Wind Concerns Ontario is a province-wide advocacy organization whose mission is to provide information on the potential impact of industrial-scale wind power generation on the economy, human health, and the natural environment.
Damage, not help for the environment—and plenty of money to be made, says new Michael Moore/Jeff Gibbs documentary
April 24, 2020
Just in time for Earth Day, doc filmmaker Michael Moore released his newest film, directed by and starring environment writer Jeff Gibbs, “Planet of the Humans.”
The film is a scathing indictment of how huge corporations adapted the public desire to have “green” sources of power and used it to make billions, while excoriating the environment through development.
See the video here; Moore made it available for 30 days for free, but the forces behind the renewables money grab are actively working to have the film taken down.
People who enjoy watching shows like Law and Order or The Good Fight on TV would find real court hearings quite dull. But that doesn’t mean there isn’t plenty of drama—that was the case last Friday when Spain-based power developer EDPR faced off against the Minister of the Environment no less, in a battle over approval of an Ontario wind power project.
EDPR, developer of the 100-megawatt Nation Rise wind power project, applied for a judicial review of the decision by the environment minister in Ontario to revoke the Renewable Energy Approval (REA) for that project. The Minister issued his decision last December, following a direct appeal.
Nation Rise was one of five wind projects that received REAs in 2016; almost all the others were cancelled, in 2018.
The court challenge is remarkable in that a power developer (and the industry lobbyist) is alleging the minister had no authority to make a decision for his own department.
The EDPR lawyer, John Terry of mega law firm Torys, claimed that the current government was “implementing its anti-green energy platform” and that the decision was not warranted. He claimed further that the appeal to the minister brought by community group Concerned Citizens of North Stormont (CCNS) was not proper, that the minister’s decision was not “reasonable,” that in fact he showed bias (they quoted a statement by Mr Yurek in the Legislature in support of his own community’s fight against a wind power development), and that he “simply revoked the REA” without a remedy hearing.
Mr. Terry said if only EDPR could have presented its mitigation plan to prevent bat deaths, that remedy “will completely take care of it [the threat to wildlife].” He said Minister Yurek in fact had “no authority” to do what he did.
The lawyer for CanWEA told the court that the community group appeal to the minister was an attempt to hold a new hearing; moreover, the Minister’s powers are “confined,” he said and there are very limited circumstances in which an REA can be revoked.
Not so, said the Ontario Attorney General lawyers acting for the minister who countered that “The Minister has broad, discretionary authority to consider the matter before him in the ‘public interest.’ “
They also disputed the applicants’ claims that the minister was biased and unfair, and that the applicant never got a chance to present its mitigation proposal:
“The Minister provided the Applicants with more than the minimal content of procedural fairness…they were provided an opportunity to be heard, including when the Minister sought additional submissions, specifically with regard to harm to bats.”
Last, lawyers Kathleen Coulter and Eric Gillespie, appearing for the Concerned Citizens of North Stormont, asserted that the Minister had applied the “correct legal test” in his actions, he was able to act “in the public interest” and last, that allegations of bias are “completely unfounded.” Lawyer Eric Gillespie argued that the application should be dismissed, and told the panel of judges that, “The evidentiary record before this Honorable Court also establishes that, with respect, many of the factual assertions relied upon by the Applicants [EDPR] and the Intervenor CanWEA are incorrect. This results in both the Applicants’ and the Intervenors’ submission failing to provide grounds for judicial review to be granted.”
The matter is now before a panel of three judges.
This matter is important to everyone in Ontario, as the wind power lobby seeks to establish that the environment minister can’t revoke Renewable Energy Approvals, can’t act in the public interest, and must always give over to the importance of wind power.
Let’s help CCNS fight this! Their legal bills are piling up. Here’s how:
New York State governor Cuomo’s move to pass legislation that essentially removes democracy for wind power approvals and rubber stamp the power projects is hardly surprising: community opposition is strong in the U.S. and Canada … and it’s having an effect.
Robert Bryce, author of Power Hungry: the myths of green energy and frequent contributor to publications like the Wall Street Journal, has an article in the New York Postexplaining why rural/suburban communities are fighting back against industrialization by wind and solar power developers.
“The truth is that growing numbers of rural and suburban landowners are resisting these types of projects,” Bryce writes. “They don’t want to endure the noise and shadow flicker produced by 500- or 600-foot-high wind turbines. Nor do they want transmission lines built through their towns, to they are fighting to protect their property values and views.”
