps
The maps do not indicate property boundaries, or project or study area limits. The maps are
missing streets in the vicinity of the project, homes and buildings everywhere, indicate developed
areas as forested, and area missing the Ski area facilities.
For records sources it is interesting to note that the landowner, the City of Thunder Bay is not
indicated as being a source of records. Neither is the Fort William First Nation who might have
had records or information as a result of traditional use of the land or land claim interests. The
Métis are not indicated as a records source, although they also may have interest or information
related to the lands. The only agencies identified are MNR (4 offices), Municipality of Neebing
and Lakehead Region Conservation Authority. Although this might be all that is required, it is
unusual that additional sources of records or information were not utilized, especially because the
land has not been crown land for 100 years (privately held by Thunder Bay/ Fort William).
48
Perhaps this is the reason that the project originally had turbines sited in vicinity (or within) the
ANSI area.
The date of records review or contact with agencies is not identified. This is important as the
project has been ongoing since 2006, with multiple turbine relocations.
The Lakehead Regional Conservation Authority section does not identify that the area is a
sensitive groundwater area, and an area of high groundwater recharge.
The proponent must update the maps to indicate the missing streets, homes, and buildings, the
green areas that are not forest covered should be corrected, the Loch Lomond ski facilities and
structures must be shown, and the property lines/ boundaries must be added.
The proponent must clearly indicate the project and study area boundaries. This is for the
turbines, roads and electrical tap lines. The study/project areas related to records searches
should be identified (as project and turbine locations changed)
The dates of records searches and the areas those searches relate to (within study area) must be
clearly identified
The records review must identify records requested or referenced from the existing landowner
(City of Thunder Bay) and those with interest and knowledge of land (Fort William First
Nation)
The importance of the area as a sensitive groundwater and recharge area must be acknowledged
3.25 Natural Heritage Site Visit Report

The information contained in Appendix A provides detailed comments by page on the report, and
is summarized in Table 8 Natural Heritage Site Visit Initial Comments Summary. The comments
in Appendix A indicated that there were 4 specific issues identified with the report.

(Total = 4)
Natural Heritage site visit Minor infractions
False information
REA conflicts 1
Credibility
Table 8 Natural Heritage Site Visit Initial Comments Summary
49
Further to the comments in Appendix A., following are more comments on the Natural Heritage
Site Visit Report.
The Natural Heritage Site Visit Report dated May 18, 2010 introduction section 2 provides little
useful information regarding what is in the report. It simply states that the report is a natural
heritage site visit report and describes briefly the regulations that the site visit conforms to. The
following section 3, background, provides as an introduction to the report, and perhaps could be
incorporated in the introduction section. The Introduction section is improperly labeled section 2,
because the table of contents was assigned a section number one.
The background section provides an introduction to the report, but no background. This section
should be revised to indicate background relative to the natural heritage site visit.
The site map does not provide the project study area. The project study area was 17,000 acres in
size and included significant areas to the south of the map extent. The limits of the property are not
shown. Large areas indicated as forested are actually residential. There are significant road and
developed areas not indicated (Caspian drive area). Residences are not indicated. The Loch
Lomond ski facility is not indicated. There appears to be 2 versions of electrical tap line Phase 2
option 2 , one that terminates in Fort William and one that terminates in Broadway Avenue – it
was understood that only one termination was needed for each option.
Section 4, identifies that the site search was accomplished in 49.5 hours over 6 days. This is to
survey, identify and record vegetation types and features such as wetlands streams, endangered
species, stick nests, fish habitat within 120 meters of all tap lines, proposed turbine sites, access
roads and facilities. This would require surveying a minimum 240 m wide area (plus right of way
widths) for,
approximately 20 km of electrical tap lines through remote and steep terrain, residential areas,
industrial areas, railway yards, river crossings, and along roadways
approximately 10 km of site roads and site electrical lines
18 turbines sites, 3 transformer sites, and various lay down and construction areas
Because the field notes for the second site visit are almost illegible it is not possible to review
these. The level of detail of investigation, and features found cannot be confirmed.
The proponent must address the 4 comments as included in Appendix A related to the Natural
Heritage Site Visit.
The proponent must revise the introduction and background sections to clearly indicate the
introductory and background information relevant to the natural heritage site visit
The proponent must include transcribed and typed versions of the field notes to allow reviewers
to read and verify field visit information. This is especially important in light of the significant
area, including rugged and inaccessible terrain that is identified as part of the project area.
3.26 Environmental Noise Impact Report

The Environmental Noise Impact Report was reviewed initially and comments collated within the
attached Appendix A. These comments were provided to Horizon Wind Inc. on August 24th, 2010.
50
For that initial review only 3 comments were identified. Subsequently another reviewer provided
12 comments.
The review of the Environmental Noise Impact Report for BTWP dated alternatively April 30 ,
2010, and May 14, 2010 (within same report) indicates that there are concerns regarding when this
report and analysis was actually written. The information contained in Appendix A provides
detailed comments by page on the report, and is summarized in Table 9 Environmental Noise
Impact Report Initial Comments Summary. The comments in Appendix A indicated that there
were 3 specific issues identified with the report. Further comments are provided following the
table.

