October 1, 1999
To:Works Committee
From:Commissioner of Works and Emergency Services
Subject:Approval Process for the Siting of Waterfront Windmills
Purpose:
The purpose of this report is to seek Council's support in principle for the siting of waterfront electricity generating
windmills (wind turbines) along the Toronto Waterfront in areas that appear to best meet the selection criteria and that may
be sited on City owned or leased lands, subject to the proponent's satisfactory completion of required environmental
assessments including public consultation, and to clarify the approval process required to locate windmills on the Toronto
waterfront.
Source of Funds:
There is no direct financial implication to the City associated with this report.
Recommendations:
1.That Council support, in principle, the potential use of City owned lands or lands leased by the City as sites for
waterfront windmills (wind turbines) so that City owned or leased sites may be considered in the comparison of potential
sites for a windmill under the Provincial Environmental Assessment process.
2. That the Toronto Regional Conservation Authority be requested to support, in principle, the use of its lands that are
leased to the City as potential sites for waterfront windmills so that these sites may be considered in the comparison of
potential sites for a windmill under the Provincial Environmental Assessment process.
3. That the Toronto Renewable Energy Cooperative (TREC), be requested to provide a proposed environmental assessment
Terms of Reference including public consultation procedures, in accordance with the requirements of the Provincial
Environmental Assessment Act, for approval by City Council prior to proceeding within the environmental assessment
study.
4. That City staff be requested to report further in the event that City owned or leased lands are identified as preferred site
locations through the environmental assessment process, and to clarify what, if any, additional approvals, leasing
agreements, or zoning amendments would be required, and how best obtained, at that time.
5. That Toronto Hydro and TREC be requested to take into account, as part of the environmental assessment, the
comments and recommendations of City Council with respect to this matter.
6. That this report be referred to the Economic Development and Parks Committee and each of the Community Councils
for information.
7. That TREC and Toronto Hydro be advised that the City reserves the right to accept or reject the use of any City owned
or leased lands for a windmill, irrespective of any environmental assessment process.
Report Request:
The Works Committee on July 14th, 1999, had before it a communication (July 8th, 1999) from Councillor Jack Layton,
Vice-Chair, Toronto Hydro Board, recommending that the Commissioner of Works and Emergency Services report to the
Works Committee in September 1999 on the siting of two wind turbines along the Toronto Waterfront (a.k.a waterfront
windmills). The Committee also received a communication (July 21st, 1999) from Councillor Irene Jones
(Lakeshore-Queensway) listing concerns of constituents and requesting that they be addressed in the report. Councillor Bill
Saundercook, Chair, Works Committee, agreed in a communication (July 22nd, 1999) to Councillor Irene Jones that her
constituents' issues should be taken into account in the staff report. Subsequently, TREC wrote to Councillor Saundercook
(August 10th, 1999) requesting that the report be forwarded to the October meeting of the Works Committee as a deputation
item.
Specifically, the request was to identify the approval process required to locate two wind turbines (windmills) on the
Toronto waterfront, including an outline of the process needed to obtain City and other agency approvals (including
environmental assessment), the technical viability and environmental expectations to be satisfied, other environmental
impacts and viability concerns, the public consultation and communication process to be followed and other legal and
financial aspects including potential leasing arrangements.
This report addresses the original request and the supplementary request but deliberately does not fully address all issues in
order to avoid prejudicing the appropriate environmental and planning approval processes, both of which require
community consultation and input.
However, the report does indicate the criteria used to identify and select potential sites; the sites that appear to meet the
selection criteria; the sites that meet the selection criteria and that are also City owned or leased; and the various site
dependent approval processes required to permit the construction and operation of the waterfront windmills (wind
turbines).
The report has been prepared in consultation with Toronto Hydro and Toronto Renewable Energy Cooperative (TREC).
Comments:
The City's Perspective:
City Council has adopted a commitment to achieve a reduction of 20% in carbon dioxide (CO2 ) emissions from all sources
by the year 2005 (Clause embodied in Report No 26 of Strategic Priorities & Policy Committee, as adopted by Council,
December 16th and 17th, 1999).
