Sask Environmental Society takes a strong position on Chaplin Wind Project

this video by "Saskbirder" on Youtube shows the endangered Piping Plover where it nests on the shores of Chaplin Lake. The Chaplin area is one of its last protected nesting areas on the Northern Great Plains

Many people and organizations sent in their submissions to Saskatchewan's Environmental Assessment Branch expressing their serious concerns with the proposed siting for the Chaplin Lake Wind Energy Project, and their submissions are now being considered by the Ministry of Environment.

One of the most thorough and cogent submissions was prepared by the Saskatchewan Environmental Society. While many emphasized important points about the threat to native grassland habitat, the SES proposal is the most clearly stated argument highlighting the risk to birds and bats presented by the turbines. With the society's permission, I am presenting their submission in its entirety below. 

Premier Wall's recently announced plan for Saskatchewan to convert to 50% alternative energy is a worthy goal. Let us hope that it begins with a project that will provide truly clean energy, rather than one that will see the Province tied up in court rooms for having ignored warnings and violated the Migratory Bird Convention Act and other international agreements.

Brianne England

Environmental Assessment Branch

Ministry of Environment

Room 486 – 3211 Albert St  

Regina, SK S4S 5W6

Topic: Response to Windlectric EIS on Proposed Chaplin Wind Energy Project

Dear Ms. England,

     As you know, the Saskatchewan Environmental Society has been a long- time advocate of expanded wind power in Saskatchewan.  For the past several years we have been urging SaskPower to move forward with a plan that would see 20% of Saskatchewan’s electricity come from wind.  

     However, the siting of wind power turbines must be done with care – both to ensure wind farms are not located too close to population centres, and also to ensure that wind farms are not located adjacent to biodiversity hotspots.

      In the case of Windlectric’s proposal to site a large wind energy project near Chaplin Lake, Saskatchewan, our concern is that the proposed facility is too close to a major biodiversity hotspot.  Windlectric is proposing to locate their wind turbines between several Important Bird Areas that are nationally and globally recognized.  These areas provide nesting habitat and staging grounds for hundreds of thousands of birds, including many birds listed under the Species at Risk Act. 

     The importance of Chaplin Lake is recognized by both Birdlife International and the Western Hemispheric Shorebird Reserve Network.  The Saskatchewan Environmental Society is concerned that the proposed wind farm could have significant negative impacts on wildlife in the region, and particularly on bird life.  We are thus surprised that SaskPower and Windlectric considered this to be a preferred location for siting turbines – given that there were many other site options to choose from.

     The Saskatchewan Environmental Society does not want to see wind power in Saskatchewan get a bad reputation by virtue of a poor siting decision on a major wind power project. 

     We acknowledge the proactive mitigation measures Windlectric proposes to take at the Chaplin Lake site, but are of the view there is still a significant risk that unacceptable environmental impacts will be experienced if this site is approved.

     Our biggest concern focuses around the environmental impact of the wind generation turbines during the 25 years in which they will operate.  We focus here on the potential for bird and bat mortality, particularly due to collisions with wind generation turbines.

Specific Concerns Related To High Risk Of Bird and Bat Mortality During Project Operations

1.          We share the proponent’s view that “relatively long lines of turbines or large wind farms can be a barrier to local or seasonal movements of birds between feeding, roosting, moulting and breeding areas”.

2.          We are particularly concerned about the risk of significant bird and bat mortality due to collisions with the proponent’s proposed 79 large rotating turbines that would extend up to 165 metres above the ground and that would each have a blade sweep range of 80 to 125 metres. (Refer to Figure 2.3 in the main EIS)  Collisions will also occur with nacelles and towers.

3.          It is our view that the EIS – while appropriately paying special attention to species of conservation concern – does not pay enough attention to all bird species in the area. It would be unfortunate if a large number of birds and bats were killed each year by the proposed Windlectric installation.  This could also become a serious problem, not only for SaskPower and Windlectric, but for the reputation of the Saskatchewan wind industry. 

4.          There are 12 wetlands within 500 metres of potential wind project infrastructure.  Many bat species and many breeding birds (that constitute species of concern) reside in the geographical boundaries of what the EIS calls the ‘Local Assessment Area’.

5.          There are many species of conservation concern identified in the EIS Local Assessment Area, particularly grassland-associated species.  These grassland species have already suffered major declines in Saskatchewan over the past four decades.  Avoiding further declines of grassland species through careful planning is therefore important.

6.          According to the EIS, avian use surveys indicated that “at baseline 60-74% of the flight paths occurred above the height of the rotor swept area”.  (Refer to EIS section 6.2) However, this implies that at least 26% of avian flights paths occurred at or below the height of the rotor swept area.  If that is the case, it has the potential to be problematic.