Noise assessment Minor infractions
False information
REA conflicts
Credibility
Table 9 Environmental Noise Impact Report Initial Comments Summary
Further too that initial review, a number of other comments were identified and are summarized as
follows,
1. The transmittal letter dated May 14, 2010 identifies that the noise study based on May 11
data, but the model output description identifies model based on April 21 data. The report
itself is dated on each page as April 30.
This is a significant issue in that the report data and information, and therefore the results
are in question.
2. Given that turbine locations have moved a number of times in this process, the date of the
modeling should be clear, and the fact that turbine locations have moved should be clearly
stated in the report.
3. The report is missing property boundary of project and location of all dwellings, municipal
zoning for City of Thunder Bay, terrain cover.
4. Report only identifies receptors as existing homes. Should include vacant properties and
assumed building locations. Also the ski area lodge, work areas and educational facilities
are ignored. (p2)
5. Topography section does not adequately address complex terrain. There are significant
rock faces, cliffs, and valleys in the area. (p2). The report identifies less than 60% of
surface is rock, but ignores the potential for sound reflection off of vertical rock faces. The
existence of cliffs is specifically ignored (p6). The complex situation of turbines located
atop170 m cliffs, over homes and a flat area is ignored. Terrain cover ignores the case of
snow and ice cover (occurs December to April, 6 months) especially in areas with ski runs.
51
Given all of these issues, a more thorough modeling of the complex topography and ground
surface would be appropriate.
6. The table with points of reception does not identify address of receptor and identify all as
assumed 2 story residence. Easily obtained ground truthing would have confirmed
addresses and building types.
7. Wind turbine characteristics ignore manufacturer’s data sheet which clearly identifies a
reduced noise night time operation mode. This is not identified (as it should be in ch 4), nor
is it considered as possible mitigation anywhere else in the REA reports.
8. Also ignored is the manufacturer data which indicates a tonality K factor of 2 dB, but rather
the report relies on a letter from a unknown Vensys representative to Horizon Energy
Legacy Group that there is no significant tonality. This letter should have no status as the
basis of this claim is not substantiated, nor is the qualification of the Vensys representative
provided. This letter should not be relied upon without further information.
9. Also ignored is the statement on manufacturer data sheets dated 12.10.2009 that the data
are based on similar wind energy converters and will be confirmed after erection of the first
turbine. There is no indication of whether any turbines have been erected and data
confirmed since the data sheets were estimated in late 2009.
10. The noise calculations in Appendix 3 reveal a number of concerns. First the date of
calculation is uncertain, as is the data upon which the calculations are based.
11. The data sheets identify conflicting dates of April 21 and May 11, 2010. The receptor
descriptions identify that many have been moved or modified, where the movement,
modification and basis of the changes should be clearly identified
12. The conclusions and recommendations

Neglects stating that the noise levels predicted are just below (1.2 dB) the MOE noise limit
of 40 dB.
Are more a restatement of model and study assumptions
Do not address potential sources of error
Do not address the uncertainty associated with estimated manufacturer data
Do not interpret the study results as to which turbines are the most impactive ( turbines
8,9,10,11), potential mitigation (night time reduced noise operation), or the sensitivity of
any of the assumptions
Overall there are serious concerns with the use of the noise study report. The main issues are
missing receptors, questionable manufacturer data, uncertainty regarding turbine and receptor
locations, and ability of the model to accurately assess noise in this complex terrain
The proponent must address the 3 comments as included in Appendix A related to the Noise
Impact Study.
52
The proponent must revise its noise study to address the identified further twelve (12) issues.
Until manufacturers’ data as measured is available, use of estimated data must include an
evaluation of the uncertainty regarding noise levels, and a sensitivity analysis to clearly identify
the impacts of the uncertainty.
The proponent must use a more detailed model to more thoroughly assess the complex terrain,
winter icy ski slopes, cliff faces and rock areas, and other site specific features.
3.27 Visual Impact Assessment Report

The visual impact assessment report was reviewed and 7 comments were identified. These
comments are summarized in Table 10 Visual Impact Assessment Initial Comments Summary and
included in Appendix A.

(Total = 7)
Visual impact assess Minor infractions 2
False information
REA conflicts
Credibility
Table 10 Visual Impact Assessment Initial Comments Summary
Further to these comments in Appendix A, a further review was carried out and the comments are
as follows,
The report has no introduction, assumptions, model description, method description, analysis,
results, conclusions or recommendations. It does not seem to be a report, but rather a collection
of photos and a georeferenced map
There is no indication of who specifically prepared the report, their qualifications, or
experience in carrying out a visual impact assessment
The zone of visual influence mapping is not described as to how calculated or the significance
of proximity or amount of turbine viewed relative to visual impact.
The photo simulations are from a limited number of locations, often from extreme distances,
and use sky colors that blend in turbines. The areas that identified the most concerns regarding
visual impacts are not represented (Broad Oaks, Tuxedo, Mount Forest, Caspian , Mountain
Road)
The photo simulations appear to be somewhat hazy and vague, perhaps due to printing. These
should be clear and crisp images.
There are no computer ‘stick’ or line drawings provided to verify the photo simulations or to
provide clear indications of turbine size and locations
The assessment does not identify which turbines are the sources of the most visual impacts.
That would assist reviewers in understanding whether the impacts are from a few or from most
of the turbines, and whether relocating turbines is a reasonable mitigation.
53
The proponent must address the 7 comments as included in Appendix A related to the Visual
Impact Assessment.
The proponent must prepare a visual impact assessment report that fully describes the methods,
models, analysis, and results. Conclusions and recommendations from qualified assessors
should be included.
The proponent must present a visual assessment, including computer line modeling and photo
simulations from the areas that have the most concerns regarding visual impacts. The photo
simulations should use sky colors and that do not mask the turbines.
3.28 Maps
The report maps were reviewed and 3 comments were initially identified. These comments are
summarized in Table 11 Maps Initial Comments Summary and included in Appendix A.

