Losses to citizens, damage to environment not calculated
Turbine close to home in North Stormont last week: too close [Posted on Facebook Stop Wind Turbines in North Stormont]
December 20, 2019
OTTAWA— EDPR, the Portugal-based renewable power development company building the Nation Rise wind power facility in North Stormont for new owner Axium Infrastructure, is claiming losses of more than $200 million following the revocation of the Renewable Energy Approval by Ontario environment minister Jeff Yurek, last week.
The minister cited the potential for harm to wildlife in the area from the 29-turbine power project, specifically “localized harm to an already small bat population.”
The minister said further in a letter to the Concerned Citizens of North Stormont, the community group that had appealed the power project, that he was required “to balance several things in my considerations of the public interest, including the benefits of renewable energy against the harm to bats, the impact of the project on the community, and the need for the electricity from the project.”
He concluded that, on balance, the project wasn’t needed, and posed too great a risk to wildlife.
The power developer responded demanding a stay to the minister’s decision and was due in court today in Toronto to argue that; meanwhile, the Independent Electricity System Operator (IESO) has extended the project Commercial Operation Date so that Nation Rise will not be in violation of its contract before the judicial review also requested by the developer is heard.
In the meantime, construction has halted.
Quoted in a news release put out by Wind Concerns Ontario*, the chair of the Concerned Citizens of North Stormont Margaret Benke said the power project had been a very divisive issue for the community, and she hoped North Stormont could again be a “good place to grow.”
The power developer however is claiming millions in losses if the project is halted, according to a report today in the National Observer. EDPR claims it has put more than $200 million into the project to date, although fewer than 10 of the 29 turbines are actually built.
The project could have cost Ontario electricity customers as much as $400 million over its 20-year contract. Property value loss could also have been significant for people forced to live beside the 29 50-storey wind turbines.
Also in the National Observer article, Wind Concerns Ontario president and Ottawa Wind Concerns chair Jane Wilson pointed out that citizen concerns about the project were not personal but environmental in nature. The appeal brought forward by the community group dealt with wildlife, health and safety, and potential damage to the water table in an area designated as a “fragile aquifer” by the province.
“There has never been a cost-benefit analysis or impact study done for Ontario’s wind power program,” Wilson says.
The Concerned Citizens of North Stormont spent about $100,000 to launch their appeal and various legal actions against the power project.
To donate toward legal fees, please send a cheque to Concerned Citizens of North Stormont, 14950 County Road 9, Berwick ON K0C 1G0.
*Both CCNS and Ottawa Wind Concerns are members of the community group coalition, Wind Concerns Ontario.
Crane used to dismantle grid-scale wind turbine in Prince Edward County this week. Meanwhile, more going up south of Ottawa [Photo: Alliance to Protect Prince Edward County]
Contrast between North Stormont and Prince Edward County an indication of Ontario’s muddled electricity file
November 19, 2019
While people in Prince Edward County are celebrating the demise of the “White Pines” wind power project as government-ordered decommissioning of the industrial-scale wind turbines is going on this week, the people of North Stormont, south-east of Ottawa, are watching the behemoths go UP.
The White Pines project in Prince Edward County, developed by Germany-based wpd, was a controversial power project appealed several times by residents concerned about the environmental impact of the wind power generators and infrastructure on wildlife and people. The original plan was for 29 turbines; that was reduced to 27 after legal action and finally, to nine.
The new Ontario government passed legislation not long after taking office cancelling the power project — residents say it should never have been approved in the first place.
But now, more than 30 giant grid-scale wind turbines are currently being erected in North Stormont, near the communities of Finch, Crysler and Berwick by Portugal-based power developer EDPR. EDPR sold the project last year to Axium Infrastructure; that consortium also owns the K2 Wind power project in Huron County, which has been the subject of appeals, and post-operation, hundreds of noise complaints.
K2 Wind is currently under order by the Director of the environment ministry to implement and evaluate a noise assessment plan for more than 80 of its 140 turbines, which were found to be out of compliance with Ontario regulations for wind turbine noise emissions.
“Nation Rise” as the North Stormont project is called, was also the subject of appeals, and a last appeal was submitted to the Ontario environment minister six months ago. No word on the status of the appeal, nor on the status of a request for a stay of construction, filed in May.
Residents are concerned not only about noise (the project got to use old, pre-2017 noise assessment rules under the Wynne government), and also damage to the environment, especially a fragile or “vulnerable” water table.
The Nation Rise final approval came through days before the provincial election in 2018, despite the “caretaker” government convention which discourages major decisions during the election period. The Independent Electricity System Operator (IESO) also granted a Notice To Proceed days after the election, despite being warned by government leader MPP Todd Smith not to approve any more projects.
Now, the giant towers are rising in the quiet communities of North Stormont, as the power developer races to meet a December operational deadline. The local MPP Jim McDonell claims there’s nothing he can do about it—that Notice To Proceed meant the project had to go ahead.
