EBR #012-1279 wpd Canada White Pines Wind Farm – PECFN Position Statement

May 11, 2014 Borys Holowacz Latest Posts

May 9, 2014                                                                                                                         –

Prince Edward County Field Naturalists comment on EBR #012-1279 wpd Canada White Pines Wind Farm.

The White Pines Wind Farm should not be approved since it is proposed on a site of significant wildlife habitat of high conservation value.


Gord Miller, Environmental Commissioner of Ontario, has said that the Government of Ontario must design a new strategy to stem the continuing decline in Ontario’s species and natural spaces.  In a special report released January 10, 2012, “Biodiversity: A Nation’s Commitment, an Obligation for Ontario,” Miller described the role of the government ministries in carrying out its commitment:

“The MOE is the lead provincial ministry in implementing the Canada-Ontario Agreement Respecting the Great Lakes Basin Ecosystem. The 2007 agreement states that Canada and Ontario will complete and implement binational biodiversity conservation plans for the Great Lakes. Some of these biodiversity conservation plans have been created; implementation led by MOE could make a key contribution to conserving the biodiversity of the Great Lakes.” And that the MNR should ensure that:

  • terrestrial areas and inland waters are conserved through ecologically representative and well connected systems of protected areas integrated into the wider landscape.
  • the rate of loss of all natural habitats, including forests, is at least halved and where feasible brought close to zero, and degradation and fragmentation is significantly reduced.
  • the extinction of known threatened species has been prevented and their conservation status, particularly of those most in decline, has been improved and sustained.

Contrary to the Commissioner’s view of the government’s mandate this project and others show the role  Ontario government ministries have been taking in facilitating the industrialization of the last undeveloped land on the northern shore of Lake Ontario.

Ontario is a signatory to the Canadian Biodiversity Strategy.  It is known that legal protected status is effective at reducing the loss of natural land-cover within sites of high conservation importance and thereby will conserve the biodiversity remaining in Southern Ontario.  (Beresford et al. 2013 Protection reduces loss of natural land-cover…)

The White Pines project is sited in the centre of the Prince Edward County South Shore Important Bird and Biodiversity Area (IBA).  The IBA 2001 Conservation Plan is currently being updated by the appointed Caretaker, Prince Edward Point Bird Observatory (PEPtBO).  The Conservation Plan update may include an extension of the boundaries to incorporate the South Bay Marsh and Black Creek Valley ANSI including McMahon Bluff.  The update will incorporate 13 years of data from PEPtBO records of annual bird migrations and breeding Species at Risk (SAR).

The Environmental Commissioner of Ontario, Nature Canada, Ontario Nature, National Audubon Society U.S. and Birdlife International have all declared that turbines should not be sited in IBAs and that they should be protected from development.

White Pines construction of 29 turbines and extensive access roads will create habitat loss and fragmentation within this wildlife habitat.  The habitat corridors linking all the above named significant wildlife habitats will be harmed and thus also the biodiversity of this area.  It will affect the connectivity among the migratory stopover sites of millions of birds traveling the Eastern flyway in spring and fall.  The population density of North American species living in seasonal environments is dependent on their moving south for winter survival and reaching breeding habitats in spring. Any increase of mortality rates in spring effects the breeding population of species, especially those of declining populations at risk. A similar increase in fall would reduce the population of fledglings on their first migration.  Certainly the development of an industrial site and roads will displace migrant and breeding wildlife’s access to food, water and cover.