Locating windmills, as along the Toronto Waterfront, is clearly supportive of this policy, since the use of wind for
electrical generation reduces the need to burn fossil fuels and hence would contribute to the achievement of the City's 20%
CO2 emission reduction goal. The recommendations contained in this report are directed towards a process that will result
in the implementation of a windmill project. However, the recommendations contained in this report do not pre-determine
the site to be selected, nor do they resolve the apparent social conflicts over cluster area selection or conflicts with other
environmental directions, such as use of public parkland areas. These questions will be addressed and resolved as part of an
environmental assessment process complete with public consultation, and will be subject to subsequent Council review,
including potential further public input if City lands are selected for the project and land use regulation amendments are
required.
City Council has also adopted Report No.26 of the Strategic Policies and Priorities Committee at its meeting of December
16th and 17th 1998, which included adopted recommendations for staff to report back on how to further "¼ facilitate the
expeditious development of the ¼ . TREC wind turbine and similar renewable energy projects as part of the City's overall
sustainable energy strategy".
The Proponents:
The waterfront windmills project is a joint venture partnership of Toronto Hydro (through Toronto Hydro Energy Services
Inc.) and Toronto Renewable Energy Cooperative, TREC, (through Toronto Renewable Energy Windpower Co-op,
TREC-WPC).
TREC was founded in 1997 by members of the North Toronto Green Community, a neighbourhood-based environmental
group. The Cooperative was launched with grants from the Toronto Atmospheric Fund, a statutory agency of the City of
Toronto whose mandate is to fund projects to help Toronto meet its commitment to lower carbon dioxide emissions.
Toronto Hydro was incorporated in May 1999. It has supported several local community-based green energy programs
and is committed to work with the City of Toronto to meet the 1990 United Nations Summit objective of reducing carbon
dioxide emissions by 20% by 2005.
Proposal Concept:
Modern windmills are more technically called wind turbines (wheel driven by air flow) or a wind driven generator because
they are used to generate electricity rather than mill grain. However, in more common parlance, the modern wind driven
turbine is still referred to as a windmill, and that common use is continued here.
Modern windmills differ in appearance and purpose from their predecessors. The proposed waterfront windmills will
consist of a white painted, hollow tubular supporting tower structure which is approximately 4 metres in diameter at its
base, tapering to less at the top, and between 55 and 65 metres high (depending on specific local wind regime requirement).
Mounted to the tower is a three-thin-bladed impeller (a reverse propeller) made of white fiberglass laminate with each
blade being approximately 25 metres long (23.5 or 26 metres). The tower and blade (at blade zenith) together have an
approximate maximum height of between 80 and 90 metres.
The proponents propose to construct two wind turbines each with a rated output between 660KW and 1MW. Within the
anticipated wind regime of the Toronto waterfront, these will be sufficient to generate 2800 MWh (megawatt-hours) of
electricity annually. This is sufficient to provide the electricity requirements of 500 to 600 households in Toronto. The
"green electricity" obtained (i.e. non-fuel combusting or CO2 releasing) from these turbines is equivalent to the benefit
obtained by 400,000 medium sized trees sequestering carbon dioxide. For comparison, replacement of the power generated
by the Lakeview Generating Station would require in the order of 1000 wind turbines.
The wind turbine generates electricity that can be added to the electricity grid. The recent restructuring of Ontario Hydro
included generic permissions to allow local power utilities to generate power and provide it to the grid. This recent change
provided TREC and Toronto Hydro with an opportunity that was not previously available. Power can be added to the grid
directly and customers can be charged for that "green electricity" plus a "wheeling" or transmission fee. The wind turbine
provides green power that can be purchased at a modest premium by anyone with a share in TREC, or by direct purchase
through Toronto Hydro . Technically, TREC's shareholders each own a portion of the wind turbine structure rather than
any share of the power output. Shareholders contribute to initial capital construction and to subsequent operating costs.
TREC's shareholders will obtain a credit on their electricity bill as partial return of their investment.