(Total=3)
Maps Minor infractions
False information
REA conflicts
Credibility
Table 11 Maps Initial Comments Summary
Further to that initial review, some of the maps were further reviewed, and the following
observations made,
Map BT-HE-SP-2010.05.20
Map does not include entire study area, the 17,000 acres
No date indicated for map background data source (NTS map data)
Missing streets (Caspian Drive development off Mountain Road)
Built up areas indicated as green tree cover
Homes and buildings not indicated
Missing property lines
Missing vacant property receptors
Missing road names
Missing significant geographic feature names
Missing ski area structures
Missing railroad lines/ yard in Fort William where electrical lines cross
Map HV-BT- Figure 1-2009-10 -01 , dated Oct 02,2009 Avian Impact Assessment
Map does indicate entire study area
54
Date indicated for map background data source is 1990 NTS data (20 years out of date)
Built up areas indicated as green tree cover
Homes and buildings not indicated
Missing property lines
Missing road names
Missing significant geographic feature names
Missing ski area structures
Missing railroad lines/ yard in Fort William where electrical lines cross
A review of all the maps was not made due to time constraints.
The proponent must address the 3 comments as included in Appendix A related to the Maps
The proponent must review the maps, and ensure that the information on the maps clearly
identifies the information referenced in the associated report text. This includes project and
study area boundaries, and property boundaries.
The proponent must provide maps that indicate the location of environmental features that are
discussed in the report.
The proponent must provide maps indicating the technical information it refers to in its reports,
especially for decision making purposes. This would include wind mapping (intensity and
direction).
The proponent must review and update the maps with more current data. Site conditions and
development has changed since 1990. Out of date information should not be used in the project
information gathering, evaluation, or communication tools.
The proponent muse review and revise the maps to ensure that sufficient detail and geographic
and place name references are included so that the maps may be interpreted properly.
55
4. Summary of Comments
There were in essence 2 reviews done on the draft REA reports for proposed Big Thunder Wind
Park project. The first review was an initial assessment, using a database to collate those initial
comments. Further to that, the reports were reviewed and comments and recommendations
identified in this document.
The initial review identified 412 comments or items, that the proponent should address to improve
the reports, and to meet the MOE technical guidelines. These comments are included as Appendix
A. These comments range from simple spelling or grammatical errors, to omission of information
as specified in MOE Technical Bulletins. These comments were provided to Horizon on August
24th with a cover letter that offered to meet and provide additional details and information on each
comment. That additional information and meeting is important to resolving those comments
The further review identified 139 comments as specific recommendations. Those specific
recommendations are provided in this report, at the end of each chapter or section. They are also
collated into a single list and included in Appendix B. These recommendations identify what the
NMEPC considers must be done to improve the draft REA documents, the process, and ultimately
the project.
In general, the specific recommendations provide the following,

The reports do not meet the requirements of the MOE Technical Bulletins. There was a lack of
information as required by those bulletins, and the presentation of material was not in a clear
and well communicated manner. The information on maps should be improved. Presentation of
material in tables would be very helpful.
There appears to be a failure to consult properly and not document the public, agency and First
Nations consultation processes and activities. How these activities fit into the planning process,
and how they affected decisions was not identified.
The planning and decision making process, and the information that affected those decisions is
not clearly identified. There should be clear communication of how decisions were made to site
turbines in specific locations, especially where locations are controversial. The rationale for
considering turbine locations was not included in the reports.
The mitigation measures considered in the reports tend to avoid discussing basic and simple
mitigation for significant community concerns, including moving of turbines and roads, and
considering alternative turbine configurations and operational modes. Even if these mitigation
measures are not preferred, they should be identified and rationale provided.
The noise and visual impact studies need to have documentation improved, and the
assumptions and models used need to be verified. The results of the studies did not seem to be
included in the turbine siting decisions or potential mitigation. For instance there are only 3
towers that cause shadow flicker, and perhaps relating those turbines even a small distance
could relieve those concerns.
56
5. Review Conclusions and Recommendations

