Why was an amendment to the approval needed for a 15-year-old industrial wind power site? Who is in charge here?

August 31, 2026

Who is hiding what about a northern Ontario wind power site? And, why now?

In mid-July, a notice was posted on the Environmental Registry of Ontario (ERO) in the Ministry of Environment, Conservation and Parks (MECP) with a request to amend the approval for the Greenwich Wind Farm industrial wind power site in Dorion Township. The request was related to “noise.”

The 99-megawatt Greenwich Wind site has been operating since 2011, and is owned by Enbridge and RES Canada. The project has 43 2.3-MW Siemens wind turbines and two transformer substations.

The Proposal was described as:

Proposal summary

This proposal is to amend the Environmental Compliance Approval (noise) No. 2070-7WJKDH for Greenwich Windfarm GP Inc. for the wind farm operation in the Township of Dorion, Ontario.

No other details were provided, and a click on “Supporting Materials” got the message that the relevant documents were not available online.

The comment period closed on August 30. During that period however, Wind Concerns Ontario conducted research into this request, and provided a comment to the ERO on August 29. The full comment is not posted publicly on the Registry yet, but we provide some highlights here.

The process

If the ERO thought posting a scant notice would discourage people they made a mistake: we instantly were concerned about why there were almost no details about this request.

Our comments:

The Notice Does Not Provide Basic Factual Information

• The Notice says the amendment is to reflect the “as-built substation transformer locations” but does not show the approved locations, the as-built locations, or explain the difference between them.  The public is therefore being consulted on an amendment whose stated purpose is to reflect the “as-built substation transformer locations” without knowing where those transformers are located.

The Notice Does Not Provide Access to Materials Relating in the Most Fundamental Way to the Proposal such as pdf files and/or links to materials  

• The Notice does not provide access to the existing Environmental Certificate of Approval, to the amendment application, to a site plan showing the approved and as-built transformer locations or to supporting technical reports such as a noise assessment.  In fact, the Notice assumes (wrongly) that the amendment is self-explanatory.

The Notice Does Not Explain the Purpose of Public Consultation

• The Government of Ontario describes the Environmental Registry as the place where Ontarians can participate in provincial decision-making that may affect the environment. In regards to ERO #026-0734, the public is being asked to comment on information it has not been given.  At minimum, an application for an amendment to reflect the “as built substation transformer locations” must address whether the relocation changes distances to receptors or otherwise affects the noise impacts upon which the original approval was based.  

The Notice Does Not Meet the Most Basic Requirements for Meaningful Public Consultation

• The Notice is so vague that the public cannot determine what, precisely, MECP is being asked to approve. Is this merely a technical amendment to replace the approved transformer coordinates with the as-built coordinates? Or does approval necessarily include formal acceptance of the updated Noise Impact Assessment (2026) and other supporting project documentation that the public has never seen? The Notice does not say.
• The Notice does not identify or address the environmental implications of this change.  The Notice almost appears to be intentionally vague in this respect.  Indeed, under “Supporting materials”,  there are no online supporting materials at all; the public is simply told that “[s]ome supporting materials may not be available online” and to contact the Ministry to find out whether they can be viewed in person at its Toronto office at 40 St. Clair Avenue West.  

This is not a reasonable substitute for making the relevant documents available through the Environmental Registry, particularly for an application concerning a wind energy facility located in the Township of Dorion in northwestern Ontario. The approach taken by the MECP effectively places members of the public who do not live in Toronto at a significant disadvantage.

Is this really public engagement?

A theoretical opportunity to submit a comment is not meaningful public participation if the Ministry withholds from the Registry the information necessary to understand and evaluate what is being proposed.  The public cannot tell from the posting how the as-built locations differ from what was approved, why they differ, when that occurred, or whether the environmental consequences of the change were assessed before construction. The Ministry is asking the public to comment retrospectively on an as-built deviation from an existing environmental approval but has not even disclosed what that deviation is.

No supporting documents

We were able to obtain from environment ministry staff a copy of a noise assessment report, done by Dillon Consulting May, 2026.

As this was not available as part of the ERO posting, the general public and the residents and property owners in Dorion, may not be aware that it exists. The Greenwich Wind Farm has no public website where documents and updates can be viewed.

