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APPEC REPORT ON TOURIST TRAFFIC ON MUNICIPAL ROADS IN THE WHITE

PINES WIND PROJECT DURING THE OPERATION OF THE PROJECT

SUMMARY wpd is proposing a mitigation to return upgraded roads to pre-construction maintenance

standards. It is suggested that after road upgrades are removed and roads are restored to

their pre-construction condition there will be a return to the existing status-quo. wpd fully

expects that traffic in the project area will go back to the levels they were before the upgrades

with only a “negligible increase” in traffic during the operation of the project from

maintenance and other work.1

At the ERT hearing on the White Pines Wind Project Shawn Taylor testified that: “(R)oad

upgrades could be removed after construction and returned to their current condition. .

.(T)he footprint and condition of the roads will largely remain unchanged and the existing low

traffic volume will likely continue.”2

The primary mitigation proposed at this time is to return all of the upgraded roads to their

pre-construction conditions

After the segments of roads are returned to their original state, they will be allowed to degrade

throughout the year, as is the case currently, such that over the course of one calendar year,

they will return to their pre-construction conditions as to avoid enabling increased traffic and

speed along such roads as a result of the operations phase of the Project. By implementing

these avoidance and mitigation measures, it is expected that existing rates of speed and traffic

volume currently experienced on the secondary and tertiary roads prior to the Project will be

maintained throughout the operational phase of the Project. As a result there will be no impact

on the mortality rate attributable to the Project due to the restoration of previous conditions.

(Table 3-1, White Pines Wind Project Additional Avoidance and Mitigation Measures to

Minimize Potential Impacts to Blanding’s Turtle, Prepared for wpd Canada by Natural Resource

Solutions Inc. July 2016, pp. 21).

As this report shows, it is unreasonable to anticipate a return to pre-construction levels of

traffic during the operational phase of the project. In fact this would be contradicted by wpd

project documentation on the expected impact of the White Pines Wind Project (the

“Project”) on tourism. wpd asserts in project documentation that the Project can provide a

sightseeing opportunity for potential tourists. Indeed wpd has proposed a Park that among

other things would attract people to the area to enjoy other aspects of the County.

Based on statements by wpd and others3 and based on the large pool of tourists already in

the County between May and September every year there will be an increase in traffic in the

Project area. The increased number of vehicles on municipal roads that “traverse Blanding’s

turtle habitat”4 raises justified concerns of increased Blanding’s Turtle fatalities on the roads.

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1 “Potential Adverse Effects - Local Traffic – Negligible increase in traffic.” Stantec White Pines Wind Project, September 2012, Project Description Report – Appendix C2 Summary of Potential Environmental Effects and Mitigation Strategy for Operation of the Project pp 21.

2 Environmental Review Tribunal, Case No. 15-068, Hirsch v Ontario (Environment and Climate Change) dated February 26, 2016 pp 263.

3 See Appendix 2.

4 Environmental Review Tribunal, Case No. 15-068, Hirsch v Ontario (Environment and Climate Change) dated February 26, 2016 pp 84.

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COMMENTS

wpd states that wind projects can provide a sightseeing opportunity for potential tourists.5

wpd notes the positive influence on tourism at a wind project in Prince Edward Island and

proposes that “Prince Edward County and specifically South Marysburgh, could experience

similar benefits.”6

wpd proposes a Park with “other components” including nature trails and rest areas in the

Project area that will attract visitors to the Project.7

Prince Edward County is a well-known tourist destination. It is estimated that 700,000 tourists

visited the County in 2015. The population base of Prince Edward County within a 3 hour drive

is in excess of 7 million people (Toronto, Ottawa and Montreal). Sandbanks, a Provincial Park 18

km from Milford, at the north boundary of the Project Study Area, is visited by half a million

tourists on an annual basis.

