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.
Report on Environmental Review Tribunal Hearing on White Pines Wind Project
On Day 18 of the Environmental Review Tribunal (ERT), APPEC expert witness Dr. Daryl Cowell testified that there is substantial evidence of karst in the White Pines study area and that serious and irreversible impacts will occur if this project proceeds. WPD witness Ronald Donaldson and Ministry of the Environment and Climate Change (MOECC) witness Mark Phillips disputed this.
Dr. Cowell told the ERT that he has appeared as a karst expert witness before eight Ontario Municipal Board hearings, done work for municipalities across Ontario, and authored or co-authored hundreds of technical documents, including peer-reviewed papers. He has spent 40 years studying karst, with the past 20 years focused on hazard assessment. Dr. Cowell was qualified as a professional geoscientist with expertise in karst.
Dr. Cowell said that a major karst area runs through Black Creek Valley ANSI (Area of Natural and Scientific Interest). Physical evidence of karst includes sinkholes and crevices (as identified earlier by area resident and presenter Doug Murphy), an artesian-like stream, year-round springs that go underground, dry wells, and extensive limestone pavements. Turbines would be located in epikarst, the upper boundary of a karst system, close to the edge of the valley. The access road to wind turbines T02 and T03 crosses Black Creek and proceeds through a zone of karst features including crevices one foot wide and ten feet deep.
However, none of WPD’s Renewable Energy Approval reports identified karst features, assessed potential impacts, or even surveyed water bodies except in September and October, known to be low-flow periods.
Dr. Cowell noted that mapping the watershed in a karst aquifer is extremely difficult when vertical and horizontal fractures make water flow unpredictable and boundaries are always in flux. A storm water management plan is out of the question because it is impossible to determine the high water mark, a basic requirement for construction activities.
According to Dr. Cowell, blasting and trenching for 16 kilometres of new access roads, collector lines, and turbine bases will cause serious and irreversible harm to shallow karst areas. Blasting and backfilling through the upper metre of bedrock will dam and divert flows resulting in permanent impacts to the surface water/groundwater regime.
WPD witness Ronald Donaldson was qualified by the Tribunal as a hydrologist. His testimony focused on potential interference with the quality and quantity of the local water supply aquifer and groundwater.
Donaldson reviewed aerial photographs, maps and literature that show no conclusive evidence of karst in Prince Edward County. He considers the Black Creek Valley a sub-glacial tunnel formed long ago by glacial melt-waters. Though predicting impacts such as sediment in shallow water wells and wetlands, he said there are mitigations for the temporary effects as well as for sinkholes or fractures opened during construction. Donaldson agreed with APPEC counsel Eric Gillespie, however, that alterations to the top three metres could impact wetlands.
Mr. Gillespie referred Donaldson to a 2013 study cited by Dr. Cowell, “Evaluating karst risk at wind power projects.” While agreeing that karst evaluations should be done early, Donaldson said he was not qualified to speak to the study’s number one mitigation—to move the turbines.
Mark Phillips, of the MOECC, was qualified as a surface water specialist with expertise in identifying risks to and mitigation of surface waters. Starting in October 2014, Phillips raised a number of issues about the lack of detail on project impacts on wetlands in WPD’s Construction Plan Report, the risk of impacts during construction on surface water, and the timing of surveys for water bodies. However, WPD chose to rely on existing MOECC records rather than carry out additional field work.
Nonetheless, Phillips considers that risks from erosion and sediment can be fully managed by the “mitigation toolbox” and the effects will be temporary. He confirmed with Mr. Gillespie that he did not review the wetlands near turbines T27, T28, and T29 or, indeed, the Natural Heritage Assessment on wetlands.
Report on the ERT Hearing on the White Pines Wind Project – Dec. 4, 2015
By Henri Garand, APPEC
On Day 17 the Environmental Review Tribunal (ERT) of the White Pines wind project heard the testimony of WPD witnesses Shawn Taylor and Dr. Paul Kerlinger.
Mr. Taylor was qualified by the Tribunal as “an ecological restoration and construction mitigation specialist.” However, he testified at length about Blanding’s turtles because of his participation in a four-year study involving a Kanata road extension into their habitat.