7.          The EIS cites a review of effects of wind energy developments on birds and bats. Rydell et al. (2012) summarized results from a study that “noted 62% of observations from 91 bird species changed either direction or altitude of flight when birds encountered Wind Turbine Generators”.  However, this implies that in a significant minority of cases, bird species did not change direction or altitude. 

8.          To date, Saskatchewan wind farms have averaged 10.1 bird mortalities ‘per turbine’ annually. (Refer to EIS 6.2.5.3.1 Operation and Maintenance Direct Mortality Risk) Given that Chaplin Lake is only 4.5 kilometres away from the nearest wind turbine generator in the Windlectric Chaplin Wind-Energy Project, we believe it is likely the number of ‘per turbine’ bird mortality incidents would increase significantly over this average figure.   

9.          We share the view of the Saskatchewan Ministry of Environment technical EIS reviewers that migrating passerines, nocturnal migrants, and grassland birds with aerial courtship displays will be at increased risk of collision.  Moreover, as Windlectric acknowledges in the EA, diurnal raptors and migratory bats will also face elevated risks.

10.     We note that the statement by technical reviewers for the Saskatchewan Ministry of Environment that they “have remaining concerns about the siting of the project on native grasslands near Chaplin Lake in the vicinity of the Chaplin-Old Wives – Reed Lake (C-OW-RL) WHSRN sites because of the importance of the area for shore birds, waterfowl, multiple migratory and prairie species at risk.”  As indicated earlier in this submission, the Saskatchewan Environmental Society shares these same concerns.

11.     We note with concern the conclusion of Ministry of Environment technical reviewers “that the assessment for this project  (i.e. the Environmental Impact Statement and supplementary material prepared by Windlectric) may not provide an accurate estimation of the collision risk posed by the project”.  The reviewers go on to suggest that the potential for mortality events could be significantly larger than predicted.

Conclusions and Recommendations

1.     As it pertains to wildlife impacts, we do not share the proponent’s expressed view in the EIS that “with mitigation”, the potential adverse residual effects of the project “are not expected to be significant.”

2.     We recommend that Windlectric be asked to come forward with a more suitable site for its proposed wind energy project installation.  In our view, the proponent has not demonstrated that the Chaplin site is acceptable.  We hope the Ministry will reject wind farm development at this specific site.

3.     The Windlectric EIS makes reference to the “absence of wind project development-specific protocols and guidelines in Saskatchewan”. We recommend that in the near future the Saskatchewan government establish clear siting guidelines to better guide future wind power projects, and do so in consultation with the wind industry, urban and rural municipalities, and provincial environmental and conservation groups. 

4.     Using the above-mentioned consultative process, we recommend that a number of areas in Saskatchewan where wind power generating facilities can be acceptably sited be identified. The Saskatchewan Environmental Society would be pleased to participate in such a process.

5.     Saskatchewan does not currently have guidelines for bird and bat mortality thresholds for wind energy projects.  We urge the provincial government to establish such guidelines.

Thank you for considering our recommendations.

Yours sincerely,

Peter Prebble

Peter Prebble

Director of Environmental Policy | Saskatchewan Environmental Society

t. 306.665.1915 |m. Box 1372 Saskatoon SK S7K 3N9 | o. 220 20TH W. Saskatoon

One week left to protect the birds at Chaplin

click on the image above to go to a page where you will hear the sounds of Chaplin grasslands

There are only six days remaining to express opposition to the site chosen for a wind farm in native grassland adjacent to the Western Hemisphere Shore Bird Reserve at Chaplin. (See previous posts here for more details.)

Email your comments before the end of day on November 17 to environmental.assessment@gov.sk.ca

I have heard that there have only been fifteen emails sent to environmental assessment on this issue so far. That may not be enough. 

We are told that 34 of the 79 turbines in this proposal will be placed right in the native grassland. As the province's Technical Review itself points out, this will destroy an estimated 62 hectares of native prairie, which supports many species at risk. In a province that has lost more than 80 % of its native grassland, it is unacceptable for the government to give its blessing to a project that will eliminate that many hectares of a rare habitat and create a disturbance that will in effect degrade the quality of many more hectares of habitat radiating outward from the footprint at each of the 34 sites.

Wind energy is going to be a vital part of our future in this province, but we must get this right by working together to identify areas where we can place wind farms without destroying and degrading native grassland and displacing species at risk.

If you need inspiration, I urge you to listen to this chorus of grassland bird song recorded at Chaplin by a well-known birdsong recordist just three months ago. Bob McGuire traveled from his home in New England to Saskatchewan this summer specifically to record the sounds of our endangered grassland birds. This is an incredible recording and gives you a sense of the value of our remaining native grasslands at Chaplin and elsewhere. The birds you will hear in the recording, including Sprague's Pipit and Baird's Sparrow, need large pieces of native grass to thrive.