In the U.S., jurisdictions are now passing zoning bylaws that enact much greater setbacks between turbines and houses, and specifying more stringent noise limits.
In Ontario, the government returned local land-use planning to municipalities but few have taken advantage of the timing to create new bylaw protection. If a pro-wind government is elected in 2022, it will be too late to take such action after a new procurement regime is announced.
Wind and solar power development takes up a lot of land, Bryce says; renewables will grow, but there must be a better way to “keep the lights on” than using up vast tracts of land for intermittent, weather-dependent power generation.
Read the full article here: https://nypost.com/2020/03/07/angry-us-landowners-are-killing-off-renewable-energy-projects/amp/
Cruel joke: Ontario’s 550 metre setback and government/industry notion that it is impossible to hear turbines past 1500 metres
March 3, 2020
New research from Australia has been published in the Journal of Sound and Vibration which shows that wind turbine noise goes a lot farther than the wind power lobby and turbine manufacturers would have you believe.
A lot farther.
Ontario’s setback, supposed to protect people from sleep disturbance and other effects of environmental noise pollution, is just 550 metres. This was suggested to the McGuinty government by the wind power lobby, after the Ontario government proposed a setback of 1 km.
The Australian research demonstrates that indoor low-frequency tone was detected 20 percent of the time at distances up to 2.4 km; the noise dissipated somewhat but was still perceived 16% of the time at a distance of 3.5 km. The authors note that complaints made to the South Australian Environmental Protection Agency came from people living as far away as 8 km!
Here is an excerpt from “Prevalence of wind farm amplitude modulation at long-range residential locations”:
Overall, it is important to determine how often AM is present at residential locations near a wind farm. In this view, Australian researchers from the Flinders University: Dr. Kristy Hansen, Phuc Nguyen, Dr. Branko Zajamšek, Prof. Peter Catcheside, in collaboration with Prof. Colin Hansen at The University of Adelaide studied the prevalence and characteristics of wind farm AM of a certain windfarm in Australia. Their goal was to determine how often AM occurred at various distances from the wind farm and to assess the suitability of the IOA ‘reference method’ for detecting low-frequency AM of a tone that is generated by wind turbines. Their research work is currently published in Journal of Sound and Vibration.
Their approach involved outdoor measurements for a total of 64 days at 9 different residences located between 1 and 9 km from the nearest wind turbine of a South Australian wind farm, which at the time of measurements was made up of 37 operational turbines, each with a rated power of 3 MW. The motivation for their analysis was to investigate the prevalence of a low-frequency ‘thumping’ or ‘rumbling’ noise that had been mentioned in complaints from residents.
… In summary, the study investigated the prevalence and characteristics of wind farm AM at 9 different residences located near a South Australian wind farm. Their work showed that, despite the number of AM events being recorded to reduce with distance, audible indoor AM still occurred for 16% of the time at a distance of 3.5 km. At night-time, audible AM occurred indoors at residences located as far as 3.5 km from the wind farm for up to 22% of the time. In a statement to Advances in Engineering, Dr. Kristy Hansen pointed out that the adopted approach was successful, although more research was needed to quantify the annoyance and sleep disturbance potential of the recorded type of tonal AM.
In Ontario, wind turbines are approved using a noise assessment protocol (developed by acoustics consultants often contracted to do work for wind power developers), using a computer-generated predictive model of the noise. As well, Renewable Energy Approvals require post-operational audits, many of which are incomplete, or have not been submitted at all.
The environment ministry has held the belief that it is impossible to hear turbine noise at 1500 metres and callers to the ministry District Offices or Spills Line are told their complaint is not accepted, and their files are closed, Wind Concerns Ontario has discovered in reviews of Incident Reports provided under Freedom of Information requests. Wind Concerns ONtario has so far tracked 5,200 formal records of complaints held by the government. How many would there be if people had not been told their complaint was impossible?
The wind power lobby in Canada is busy crowing about “low-cost” and “free fuel” but the truth is something else. Entirely.
Sure, it’s fast and easy the whack up wind turbines, faster than building new nuclear (though not small modular reactors, but that’s another story) but there are many costs to wind that are both visible and invisible.
