C4CA Response to TransCanada Draft Environmental Assessment
April 28, 2010 Via Fax and Canada Post
To TransCanada Corporation’s Health and Safety Committee
Mr. E. Linn Draper - Chairman
Dr. Wendy K. Dobson
The Hon. Paule Gauthier
Mr. Kerry L. Hawkins
Mr. W. Thomas Stephens
The Citizens For Clean Air (C4CA) is a concerned group of residents from Oakville and
Mississauga opposed to the proposed location of TransCanada Energy Limited’s (TCEL) 975
megawatt natural gas fired power plant. We represent a broad cross-section of the Oakville and
Mississauga community including many, who like you, have served at senior corporate levels.
As members of TransCanada Corp’s Health, Safety and Environment Committee, you are
charged with responsibility for monitoring the health, safety, security and environmental
practices and procedures of TransCanada and its subsidiaries. We note, and support, the high
standards that TransCanada has set for itself, as stated in the Company’s 2009 Management
Discussion and Analysis “The Company is committed to being an industry leader in conducting
its business so that it meets or exceeds all applicable laws and regulations, and minimizes risk to
people and the environment.”
We are writing to you, however, to point out that the proposed Oakville Generating Station fails,
in our view, to meet the standards set forth in this statement of commitment, and exposes the
communities of Oakville and Mississauga to serious, and potentially catastrophic risks.
This power plant would be located 300 metres from a school, 400 metres from houses and
adjacent to high traffic rail lines carrying thousands of GO Train commuters and hazardous
materials. This location provides no buffer zone and no margin for error in the event of an
accident at the plant or to a high traffic rail line that is only 30 metres from the site.
We all know that risk management, safety or quality assurance systems can never provide
absolute assurance or protection from breakdowns or accidents - whether they are caused by
design defects, human error, technology malfunction, mechanical breakdowns or acts of God.
The unfortunate experience of the Toyota Motor Corporation, which had a world class reputation
for quality, proves this point. Sadly, we can also point to recent precedents - the tragic explosion
at a smaller natural gas fired power plant in Middletown, Connecticut, in February 2010 which
resulted in 6 fatalities and 26 injuries. There have also been train derailments in Pickering on
March 30, Oshawa on February 19, and, this month’s train derailment in Oakville.
TransCanada’s commitment to safety, and its track record, does not, and cannot, eliminate the
possibility of serious and potentially catastrophic accidents, nor does it eliminate the need for
prudence and establishing meaningful buffer zones as a precautionary measure.
Consider the following:
• The Kleen Energy natural gas fired power plant was a 600 megawatt plant located on a
137 acre site in Middletown, Connecticut.
• TCEL’s 600 megawatt natural gas fired plant in Halton Hills is on a 79 acre site, of
which 24 acres is used for the plant, with no residential communities or rail lines adjacent
or nearby this facility.
• The Oakville Generating Station which is 50 percent larger than either the Kleen Energy
plant or the Halton Hills plant, would be constructed on a 13.5 acre site which is 1/10th
the size of the Kleen Energy site and 1/2 the size occupied by the Halton Hills plant –
WITH NO BUFFER ZONE.
In our view, TCEL, TransCanada and its Board of Directors would be putting the health, safety
and security of the residents of Oakville and Mississauga, including school children, at serious
risk should this power plant proceed. In light of the lack of any reasonable buffer zone, we
expect there would be catastrophic consequences should there be an incident, such as an
explosion or train derailment. Knowingly taking on such risks could very well create very
significant liability exposures for TCEL, your senior executives and your board of directors, if
the construction of the power plant proceeds and a high impact, low probability risk, occurs.
The decision to build this huge power plant without any reasonable buffer zone has shocked our
community, frightened our citizens and is damaging TransCanada’s reputation. We have found
no evidence that a thorough assessment of health, safety and security risks was performed before
this contract was awarded to, and accepted by, TCEL. People in Oakville and Mississauga
constantly ask – why would anybody make a billion dollar investment to build a 975 megawatt
power plant on a 13.5 acre site in a residential community with no buffer zone and no assessment
of the health and safety risks to the community? The answer seems to lie in the statement made
by TransCanada’s CEO last November on the third quarter analyst call, when he said that:
“TransCanada expects to invest approximately $1.2 billion CAD in this natural gas-fired
combined cycle plant with an expected after tax unlevered internal rate of return of 9%.” The
people of Oakville and Mississauga have concluded that profits, not safety, are driving this
decision and TransCanada’s actions.