Many of these birds will be silenced if the province approves the current site for the Chaplin wind farm. 

Finally, I urge you to add your signature to this Avaaz petition on the project as well.

A Baird's Sparrow in full song--one of many species that needs the grassland at Chaplin to remain intact

Sask Gov't distorts its own research to give away the farm

A few days ago, Saskatchewan’s Minister of Agriculture, Lyle Stewart announced that his government will begin selling off thousands of acres of Crown farm land at a 15% discount.

There are many reasons Saskatchewan people should be alarmed by this latest decision to sell provincially-owned lands at below market prices, while threatening current lessees with higher lease rate in future years if they don’t buy the land. Here are a few:

1. Minister Stewart has said repeatedly that this land is of low ecological value and therefore can be sold. His messaging implies that government science staff have given their blessing by declaring that the land has little ecological value.

Well, here is what actually happened: yes, biologists and ecologists from various provincial government agencies were told to devise a scoring system to determine the relative ecological value of Crown land south of the forest. That is a scientific process in itself and has some objectivity, though one could perhaps argue over the weighting process they developed. But—and this is an important but—the decision of where to draw the line and say 'below this mark everything can be sold' was not scientific or objective. It was entirely political and arbitrary, and it is simply wrong for the Saskatchewan Party to draw that line behind closed doors without a fully transparent public process. 

this whooping crane landed on farm land just south of Regina that
is cultivated and therefore would not score high in any ranking of ecological value

Minister Stewart will argue that they consulted with conservation NGOs to have them approve the ranking system, but again, these groups, like the government scientists, were not involved in determining what score in the system would trigger the decision to sell land. The ecological value ranking system, as applied by Saskatchewan Agriculture, is much like marking students on a curve. A certain percentage is required to fail.

2. By selling off Saskatchewan’s Crown farmland at bargain prices, the Provincial Government is literally “giving away the farm”—taking reliable assets taxpayers have invested in and benefited from for decades and trading them for a one-time gain. If we "sell the goose" we give up future revenue that would support good environmental programming, agricultural support and other public goods.

3. In the media coverage, Minister Stewart uses their public review of farmland ownership rules to justify the sale of Crown land. "During our recent review of farmland ownership rules, a large majority of producers told us they opposed large institutions owning farmland,” said Stewart. “The provincial government is probably the largest institutional owner of farmland." 

Hold on a moment--the government is not just another institution. The government is us, represents us and our interests. Stewart is claiming that the survey indicated that most producers do not want the government to own farm land. This is a baldfaced distortion of the survey and its results. The survey was not about land owned by the Crown. It did not ask respondents if they are for or against government ownership of land (see the results for yourself here). Its questions focused on pension plans and investment funds and of course most farmers surveyed were opposed to that kind of institutional land ownership. And in fact, the survey does show that more than 75% of respondents believe it is important for lease land to remain affordable, flying in the face of the Minister's plan to jack up lease rates for those who choose not to purchase. 

For Minister Stewart to slide Crown land and government ownership under the heading of institutional investment in his speaking points is simply a load of spin to justify a plan to bring short-term revenue into a budget hampered by falling resource prices.

4. With climate change looming, all governments will need ways to use land to maximize carbon sequestration and ensure that we have enough natural cover on the landscape to withstand extreme weather events. If we privatize more Crown land—whether it has native grassland and high ecological value or not—we lose more capacity to manage for climate change.

5. Affordable lease land plays a role in helping young producers get started. Even at a 15% discount, if you are a rancher who is suddenly being told you have to purchase thousands of acres or else face a big jump in your lease rates, you either take on a big debt load to purchase or you swallow the higher lease rates and just push the land harder to make more income. The sale of Crown land may be good for a few producers who are already doing well financially, but it will hurt many others.

This government is placing our children's prairie heritage at risk while trying to divest itself of responsibility for caring for the soils and land of Saskatchewan. 

It is a strategy that sells well in the board rooms of industry and land developers because it removes government oversight and environmental regulations from a lot of land. 

It might even please the farmers who have the money to buy the land at reduced prices, but it does nothing for the majority of farmers faced with escalating costs amid increasing pressure for them to steward ecological services that the rest of us benefit from.

Finally, the one-time gain from selling our shared heritage puts money in the coffers of the government just before a provincial election planned for April 2016. 

You have to wonder what else this government will sell at fire sale prices so that, come spring, they can say that they balanced the budget.

land with non-native grass may not rank high in ecological value but if managed
well it can provide habitat and help fight climate change