Membership in the TRE Co-op (TREC-WPC) is open to all Toronto Hydro subscribers at a cost of $500 per share or
"turbine unit". TREC-WPC members will regularly receive an energy credit on their Toronto Hydro bill for the amount of
energy their portion of the turbine produces during its anticipated 25 year life.
At this time, Toronto Hydro and TREC are proposing to establish two waterfront windmills within the boundaries of
Toronto. This not a pilot project because the technology is already proven and the business schemes have been
demonstrated to be successful elsewhere (e.g. Copenhagen, Denmark where the municipal utility combined with a similar
green energy cooperative). However, the project is a demonstration project in that it is a new concept for Toronto, and
could contribute to building awareness in the City that power may be derived from a variety of sources and that green
power, which is environmentally responsible, can also be economically viable and practically applied. The greater the
success of the demonstration, the greater the likelihood of developing further community support for additional green
energy projects in the City by Toronto Hydro TREC and other organizations. The maximum economic success is hoped for
by siting the wind turbines in as optimum a location as possible. Ideally, wind turbines should be sited where there is
strong and undisturbed wind. In Toronto, this encourages their siting in the vicinity of Lake Ontario or at high elevations.
The capital costs for each turbine (approximately $1.2 million each) is to be provided in two ways: (i) by selling "turbine
unit" shares and (ii) by Toronto Hydro providing its share of the cost of the joint venture through its capital budget. The
Government of Canada, through the Technology Early Action Measures component of the Climate Change Action Fund, is
providing $330,000 to TREC, and through Environment Canada is also providing a further $98,500 in pre-purchased
"turbine shares" for its Toronto offices and laboratories.
The Toronto Atmospheric Fund has also agreed to provide up to $800,000 in bridge financing to TREC for the project
subject to certain conditions.
Environmental Assessment
Under any Environmental Assessment (EA), either Federal or Provincial, the proponent is responsible for ensuring that
they comply with EA requirements. The proponent in this case is Toronto Hydro and TREC (TREC). This proposal could
be subject to environmental assessment under both the Federal and Provincial legislation. The Federal legislation is entitled
the Canadian Environmental Assessment Act (CEAA). The Provincial legislation is referred to as the Environmental
Assessment Act (EAA).
Under the CEAA, an environmental assessment is required for projects for which the Federal Government is the proponent
or where the project uses Federal funds or lands. Where a project is subject to a Federal EA, the applicable federal
department assesses the project under the CEAA and ensures that the project fulfills the associated CEAA requirements
including possible referral to mediation or a hearing. It is the Federal department's responsibility to establish the scope of
the project and the scope of assessment. As such the proponent should contact the specific Federal department and obtain
confirmation of EA requirements.
The waterfront windmill proponents, TREC and Toronto Hydro, have already obtained details regarding the Federal
environmental assessment requirements from Environment Canada. The proponents are required to comply with the
requirements of the Canadian Environmental Assessment Act (CEAA) because federal funds have been provided to the
project.
Only municipal and other government agency projects similar to the windmill are statutorily required to comply with the
Provincial EAA. Therefore this project is only subject to the Provincial EAA if the Province designates it under the Act
(which is possible for private projects). If the Province does deem the undertaking subject to the EAA, then the proponent
must make an application to the Ministry of the Environment for approval of the project. Such an application consists of
proposed Terms of Reference (ToR) submitted under section 6 (1) of the EAA and an Environmental Assessment
submitted under Sub-section 6.2 (1) of the EAA. Generally speaking, the ToR is the plan or road map for the actual
environmental assessment. In it, the proponent describes how their process will address the requirements of the EAA
including the consultation done in developing the ToR. Regarding the requirements of the Provincial environmental
assessment itself, the project must include a description of the purpose.
The proponents have requested a ruling from the Ontario Ministry of Environment (MOE) to determine whether or not the
waterfront windmill project is to be officially subject to the Province's Environmental Assessment Act (EAA). The
proponents have indicated that they wish to follow the Provincial environmental assessment process irrespective of the
decision of MOE. The Ministry has indicated that it will not oversee any environmental assessment if it is not "designated"
by the Ministry.