After classifying the roads (paved, gravel, and access) required for White Pines, Taylor spoke about the risks from higher traffic, but he said these are minimal due to the “block-out period” on construction between April 15 and October 15, and the later infrequent maintenance visits. Mitigations such as staff training and 15km speed limits will protect turtles.
Taylor also felt that “new roads would not increase fragmentation of Blanding’s turtle habitat.” He described the access roads as “laneways” flush to the ground surface and therefore not a barrier to turtles. Similarly, turtles will readily move through the nine culverts to be constructed. The roads would also not interfere with water flow into deep wetlands, crucial overwintering habitat.
Predation of eggs and young by foxes, raccoons, and skunks is possible but could be mitigated by compaction and reduction of roadside gravel, though neither method is cited in the White Pines construction report.
During cross-examination by APPEC counsel Eric Gillespie, Taylor admitted that his witness statement is incorrect in describing most access roads as passing through ploughed fields instead of cultural meadow, alvar, and treed land. Only nine turbines are located within current agricultural fields. The access “laneways” would be 5m wide, with brush clearance as much as 5m on each side.
Taylor also conceded that two thirds of the White Pines project lies within primary Blanding’s turtle habitat. According to a map in WPD’s Natural Heritage Assessment, wind turbines T7, T11-24, and T27-29 all fall within known turtle egg excavation or spring foraging areas.
Paul Kerlinger, Ph.D., was qualified as “a biologist with specialization in bird behavior and expertise on the impacts of wind energy projects.” Once an Audubon Society director of the Cape May Observatory, Kerlinger redirected his career to studying avian risks from wind projects in Canada, Mexico, Spain, and the United States, and he has testified in 100 cases as an expert witness on behalf of developers.
Although stating that “all wind projects kill birds,” Kerlinger does not regard this as “serious and Irreversible harm” because the fatalities are not statistically significant at the species population level, whether measured as a percentage or by population viability models (which take into account reproductive rates, dispersal and mortality). He said studies show that mortality ranges from 6-9 birds per turbines per year, and the upper figure applies to Wolfe Island when its monitoring records are averaged over three years.
Under cross-examination Kerlinger admitted there are different views of the appropriate geographical scale to be considered for assessing risk to bird populations. He also conceded that monitoring results are dependent on search area size and terrain, number of predators, frequency of searches, and staff training. Data comparison across projects is complicated by differing turbine sizes and power output. Finally, though noting the effectiveness of such mitigations as flashing lights and turbine shutdowns, he said he had made no suggestions to WPD.
The ERT resumes Monday, December 7, 10 a.m., at the Prince Edward Community Centre, 375 Main St., Picton.
Report on Environmental Review Tribunal Hearing on White Pines Wind Project
Paula Peel, APPEC
On Day 16 of the Environmental Review Tribunal (ERT), APPEC expert witness Kari Gunson testified that the White Pines wind project will cause serious and irreversible harm to Blanding’s turtles on the Prince Edward County south shore, and Dr. Smallwood completed his testimony from Tuesday.
Ms. Gunson has worked as a Road Ecologist for 16 years and has co-authored 13 peer-reviewed published articles. She was qualified by the Tribunal as a Road Ecologist, with experience evaluating the indirect and direct effects of roads on wildlife and their habitat.
Gunson focused on the large roadless areas around wind turbines T12 to T24 and T26 to T29. White Pines will increase road density in habitat occupied by the Blanding’s turtle, a threatened species, and the new roads will be used by maintenance vehicles, by landowners to gain access to their property, and by farm machinery.
Moreover, Ms. Gunson predicts that upgrades to existing municipal roads, such as Babylon and Helmer, will result in more traffic and vehicles moving at higher speeds than at present. Blanding’s turtles are at risk from vehicular strikes because they range up to 6 km, and in habitat, like the South Shore where soil is scarce, they will nest along the roads. Gravel roads can be ecological traps where turtles are also vulnerable to predation and poaching.
Access road construction, said Gunson, can lead to changes in vegetation composition and in hydrology, with changes in water temperatures and levels impacting turtles which overwinter in wetlands. Blanding’s turtle experts have recommended a 150m construction buffer from wetlands. However, WPD’s approved Environmental Impact Study provides only 120m buffers and permits construction activities metres away from wetlands.
Dr. Smallwood continued his discussion of his findings on Wolfe Island wildlife mortality for the purpose of understanding the impact of White Pines. He noted that fatalities for 57 bird and bat species have been reported, more than in any other single project he has ever seen. It is probable that the numbers will be even higher for White Pines because of the migratory pathway.