Parker Gallant documents the costs in his most recent article*, here. An excerpt:
An article posted February 10, 2020 highlighted how wind generation, on its own, represented a cost of $12.760 billion over the ten years from 2010 to 2019 to Ontario ratepayers. Industrial wind turbines (IWT) delivered 83.3 TWh and curtailed 10.5 TWh over that time. The combined cost of the generation and curtailment represented an average delivered cost per kWh of 15.32 cents—without factoring in costs of gas plants being at the ready when the wind wasn’t blowing or spilling clean hydro.
Over the same ten years, exports of surplus power to our neighbours cost ratepayers about $12.5 billion dollars. Wind’s habit of generating power in the middle of the night and spring and fall when demand is low drives down the market price, the HOEP (Hourly Ontario Energy Price), resulting in export sales at prices well below contracted rates. This results in ratepayers having to pay the difference.
Last weekend (February 22 and 23) was no exception. The wind was blowing for the two days but Ontario Demand was low, averaging 341,800 MWh. IWTs however, were generating power we didn’t need with grid-accepted wind at 148,175 MWh and 14,900 MWh curtailed. The cost of both was $24 million or 16.2 cents/kWh. IESO was busy exporting surplus power of 141,648 MWh or 96% of grid-accepted wind.
On top of that we were probably spilling water (and paying for it) at the same time.
The question is, how much were we paid for those exports? Exports sold February 22 were at the average price of $1.99/MWh and $1.64/MWh on February 23, so total revenue earned was a miserly $239,000 versus a cost to ratepayers and taxpayers of the province of over $24 million just for what the IWT delivered. Our US neighbours must love us!
Wind’s hidden costs
While the foregoing confirms IWTs are unreliable and intermittent and require backup from gas plants, they have other bad habits. One example is their killing of birds. The Audubon Society has suggested it is anywhere from 140,000 to 328,000 annually. They also kill bats in large numbers. Bird Studies Canada in 2016 estimated the kill rate in Ontario was 18.5 kills per turbine (over 50,000 annually). Many killed are on the endangered list! Additionally, tourism areas may also be negatively affected by IWT as noted in a poll in Scotland by the “John Muir Trust found that 55% of respondents were ‘less likely’ to venture into areas of the countryside industrialised by giant turbines”.
A recent report from Wind Concerns Ontario (WCO) raises many other negative issues related to IWT. The report is a synopsis of complaints about IWTs submitted by rural residents of Ontario living within close proximity. Those complaints were submitted to the MOECC (now the MECP) in 2017. The report titled: “Response to Wind Turbine Noise Complaints” analyzed 674 complaints made during 2017. The shocking issue revealed is: “Only nine of the 674 complaints, or 1.3% of total records, indicated there was a field response” [from the MOECC]. What that suggests is the MECP’s field offices are either not equipped to deal with complaints or believe the IWT-contracted parties will somehow resolve them. In excess of 5,200 complaints have been logged by WCO since IWT first started to appear in the province and most of them were related to audible and inaudible (infrasound) noise levels. Other complaints have been associated with aquifer (water) contamination, shadow flicker, ice throws, etc.
Approximately 15% of the population will experience negative health effects from the proximity of IWTs, a similar percentage to those who suffer from motion sickness [on a ship or vehicle]. The effects of audible and infrasound noise will produce nausea, headaches, anxiety, ringing ears, feeling of exhaustion, etc. Those individuals will naturally contact their doctors or other health care professionals for treatment, adding to the cost of Ontario’s health care system. Those costs are not attributed to the cause, which are the IWTs!
Let’s summarize the visible and invisible costs of IWT:
Increased electricity costs due to the need for duplicate power sources such as gas plants.
Increased surplus power which must be curtailed or sold for pennies on the dollar.
Increased costs due to IWT inability to generate power when actually needed.
Increased surplus power from IWT often means other clean sources must either spill (hydro) or steam off (nuclear) power which adds costs to our electricity bills.
IWT kill birds and bats, many of whom are “species at risk” meaning insects, damaging to crops, are not eaten and farmers must spray their crops with insecticides adding costs to produce.
IWT may affect tourism areas driving away tourists and thereby affect income to those regions.
IWT cause various health problems requiring our health system to respond to individuals affected, thereby adding to health care costs.
IWT cause property values to fall affecting the realty tax base where they operate and the value of the property should the occupants try to sell after the installation of those IWT has occurred.
