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