If Wolfe Island rates are realized at White Pines, Dr. Smallwood predicts project-level fatalities up to 954 birds and 1800 bats per year. Dr. Smallwood noted his concern with bats, which are drawn to heat-releasing vents in the turbines. It is difficult to estimate how many small bats are killed as they are not readily detected in carcass searches.
Dr. Smallwood told the ERT that the best way to prevent harm is siting White Pines to avoid problems. Little can be done after the project is built. He strongly disagrees with claims by Dr. Kerlinger and Dr. Strickland, witnesses for WPD, that impacts can be effectively mitigated once the wind turbines have been constructed.
The ERT continues Friday, December 4, 10 a.m., at the Prince Edward Community Centre, 375 Main St., Picton.
Last week, my colleague MPP John Yakabuski tabled a bill entitled Energy Referendum Act, 2015.
If passed, this bill would mandate that local municipalities hold a referendum before large-scale renewable energy projects are approved so that residents are the ones who decide if these projects will go forward.
Forced industrial turbines have been a serious issue in our communities, and I support MPP Yakabuski’s efforts to return decision making powers to municipalities and residents.
If you would like to voice your support for this bill, I have attached a copy of a petition that you can sign. I will be introducing all completed petitions in the Ontario legislature to send a strong message to the government.
Please return original copies of the petition to my office: 55 Lorne Avenue, Unit 2, Stratford, Ontario, N5A 6S4.
Wolfe Island a killing field for birds, White Pines high-risk for wildlife experts testify
More stunning testimony yesterday at the White Pines appeal as an avian behavior expert spoke on reported bird fatalities at Wolfe Island, a few kilometres away from both Ostrander Point and the White Pines project areas.
Report on Environmental Review Tribunal Hearing on White Pines Wind Project
On Day 15 three experts testified at the Environmental Review Tribunal (ERT) that the White Pines wind project will cause serious and irreversible harm to birds and bats. All had concerns with the project location on a migratory path on Lake Ontario’s shoreline.
Dr. Michael Hutchins, Director of the American Bird Conservancy’s Bird Smart Wind Energy Campaign, was qualified as a biologist with specialization in animal behaviour and with expertise in the impact of wind energy projects on birds and bats. Hutchins told the ERT that one function of the Bird Smart Campaign is to educate decision-makers so turbines are properly sited. White Pines is in a high-risk location. The U.S. Fish and Wildlife Service recommends three-mile setbacks from the Great Lakes.
Hutchins cited a recent U.S. study showing significant displacement of breeding grassland birds in mid-western states after turbine construction. White Pines will displace protected Bobolink, Eastern Meadowlark, and Eastern Whip-poor-will, and the impact could easily result in local extirpation.
Bill Evans has researched the impact of wind projects on birds and bats for 20 years. Evans was qualified as an expert in avian acoustic monitoring and nocturnal bird migration. He said that a number of species in Ontario, including the Purple Martin, have been in long-term decline, but Stantec did no surveys of Purple Martins during late summer when large numbers gather to roost. Evans noted that Purple Martin collision fatalities are increasing at Ontario wind facilities and made up 6.09% of all bird fatalities in 2014, higher than in 2012.
Dr. Shawn Smallwood was qualified as an ecologist with expertise in avian wildlife behaviour and conservation. In addition to 70 peer-reviewed publications Smallwood has done research at the Altamont Pass Wind Resource Area (WRA), a California wind project notorious for its high raptor mortality.
Smallwood told the ERT that impact monitoring at Wolfe Island indicates the highest avian fatality rates in North America other than at Altamont Pass WRA. Based on methods commonly used across the rest of North America, Smallwood estimates that Wolfe Island kills 21.9 birds per turbine per year. This is nearly twice the number reported by Stantec using searches only within a 50-foot radius, less than half of standard practice. Smallwood considers Wolfe Island one of the most dangerous wind projects on the American continent.
Smallwood predicts similar or higher fatality rates at the White Pines project because the peninsula is targeted by migrating birds as a stopover site and because the project is surrounded by wetlands and woodlands intensively used by birds. Moreover, many threatened and endangered species occur at the site. Stantec surveys for White Pines foster a high level of uncertainty because 19 hours of field work is so minimal that it’s impossible to know much about the large project area, and no surveys were done for migratory bats.