IWT lifespan is relatively short (20 years at most) compared to traditional sources of electricity generation and when unable to perform, create costs of remediation and disposal of recyclable and non-recyclable materials they consumed when built and erected.
*This is provided for information purposes only and does not represent Wind Concerns Ontario policy; the views and opinions are the author’s.
Recent news from New York State and Arizona indicate a disturbing trend in the United States. With the awareness of negative impacts on the environment and human health from industrial-scale or grid-scale wind turbines rising (together with discontent over rising electricity costs), opposition to wind power projects has become vocal and powerful.
Legislate their approval no matter what and obliterate the possibility of any opposition from communities.
Quoted in an article in today’s Post-Journal, NY Senator George Borrello said the move to fast-track wind power projects by Governor Cuomo is clearly aimed at “crushing” any citizen opposition. Borrello said:
“The governor’s 30-day amendment to accelerate renewable energy projects is a maneuver designed to bypass Article 10, which established a siting process for these projects that, appropriately, included local input. Now, in order to advance an extreme environmental agenda, he is proposing to eliminate home rule in order to force these renewable energy projects on communities. This is bypassing local zoning and crushing any opposition. In order to meet his environmental targets, these projects will need to be constructed on a massive scale and with a density that will literally change the face of upstate New York, transforming it into a barren industrial wasteland. Countless acres of farmland will need to be blanketed with solar farms. Our beautiful shorelines will be marred by the sight of massive mechanical wind turbines towering over the water.”
Ontario’s Green Energy Act passed in 2009 by the government under Dalton McGuinty, did much the same thing, removing all local land-use planning powers with regard to renewable energy projects. The current Ontario government returned those powers but few municipal governments have followed through on the opportunity to protect their citizens from negative impacts of potential wind power developments by enacting protective zoning bylaws.
The democracy-killing trend is not unanimous, however: In Ohio, the state government is considering legislation that will allow communities to hold a referendum for a proposed renewable energy project.
“No one should underestimate the influence of the well-funded wind power lobby,” says Wind Concerns Ontario president Jane Wilson.
CanWEA, the Canadian wind lobbyist, has been approved for Intervenor status in the court action over the revoking of the Renewable Energy Approval for the Nation Rise wind power project. The Ontario environment minister said in a letter to the community group which had appealed the approval that the power from the project wasn’t needed, and proceeding on it was not worth the environmental risks.
Wind Concerns Ontario releases a report on Ontario government records of 2017 wind turbine noise complaints
A report released today by Wind Concerns Ontario (WCO) shows that the government under Premier Kathleen Wynne did little to respond to citizen reports of environmental noise pollution by industrial-scale wind turbines. And, when government staff in the environment ministry offices did try to enforce Ontario noise regulations, they were rebuffed by corporate wind power operators.
The Wind Concerns Ontario report is a review of almost 700 noise complaints from people living inside 23 wind power facilities across Ontario. The total number of complaints records received by WCO now exceeds 5,200.
Response by the environment ministry was recorded in only 1.3 percent of the records in 2017; 54 percent of the files were marked “No” response by government staff.
Adverse health impacts were noted in staff notes and recorded comments by citizens calling in or emailing in 42 percent of the files, and 16 percent contained description of symptoms suggestive of exposure to low-frequency noise which is not audible but can cause harm.
The Wind Concerns Ontario report comes after a 17-month wait and several appeals to the Ontario Information and Privacy Commissioner following the initial request for the records under the Freedom of Information Act. The noise complaints were made to the MInistry of the Environment and Climate Change during the pro-wind power Wynne government’s last full year in office.
Excerpts from the citizen complaints are included and provide a “litany of suffering” according to the WCO report.
“We find no peace … the assault is the same and at times greater in low wind speeds. [We have had] a thumping noise through our heads, long and steady, all day,” was one comment from someone living near the single turbine in Port Elgin, owned by the union Unifor.
“The noise has been bad for 24 hours,” said another resident, living inside the 140-turbine K2 Wind power facility. “I am exhausted from not sleeping.”
Another K2 Wind neighbour reported that the noise “drives a person insane when it goes on for hours…We are being impacted health-wise and are extremely agitated with the noise.”
“Unbearable … torture,” said another person. No response from the environment ministry was recorded on the file.