With these large numbers of tourists already in the County there is potential for a constant flow

of tourists to the Project. The numbers will increase if the Project is advertised in brochures or is

being actively marketed and promoted as a tourist attraction as has occurred at other wind

projects. Even if only 1% of tourists visit the Project any given year the Project will be visited by a

total of 7,000 tourists annually during its 20 - 25 year lifespan.

The Project will also attract curious visitors from other parts of the County, from Trenton and

Belleville8 and potentially all over south-eastern Ontario, many of whom may never have seen a

wind project before. There are no other existing wind projects in the south-east region of the

province at this time other than at Wolfe Island and that project is only accessible by ferry.

According to CanWEA wind turbines are a natural tourist attraction.9

5 “Wind projects can boost the effectiveness of traditional industries by providing an additional source of income for participating landowners and by providing a sightseeing opportunity for potential tourists.” Record of the

Decision of the Director, s. 47.5, Environmental Protection Act June 20, 2016 Court File No.: 15-2162 ERR Comments – wpd White Pines Wind Project Updated June 12, 2015 pp 143. See excerpt in Appendix B of this report. 6 “(E)vidence in Prince Edward Island suggests that wind turbines have a positive influence on tourism

http://www.gov.pe.ca/photos/original/wind_energy.pdf {see page 26}). It is possible that Prince Edward County,

and specifically South Marysburgh, could experience similar benefits.”

http://southmarysburghmirror.com/wp-content/uploads/2012/07/responses-to-questions-from-Steve-

Ferguson-South-Marysburgh-Mirror.pdf 7 Email from Valerie Kitchell, Manager, Renewable Energy Approvals, wpd to Kathleen Pitt, MNR dated March 6, 2013 (Appendix A attached). 8 With the new Belleville Casino being built more tourists are expected to visit the County and will be drawn to visit the Project, particularly if the Project is advertised as a tourist attraction. 9 CanWEA “A Natural Tourist Attraction” pp. 8.

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Wind projects are promoted as tourist attractions.10 At Erie Shores Wind Farm an Interpretive

Centre has been established to act as an educational resource for visitors “and for busloads of

local students who are learning about green energy options through the school’s curriculum.”11

There is nothing to prevent anyone in the County from competing for tourist dollars by

marketing the Project as a tourist attraction offering tours, project maps, etc.

CONCLUSION: wpd CANNOT HAVE IT BOTH WAYS, I.E., A NEGLIGIBLE INCREASE IN TRAFFIC DURING

THE OPERATION OF THE PROJECT AND A PROJECT THAT IS A TOURIST ATTRACTION.

wpd has proposed to the MNRF to put in a Park and “other components” including nature trails,

rest areas, the possibility of providing tours to view the turbines, etc. According to wpd: “a Park

would attract people to the area to enjoy other aspects of the County”.12

The nature trail component raises further concerns of poaching as well as visitors finding a Blanding’s turtle and taking it home.

Even if wpd has reconsidered its vision of a Park there is nothing to prevent landowners and

entrepreneurs from promoting the Project. The Project is located in a scenic location with

woodlands and wetlands and its location within walking distance of Lake Ontario will only add to

interest in visiting the Project.

Tours of the project site, an Interpretive Centre and tour maps of the Project area are examples

of services that may be offered by private enterprise opportunists taking full advantage of the

large pool of tourists already in Prince Edward County between May and September.

CONCLUSION: wpd’s VISION TO WORK WITH LANDOWNERS TO DEVELOP A PARK AND “OTHER

COMPONENTS” INCLUDING REST AREAS AND NATURE TRAILS WILL ATTRACT EVEN GREATER

NUMBERS OF TOURISTS AND VISITORS TO THE AREA.

THE ADDITION OF REST AREAS AND NATURE TRAILS WILL HAVE DIRECT IMPACTS ON NATURAL

HERITAGE IN THE PROJECT AREA INCLUDING VEGETATION . NATURE TRAILS ON PROJECT LANDS

WILL CREATE ADDITIONAL OPPORTUNITIES FOR POACHERS.