As noted above, if the Ministry of the Environment does not "designate" the project as subject to provincial requirements
the proponents have indicated that they will still informally follow, to the fullest extent possible, the guidance provided by
the provincial environmental assessment process while ensuring that they satisfy the federal environmental assessment
requirements. However, if the project is formally "designated" by the Province, a more formal melding of the two
processes will be developed. Regardless of the outstanding Ministry of Environment decision, the proponents have already
initiated a joint study and public communication program to satisfy both the Canadian Environmental Assessment Act
(CEAA) and the Provincial Environmental Assessment Act (EAA). They are also developing a procedure to address all
identified aspects of both. The expanded study, communication and reporting procedure is intended to ensure the
appropriateness of the project and to ensure that appropriate public consultation takes place. The study process, including
the public consultation process, should be approved by City Council before being proceeded with.
Use of City Owned or Other Sites for Windmill:
It could be considered prejudicial to the environmental assessment process if the City were to recognize and approve of any
sites without an appropriate environmental assessment being conducted. Therefore, at this stage only the use of public land
for the purpose of installing wind turbines (windmills) should be supported in principle.
Further municipal approvals related to municipal planning and ownership may be required. Potential sites may need
Official Plan and Zoning By-Law Amendments before a Building Permit can be issued.
If the yet-to-be-identified preferred site is City owned or leased, the proponent will require the City's approval subject to a
satisfactory leasing agreement.
Most of the City's remaining unbuilt waterfront lands are "open space" and are in public ownership. The waterfront
windmill proponents have not established ownership as a selection criteria, but the application of other comparative
criteria, plus the apparent shortage of siting opportunities on private lands on the waterfront, indicates that serious
consideration should be given to siting the project on public lands.
In the City of Toronto, such public open space is most commonly associated with one of the following categories:
lands used for public works (sewage treatment, water filtration);
lands used for recreation (public parks);
lands with restricted use (environmentally sensitive areas, natural areas); and
lands that are vacant (abandoned or undeveloped industrial lands).
The use of several publicly owned sites will also require additional approvals and or comments to be obtained from
Toronto Region Conservation Authority (in areas of Lake Ontario Shoreline flooding) from the Waterfront Regeneration
Trust (in areas proximate to the Waterfront Trail), public liaison committees, the Greater Toronto Airports Authority (in
flight path zones of Lester B. Pearson Airport), Toronto Port Authority (in flight path zones of the Toronto City Centre
Airport on the Toronto Islands), Transport Canada and NavCan (in proximity to navigation equipment for both airports).
Public Consultation and Communication Process:
TREC and Toronto Hydro have been conducting ongoing public consultation on the proposed wind turbine siting project
since May 1998. TREC and Toronto Hydro have advised that public involvement and consultation has four goals:
raising awareness and educating the public about wind turbines as a sound source of "green energy";
scoping issues of public concern related to the proposal;
addressing and responding to concerns using educational material, oral responses, research of issues, and where needed,
further study to develop factual responses; and
development of public acceptance of wind turbine sites on publicly owned land in the City of Toronto.
Toronto Hydro and TREC have indicated that public consultation activities are directed to site-specific interested parties, to
create early involvement of those groups in the siting process, and to the broad citywide public for the purposes of building
public awareness about wind turbines as a renewable source of energy. Toronto Hydro and TREC have indicated that
through its public consultation activities, it will address public concerns, propose mitigation and develop a critical level
of public acceptance for wind turbines in the City of Toronto.
Toronto Hydro and TREC's public consultation activities have included a tour of a wind turbine in Kincardine, Ontario,
presentations to stakeholders and environmental groups, and two public meetings. Toronto Hydro and TREC have held
public meetings in those areas where they are of the
opinion that the siting for the wind turbines appears favourable. One meeting was held in the east end of Toronto near to
the Ashbridges Bay Treatment Plant and the other in the west end of Toronto near the Colonel Samuel Smith Park/R. L.
Clark Water Filtration Plant.
A City staff review of the consultation process to date indicates that the public is generally not aware of key decision
making points in the process, or when and how its input should be given.