Smallwood recommends that serious and irreversible harm be assessed from a biological perspective, not from population analyses. Fatalities cause harm not only to the individuals killed but also to mates, dependent young, and social connections. Serious and irreversible harm should not be based only on body counts.
The ERT resumes Thursday, December 3, 10 a.m., at the Prince Edward Community Centre, 375 Main St., Picton.
This report from the Alliance to Protect Prince Edward County (APPEC), the appellant in the appeal of the White Pines wind power project approval, is just stunning: the Ontario Ministry of Natural Resources and Forestry staffer in charge of issuing permits was completely unaware that the power plant site was an important location for migratory birds and home to at-risk species. In other words, she just took the wind developer at their word, and did not investigate further. No oversight on this process at all, is the only conclusion one can come to.
Report on Environmental Review Tribunal Hearing on White Pines Wind Project
On Day Fourteen the Environmental Review Tribunal (ERT) of the White Pines wind project heard the testimony of Kathleen Pitt and Dr. Brock Fenton.
Ms. Pitt, summoned by APPEC and qualified by the Tribunal as “a biologist,” has a B.A. in Environmental and Resource Studies and is a manager with the Ministry of Natural Resources and Forests (MNRF). She was responsible chiefly for assessing the Species-at-Risk report for White Pines, recommending Endangered Species Act (ESA) permits for the bobolink, eastern meadowlark, and whip-poor-will, and deciding not to recommend a permit for the Blanding’s turtle. She explained that ESA, or “overall benefit,” permits are issued when it is possible to compensate for harm through other activities like research or habitat restoration. Permits are not issued when avoidance and mitigation measures are considered sufficient.
Under examination by APPEC counsel Eric Gillespie, Pitt showed she was slightly familiar with the nearby locations of the Prince Edward Point National Wildlife Area, Point Petre Provincial Wildlife Area, and South Shore Important Bird Area (SSIBA), and was not at all familiar with the Prince Edward Point ANSI (Area of Natural and Scientific Interest) or the Miller Family Nature Reserve. She also admitted that she did not know the SSIBA has the highest concentration of migratory birds in eastern Ontario, has the highest concentration of migratory raptors and saw-whet owls, has high bat migration, and is a significant stopover site for migrating birds. Nor did she know that diversity of habitat is best for migrating birds, undisturbed sites are preferred, and migrating sites are unique in exposing ascending and descending birds to wind turbines. Consequently, perhaps, she did not agree that “the South Shore is a funnel for migration.”
For Blanding’s turtles, Pitt never consulted MNRF herpetology expert Joe Crowley. She said she did not know if the entire South shore was their territory but conceded that Ostrander Point turtles could move offsite. Though she had not read the entire ERT decision on Ostrander Point, she disagreed that it was necessary to exclude turbines. She felt that standard setbacks of 120m from wetlands as well as other avoidance and mitigation measures would provide protection.
Brock Fenton, Ph.D., a professor emeritus at Western University, was qualified as an “expert in bat biology.” He said it was well established that operating wind turbines kill bats. The mortality can be significant because bats have a low reproductive rate (one per female per year) and 60 percent of young perish in the first year. The little brown bat is especially vulnerable due to an estimated 90-percent population drop since 2009 from White Nose Syndrome. However, considering uncertainty about the size of bat populations, Dr. Fenton said that all species are a “grave cause for concern.”
In cross-examination Dr. Fenton disagreed with the condition in the White Pines Renewable Energy Approval that mitigation is necessary only if bat deaths total 10 per turbine per year. He said that even one dead bat should trigger a shutdown because it is possible to use acoustic monitoring for bats and to turn off turbines when they are present.
The ERT resumes Tuesday, December 1, 10 a.m., at the Essroc Centre, Wellington.
Writing in yesterday’s National Post and for Postmedia, Michael Den Tandt puts the climate change discussion into perspective and in particular, has some advice for the new federal government on “clean” energy:
The Liberals will also need to take pains to avoid the multi-billion-dollar waste and anti-democratic outrages of Ontario’s Green Energy Act, which foisted inefficient, hugely expensive and environmentally harmful wind turbines on rural communities that in many cases did and do not want them.