It has been suggested that community health and safety risks will be addressed in the
Environmental Review Report being completed by TCEL's management. Unfortunately, any
post contract assessment of community health, safety and environmental risks by TransCanada
lacks objectivity and credibility given the substantial financial rewards contained in this 20 year
contract and TCEL’s (and TransCanada's) continual statements of commitment to the project and
to using natural gas to replace coal fired power plants – and a process that involves no
consideration of alternatives.
Let me emphasize, again, that our communities strongly believe that this proposed power plant
threatens our health, safety and security. This is not a Not-In-My-Back-Yard (NIMBY) issue,
and it should not be viewed as such. Our opposition to the project is because of the health, safety
and security risks inherent in building a power plant at this location, not because it is natural gas
or the generation of electricity. Our concerns are shared and supported by the Mayors and elected
councils of Oakville and Mississauga, the regional government, Halton and Peel Chief Medical
Officers of Health, and our elected members of Parliament and the Ontario Legislature.
Last Thursday, members of all Ontario’s political parties voted in favour of the second reading of
Bill 8, “The Separation Distances for Natural Gas Power Plants Act, 2010, a Private Members
Bill” that was introduced by Oakville MPP Kevin Flynn. Bill 8 passed by a margin of 28 votes
to 1 with support from MPPs from all parties, including 15 Liberal MPPs. This bill would
prohibit the construction of a natural gas power plant within 1,500 metres of land zoned
residential or for a school, day nursery or health care facility. The following comments were
made in support of this Bill:
“Having observed the extensive review processes required by the State of Connecticut, the
federal government as well as our own local regulatory commissions, I would like to
encourage you to continue to insist on a careful, transparent and objective evaluation of all
of the issues involved in the siting of electric power generating plants. We were fortunate in
that the Kleen plant is located in a very remote and sparsely populated area of Middletown.”
- Sebastian N. Giuliano, Mayor, City of Middletown, Connecticut, U.S.A. comments on
proposed TransCanada facility in Oakville following the explosion at the Kleen Energy
natural gas power plant in his community
Bill 8’s proposed set back requirements are consistent with principles set forth in Ontario’s New
Rules for Renewable Energy that were implemented by the Ontario Government on September
24th, 2009. The regulations contain minimum setbacks for even a 50 kw wind turbine (almost
20,000 times smaller than the proposed gas plant) of 550 meters from sensitive receptors.
TransCanada’s 2008 Corporate Responsibility Report contains the corporation’s crucial set of
core values, one of which is - “We make safety a priority for ourselves, each other, our
contractors and for members of our communities.” In our view, it is not appropriate or
reasonable to propose a 975 megawatt gas-fired power plant on a 13.5 acre site, 320 metres from
a school and 400 metres from houses, where you could not even have a wind turbine. This is
clearly not making safety a priority for local communities and is contrary to TransCanada's
stated core values.
As Directors of TransCanada and as members of the Board’s Health, Safety and Environment
Committee you understand that you are tasked with some very specific responsibilities and we
pose the following questions:
1. Has your Committee fully examined, and are you prepared to personally accept, the
health and safety risks posed to thousands of people who live, work and go to school
within the immediate area that would most likely be impacted by this power plant if there
were an incident such as the one that occurred in Connecticut?
2. Does your Committee support a business practice of signing billion dollar investment
contracts before conducting a comprehensive risk assessment, including the health,
safety, security and environmental risks that will impact the communities in which your
investments will be located? How can a business practice that puts profits ahead of
safety satisfy the standards you have set for the corporation, and the corporate reputation
you strive to build?
3. Are you comfortable that, in the absence of a buffer zone, complete reliance and
responsibility will be placed on TCEL’s engineering and management practices, and the
oversight thereof, to protect the school children, businesses and other residents in the
adjacent community (i.e., there is no margin for error)?
4. Do you support the actions of TCEL’s management to overturn the Town of Oakville's
Interim Control By-law No. 2009-065? This by-law is simply to allow for the necessary
review prior to locating a power plant in our community, so that safety issues and
reasonable buffer zones can be addressed.
5. Can you really support building a 975 megawatt gas fired power plant on a site where the
building of a wind turbine would be prohibited – simply because there are no set back
requirements, as yet, for gas fired power plants? Does this really satisfy your standard
for meeting or exceeding all applicable laws and regulations?
In response to my letter of February 26, 2010 to Mr. Kvisle, your management replied that “We
continue to believe that our site is an excellent one for this clean energy project that supports the
Province’s initiative to phase out coal fired electricity generation.” We invite you to come to
Oakville and see for yourself just how wrong and misleading this statement is by touring the site
and the community adjacent to it.
We ask that you please take the time to reflect on this project, the risks you and TCEL are
assuming, and the risks you are forcing our communities to assume. And then encourage TCEL
management to work together with us to find a better, safer and healthier alternative.