Toronto Hydro and TREC have indicated that public consultation activities to date have been done in support of their
Federal Environmental Assessment requirements. As noted above, Toronto Hydro and TREC have already indicated that
they will adopt the guidance provided by the Provincial EA Act, including all public consultation, even though they may
have no obligation to do so. City Council should confirm its endorsement of this arrangement.
Potential Windmill Locations:
A. Site Selection Criteria proposed for use by TREC and Toronto Hydro:
A number of site selection criteria developed by TREC and Toronto Hydro effectively scope the proposal to a limited set of
sites. The criteria fall into two groups: those which must be met (i.e. they are essential) and those that are deemed preferred
(i.e. they are desirable but not essential).
The essential site selection criteria group consists of those criteria that must be satisfied, a site must:
be in Toronto Hydro's grid connection area and billing zone;
have adequate wind regime;
be compatible with present and future land uses;
comply with Official Plan and Zoning requirements;
have landowner's permission to use the site; and
be more than 200 metres from the nearest residence.
The preferred criteria group identified by Toronto Hydro and TREC includes those criteria that encourage a speedier
approval, and minimize avoidable extra costs and problems, as well as maximize benefits. Wherever possible a site should
preferably:
not require soil clean-up;
not require to be flood-proofed;
have suitable soil and groundwater conditions to support the required structure;
require minimum connection requirements (length) to grid;
be accessible to the public for educational purposes; and
receive local community support.
Toronto Hydro and TREC have indicated that the project has to be located in the City of Toronto in order to connect to
the Toronto Hydro grid. Early regional wind studies were undertaken in the Toronto area by Zephyr North on behalf of the
Federal Government. Zephyr North's study indicated the desirability of choosing a site in close proximity to the waterfront.
More recently,
TREC commissioned Zephyr North to confirm their findings for the Toronto Waterfront and to undertake further analysis
of local wind regime in site cluster areas.
B.Preliminary Site Search
A number of City owned sites have been previously ruled out in a preliminary assessment by Toronto Hydro and TREC for
various reasons such as: land stability and suitability for foundation requirements, Transport Canada height restrictions as a
result of the operation of Toronto Island Airport, poor or obstructed wind regime, close proximity to residences and cost
prohibition. Also, a number of City owned and leased sites have been identified by TREC and Toronto Hydro as suitable
for further investigation
C.Site Selection Conflicts To Be Resolved
The potential City owned and leased candidate sites includes parklands owned by the Toronto Conservation Authority
(TRCA) and operated by the City. The agreement of the TRCA as landowner and of the City as operator, needs to be
obtained prior to final approval. The City should consider providing its support in principle for locating windmills in the
City and on City lands and requesting similar support from the TRCA, subject to the proposed site being identified through
an appropriate Environmental Assessment Process.
A number of potential conflicts need to be considered in locating a windmill in, or near to, any parklands. These issues
include, but are not limited to recreational issues, such as kite flight and picnicking, environmental issues, such as possible
impacts on bird and butterfly migrations, and impacts on adjacent natural areas (conservation lands), plus the visual
impacts, if a windmill is sited in or near a park, that could detract from park users enjoyment.
Clearly, although the provision and use of "green energy" is likely to be environmentally beneficial, there are other
environmental aspects that should be considered. All such issues will be addressed and resolved as part of the intended
Environmental Assessment process, including holding public meetings and consulting with affected agencies. Support, in
principle to consider the use of City owned or leased lands, in the context outlined above, would help to facilitate the
environmental assessment process but not pre-determine its outcome.
The potential use of the City's Water Filtration Plant or Wastewater Treatment Plant lands are also complicated by future
operational expansion requirements, ongoing environmental assessments, and related matters, including community
approval. These issues will be further explored and resolved as part of the environmental process.
Project Viability:
The general technical validity of the proposed installations has been proven at numerous sites in Europe, California,
Alberta and elsewhere. The sufficiency of the expected local wind regime to generate wind energy has been proven by
analysis of anemometer readings taken in the west and east ends of the City.
