Eric R.

Prevost RENEWABLE ENERGY PLANNER Ministry of Natural Resources Regional Operations Division Southern Region Peterborough District 300 Water Street Floor 1 Robinson Place South Tower Peterborough Ontario K9J 8M5 Phone: (705) 755-3134 Fax: (705) 755-3125 Re: EBR Registry Number: 011-9443 25 July 2013 Dear Mr. Prevost; I am writing today to express my opposition to the issuance of approvals under the Public Lands Act related to the Amherst Island Wind Energy project proposed by Windlectric Inc. In the EBR 011-9443, the proposed public lands authorizations may include: a Work Permit to facilitate the construction phase of the project a Land Use Permit for a transmission line to be located on the bed of Lake Ontario a Crown land lease for docks on both the main land and at Amherst Island. I understand that the policies referenced when making such include PL 4.02.01. I would like to demonstrate that the proposed project is incompatible with many of the criteria listed in PL 4.02.01: 1) (from page 2) MNR will favourably consider disposition of public land to accommodate opportunities for socio-economic development that are compatible with environmental and ecological integrity. The proposed project does not create opportunities for socio-economic development compatible with environmental and ecological integrity. As we have seen in other areas where large industrial wind developments have been placed, local residents face significant personal cost due to the building of industrial wind turbines that contributes to the socio-economic devaluation of a community. Due to the unattractive nature of having a wind turbine next door, these developments negatively impact property values in a community. This harms the wealth of a community and can lead to a communitys degradation.

The disposition of public land for this project will also negatively affect the socio-economic development of people in Ontario outside of this area. In Ontario, we are already producing electricity beyond demand. Based upon demand forecast and the current government's energy infrastructure plans (including wind and solar), the OPA has advised the government that "SBG [Surplus Baseload Generation] will become significant in the period between 2014 and 2016." Because we have no ability to store this surplus electricity, we often have to pay other jurisdictions such as New York State and Quebec to take our surplus from us. The only way that this project can be profitable is for tax dollars which could better be used on roads, subways, education, etc to be used to subsidize a project that will never have a positive return on investment. This is an economic loss, not a benefit, and debt is not compatible with the socio-economic or economic development interests of the people of Ontario. Even if the reduction of socio-economic opportunity could, in some way, be called development, the project is still incompatible with environmental and ecological integrity. Amherst Island is home to a number of species that appear on Ontarios endangered species list, it has been identified as an IBA (Important Bird Area) and is recognized by both the United States and Canada to be part of a significant migratory route for a number of avian species. Numerous studies have shown that electricity generated from wind farms has significant detrimental effects on bird populations; the wind farm on Wolfe Island kills approximately 1,114 birds for every peta-joule of energy produced, a rate of nearly 450 times that of the often criticized Alberta Tar Sands. 2) (from page 2) When requests for public land are received from individuals, private enterprise or government agencies, the merits of the development initiatives are evaluated along with factors which might warrant the lands restricted use and/or retention by the province. Conversely, reasons to deny or limit disposition might include anticipated MNR land needs, projected land requirements of other government agencies, local community interests, compatibility with adjacent land uses and environmental risks. Though Amherst Island has experienced slow growth and has fewer projected land requirements for government agencies than other communities might, it has significant community interests, environmental factors and adjacent land uses which are in direct contention with those of the proposed project. The siting of industrial wind turbines will potentially entrench this slow growth. Wind farms are significant killers of birds and placing a project such as this in an area that is known to be a migratory area for a number of endangered bird species does not make for good stewardship of our fragile eco-systems. Additionally, this project may have the effect of hurting tourism expansion on Amherst Island. According to a survey completed for the Government of Scotland, 17% of claimed that they were less likely to go to tourist destinations if more wind farms were built. 3) (from page 6, Section 3.4 Sub D) Objectives and Strategies When considering the disposition of public lands, the Ministry will have regard to the following economic considerations such as: a) Contribution to economic renewal(i.e. jobs created/investment stimulation); b) Effects on tourism industry; c) Effects on resource extractive industries; d) Expansion of the municipal tax base; and e) Suitability of applicants business plan, if applicable (i.e. MEDT and MNDM Regional Economic Development Branch concurrence).

The belief that this project will create economically-beneficial jobs in either Amherst Island or elsewhere in Ontario is specious. Instead of investing that money in goods and services for which there is a known present and future demand creating long term jobs and increased productivity, this project will only create short term jobs at significant cost for Ontario taxpayers. Ontario energy consumption has been falling for a generation and continues to fall as our appliances become more energy efficient. In fact, Ontario already pays surrounding states and provinces millions of dollars to take excess electricity off our hands. The building of another power generating facility in an area where we are building a gas-fired power plant next to a gas-fired power plant operating at 5% capacity is a recipe for future and continued unnecessary costs for the taxpayer. This project will destroy jobs on the whole; the only way that this project can be built is with significant subsidies coming from the Ontario taxpayer, money that could be better invested in projects that would actually have a real positive rate of return. There is significant reason to believe that the proposed wind turbine development will cause a reduction of property values, which will in turn detrimentally affect the municipal tax base. An April 2013 decision by an Ontario Superior Court of Justice has determined that landowners living near industrial wind turbine projects suffer from diminished property values and accepted the proposition that a 22% to 55% loss of property values will occur due to the proximity. There is no reason to believe that Amherst Island would be less affected than the Collingwood area, which was in question in the case. This reduction of a communitys wealth cannot be construed as being beneficial. The business plan of the applicant is unsuitable as well. For a project like this to succeed, significant subsidies are required. Given the financial situation of the Province of Ontario, it is doubtable whether subsidies for a project like this will continue in the long term. This project imposes significant economic and environmental costs on not only the residents of Amherst Island, but on the people of Ontario as a whole. Construction of the proposed wind turbines on Amherst Island will lead to the continued loss of productive employment in Ontario, as tax dollars are inefficiently redistributed to a project which is uneconomical and burdens Ontario taxpayers and ratepayers will liability, and to the death of many birds, included those that are endangered species. As well, this project will lead to the reduction in tourism, property values and municipal taxation revenue in Amherst Island. Given the significant downsides outlined above that are in conflict with policies such as PL 4.02.01, it is my recommendation no Crown land work permits or land use permits be approved. Best Regards,

Randy Hillier