Due to the inconsistencies, inadequacies, missing, misleading and false information, duplication
and lack of organization seen in this document it should be rejected and not considered worthy of
presentation for public review as draft REA documents.
Draft REA documents are expected to be essentially complete, and representative of the final
documents. If documents are presented with minor errors or missing information, they could be
considered reasonably complete, and satisfactory as drafts for public review. If the errors or
missing information are significant, the public has not really reviewed reasonably complete
reports. These documents not only have significant errors and missing information, but the entire
basis for selection of turbine locations is missing. The public and regulators cannot assess the
impacts and whether reasonable decisions have been made.
Public consultation and the record of consultation are not sufficient for this project and draft REA
reports. Since the beginning of this project, consultation has been weak, and since the fall of 2009
there has been no engagement of the public by the proponent The lack of real consultation was
painfully apparent during the August 2010 open houses where there ware always more questions
than time. At this stage of the project those questions should be clearly answered and documented
in the reports – but they have not been.
Once the identified issues are addressed revised draft REA documents should be issued for public
review. Following the reissue, pubic open houses should be scheduled at 60 days later. This would
enable the public to ask relevant questions and concerns of the proponent regarding this Wind
turbine project. This would reset the consultation process, and provide the proponent time to
engage the public and resolve the many outstanding issues and concerns.
We ask that MOE halt this project pending a review of the ‘draft’ REA documents and the
public consultation process to date.
We ask that MOE review its decision to grant special ‘transition’ conditions to this project,
and ensure the proponent follows the complete and full REA process.
We ask that MOE consider these documents as insufficient, and require the proponent to
revise and reissue the draft documents to meet the MOE Technical Bulletins with open
houses for these updated draft
57
APPENDIX A Draft REA Initial Comments (as provided to
Horizon August 24, 2010)
Listing of REA review comments by various reviewers
These comments were provided to Horizon Wind Inc at the August 24th 2010 public open house at
Blake Hall in Neebing Township.
1
APPENDIX B List of Review Comments – Specific

Recommendations
1
Background
1. MOE must review the project and consultation from September 2009 to August 2010 to
determine whether reasonable attempts were made to engage and consult with the public.
Should it be determined that there was a failure to consult appropriately, the proponent
must be required to develop and carry out a consultation program satisfactory to MOE
before any REA report is prepared.
2. MOE must review the direct notifications made in this project to determine if they satisfy
the requirements. Failure to provide appropriate notification should be considered a
significant flaw in the process, for which the public should not suffer.
3. MOE must require the proponent to include in its REA reports sufficient and detailed
description of the ongoing public and community concerns. Also, the proponent should
identify how it has addressed specific individual and community concern.
Approval Requirements and Expectations

4. The proponent must be required to satisfy its public commitment of August 5th and 24th,
2010 and fully meet the requirements of the MOE Technical Bulletins for all the REA
reports.
Transition Process
5. The proponent must identify to the public in the draft REA documents what special
provisions apply outside the normal process. This is specifically the ‘transition project’
provisions.
6. The August 4, 5, 23, 24 open houses must be considered as the PDR (first) open houses.
The information presented at prior open houses was general and non specific. The
changes in the project and lack of consultation since 2009 are significant. The proponent
must update and revise the draft REA reports, reissue draft REA reports based on the
first real public input. After reissuing the draft REA documents the proponent must then
have draft REA open houses.
Review of REA Reports

chapter 1.
7. The proponent must clarify the project relationship and names relative to the large
number of projects known as Big Thunder Wind Park.
8. The proponent must clarify the nature and relationship of all parties involved in
development of the project.
9. The proponent must clearly communicate the special transition provisions and how that
impacts public opportunities for involvement.
ESR Chapter 2 Project Description

10. The proponent must address the 32 comments as included in Appendix A related to the
ESR chapter 2
11. The proponent must identify and clarify the nature and involvement of all parties
involved in project development.
-1-
12. The proponent must include in the purpose that its objective is to make money. If not, the
proponent should not identify economics as rationale for turbine location, or rationale
for not implementing certain mitigation.
13. The proponent must clearly disclose that the turbine and turbine information is
estimated and that no tower and turbine of this type has been constructed.
14. The proponent must clearly identify the electrical connections, land uses associated, the
turbines and schedule for various stages, and how potential stages of the project will be
incorporated, for 3 MW, 16.5 MW, 27 MW and other stages to 79.5 MW.
15. The proponent must clearly identify how the First Nations and Métis have been
consulted, and how their land claims and use of lands could be impacted.
ESR Chapter 3 Scope of the Assessment

ESR chapter 3
17. The proponent must clearly identify how it scoped issues, and how consultation and
professional judgment were used in the scoping and turbine locating process.
18. The proponent must clearly communicate the process it used to determine the study area,
and turbine locations. The rationale for identify locations must be known, and without
this information any evaluation and comments by the public or regulators is irrelevant.
ESR Chapter 4 Agency Consultation

ESR chapter 4
20. The proponent must identify the specific transition provisions and how agency
consultation has been impacted.
21. The proponent must clearly identify the dates, nature, and status of agency
consultations. This should be summarized in tabular format.
ESR Chapter 5 Public Consultation

ESR chapter 5
23. The proponent must identify the specific transition provisions and how public
consultation is impacted.
24. The proponent must acknowledge that since public concerns became apparent last fall
(2009) it has not engaged in any real public consultation.
25. The proponent must halt its process, engage the public meaningfully, and address the
concerns. Suggested methods would be standard consultative tools such as working
groups, stakeholder focus sessions, and meeting directly with potentially impacted
residents. This could begin immediately.
26. The proponent must acknowledge and describe the significant public and media
concerns and events, especially since fall of 2009. Also, the proponent should explain its
response to the concerns.
27. The first open houses did not have specific turbine locating information. The proponent
should not be provided the free pass on the first (PDR) open houses. The proponent must
hold open houses further to its first real set of open houses in August
-2-
28. The proponent must provide more information, preferably in a tabular form, identifying
how written, email, and phone questions were responded to.
29. The proponent must identify how issues raised were addressed, and not merely provide
report section to refer to. Provided in a tabular form this would communicated clearly
how issues were addressed.
ESR Chapter 6 First Nations Consultation