The financial viability depends on the market price for electricity. Preliminary assessment by the proponent indicates that
wind power might have to be sold at a premium. Accordingly, in the case that the City of Toronto enters into a land lease
agreement with the proponent such an agreement should stipulate the requirement of dismantling the turbine by the
proponent when the operation of the turbine is terminated.
The viability of the project from a community standpoint as identified from public meetings which have already been held,
appears to focus on concerns regarding noise, birds, and ice shedding plus a further concern regarding visual aesthetics.
The literature regarding wind turbines suggests that additional noise associated with such installations is virtually inaudible
beyond a 200 metre radius in urban environments. The potential for birds to fly into the tower, or into the surface of the
rotating blades is apparent, especially during storm conditions, however, the literature suggests birds can normally see and
avoid such installations during less active weather conditions.
Ice shedding, from tower and blades, is possible following periods of freezing rain or following windless periods where
ambient air temperatures are below the freezing point and the air is saturated or supersaturated such that rime coatings
develop. The occurrence of freezing rain or rime (i.e. ice) coatings will occur similar to any unheated structure, tower or
tree. What is different is the potential for ice to be "thrown" from the windmill's blades as they turn.
However, wind turbines installed in comparable European installations in similar climates are governed by sensors that
close down the turbine in the event of ice build-up on the blades. This is a standard operating procedure and precautionary
measure to prevent damage to the turbine unit by unbalanced blade weights causing uneven rotation, but it also acts to
address ice on blades being "thrown" off. Maintenance people attending on site are required to restart the windmill. Heated
blades are another possible option for the waterfront windmills. There is every reason to assume that with appropriate
facility design and operation ice thrown from windmill blades should not occur.
In order to address perception and acceptance of the visual aesthetics of wind turbines, Toronto Hydro and TREC are
encouraging and facilitating guided visits to the Ontario Hydro installation on the Bruce Peninsula to allow people to judge
the visual impacts for themselves, as well as to experience the additional noise levels created by similar installations, albeit
in a non-urban setting.
The proponent has indicated that all of these potential concerns will be fully addressed as an integral part of the project's
environmental assessment.
Conclusions:
Waterfront windmills (wind turbines) are a renewable power source (green energy). Their use assists in meeting Council's
commitments to reduce generation of greenhouse gases and reduce the use of air polluting and smog producing power
sources.
Conceptually, the proposal is potentially environmentally beneficial and technically viable as exemplified by many
installations in Europe, California, Alberta and elsewhere. The specific location(s) at which such wind turbines can be
installed will be determined as part of an environmental assessment process including appropriate public consultation.
It is recommended that in order to better facilitate the use and acceptance of electricity generating windmills in Toronto,
that Council should support in principle, subject to the conclusions of an environmental assessment, the installation of
waterfront windmills in Toronto, in support of Council's own commitment to a 20% carbon dioxide (CO2 ) reduction by
the year 2005.
Further, prior to the environmental assessment being proceeded with, its Terms of Reference should be submitted to City
Council for approval.
Also, to facilitate the evaluation of siting options under the environmental assessment process, it is recommended that
Council support, in principle, the potential use of City owned or leased land for two waterfront windmills.
City Council's support, in principle, should be subject to the satisfactory completion of an appropriate site selection
process in keeping with the principles of the provincial environmental assessment process, and in keeping with provincial
requirements if the project is "designated" by the MOE. The environmental assessment should also comply with federal
environmental legislation; and be in compliance with local by-laws (or amendments to these by-laws should be sought).
It is also recommended that staff be requested to report back on the completion of the site selection process and the
determination of the preferred site(s) resulting from the CEAA and EA process, and the details of any required lease
arrangement and land use regulation changes that are required. Public meetings should be held by the proponent rather than
City staff in order to avoid any perceived conflict of interest.
This report has been prepared in consultation with the Commissioner of Economic Development, Culture and Tourism.
Contact Name
Christopher Morgan
Senior Specialist - Air Quality Improvement Branch
Technical Services
Tel. 392-6903
T. G. Denes, P.Eng.
Executive Director
Technical Services Division
B. H. Gutteridge
Commissioner
Works and Emergency Services