The following studies all pertain to this site and its importance as the last undeveloped land on the northern shoreline of Lake Ontario:

“During a normal year 500,000 to 750,000 birds are counted in and around Prince Edward Point alone and data suggest that the same density of birds are passing through the whole of the Prince Edward County South Shore Important Bird Area.” (David Okines, Peptbo Station Manager)  These data are the result of observations through a 1 km wedge of shoreline and as a result are only a small estimation of the total birds passing through the PEC South Shore at migration time.  A study at a similar peninsula migratory habitat, Long Point on Lake Erie, tracked birds and bats moving 1-30 km over the stopover landscape for days to feed before continuing on the migration.  (Taylor, PD et al.  Landscape Movements of Migratory Birds and Bats Reveal an Expanded Scale of Stopover. 2011.  PLoS ONE 6(11))

“This is one of the most important landfall sites in Ontario.  Unique about this particular site is that birds are ascending and descending during migration, whereas normally they migrate over the landscape in a broad front above the typical height of wind turbines.  Since birds on migration in this area can therefore be found at tower height, and are typically very tired and stressed when descending, they may be more at risk of collision with wind turbines.” (Denise Fell, Environmental Assessment Officer, Mar 4, 2008.)

“Conservation of migratory birds, including many “species of greatest conservation need,” requires protecting a network of stopover sites, particularly in the highly‐altered Lake Ontario watershed… Both species richness and abundance of migrants is greater closer to the shores of Lake Ontario than farther inland. ..Woody habitat within diverse inland wetland complexes…may also harbor high concentrations of migrants within our study area. Migrants are also concentrated within suitable habitat that is surrounded and isolated by matrices of developed and agricultural cover. Indeed, contrary to some studies in other areas, the percentage of urban cover and road density within the landscape are better predictors than the percentage of cover of suitable habitat. These relationships suggest migrants are squeezing into patches of suitable cover in landscapes where such cover is limited by other predominant land uses.” (Lake Ontario Migratory bird stopover report Abstract. The Nature Conservancy and Audubon NY. August 2012)

The Prince Edward County Official Plan Review is currently drafting a designated Core Area of Conservation for this candidate Area of Natural and Scientific Interest (ANSI) on the South Shore.  The County is aware of the results of a study commissioned by MNR which reported the value of ecosystem services provided by woodlands and wetlands to be over $58 million.  (Spatial Informatics Group, Austin Troy and Ken Bagstad, 2009) This particular site is an important part of PE County’s natural heritage ecosystem and tourism economy.

[All information below comes from a review of Stantec Consulting Ltd.  White Pines Wind Project Natural Heritage Assessment and Environmental Impact Study May 2012.]


The following wetlands are part of the IBA:

The project includes the Provincially Significant South Bay Coastal Wetland, 231 ha in size, noted for supporting Black Tern (SP Concern), Snapping turtle (Sp Concern), Blanding’s turtle (Thr), Least Bittern (Thr).

Among the 17 unevaluated (by MNR) wetlands considered significant 9 (# 1-6, 10-11, 17) are on tributaries within 2 km of Lake Ontario and therefore qualify under the definition of the Coastal Wetland (Stantec 2012 NHA/EIS (c), Figure 4.0)

  • Wetland 1 (21 ha) is part of Big Sand Bay, a Provincially Significant wetland,  21 m from Turbine #29’s access road;
  • Wetlands 3 (244 ha), the aforementioned Coastal Wetland, and 4 – 5 (2 ha) are situated between Turbines #25 on the eastern border and # 21-22, and completely surround turbines #23 -24 approximately 400 m from the shoreline. Its entire length would be trenched for the associated connection lines and access roads;
  • Wetland 6 (2ha) would be 82 m from the access road to Turbines #18-20;
  • Wetland 17 (9ha), the headwater of tributaries within the Miller Family Nature Reserve. would be cut in two parts by trenching for connection lines;
  • Wetland 10 (39 ha), on the present northern boundary of the IBA and Provincial Wildlife Area, contained 2 ponds of fish habitat, suitable habitat for Blanding’s turtle (Thr), Milksnake (Sp concern), surrounded by 5 Alvars and Woodland 1 (2784 ha) which supported, at the time of Stantec’s study, 6 area sensitive breeding bird species, 3 PIF forest breeding bird species, 7 amphibian species, and was designated Migratory Landbird Stopover Area (MISA 1) – would be the site of 4 Turbines #14 – 17, the closest 9.5 m, and associated access roads 5 m away.
  • Wetland 11 (9 ha), adjacent to Wetland 10 in the centre of Alvars #15 and 16, designated as shrub/successional breeding bird area (SSBB) and approximately 500 m north of the heronry and osprey nest identified in the Provincial Wildlife Area, would be the site of Turbine #13 and 9m from its access road.