30. The First Nations Consultation section and the corresponding Consultation Report are
missing from the draft REA report. The proponent must issue the missing section and
Consultation Report, as part of the draft REA, with 60 days notice and open house to
follow. Not including this information was the choice of the proponent, but the public
and First Nations deserve to have this information at the draft report stage.
ESR Chapter 7 Environmental Characteristics

31. The proponent must provide clear information, on legible maps to show the location of
all environmental characteristics and information used in locating turbines and roads.
32. The proponent must acknowledge the groundwater significance of the area, and provide
more detailed information regarding potential impacts of its construction and operation
activities on the rock stability, groundwater network, and aquifer.
33. The proponent must indicate the distribution of wind over the area, and how this was
determined. Because the proponent is using the wind distribution as rationale for turbine
location this information is required.
34. The proponent must acknowledge that the area in the vicinity of the proposed project is a
residential area, valued for its proximity to the natural beauty of the Nor’Westers and the
quiet of the area.
35. The proponent must revise its tourism section to acknowledge and describe the local
tourism and the significance of the local vista and the quiet nature of the area on local
tourism.
36. The proponent must include a description of how the proposed facility will impact noise
levels. The sound power levels and the impacts on people, and properties must be clearly
communicated.
37. The proponent must acknowledge that the Ministry of Culture recommends a stage 2
archeological assessment far enough in advance to account for delay. It would be
prudent to conduct the stage 2 assessment as early as possible to allow for relocation of
turbines, roads and electrical lines as necessary.
38. The proponent must acknowledge and describe the existing and potential recreation uses
in more detail, and describe the impacts of the proposed facilities on those uses.
39. The proponent must describe the potential safety issues related to ice formation and
throw relative to the ski facility, and residences especially immediately below and
adjacent to the proposed turbines.
40. The proponent must acknowledge and describe fully the visual landscape and its
importance to the community. This is perhaps one of the most common issues raised, and
relates to property values, enjoyment of property, the local economy, and tourism.
-3-
ESR Chapter 8 Assessment of Environmental Effects, Mitigation

Requirements, and Residual Effects
41. The proponent should provide a more detailed and descriptive identification of level of
effect. The effect before and after mitigation should be quantified wherever possible.
42. The proponent must rewrite section ESR 8.2.1 to fully address the missing activities,
Specifically the proponent must clearly identify potential negative effects which have
been totally ignored.
Specifically the proponent must clearly identify the residual effects in more detail and
that they will last 25 to 45 years.
Specifically the proponent must clearly identify environmental components and potential
negative effects related to the Big Thunder ski and hiking trails destruction, and the
significant visual impacts.
46. The proponent must rewrite section ESR 8.2.6 to include the water crossing into Fort
William. Specific information and description should be included.
Specifically the proponent must clearly identify the types and sizes of vehicles and
impacts on roads and local residents and businesses.
environmental components, potential effects, mitigation measures and residual effects,
and to account for the possible impacts to groundwater and to the integrity of the
mountain rock structure.
environmental components, potential effects, mitigation measures and residual effect,
and to identify the specific mitigation required to return sites to original condition
Specifically the proponent must clearly identify potential negative effects on wildlife.
environmental components, potential effects, mitigation measures and residual effects,
and to incorporate the fisheries concerns in the Kaministiquia River
Specifically the proponent must clearly identify additional environmental components
and potential negative effects.
53. The proponent must identify in section ESR 8.31 why they cannot relocate turbines away
from cliff face, within the 17,000 acre study area. Movement of turbines away from area
would be best mitigation for potential effects. The precautionary principle should be
applied and turbines moved as far as possible from peregrine falcon potential nest areas,
given the project life of 25 to 45 years.
-4-
54. The proponent must rewrite section ESR 8.3.3 of the report to fully address the potential
mitigation and uncertainty regarding estimated manufacturer’s data.
55. The proponent must rewrite ESR 8.3.3 of the report to fully describe the mitigation
measures available including manufacturers reduced noise night time operation mode,
as well as the rationale for the mitigation to be used (and not used ) in this project (i.e.
turbine location, blade size, tower height etc). Reference the ‘Environmental Noise Study
Appendix K’ for more specific recommendations regarding the noise study
There must be more detail and negative effects must be identified and considered.
57. The proponent must rewrite Section ESR 8.3.5 Landscape to fully address the missing
activities, environmental components, potential effects, mitigation measures and residual
effects. There must be more detail, and mitigation measures must be identified and
considered.
58. The proponent must rewrite Section ESR 8.3.5 Recreation to fully address the missing
effects. There must be more detail and mitigation measures must be identified and
considered. There must be recognition of the residual effects of the roads, noise and
visual impacts on recreational uses in the area.
59. The proponent must rewrite Section ESR 8.3.8 Property values to fully address the
missing activities, environmental components, potential effects, mitigation measures and
residual effects. There must be some discussion of this specific area, and potential for
property value loss as the areas’ main attraction to buyers is the natural beauty and the
lack of noise.
60. The proponent must rewrite Section ESR 8.3.9 Public Safety to fully address the missing
effects. There must be some discussion of the various public safety risks and mitigation.
Mitigation measures including moving turbines away from homes should be considered
given the potentially disastrous impacts of ice throw, blade throw, or turbine failing.
61. The proponent must rewrite Section ESR 8.3.10 Aeronautical Obstruction to clearly
identify the potential effects, and possible mitigation including turbine relocation and
smaller turbines.
62. The proponent must clearly identify in Section ESR 8.3.11 radio Communications and
Radar how any effects apparent during operation will be mitigated, and what will be the
criteria used to determine if mitigation is ‘necessary’
63. The proponent must rewrite section ESR 8.3.13 to fully address mitigation for shadow
flicker, including shutdown operation modes, and movement of turbines (pre and post
construction).
64. The proponent must rewrite section ESR 8.3.14 Human Health to consider and evaluate
information brought forward by concerned residents. Ignoring this information is not
right. The mitigation, including shutdown operation modes, and movement of turbines
(pre and post construction, reduced turbine/ turbine size, lower power operation and shut
down modes must be included.
65. The proponent must summarize the information in chapter ESR 8 in tabular format to
clearly present the environmental effects and mitigation
ESR Chapter 9 Follow-up Measures