Actually harm the environment they are supposed to be saving—that’s the lesson to be learned from Ontario about wind turbines. Only Ontario hasn’t learned it, as the government contracts for 300 more megawatts of wind in 2015 (well, turns out we have to wait now until 2016 to learn which communities are on the chopping block), and another 200 megawatts in 2016.
Worse, Big Wind has convinced the Ontario government that the 3-megawatt machines are actually “quieter” and so, new regulations for turbine noise, to be released shortly, will have zero mention of low-frequency noise or infrasound, because Big Wind says it isn’t a problem. Meanwhile, anecdotal reports out of communities where the 3-megawatt behemoths have begun operating show that people are getting sicker, faster.
Analysts such as Tom Adams, Scott Luft and Parker Gallant repeatedly offer data that shows wind power is not only high impact on the environment it is for very little benefit, and is costing Ontario in terms of competitiveness, and standard of living.
Ontario has a lot to learn, not the least of which is how to protect its citizens.
On November 19, 2015, the Environmental Review Tribunal released a decision in the Settlers Landing Wind Park hearing, finding that elements of the proposed wind project will cause serious and irreversible harm to the natural environment. This is only the second case in which the Tribunal has made such a finding and the first since the Court of Appeal decision in Prince Edward County Field Naturalists v. Ostrander Point GP Inc.
While the Tribunal dismissed several grounds of the appeal, it found that elements of the project, specifically the construction and decommissioning of Turbines 3 and 5 and the construction of certain access roads, will cause serious and irreversible harm to a woodland. Full reasons for the Tribunal’s decision were not issued and will follow in the future. This finding engages the Tribunal’s authority to revoke the approval, alter the Director’s decision (the Renewable Energy Approval) or direct the MOECC Director to take specified actions. It will be interesting to see both the process used by the Tribunal and the ultimate remedy resulting from this decision.
PICTON, ONTARIO. NOVEMBER 30, 2015. At the Ottawa Divisional Court, CCSAGE Naturally Green (CCSAGE NG) has filed notice for a Judicial Review of the process by which on July 16th the Ontario Ministry of Environment and Climate Change issued a Renewable Energy Approval for the White Pines wind energy project of 27, perhaps 29, turbines in Prince Edward County. As part of this REA approval process, on September 11th, 2015, the Minister of Natural Resources and Forests issued a permit for the project to kill, harm and harass endangered or threatened species at risk. Citing institutional bias, lack of science-based studies, disallowance of municipal input, and denial of natural justice, CCSAGE NG has prepared affidavit evidence exceeding 1500 pages claiming that the Ontario government’s approval process has violated several constitutional rights of rural citizens and communities as well as international treaties and agreements.
CCSAGE NG is a federally incorporated not-for-profit corporation.. It works with citizens and other groups to ensure that “Green Energy” initiatives of governments and industry are safe and appropriate for the citizens, the wildlife and the natural and heritage environments of Prince Edward County.
CCSAGE NG continues to support other groups appealing two wind energy projects in the County. However, Ontario’s Green Energy Act permits Environmental Review Tribunal (ERT) appeals only on grounds of serious harm to humans or serious and irreversible harm to animal and/or plant life and to the natural environment. That Act does not permit ERT appeals on any other grounds such as biased approval processes, denial of natural justice, violation of constitutional rights, harm to local economies, harm to tourism, harm to heritage assets, diminution of property values, or violation of international treaties and agreements. CCSAGE NG has therefore filed its application for a Judicial Review of this project’s approval process, in an effort to restore equity, accountability and justice.
CCSAGE NG Chair Anne Dumbrille observed that, at an ERT, it is difficult for citizens to get a fair hearing of their grievances against government-approved wind projects because the ERT process is heavily biased in favour of the wind energy developer and the government ministries that approve its projects. “ERTs are government-appointed tribunals that follow government rules and use taxpayer-funded lawyers to permit destruction of environmentally sensitive areas and to deny natural justice to local citizens who have constitutionally assured rights and freedoms. Our only recourse is to Canada’s courts, where rules of equitable justice prevail,” she said.
In preparing the Application, CCSAGE NG has had the benefit of considerable research contributed by five students from the Osgoode Hall Law School at York University.