Frank M. Clegg,
Chairman of the Board of Directors, C4CA
Board of Directors, TransCanada Corporation
The Hon. Dalton McGuinty, Premier of Ontario
The Hon. Brad Duguid, Minister of Energy and Infrastructure
The Hon. John Gerretsen, Minister of the Environment
The Hon. Deb Matthews, Minister of Health and Long Term Care
Colin Andersen, CEO, Ontario Power Authority
Rob Burton, Mayor of Oakville
Hazel McCallion, Mayor of Mississauga
Kevin Flynn, MPP, Oakville
Charles Sousa, MPP, Mississauga South
Ted Chudleigh, MPP, Halton
Dwight Duncan, MPP, Windsor-Tecumseh
Gary Carr, Chair, Region of Halton
Terence Young, MP, Oakville
John Baird, MP, Ottawa West-Nepean
The Honourable Gail Shea, Minister of Fisheries and Oceans
The Honourable Jim Prentice, Minister of the Environment
Wendy Tadros, Chair, Transportation Safety Board of Canada
What people are saying about Kevin Flynn’s BILL 8 –
An Act to Establish Separation Distances for Natural Gas Power Plants
“Having observed the extensive review processes required by the State of Connecticut, the federal government as well as our own local regulatory commissions, I would like to encourage you to continue to insist on a careful, transparent and objective evaluation of all of the issues involved in the siting of electric power generating plants. We were fortunate in that the Kleen plant is located in a very remote and sparsely populated area of Middletown.”
- Sebastian N. Giuliano, Mayor, City of Middletown, Connecticut, U.S.A. comments on proposed TransCanada facility in Oakville following the explosion at the Kleen natural gas power plant in his community
“I have had an opportunity to review MPP Kevin Flynn's proposed Bill 8 which addresses the very real and necessary need for our government to establish responsible guidelines with respect to the construction and development of natural gas power plants in our communities. The proposed bill identifies a gap in current regulations…this is a common sense measure worthy of all-party support.”
- Christine McGee, President, Sleep Country Canada
“A number of health studies have linked particulate matter (PM) 2.5, a major emission from natural gas power plants, to increased levels of cardio and respiratory diseases such as asthma and bronchitis and various forms of heart disease. Due to these detrimental health effects, I am supportive of proposed legislation that mandates a 1500 metre separation distance between natural gas power plants and residential communities.”
- Dr. Thomas Stewart, Director of Critical Care Medicine, University Health Network
“Amazingly, there is no regulation in Ontario that requires a buffer zone between gas-fired power plants and people. Mr. Flynn’s bill seeks to correct this problem by mandating a 1500 metre buffer between gas-fired power plants and the communities they serve – so every community in Ontario will be protected.”
- Frank M. Clegg, Chairman of Navantis Inc. and former President of Microsoft Canada
"MPP Kevin Flynn's private member bill provides Ontario with a unique opportunity to re-evaluate the suitability of large-scale polluting plants in our residential communities and to discuss the merits of smaller community projects such as combined heat & power projects which could be financed through expanded feed-in tariffs and district heating policies which will help enhance Ontario's position as a North American leader in green energy initiatives."
- Jose Etcheverry, Assistant Professor, Faculty of Environmental Studies, York University
“When I have a power plant that is going to be located 300 metres from a school, I have to believe that while my kids don’t go to that particular school, I have to conduct myself as though my kids were going to that school as well. I want to say to my government that I cheer for you and I want you to make great decisions…300 metres from a school doesn’t seem to be a great decision.”
- Mike “Pinball” Clemons, Toronto Argonauts Executive in speech to rally outside Ontario Legislature, March 2, 2010
“MPP Flynn has proposed legislation to mitigate the impact of natural gas power plants by introducing legislation that will create a 1.5 kilometre buffer zone. I think this approach meets the health and safety needs of communities and the energy needs of Ontario”
- Pierre L. Morrisette, Chairman & CEO, Permolex Media Inc. and The Weather Network
“I fully support this bill. A minimum distance of 1500 metres seems reasonable to help to minimize local negative human health impacts as well as to maintain reasonable quality of life for those working and living within close vicinity of the proposed power plant.”
- Madhur Anand, Associate Professor & Canada Research Chair, Department of Environmental Studies, University of Guelph
"Sensitive approaches to balancing the needs of industrial, commercial, service and residential needs have been the goal of municipal and community leaders over many years…for reasons of safety, aesthetics, and by way of setting a good example for the future growth of Ontario I am fully supportive of the Private Members Bill and in agreement with the a 1.5 kilometre setback.”