The corporate power operators are required by the terms of their Renewable Energy Approvals or REAs to act on these complaints, and to investigate the cause of complaints, take action, and ensure the complaints are not repeated. The Environmental Protection Act gives specific power to the environment ministry to take action.
In practice, however, Wind Concerns Ontario found in its review, the power operators were delinquent in filing audits to confirm compliance, and refused to take action when called upon by ministry staff. When the Owen Sound District Office, for example, demanded the operator of K2 Wind respond to noise complaints and implement noise mitigation until their (overdue) audit was filed, the company wrote back from its Texas headquarters with a refusal, stating “It is the Company’s view that the current circumstances do not objectively establish reasonable and probable grounds to require interim mitigation measures.” The operator, Pattern Energy, referred to its computer-generated predictive modeling for noise and said the modeling “is accurate.” In other words, our models say this can’t happen, therefore it isn’t.
The situation is unacceptable, Wind Concerns Ontario says.
“We’re recommending that the current Ontario government take action to enforce the regulations immediately,” says Wind Concerns Ontario president Jane Wilson. “It’s time to get rid of the outdated and non-protective protocol for measuring noise, stop letting the corporate power operators police their own operations, and re-invest and support our trained Environmental Officers—let them do the job they were supposed to do, and help the people of rural Ontario who have been forced to live next to these power generating machines.”
Wind Concerns Ontario is a coalition of community groups, individuals and families concerned about the negative impacts of industrial-scale wind power development on the environment, the economy, and people’s health.
“Government and industry not trusted to resolve noise complaints effectively or fairly” researchers said in 2016
January 20, 2020
An interesting story popped up in the news feed this morning, out of Missouri.
A wind power project has been proposed for Buchanan County and a new protective zoning ordinance drafted. The ordinance specifies a two-mile setback between turbines and the city limits, but there is no restriction on the distance between the huge wind power generators and rural homes.
Once again, rural communities are pitted against city dwellers; the latter seems all too eager to have their wind power but not have to hear it, too.
Any minute now, the N-word will come up.
City dwellers will be encouraged by the wind power proponents to accuse their country cousins of being “NIMBY” (Not in My Back Yard) while at the same time, these large power generators will never be in their back yards. Or even close to them.
The use of the epithet NIMBY has been used effectively by the wind power lobby as a marketing strategy designed to put rural residents offside, and help depict them as uninformed people worried only about property values and views.
The Buchanan County ordinance is interesting because a) it acknowledges that there are problems with wind turbine noise, and b) significant setbacks are needed to try to counter that problem.
Let’s be clear: NIMBY is an insult. It’s also completely inappropriate say two authors and academics, in a paper published in the journal Renewable Energy Law and Policy, not long after the Green Energy Act was passed.*
When it comes to community concerns about wind power projects being forced on residents, there are very real problems, authors Stephen Hill and James Knott said. Noise issues were “conflated with other social issues such as property value,” there was “inadequate communication and public engagement” and a “loss of local government authority over planning matters,” all of which led to a “growing mistrust in government and industry’s ability to effectively and fairly manage the risks of wind turbine noise.”
The McGuinty and Wynne governments became regarded “not as a neutral arbiter of wind regulation but rather an active proponent,” the authors said. “A crucial error, in our view, was not to have created an independent expert panel to assess the central points of controversy,” i.e, the noise and health impacts.
Hill and Knott are not alone: several other academic authors said that use of the term NIMBY is “an oversimplification of opposition that more accurately is based on a complex mix of factors.”
“Many communities have genuine concerns about impacts on environmental integrity, viewscapes, food production, and social fabric” wrote a team of authors, also published in the Renewable Energy Law and Policy journal.**
Today, with thousands of reports of excessive wind turbine noise and complaints of associated health effects logged by the Ontario government (even with a deeply flawed and inadequate reporting system), we have more than enough evidence that something is terribly, terribly wrong.
Ontario’s current government has pledged to do something to help; insisting on complete compliance with current noise regulations (which do not meet World Health Organization standards) and enforcing Renewable Energy Approvals is a start.
In the meantime, in view of all the very serious problems with industrial-scale wind power, no one should be calling anyone a NIMBY.
*Stephen Hill and James Knott. 2010. Renewable Energy Law and Policy. Too Close for Comfort: Social Controversies Surrounding Wind Farm Noise Setback Policies in Ontario.