-5-
66. The proponent must review their monitoring objectives to ensure that they are relevant to
its methodology, and monitoring activities.
67. The proponent must define what environmental effects monitoring systems and
management structures are. These sections have general descriptions of how the
proponent will supposedly be environmentally responsible and refer to other reports
without sufficient information in this report.
68. The entire section follow-up measures dealing with monitoring must be reviewed and
completed to identify properly the objectives and monitoring consistent with the
environmental effects and the entire report. In its present form it lacks detail and
consistency, and does not provide sufficient information to evaluate whether the
monitoring activities and program.
ESR Chapter 10 Summary of Mitigation, Effect Management and Monitoring

Commitments
69. The proponent must identify clearly how each effect is mitigated and the monitoring.
Should monitoring identify problems the commitments to address the problems must be
identified. This was done verbally in open houses for some effects, for instance which if
noise is above 40 dB at a receptor, the farm (or offending turbines) will be shut down.
ESR Chapter 11 Project Advantages and Disadvantages

70. The proponent must revise the project advantages and disadvantages to provide
information relevant to this project, and fully describe the actual and potential
disadvantages, especially those that the public have raised. This includes loss of sugar
maples, and potential property value losses and health impacts.
ESR Chapter 12 Conclusion

71. The proponent must fully and accurately describe the regulatory requirements, how they
changed during the project, how this project does not satisfy the full REA process, and
the impacts on opportunities for public involvement.
72. The proponent must acknowledge that there are potential negative impacts identified by
local residents and stakeholders, and that they consider the residual effects significant.
ESR Chapter 13 References

73. The proponent must update the references section to clearly identify the source material.
Use of tables and numbered cross references would greatly assist readers and reviewers
in confirming sources.
ESR Appendix A Agency Correspondence

74. The proponent must identify the role of the various companies and people involved in the
project and agency consultation. Without this, the public cannot be sure of whether the
agency contacts are relevant and appropriate to this project.
75. The proponent must identify the various agency correspondences in a table, and
correlated how they relate to the various elements of the project. A clear path of agency
consultation and issue resolution would benefit the public in understanding the process
and status of agency consultation.
-6-
ESR Appendix B Technical Specifications

76. The proponent must provide technical specifications based on actual data, or clearly
identify that the data is estimated. Use of estimated data in noise studies should include a
sensitivity analysis to account for possible estimation errors.
77. The proponent must provide additional information related to tonality. Reliance on a
single letter with a statement from an unknown representative of the manufacturer is not
appropriate.
ESR Appendix C Public Consultation

Consultation
79. The proponent must identify the various public related correspondences, articles, and
information in a table, and correlated how they relate to the various elements of the
project. A clear path of public consultation and issue resolution would benefit the public
in understanding the process and how the public concerns have been addressed (or not
addressed).
80. The proponent must acknowledge the significant community concern and identify
specifically what was done in that regard. Whatever specific actions taken and the results
should be clearly documented
ESR Appendix D First Nation Consultation

81. The proponent must provide a proper First Nations Consultation report, identifying more
than simply correspondence. The consultation report should identify the contacts, issues,
mitigation and residual effects associated with First Nations related concerns.
ESR Appendix E Avian Impact Assessment Report

82. The proponent must ensure that mitigation for identified effects is included in the
appropriate activities in the ESR, where issues are outstanding these should be clearly
identified in all relevant sections of the ESR, and that all information is up to date and
complete.
ESR Appendix G Archeological Impact Report

83. The proponent must confirm the location of the assessment, and ensure that the input of
First Nations and Métis peoples are included.
84. The proponent must undertake a stage 2 archeological assessment before final design
and location or turbines and roads, as per its own consultant and Min of Culture
recommendations. To finalize turbines and roads before the stage 2 assessment risks
damaging heritage features during construction and the entire project viability.
ESR Appendix H Rare Terrestrial Species

85. The proponent must ensure that the relevance of the data listed in this appendix, to the
specific project and potential impacts is identified. This could be in the appendix or more
appropriately in the ESR.
-7-
ESR Appendix I Areas of Natural and Scientific Interest

86. The proponent must identify the source, and date of the information sheet which
describes the ANSI.
87. The proponent must identify the location of proposed turbines on a map which includes
the ANSI.
88. The proponent must discuss the important scientific and natural features, and whether
these exist elsewhere in the project area and how they will be impacted, and mitigation
measures.
ESR Appendix J Radio Communication, Radar, and Seismoacoustic Impact