Given the design of this project from one end of South Marysburgh to the other project-related

tourism will lead to more traffic on all municipal roads in the Project area. There will be

10 Wind Farms as Tourist Draws http://www.chambersforinnovation.com/c-i-a/wind-farms-as-tourist-draws/ Green Quinte: Tourists Flock to Wind Turbines http://greenquinte.com/2014/02/tourists-flock-to-wind-

turbines-14-examples-of-ecotourism/ Norfolk Tourism: http://www.norfolktourism.ca/erie-shores-wind-farm/ See also APPENDIX 3.

11 Appendix 2, pp. 9. 12 Email from Valerie Kitchell, Manager, Renewable Energy Approvals, wpd to Kathleen Pitt, MNR dated March 6, 2013 (Appendix A attached).

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increased traffic on roads in close proximity to turbines, regardless of the condition of the roads,

and at junctures where access roads join up to the municipal roads, as many of the access roads

provide clear sightlines for viewing turbines.

Some portions of the municipal roads are in close proximity to turbines. Visitors will slow down

At those locations and/or park for close-up views and photos. Some of these locations are: T6

about 150m from County Rd 10; T16 about 200m from Army Reserve Rd; T20 about 150m from

Brewers Rd; T23 about 350m from Helmer Rd; T25 about 300m from Whattams Rd.

CONCLUSION: THE PROPOSED MITIGATION TO RETURN SEASONAL MUNICIPAL ROADS TO PRE-

CONSTRUCTION MAINTENANCE STANDARD WILL NOT HAVE THE INTENDED RESULT, I.E. A RETURN

TO PRE-CONSTRUCTION LEVELS OF TRAFFIC ON THE SEASONAL ROADS. SIGHTSEERS WILL USE ANY

ROADS THAT PROVIDE GOOD VIEWING LOCATIONS AND / OR CLOSER ACCESS TO TURBINES.

There will be increased traffic on all of the municipal roads in South Marysburgh on an annual

basis, particularly between May and September. Some of the potential impacts of increased

traffic from Project-related tourist traffic are:

Increased collision risk for wildlife in the Project area including Blanding’s turtles and Whip-

poor-will that nest on the roads in the Project area;

Disturbance to wildlife: municipal roads transect wetlands, Blanding’s turtle habitat and habitat for breeding birds;

Dust from increased traffic on the municipal roads, particular on roads that are returned to pre-construction maintenance. According to wpd “unpaved road surfaces exposed to wind can also be a source of fugitive dust emission”13 ;

Harm to flora and fauna on roadsides from tourists parking vehicles at locations along roadsides that offer good sightlines of turbines;

Narrow roads make it difficult for drivers to swerve to avoid Blanding’s turtles or any other wildlife.

CONCLUSION: THE MITIGATION TO RETURN MUNICIPAL ROADS TO PRE-CONSTRUCTION

MAINTENANCE STANDARD COULD IN FACT INCREASE POTENTIAL RISK OF HARM TO BLANDING’S

TURTLES AND OTHER WILDLIFE IN THE PROJECT AREA.

In considering the net effects of Local Traffic wpd concludes that: “The effect of operating the

wind project is anticipated to have a limited effect on traffic.”

WPD WHITE PINES INC. HAS NEGLECTED TO ACCOUNT FOR ALL OF THE IMPACTS OF THIS PROJECT

DURING THE OPERATIONAL PHASE. ADDITIONAL STUDIES ARE NEEDED ON PROJECT-RELATED

TOURISM IMPACTS DURING THE OPERATIONAL PHASE OF THE PROJECT.

13 wpd White Pines – Design and Operations Report May 2012 s.5.5.2.

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APPENDIX A

wpd proposal for a Park, Nature Trails and Rest Areas

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WPD Responses_Record of Decision of Director_APP B_EBR Comment Table_tourism

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APPENDIX B

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APPENDIX C

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