- Alastair Wilson, Senior Technical Advisor, Gemini Power Corporation
"There are 16 schools and 5,000 homes within two kilometres of the proposed TransCanada site. You cannot install a wind turbine at this location because, due to recent provincial regulation, it is too close to homes, schools and businesses. It is time for the provincial government to recognize the health and safety concerns of these facilities and legislate appropriate setback requirements."
- Steve Mueller, President, Canada Power Products
“In the construction field, we place safety above and beyond all other faucets of our organization. We adhere to the strict provincial labour laws and are proud to have an impeccable record. My main concern is the lack of vision by the government in regard to public safety in the TransCanada project in Oakville. How can the government support the construction of a power plant in such close proximity to both schools and residences?”
- Scott Bachly, President, Bachly Construction
“I am very supportive of your Bill and believe that what you are proposing is just common sense as there are serious health and safety issues about locating natural gas power plants in communities.”
- Paul Lucas, President, GlaxoSmithKline
“We fully support good community planning with appropriate separation of residential neighborhoods from massive power plants. There is no reason to expose families to serious health risks by building such facilities in such close proximity to existing neighbourhoods - where families now occupy homes and children attend schools.”
- Peter E. Gilgan, CEO of Mattamy Homes
Click on the link to view the letter.
Letters from Politicians
Letters from Concerned Citizens to Various Politicians and Interested Parties
Letters from Concerned Citizens to the Editor of the Toronto Star
In the January 27th Toronto Star editorial entitled "Power Plant Perspective," the editors demonstrated a naive perspective of the TransCanada power plant issue. The Toronto Star's perspective is: "modern gas powered stations produce few emissions"....and why would residents be concerned when the power plants will " be operating less than 10 per cent of the time." Click here to read the editorial.
Click on the links below to read some letters that concerned citizens of the Oakville-Clarkson Airshed have written to the editor of the Toronto Star in response to the "Power Plant Perspective" editorial.
Toronto Star Opinion Column: "MPP Kevin Flynn takes on Oakville gas plant"
Excerpt: "Kevin Flynn is not a ghoul. Not at all. Even so, the Liberal MPP from Oakville is as interested lately in industrial calamity as storm-chasers are in tornados." Click here to read more.
This column gives us the opening to fire in letters to the editor in support of Flynn's Bill making our key points about safety, proximity and the fact that this site wasn't even TransCanada's first choice. This plus a line saying something like it's not too late for the Premier to change his mind and take a sober second look, find a better location, would make an ideal letter to the editor. The shorter and pithier the better the chance it will be printed. Include a phone number as the paper will contact you for permission to print your letter (even though you submit it, they seek verification you are the author).
Repetition of the following messages would be helpful:
- - This location makes no sense for a 945-megawatt gas-fired energy plant.
- It’s too close. The nearest office building is less than 65 metres away.
- This wasn't even TransCanada's first choice for a location. So why was it chosen?
- There isn’t enough space. The Oakville location is less than 15 acres or 1/10th the size of the Middletown site, yet the proposed OGS plant is 50% larger. The impact of an accidental explosion or train derailment would be devastating.
-It sets a bad precedent. No other plant has this kind of density within one kilometre. Existing plants all have buffer zones of 1.25 km (Toronto – Portlands Energy Centre) or greater.
- It’s bad for our children’s health. A gas plant is a fossil fuel burning plant that will emit thousands of tons of toxins into a region with the highest youth asthma rates in the province.
- The air shed is already over-polluted. Federal and provincial environment studies show that the community's air is already dangerously over polluted.
- It affects the whole community. Within less than 3 km are five senior citizens retirement homes, eight day care and early learning centres, Oakville Trafalgar Memorial Hospital and the Town Hall.
-There is no rush to proceed. Independent Electricity System Operator (IESO) forecasts say there is ample existing power capacity for the next several years.
- Mr. Premier, there is widespread opposition to this plant from all levels of government and organizations across the region. You still have time to do the right thing.
Toronto Star Op Ed by Doug MacKenzie: "Why is Oakville's new power plant so close to residents? "
Excerpt: "The site chosen for the proposed new Oakville gas power plant raises questions that should concern all Ontarians." Click here to read the entire article.
Click on the links to read the responses Re: "Why is Oakville's New Power Plant so Close to Residents?"
Gas Plant Risks Are Unacceptable- Alan Willis of Mississauga
Conservation Should Come First- Peter Tabuns, Energy and Environment Critic, Ontario NDP, Queen's Park
Letters from Concerned Citizens Posted in the Oakville Beaver
Letter to the Editor of the The Hamilton Spectator