RE: Comments on Windlectric Draft Operations Plan - Windlectric proposed monitoring of Heritage Resources

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1 17 May 2017 Mr. Robert Maddocks CAO/ Acting Clerk Loyalist Township RE: Comments on Windlectric Draft Operations Plan - Windlectric proposed monitoring of Heritage Resources Dear Mr. Maddocks, Following are my comments on the inadequacies of the proposed monitoring for heritage resources as detailed in the latest version of the Draft Operations Plan. The most recent version of the Windlectric Operations Plan (May 2017) Section 2.13 Cultural Heritage Features states, The Project will comply with the requirements of condition M of the REA issued for the Project and provides Schedule 17 Cultural Heritage Monitoring Program which details Stantec s proposal for monitoring of Heritage Resources including Dry Stone Walls. Upon initial review, it is clear that the proposal, dated 20 December 2016 does not meet the requirements of REA conditions M1 through M7. It is important to note that one of the major concerns regarding the heritage resources is the damage that can result from vibrations resulting from construction activities, these vibrations can be generated by blasting, hoe ramming and according to Condition M of the REA include the transport by heavy vehicles of equipment and component parts necessary for the construction and installation of the project infrastructure. REA IDENTIFIED CULTURAL HERITAGE RESOURCES Condition M1 states The following cultural heritage resources have been identified: Built Heritage Resources: (1) 5170 Front Road (Neilson's General Store) (2) 5555 Front Road (Trinity United Church) (3) 2750 Front Road (4) 3190 Front Road structural integrity of narrowly set back structures and features, including the structures and vulnerable fixtures of the residence, outbuildings, the 1820's brick bake oven and dry stone fencing throughout the property (5) 3500 South Shore Road (6) 4125 South Shore Road (7) 3475 South Shore Road (8) 4725 Second Concession Road (9) 5950 Second Concession Road

2 2 Cultural Heritage Landscapes: (1) Village of Stella (2) Ferry landscape (3) 1652 Front Road (Pentland Cemetery) (4) 1995 Stella 40 Foot Road (St. Paul's Presbyterian Church) Dry Stone Walls Located at: (1) Emerald 40 Foot Road and Second Concession Road (2) 3190 Front Road (3) 3850 South Shore Road (4) 570 Front Road (5) 2400 Front Road (6) 2750 Front Road (7) Front Road (8) Front Road (9) Front Road (10) Front Road REA MANDATED PROTECTION FOR CULTURAL HERITAGE RESOURCES Conditions M2, M3 and M4 of the REA detail the protective measures that will be uniformly applied to all cultural heritage resources including Built Heritage Resources, Cultural Heritage Landscapes and Dry Stone Walls. M2. The Company shall use best efforts to not construct within 50 metres (m) of the cultural heritage resources identified above. M3. If construction is within 50 m of the cultural heritage resources identified above, the Company shall ensure that peak particle velocity (PPV) levels are within the acceptable levels that were established prior to construction in accordance with Condition M4. M4. Acceptable vibration levels (peak particle velocity [PPV] levels) shall be determined for each cultural heritage resource prior to the commencement of construction within the 50 m buffer zone surrounding the cultural heritage resource by a Qualified Independent Structural Engineer with previous experience working with built heritage under similar circumstances. Section 1.1 Monitoring Plan Development of the Stantec Monitoring Program Report provides the following information:

3 3 Section does not meet REA requirements the second paragraphs states This information and the condition assessment will be used to determine if the building requires instrumentation to monitor PPV or if a similar, possibly more sensitive, structure in the vicinity should be instrumented. The REA conditions do not allow for similar buildings in the vicinity of the cultural heritage resources to be monitored for PPV vibration. Contrary to section 1.1.1, the REA requires that the identified cultural heritage resources must be monitored as specified in the REA. Section does not meet REA requirements as this section states Where residential structures of conventional construction exist. we would undertake to monitor representative or sensitive structures not assigned a heritage designation. Condition M 1 identified the 4 cultural heritage landscapes as cultural heritage resources; therefore ALL structures (and not just residential structures) within these cultural heritage landscapes are cultural heritage resources. Further, conditions M2 through M7 make no mention of monitoring representative or sensitive structures. The REA stipulates that cultural heritage resources must be monitored; this means that contrary to the statements in section 1.1.1, every structure within the cultural heritage landscapes must be subject to PPV monitoring.

4 4 Section does not meet REA requirements as paragraphs 3 states, Accordingly it is unlikely that construction activity will result in vibrations within this range. In such case, visual monitoring of the dry stone walls would be carried out in accordance with M6 (1) through (3). Per Condition M1, the dry stone walls are considered cultural heritage resources, and M2, M3 and M4 which are conditions applicable to cultural heritage resources do not allow for visual monitoring. In order to comply with REA requirements conditions M6 (1) through (3) must be applied in addition to conditions M2, M3 and M4. Further, the final paragraph states Should the identified three stone walls be within 50m of construction, we propose to conduct baseline testing during peak large vehicle movement... To begin conditions M2, M3 and M4 make no reference to walls of poor condition but require that all dry stone walls within 50m of construction received PPV monitoring. Additionally the final paragraph states we propose to conduct baseline testing during peak large vehicle movement. This baseline monitoring will measure vibration In PPV under this extreme condition. We will use this as reference point for future monitoring practice. The REA makes no provisions for this proposed practice and quite simply requires ongoing PPV monitoring. Additionally, per condition M4 above, acceptable vibration levels will be determined by a Qualified Independent Structural Engineer with previous experience working with built heritage under similar circumstances. Looking at the team proposed by Stantec, there is no Qualified Independent Structural Engineer (QE) with the required experience listed. Therefore the

5 5 opinion of the QE listed in paragraph 3 above, must be re-evaluated by a QE meeting REA requirements. REA MONITORING REQUIREMENTS Condition M5 states Should, during ongoing monitoring by the Qualified Independent Structural Engineer, PPV levels be exceeded: (1) the Company shall cease construction activities within the 50 m buffer zone until an acceptable solution can be identified by the Qualified Independent Structural Engineer; (2) the Qualified Independent Structural Engineer prepares and signs a report with recommendations regarding the solution; and (3) the Company shall follow the recommendations and submit a copy of the Qualified Independent Structural Engineer's report to the District Manager. Section Vibration Monitoring Program of the Stantec of the Stantec Monitoring Program Report provides the following information:

6 6 The final paragraph in section seems to suggest that 3 seismograph units will be used for a 12 week period to monitor the Amherst Island Project. As REA condition M5 requires ongoing monitoring of all cultural heritage resources within 50m of construction activities, it is quite clear that 3 seismograph units are insufficient to achieve compliance with REA requirements. Further, the construction period is estimated to continue from 7 to 12 to 18 months (depending on the report referred to). Section Visual Monitoring of the Stantec of the Stantec Monitoring Program Report provides the following information: The conditions listed in the REA do not state that monitoring of the dry stone walls can default exclusively to visual monitoring under certain circumstances as stated in paragraph Nor does the REA state that monitoring can be conducted by Stantec site staff acting under the direct supervision of a heritage masonry professional. For these reasons section does not meet REA requirements.

7 7 Additionally, while the REA requires that PPV monitoring be undertaken, section 1.2 seems to indicate that an alternate method will be used. Mr. Maddocks, thank you for the opportunity to comment. Best Regards, Denise Wolfe APAI Board Member