** D. McRobert, J. Tennent-Riddell and C. Walker. 2016. Renewable Energy Law and Policy. Ontario’s Green Economy and Green Energy Act: Why a Well-Intentioned Law is Mired in Controversy and Opposed by Rural Communities.
Minister Revokes Approval for Nation Rise wind power project
Controversial wind power project will cause irreversible harm to wildlife minister says in revoking approval; decision made in context that the power isn’t needed
December 9, 2019 OTTAWA:
Jeff Yurek, Ontario Minister of Environment, Conservation and Parks issued a decision revoking the Renewable Energy Approval for the Nation Rise wind power project under construction in North Stormont, near Ottawa.
The Minister’s decision was in response to an appeal filed by community group Concerned Citizens of North Stormont of a quasi-judicial decision supporting the project approval.
In his decision, the Minister concluded that the wind turbines would cause serious and irreversible harm to endangered bat populations in the area. The potential for harm to wildlife was considered in the context of the contribution to Ontario’s electricity supply in Ontario, which would be minimal; the Minister concluded that it was in the public interest and a precaution to protect the environment to revoke approval for the power project.
Margaret Benke, representing the Concerned Citizens of North Stormont (CCNS) welcomed the Minister’s decision. The group had raised many concerns about the environment in its appeal. “Now,” she says, “the environment, wildlife and human health will be protected from the harmful effects of wind turbines.”
Benke thanked the many people who supported the Concerned Citizens group financially and with submissions of information for the original appeal before the Environmental Review Tribunal and subsequent appeal to the Minister.
“This power project has been very divisive for our community; now North Stormont can again be a good place to grow.”
The Nation Rise project consisted of up to 33 turbines located near Finch, Berwick and Crysler in Eastern Ontario. The project was planned to generate up to 100 MW of electricity under a 20-year, $400-million contract awarded by the IESO.
CCNS is a community group member of the Wind Concerns Ontario coalition.
CONTACT: Wind Concerns Ontario at email@example.com or firstname.lastname@example.org
Concerned Citizens of North Stormont: email@example.com
“a particular focus on larger gas, wind and solar…”
November 8, 2019
Ontario energy minister Greg Rickford and associate energy minister Bill Walker have announced a Minister’s Directive to retain an “independent party” to conduct a review of the province’s power generation contracts, to reveal cost-saving opportunities.
The Order-In-Council specifically says [emphasis ours]:
Therefore, in accordance with my authority under subsection 25.32(5) of the Act, I hereby direct (IESO) as follows:
To retain the services of an independent third party with relevant qualifications, experience and expertise to undertake a targeted review of existing generation contracts to identify opportunities to lower electricity costs within such generation contracts.
The review referred to in paragraph 1 shall:
identify measures or adjustments that could result in reduced costs for Ontario consumers;
place a particular focus on larger gas, wind and solar contracts that expire in the next ten years, including portfolios of contracts held by the same proponent and any other areas where IESO or the third party determine that there is the potential for cost savings; and
take into consideration system reliability and potential impacts to Indigenous, municipal, and local partnerships.
The review shall not consider the Bruce Power Refurbishment Agreement or contracts related to conservation and demand-management initiatives.
IESO shall provide the third-party report containing its key findings and recommendations, along with IESO’s assessment of the findings, to the Ministry by no later than February 28, 2020.
The statement that “impacts to … municipal and local partnerships” is interesting: it may mean that citizen reports of excessive noise/vibration and water well disturbance (to name a few negative impacts of grid-scale wind power development) may also be considered in the review.
It is also a positive move in that the review will include “system reliability”: many analysts and stakeholder groups such as Ontario’s professional engineers have repeatedly demonstrated that wind power is variable, unreliable, and produces power out-of-phase with demand, which means much of it is constrained (operators are paid not to have power added to the grid) or sold on the open electricity market at a loss.
“Wind Concerns Ontario welcomes this review,” says president Jane Wilson. “For too long wind power has skated by common sense and basic economic principles on the ideology that it is ‘good’ for the environment. We know from multiple environmental impacts such as the thousands of citizen reports of excessive noise and vibration from wind turbines, with accompanying adverse health effects, that wind power is high impact on the environment for little or no benefit.
We look forward to a comprehensive review that takes all these factors into account.”