Dear Mr Duffey
EBR Registry Number: 011-0089
Renewable Energy Approval Requirements for Off-shore Wind Facilities – An Overview of the Proposed Approach
I would like to propose that the mandatory 5km shoreline exclusion be removed entirely, for the following reasons:
1 Drinking Water Source Setbacks
While the “Technical Rules: Assessment Report”1 of the Clean Water Act 2006 is cited as a major reason for the 5km shoreline setback, the assessment report itself provides for no greater setback than 1000m from a water intake in a Great Lake. It is suggested that this one kilometre setback be maintained for existing and planned intakes, but should not be applied as a blanket distance for all development. To force a larger setback than the Act allows is to discriminate against wind energy and the industry.
2 Lake Bathymetry
Taking the particular case of Lake Ontario near Toronto, the water depth at 5km from shore is typically2 40-70m. This is far greater than is practical, and would require massive and costly foundations.
The proposed shoreline exclusion unscientifically precludes any project coming closer to shore. As your document states that noise guidelines for offshore projects are in development, setbacks derived from these guidelines should be allowed. The document should also clarify that the 5km shoreline exclusion is typically larger than the setback required by the Noise Guidelines for Wind Farms3, as at a recent MOE session on Low Frequency Noise Measurement4, representatives of “The Society for Wind Vigilance” stated that 5km was now the setback recommended by the MOE for all wind projects.
4 Positive Visual Enhancement
Wind energy is the most visual form of electrical generation, and it is a subjective matter as to whether the turbines are ugly or beautiful. The major shoreline constraint cited by the Ohio Department of Natural Resources is due to “aesthetic hindrance”5, yet the Great Lakes Wind Energy Center’s Final Feasibility Report6 wishes to site their pilot turbine as close to shore for “the highest iconic value”. Copenhagen, the capital city of Denmark, has an arc of wind turbines in the bay approximately 3km from the shore, and less than 5km from the Amalienborg Palace. By placing these turbines close to the city, they have made a statement of their commitment to sustainability, and avoided rows of pylons, which few (if any) could call anything but ugly.
I would hope that you would take my comments into account.
Stewart C. Russell, P.Eng.
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