North of the current boundary of the IBA:

Wetland 13 (73 ha), immediately south of and parallel with the Black Creek Valley ANSI, includes a vernal pool – suitable habitat for Wood frog, 3 species of endangered Salamanders and 5 species of endangered turtles, and surrounded by Woodland 3 (232 ha) would be the site of Turbine #5, trenched for its collector line 1 m away, and Turbine # 6 as well as the associated access roads.


9 of the woodlands present in the project’s location met the criteria of Significant Woodland.  The largest is estimated to cover 2784 ha of land.  Approximately 50 ha of these woodlands will be removed.  Since all the turbine sites, except one, and their access roads and connection lines (6.7, Figures 9.1-5) are planned within these woodlands the operation of the project over the projected lifetime of 25-40 years will affect countless staging and nesting birds, bats and butterflies as well as displacing unknown numbers of terrestrial wildlife. 


20 Alvar features were identified in Stantec’s study of the project’s location.  MNR considers all alvar habitat in Ecoregion 6E to be provincially rare and as a result all the alvar ecosites in this study are considered significant wildlife habitat.  20 of the 29 turbines are on these alvar sites ranging in size from less than a hectare to 584 ha.  Approximately 35 ha of treed, open and shrub alvar will be removed.

The Stantec study describes these alvars as 5% of the total land cover of the Picton Ecodistrict which includes hundreds of kilometres of shoreline from Trenton to east of Kingston.  However a truer perspective of the proportions of this habitat is provided in the Assessment of Significant Natural Areas in Site District 6E-15 2001 prepared for MNR by Snetsinger, Mary Alice et al. which declared the Limestone Plain landform, extensively alvar, to be 57% of the Prince Edward Peninsula.

The alvar habitats are highly interspersed with other natural habitats, including woodlands, wetlands, swamp and marsh.  The removal of alvar indicative species, the fragmentation caused by turbine site construction, access roads and trenching for connection lines will have far reaching effects on the habitat.  Especially damaging will be changes in the hydrology on the entire landscape of wildlife habitat.

Paul Catling, PhD, gave evidence at an ERT appeal concerning another site that is integral to the Coastal Wetland #3.  He said “Several types of alvar communities are ‘globally imperiled’. At least six globally imperilled and vulnerable alvar communities exist on this site…The changes in drainage as a result of surface landscape modification will result in changes over a much more extensive area because of the high water table and the fact that surface flow plays an important role in maintaining certain kinds of vegetation. While there is some hope of restoring dryland vegetation after damage, there is definitely no guarantee because of the complex aspects of surface water flow on alvars upon which the vegetation depends. The possibility of restoring more mesic habitats that depend on soil moisture, such as savannah, is less and that of restoring wetlands where present vegetation is dependent on a complex of variables including variations in levels and flow rates and water chemistry. “

Dr. Catling, an acknowledged alvar expert, has also explained the effects of construction: “Changes in hydrology due to roads, ditching, complete destruction of flora and fauna to seriously altered compaction, ruts, and cable trenches, all leading to excess flooding in some areas and excess drainage in others…have the impact of complete destruction of flora and fauna to communities.  A very delicate balance of extent and timing of water flow is essential to maintenance of natural alvar communities and it may include ground water, rain dispersion, sheet flow and temporary ponding over flat rock.”

Catling, Paul M. 2013. Can we create alvars or fully restore those damaged? Canadian Field-Naturalist 127(1): 97–101.

The White Pines proposed mitigation measures for alvar communities includes a Replanting and Restoration Plan and states that “All disturbed areas of the construction site will be restored to preconstruction grades as soon as conditions allow.” (6.10.2) It is assumed that this refers to after the construction of turbines and roads but also after decommissioning.