Pre-construction liability for Nation Rise (i.e., the cost of the government cancelling the contract) was about $400,000. If it goes into operation, the people of Ontario will bear the cost of the project which will add more than $400 million to electricity bills, over the 20-year life of the power contract.
So, while the turbines go up, others — already approved and built — come down. And you’re paying for it all.
OTTAWA WIND CONCERNS
Turbine blades at Johnstown, destined for Nation Rise
Turbine components waiting for delivery to Nation Rise wind power project. Another $450 million to go on your hydro bill. [Photo: Leanne Baldwin]*
October 24, 2019
Ontario Premier Doug Ford gave his first interview after the federal election today, with host Bill Carroll on Ottawa talk radio CFRA.
The topic was how Ford could work with Prime Minister Justin Trudeau after an acrimonious election campaign in which Ford was repeatedly used as an example of Conservative government dedicated to budget cuts, but the conversation included the cost of electricity in Ontario, and why hydro bills are set to go up next week, when the Ford government had promised to get them down.
“[The electricity file] has been very frustrating,” Ford told Bill Carroll. He put some of the blame on the McGuinty-Wynne governments which cut lucrative deals for wind and solar with “cronies” Ford said, and Ontarians are now stuck paying above-market rates for electricity.
“We’re trying to get a handle on it,” he said.
Meanwhile, despite a citizen appeal that cost the people of North Stormont, south of Ottawa, about $100,000 in legal fees as they brought forward numerous, serious concerns about the impact of grid-scale wind turbines on people and the environment, the 100-megawatt Nation Rise wind power project is under construction.
It will cost Ontario electricity customers more than $450 million over its 20-year contract.
And, in Chatham-Kent, another wind power project is being built: Romney Wind is being built by EDF of France. That will add over $250 million to electricity bills.
“If you set out to destroy the electricity file in Ontario, you could not have done a better job than they[McGuinty and Wynne] did,” Ford said.
*Note the pickup truck in the lower left corner of the photo—an idea of the scale of the wind turbines
Despite a full appeal of the Nation Rise wind power project by community group Concerned Citizens of North Stormont, which raised serious issues of concern about human health and the environment, and despite a final appeal and request for a Stay of construction, the 100-megawatt wind power project is under construction in the Finch, Berwick, and Crysler areas.
Construction updates are to be provided by the developer EDPR on its website here
There have already been citizen complaints about dust and noise during construction, as well as a couple of mishaps with trucks and trailers delivering turbine components, and citizens have reported concerns about road safety.
EDPR at its construction update meeting in Finch last week said anyone concerned about safety, or who notices a worksite where there are no flagmen, should contact the company at: Email: firstname.lastname@example.org Phone: (613) 240-0348
The Ottawa Citizen recently ran an article by Kelly Egan which outlined community concerns. Ontario does not need more intermittent or variable wind power, which is produced out of phase with demand (source Auditor General Ontario). The Nation Rise project will cost Ontario electricity customers $450 million over its 20-year contract.
The medical report supporting Ontario’s wind turbine noise regulations is now 10 years old–the regulations need to be updated
Ottawa Wind Concerns executive members Jane Wilson and Michael Baggott spoke at the meeting of the Ottawa Agricultural and Rural Affairs Committee (ARAC) today, and alerted the Committee that action is needed following new amendments to regulations on wind turbines by the Ford government.
A wind power project was proposed in 2008 for the North Gower-Richmond area, with potential to spread to Osgoode. The project did not proceed when the Germany-based proponent failed to qualify for the last round of proposals under the Wynne government. It would have exposed hundreds of people to wind power generator noise — that fact was acknowledged at the time by the power developer.
“Today, we know a lot more about wind power,” said Ottawa Wind Concerns Chair Jane Wilson. “We know that many wind turbines in Ontario were sited improperly and we know that many mistakes were made — the former Energy Minister said that in 2017. And, we know there are thousands of records of noise complaints in Ontario, that have not been resolved, and are waiting on enforcement of regulations.”
Now, the new Ontario government is making changes but they require action from Ontario municipalities. Four new amendments to regulations are in response to Ontario municipalities demanding a return of local land-use planning powers, which were stripped from municipalities by the McGuinty government and the Green Energy Act.
“The amendments have not been proclaimed yet,” Wilson said, “but we need to be ready in the event a wind power proposal is made in future.”
One of the proposals is that power developers must balance any environmental impacts against the benefit of their proposed power project. “The problem is,” Wilson told the Committee, “Ontario’s rules on wind turbine noise and setbacks for safety are inadequate and out of date. The supporting document the previous government used is now ten years old, and does not reflect practices in other countries around the world.”
She added that the Ontario regulations on noise do not meet new guidelines published last fall by the World Health Organization.
“You have to remember that wind turbines produce a range of noise emissions— it’s not like barking dogs, or traffic.”
The amended regulations also require power developers to prove their project meets all zoning regulations locally. This is a problem, Wilson said, because under the Green Energy Act, municipalities had no say, so there was no reason for them to have any such zoning or bylaws as would apply to the huge wind power projects.