Assessment
89. The proponent must ensure that mitigation measures and implementation criteria are
clearly communicated and agreed to before any construction begins.
90. The proponent must carry out surveys of the status of existing reception of potentially
impacted residences. Potentially impacted residences should be contacted individually
before any turbine sites are finalized.
91. The proponent must clearly identify the status of agency consultation, and specifically
what concerns were, and how satisfied.
ESR Appendix K Shadow Flicker Analysis Results

92. The proponent must provide proper study assumptions, model description, interpretation
of results, conclusions and recommendations for the Shadow Flicker study. Without
these the analysis has little value to most readers.
93. The proponent must include in its interpretation of the shadow flicker analysis an
indication of the extent and effects of shadow flicker, as well as the information that only
3 turbine locations are the source of the identified flicker.
94. It is recommended that the Shadow Flicker study be remodeled with receptors at existing
and potential homes (vacant lots) and that receptors are modeled at a size and location
that accurately represents the homes.
95. It is recommended that the Shadow Flicker Study Appendix K be revised to provide
sufficient detail on the model, assumptions, conclusions so that readers can understand
the modeling
96. It is recommended that the proponent identify that moving turbines 5, 8, and 12 would
eliminate all shadow flicker, and identify why these turbines cannot/will not be relocated.
Project Description Report

PDR .
98. The proponent must revise and update its Project Description section to fully describe all
the various legal entities and their relationships. The proponent’s background relevant to
wind power development must also be more fully described relevant to this project.
99. The proponent must provide additional information and description of the electrical
facilities which are off the immediate generator site, but still part of the project.
100. The proponent must revise the project data to include the information regarding
estimated data, reduced noise modes, tonal noise, and that no turbines of this particular
model have ever been constructed
-8-
101. The proponent must revise the planning section to fully address the changes in
regulations, and the project consultation process.
102. The proponent must revise the planning section to acknowledge and address the
significant public concerns, describe its stakeholder consultations in detail, and the
specific impacts on the project, planning and consultation
103. The proponent must revise its construction section to address the potential difficulties
and issues surrounding foundation installation in complex rock structures above
residences. The interconnection facilities need to be properly described so that each
phase of the project and its timing is understood.
104. The operations and maintenance section must clearly identify what are the operational
constraints and how operation will be impacted during snowmaking at the ski hill. The
public access tot the site is suggested as year round and this should be confirmed.
105. The proponent must clarify and include additional information regarding
decommissioning.
106. The proponent must provide clear maps in sufficient detail for the study area, and project
site and layout. How these maps and areas, and layouts were revised over the project
should also be indicated.
107. The current land use, First Nations interests, proximity to residential and significant
sites sections have significant errors and omissions. The proponent must fully address
the identified errors and omissions, and describe these land uses and the impacts of the
proposed project on them
108. The proponent must revise the environmental features section to adequately address the
identified deficiencies including peregrine falcons, maple sugar trees, and geological
features.
109. The proponent must clearly identify how the environmental features and impacts were
specifically considered in the decisions used to locate turbines, roads and electrical lines.
This is perhaps one of the most significant omissions in the entire report
110. The proponent must revise the environmental effects section to adequately address the
identified deficiencies including the natural heritage, noise, visual, and land use
concerns. This section should fully identify effects, specifically for this project.
111. The proponent must provide a conclusions section that has substance. The significant
environmental features, impacts, and mitigations would be a good start.
Design and Operations Report

Design and Operations Report
113. The proponent must revise and reissue the draft Design and Operations report, in a
format consistent with the requirements of MOE Technical Bulletin 2, upon which the
public can rely upon. Without the information and detail as required in TB2 the May
2010 draft report should not be considered sufficiently complete.
Construction Plan Report

Construction Plan report.
115. The proponent must revise and reissue the draft Construction Plan report, in a format
consistent with the requirements of MOE Technical Bulletin 3, upon which the public
-9-
can rely upon. Without the information and detail as required in TB3 the May 2010 draft
report should not be considered sufficiently complete.
Decommissioning Report
Decommissioning Plan Report
117. The proponent must revise and reissue the draft Decommissioning Plan report, in a
format consistent with the requirements of MOE Technical Bulletin 4, upon which the
public can rely upon. Without the information and detail as required in TB4 the May
2010 draft report should not be considered sufficiently complete.
Consultation Report
118. The proponent must prepare a Consultation report that meets all MOE requirements and
guidelines.
Natural Heritage Records Review Report

119. The proponent must update the maps to indicate the missing streets, homes, and
buildings, the green areas that are not forest covered should be corrected, the Loch
Lomond ski facilities and structures must be shown, and the property lines/ boundaries
must be added.
120. The proponent must clearly indicate the project and study area boundaries. This is for
the turbines, roads and electrical tap lines. The study/project areas related to records
searches should be identified (as project and turbine locations changed)
121. The dates of records searches and the areas those searches relate to (within study area)
must be clearly identified
122. The records review must identify records requested or referenced from the existing
landowner (City of Thunder Bay) and those with interest and knowledge of land (Fort
William First Nation)
123. The importance of the area as a sensitive groundwater and recharge area must be
acknowledged
Natural Heritage Site Visit Report

Natural Heritage Site Visit.
125. The proponent must revise the introduction and background sections to clearly indicate
the introductory and background information relevant to the natural heritage site visit
126. The proponent must include transcribed and typed versions of the field notes to allow
reviewers to read and verify field visit information. This is especially important in light of
the significant area, including rugged and inaccessible terrain that is identified as part of
the project area.
Environmental Noise Impact Report