Dr. Catling quoted The Canadian Botanical Association on the subject of restoration:  “Despite considerable expense, development of sophisticated techniques, and passage of time which might have allowed for establishment, such attempts [of alvar restoration] can only be judged as partially successful…Many concerns related to the ecosystem as a whole, but it was also felt that, unlike in situ reproduction in the natural habitat, transplanting and seeding offered little protection in the long term.”

Significant Wildlife Habitat

Migratory Landbird Stopover and Staging Area (MISA) and Shrub-Successional Breeding Bird Areas (SSBB)

The results of the proposed extensive destruction and fragmentation of habitats detailed above will have far reaching effects on migratory and breeding birds on the South Shore.

Two Migratory Landbird Stopover and Staging Areas (MISA 1 & 2) of 2784 ha and 232 ha parallel to the shoreline were identified in Stantec’s study.  Under Direct Effects the study says “The main factors identified as contributors to avian fatality at wind energy facilities are generally density of birds, topography and weather (Thomas et al., 2011)” 

These are the very factors that apply specifically to this site as it has the highest density of Great Lakes’ spring migrating birds – surpassing that of Point Pelee.  Additionally the topography of the site – a peninsula on the shoreline of Lake Ontario –attracts the higher densities of migrants resting and feeding in the spring and staging in the fall before crossing the Lake.  Weather events of driving rain and wind can drive the birds down to the site.  As Denise Fell explained, “Since birds on migration in this area can therefore be found at tower height, and are typically very tired and stressed when descending, they may be more at risk of collision with wind turbines.”   As Stantec relates, “The highest fatality rate to date in Ontario has been observed at the Wolfe Island facility” which is the closest existing turbine project to Prince Edward County.

Stretching approximately 8 km in length in the centre of the shoreline of the South Shore between two Crown wildlife areas this industrial project will cause significant loss of feeding habitat especially around wetlands. 19 of 29 turbines and over 10 km of access roads will be built within MISA features.  16 turbines and their access roads will be built within shrub-successional breeding bird areas.

Species at Risk 

Glenn Cunnington, Biologist MNR, reported on the following screening results for White Pines Project “contains no less than 23 species at risk: Review of our known and available data records indicate that there are occurrences of American Eel End., Henslows sparrow End., King rail End., Pugnose shiner End., Whip poor will Thr., Rainbow mussel Thr., Blanding’s turtle Thr., Bobolink Thr., Eastern Musk Turtle Thr., Least Bittern Thr., Bald Eagle Sp Con., Black Tern Sp Con., Milksnake, Sp Con., Bridle Shiner Sp Con., Northern Map turtle Sp Con., Red headed woodpecker Sp Con., Snapping Turtle Sp Conc., within the proposed project area. Additionally Four leaved Milkweed End., Piping Plover End., Swamp Rose mallow Sp Con., Grass Pickerel Sp Con., Climbing Prairie Rose Sp Con., have been observed in the general area of the proposed project. Other features may be present -This list should not be considered complete.”

In the NHA/EIS Section of Conservation Concern there is a reference to “White Pines Species at Risk Report (separate cover)”.  Attempts to access this report on Species at Risk found by Stantec in the project location were unsuccessful.

The MOE Environmental Approvals Branch responded to a request stating: “The Species at Risk Report does not form part of the Renewable Energy Approval application and is therefore not available for review.  You would need to request a copy of the SAR Report from the proponent.” However the proponent wpd Director of Permits and Environmental Studies replied that “it is government policy to keep these reports confidential for the protection of the at-risk species. Only the MNR can review it.”

Such lack of transparency and access to information essential for public oversight is unacceptable.

For all the above reasons the PECFN requests that wpd be told to move this project to an alternative location.

The Prince Edward County Field Naturalists (PECFN) has a mandate to foster and encourage conservation of natural habitat.  We initiated the establishment of the Prince Edward County South Shore Important Bird Area (IBA) that encompasses the Point Petre Provincial Wildlife Refuge, Ostrander Point Crown Land, the Prince Edward Point National Wildlife Area, Little Bluff Conservation Area and Miller Family Nature Reserve.

For more information contact:

Myrna Wood



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