Our comment:

It appears that MECP has chosen to consult under the Environmental Registry on an amendment whose technical justification entirely rests on the May 2026 Noise Impact Assessment (NIA).  Yet — and most alarmingly —  the MECP failed to provide this key supporting document to the public.

(A word about that: the Dillon report is an embarrassment: rife with spelling and grammar errors, it appears to be a “cut-and-paste” job, and is a predictive modelling exercise rather than a current acoustic analysis—as far as we can tell.)

What we don’t know

A 2014 article in the media indicates there was a major transformer malfunction at Greenwich Windfarm that year – one of its two main step-up transformers (T2) tripped offline.  Apparently, the transformer was shipped to South Korea for repairs before returning to service in August 2014.   Was T2 repaired and returned to service, or was it replaced? If repaired, were its acoustic emissions measured or otherwise verified following the repair? If replaced, is the transformer presently identified as TR_2 in the May 2026 NIA the same make, model and acoustic specification as the transformer assessed under the original 2009 Acoustic Assessment?  What evidence establishes that its present acoustic emissions are appropriately represented by the same calculated sound-power characteristics assigned to TR_1? 

Was T2 reinstalled in exactly the same location after its return from South Korea in 2014?  We’re trying to understand why MECP is suddenly amending the ECA to reflect the “as-built substation transformer locations”   15 years after the wind project went into commercial operation.   

At present, we don’t know whether the location discrepancy dates from original construction in 2011or whether something changed when T2 was removed and reinstalled in 2014.  Was either transformer (or both) relocated, repositioned, replaced, reconstructed or otherwise installed at a different location following the 2014 failure and repair of Transformer T2? If so, is that change part of the “as-built substation transformer locations” now being corrected via ERO #026-0734? 

Should not the environment ministry been aware of this before now, or do wind power operators have free rein to carry out whatever they want, whenever they want?

The Dillon Noise Impact Assessment (2026) makes no mention of a malfunctioning transformer or what ensued.  Given this, the MECP would be quite justified in requesting the location history of both transformers from the Applicant: the approved 2009 coordinates; original 2011 as-built coordinates; coordinates before the 2014 T2 failure; coordinates after T2 was returned to service; and current coordinates.  At the very least this information could reveal whether the repaired unit has exactly the same acoustic characteristics as the original unit assumed in the modelling, which is never explained in the Noise Impact Assessment.  

Release the documents

We ask, why is the MECP  inviting public consultation on  this  amendment to the ECA (Environmental Compliance Approval), while keeping key supporting documents for the amendment under wraps and to all appearances as far away from public view as possible.  And the Dillon noise report is most definitely a key report: it expressly says that this Report replaces the September 2009 Acoustic Assessment.    

Meaningful consultation on the ECA amendment requires public access to the Noise Impact Assessment: this Assessment should have been made readily available to members of the public as part of the ERO consultation.  Simply put, the public cannot meaningfully evaluate whether changing these transformer locations is environmentally acceptable without seeing report(s) that purport to demonstrate compliance.

It is worth repeating that posting a proposal on the Environmental Registry is not, by itself, meaningful public consultation. The information necessary to understand and evaluate the proposal must be included in the posting or be reasonably accessible. ERO #026-0734 falls well short of that standard.

Last,  ERO consultation should not require a member of the public to spend over a month making telephone calls and sending emails simply to obtain the application and the principal technical study—and then only to find that those documents do not clearly disclose the changes, and the reasons for those changes, for which retrospective approval is being sought.

What the ERO Notice should include

The Ministry should therefore make the complete amendment application and all relevant supporting materials available electronically through the ERO posting including at minimum:

• the existing Environmental Compliance Approval No. 2070-7WJKDH;
• the application to amend that approval;
• plans clearly showing both the approved and as-built transformer locations;
• the distances between the approved and as-built locations and nearby noise-sensitive receptors;
• any acoustic/noise assessment submitted in support of the amendment;
• any Ministry technical review of the proposed amendment; and
• any other documentation relied upon to determine the environmental significance and acceptability of the as-built locations of the transformers and substation.

The comment period should then be extended sufficiently to allow members of the public to review those materials and provide informed comments.

contact@windconcernsontario.ca

Screenshot excerpt from the Dillon Consulting Report (redacted). The changes in font are suggestive of a “cut and paste” report.