Noise Impact Study.
- 10 -
128. The proponent must revise its noise study to address the identified further twelve (12)
issues.
129. Until manufacturers’ data as measured is available, use of estimated data must include
an evaluation of the uncertainty regarding noise levels, and a sensitivity analysis to
clearly identify the impacts of the uncertainty.
130. The proponent must use a more detailed model to more thoroughly assess the complex
terrain, winter icy ski slopes, cliff faces and rock areas, and other site specific features.
Visual Impact Assessment Report

Visual Impact Assessment.
132. The proponent must prepare a visual impact assessment report that fully describes the
methods, models, analysis, and results. Conclusions and recommendations from
qualified assessors should be included.
133. The proponent must present a visual assessment, including computer line modeling and
photo simulations from the areas that have the most concerns regarding visual impacts.
The photo simulations should use sky colors and that do not mask the turbines.
Maps
Maps
135. The proponent must review the maps, and ensure that the information on the maps
clearly identifies the information referenced in the associated report text. This includes
project and study area boundaries, and property boundaries.
136. The proponent must provide maps that indicate the location of environmental features
that are discussed in the report.
137. The proponent must provide maps indicating the technical information it refers to in its
reports, especially for decision making purposes. This would include wind mapping
(intensity and direction).
138. The proponent must review and update the maps with more current data. Site conditions
and development has changed since 1990. Out of date information should not be used in
the project information gathering, evaluation, or communication tools.
139. The proponent muse review and revise the maps to ensure that sufficient detail and
geographic and place name references are included so that the maps may be interpreted
properly.
- 11 -

REA Review For Dumais

Загружено:

Сведения о документе

Исходное описание:

Оригинальное название

Авторское право

Доступные форматы

Поделиться этим документом

Поделиться или встроить документ

Параметры публикации

Этот документ был вам полезен?

Это неприемлемый материал?

Авторское право:

Доступные форматы

REA Review For Dumais

Загружено:

Авторское право:

Доступные форматы

Review of Draft REA Reports and Documents

Big Thunder Wind Park

Horizon Wind Inc.

Prepared by the Nor’Wester Mountain Protection Committee.

August 30, 2010

APPENDIX B Summary of Review Recommendations ................................................. Pages 1 - 11

APPENDIX C LETTER OF January 4, 2010 from MNR - Peregrine Falcon…...……….Page 1 - 3

Nor’Wester Mountain Escarpment Protection Committee

In each section, recommendations as specific direction or advice to the proponent or MOE is

2.2 Approval Requirements and Expectations

2.4 REA process

Generally the REA process as we understand it is as follows,

o Opportunity for public to provide missing information (correct errors / omissions)

2.5 Transition Process

3. Review of REA Reports

3.7 Environmental Study Report (ESR)

Report Type of issue Number of issues (Total=130)

3.7.1 ESR Chapter 1 Project Summary

3.7.2 ESR Chapter 2 Project Description

3.7.3 ESR Chapter 3 Scope of the Assessment

3.7.4 ESR Chapter 4 Agency Consultation

Appendix A includes agency correspondence. Unfortunately determining the consultation process

3.7.5 ESR Chapter 5 Public Consultation

3.7.6 ESR Chapter 6 First Nations Consultation

3.7.7 ESR Chapter 7 Environmental Characteristics

3.7.8 ESR Chapter 8 Assessment of Environmental Effects, Mitigation

ESR 8.1 Level of impact after mitigation measures

ESR 8.2 .1 General Construction Activities – Environmental

ESR 8.2.2 General Construction Activities – Social Economic

ESR 8.2.3 Surveying and Siting

ESR 8.2.4 Land Clearing

The environmental components should include runoff and siltation.

ESR 8.2.5 Road Construction/ Modification

The environmental components do not address loss of trails or visual impacts

ESR 8.2.6 Water Crossings

ESR 8.2.7 Delivery of Equipment

ESR 8.2.8 Foundation Construction

The list of environmental components is missing the identification and description of

ESR 8.2.9 Tower and Turbine Assembly and Installation

ESR 8.2.10 Interconnections

ESR 8.2.11 Water Crossings – Electrical Tap Lines

Potential effects should include disruption to fish spawning or migrations.

ESR 8.2.12 Switching Station Construction

ESR 8.3.1 Wildlife Disturbance (birds)

ESR 8.3.2 Wildlife disturbance (bats)

ESR 8.3.3 Noise effects

ESR 8.3.4 Land Use and the Local Economy

ESR 8.3.5 Landscape

ESR 8.3.6 Tourism

ESR 8.3.8 Property values

No mitigation measures are identified. There are mitigation measures.

ESR 8.3.9 Public Safety

ESR 8.3.10 Aeronautical Obstruction

ESR 8.3.11 Electromagnetic Radiation

ESR 8.3.12 Radio Communication and Radar

ESR 8.3.13 Visual Effects – Shadow Flicker

ESR 8.3.14 Human Health

Summary of review of Chapter ESR 8

3.7.9 ESR Chapter 9 Follow-up Measures

3.7.10 ESR Chapter 10 Summary of Mitigation, Effect Management and

3.7.11 ESR Chapter 11 Project Advantages and Disadvantages

3.7.12 ESR Chapter 12 Conclusion