Here is the report from the Alliance to Protect Prince Edward County (APPEC) on Day 13 of the appeal of the White Pines wind power project. Note that the MOECC’s expert witness claims the new noise regulations will be available shortly, and the appellant’s expert witness testified that the developer’s consultant failed to identify several features of the landscape that contribute to appropriateness of the site.
Report on the ERT Hearing on the White Pines Wind Project – Nov. 25, 2015
By Paula Peel, APPEC
Day Thirteen of the Environmental Review Tribunal (ERT) of the White Pines wind project focused on two witnesses: Denton Miller, a Senior Noise Engineer in the Environmental Assessment Branch of the Ministry of the Environment and Climate Change (MOECC), and APPEC witness Dr. Craig MacRae, a professional hydrologist.
Miller clarified the MOECC’s position that wind turbine noise is broadband, not impulsive, and that turbines have no low-frequency or infrasound emissions. Reports of “sensations” are among the complaints the MOECC receives. MOECC audits ensure that the sound power used in modelling is correct and complies with regulations. If compliance is an issue, there are options such as restricting operations to daytime or during certain wind conditions.
Miller explained that the MOECC’s Noise Assessment is predicated on the worst-case scenario and the model gives conservative results. Therefore, it is not a concern that sound output downwind of turbines is 6 to 7 db(A) higher than upwind, or night-time sound output may vary from 5 to 10 db(A) due to wind shear.
APPEC counsel Eric Gillespie asked Miller to consider that MOECC’s model is “practical,” not “conservative,” because acousticians suggest these scenarios happen all the time. Gillespie noted that the White Pines project is spread over a large area encompassing many receptors. At any given time would it not be possible that turbine blades will be turned away from some receptors while other receptors will be downwind? Miller replied that due to variable wind directions this might not happen and sustained impact is unlikely in any case.
Miller confirmed that the MOECC is issuing new guidelines in a few weeks to replace the 2008 Noise Guidelines. Among other things the revision includes a section on wind shear profiling and specific directions to ensure calculations are based on maximum output.
Dr. Craig R. MacRae, qualified as a hydrologist, has 32 years of professional experience in measurement and modeling of hydrologic systems, channel erosion, open channel flow hydraulics and sediment transport.
Dr. MacRae told the Tribunal that karst is an area of limestone characterized with crevices, fissures, sinkholes, and underground streams. Karst formation flows continuously throughout the Prince Edward County south shore, with different levels ranging from 2m up to 30m deep. He observed numerous karst features on his site visit of the White Pines project. Yet Stantec did not report the presence of karst and did not do any field work.
Dr. MacRae stated when karst is disturbed by construction, it is destroyed. The harm is irreversible and cannot be repaired. Underground water flows horizontally and the construction of the 16.7km access roads, cable trenches, excavations for wind turbine and crane pads, and upgrades to existing municipal roads all can damage and destroy the karst. Dr. MacRae also stated that trenching for the access roads and collector lines can drain the wetlands.
The damage is unpredictable and thus cannot be mitigated. A water management plan cannot be developed as flooding can occur in areas where there was none prior to construction. MacRae noted that the 20 culverts proposed along new access roads will not manage all the risk and more culverts would simply change the flooded areas. New access roads must be raised to allow for water flow ditches on both sides in order to prevent washouts.
Patrick Duffy, counsel for WPD, challenged Dr. MacRae in cross-examination, trying to show that there is no karst in the White Pines project area. He referenced high-level diagrams in public documents that show Prince Edward County has “unknown” karst. Dr. MacRae replied that these diagrams don’t tell the whole story and the documents describe characteristics on the south shore that are consistent with karst.
In Mr. Gillespie’s reply, Dr. MacRae identified many deficiencies in Stantec’s reports for the White Pines project. There was no field work, no methodology set out with established criteria, no physical measurements, and no topological mapping. Stream courses were insufficiently mapped, no high-water mark measurements were established, and the existing MNRF database is sorely lacking. Finally, Stantec did not identify three large sinkholes and 10 additional streams that Dr. MacCrae observed on his site visit.
ERT co-chair Hugh Wilkins asked Dr. MacRae to identify areas of concern. Dr. MacRae said that the areas of greatest risk are T1, T2 and T3 in the Black Creek Valley ANSI, T25 through T29 in the eastern portion of the township, and parts of Helmer Road and Babylon Road in the Provincially-Significant South Bay Coastal Wetland.