Ottawa Wind Concerns referred to a comment document prepared by Wind Concerns Ontario, which recommended municipalities ask the Ford government for a transition period in which they could begin the work on bylaws, and to develop new, adequate rules for setbacks between homes and turbines, and new noise limits for wind turbines.
Ottawa has already shown leadership Wilson said, in passing a bylaw asking for “substantive” input to wind turbine projects, and now is the time to take action to protect residents from the industrial-scale wind power projects.
Councillor Scott Moffatt thanked the presenters for the information, and also Wind Concerns Ontario for its work to protect rural communities.
Several North Gower residents attended the meeting.
Wind power lobby cajoles Ontario to ignore all the problems and take another chance on invasive, problem-ridden wind turbines.
April 2, 2019
Canada’s lobbyist and trade association for the wind power development industry, the Canadian Wind Energy Association (CanWEA), has just launched its campaign to make the Ontario government reconsider its position on wind power.
On Sunday, March 31st, CanWEA published a blog post entitled “Why wind energy is Ontario’s best option for new electricity supply.”
Ontario director Brandy Gianetta then lists five points.
Not a single one of them is true.
But here’s what is true:
Wind doesn’t work.
Everyone wants the best for the environment, and we all want “clean” electricity, but here’s what we know about the giant wind experiment in Ontario over its 13-year history:
Industrial-scale wind turbines have a high impact on the environment for no benefit
Wind power never replaced any form of power generation: coal was replaced by nuclear and natural gas
Wind power is intermittent, and produced out-of-phase with demand in Ontario; the Coalition for Clean & Reliable Energy notes that almost 70% of wind power is wasted in Ontario … but we have to pay for it anyway.
Wind is not “low-cost”; claims of 3.7 cents per kWh prices from Alberta ignore government subsidies. Wind power contracts are a significant factor in Ontario’s high electricity bills, and the trend to “energy poverty.”
Wind power has had multiple negative impacts in Ontario, including thousands of complaints of excessive noise reported to government. These have not been resolved, and many power projects may be out of compliance with their approvals; enforcement of the regulations is needed.
The promised jobs bonanza never happened.
In fact, a cost-benefit/impact analysis was never done for Ontario’s wind power program, according to two Auditors General.
Ontario doesn’t need more power now says the Independent Electricity System Operator (IESO), but if we did, why choose an intermittent, unreliable source of power that has so many negative side effects?
How the wind power industry made a fool out of Ontario
Noise complaints unanswered, wells contaminated, a huge job ahead to unwind the damage
April 1, 2019
It’s now almost a decade since Ontario passed the Green Energy and Green Economy Act, which opened the door to industrial-scale wind power developments throughout the province, and heralded ten years of environmental impact … for nothing.
In fact, the province had already approved a gigantic wind power project in Melancthon, and racked up hundreds of noise complaints before the Green Energy Act was passed — the government went ahead anyway.
Today, we have high electricity bills which are harming ordinary families and discouraging business investment; the government has records of thousands of complaints about wind turbine noise and vibration (mostly unresolved); there are 40 or more families in Chatham-Kent who trace the failure of their water wells to construction and operation of wind turbines on a fragile aquifer there; and, we are seeing the environmental impacts that were brought forward in citizen appeals of Renewable Energy Approvals now becoming reality.
Ontario citizens spent close to $10 million in after-tax dollars to protect their communities from the onslaught of large-scale wind power, according to a survey Wind Concerns Ontario did of our coalition members.
The Ontario wind power disaster should not have been a surprise.
Auditor General Jim McCarty chastised the McGuinty government for never having done a cost-benefit or impact study on the wind power program; subsequently, current Auditor General Bonnie Lysyk estimated that Ontario electricity customers overpaid for renewable energy by $9.2 billion.
Guaranteed to fail
The program to encourage large-scale wind power (the province had a choice back in 2004 onwards to go for small-scale power generation–that’s not what they chose, guided by wind lobbyists) was based on ideology and was criticized by such informed analysts as Michael Trebilcock, who said “This combination of irresponsibility and venality has produced a lethal brew of policies.”
Economics professor Ross McKitrick predicted, “If the goal [of the Green Energy Act] was to promote industry and create jobs, it is guaranteed to fail.”
And Tom Adams, who said, “Urban Ontario, including city-bound journalists, are largely unaware of the corrosive effects some wind developments are having on communities, neighbourhoods, even families. This is expropriation without compensation.”
The jobs never materialized, electricity bills went up, a new phrase “energy poverty” was coined, businesses closed or left, and families were forced to leave their homes because of unbearable noise.
Noise complaints are so prevalent in Huron County that the health unit launched a follow-up study (results will be published later this year). Preliminary data showed that 60% of the people participating in the follow-up were experiencing problems because of wind turbine noise.
Wind Concerns Ontario presented the government’s own noise complaint data as evidence at the appeal of the Nation Rise power project last summer; the approval was upheld regardless of citizen concerns about noise, and damage to a provincially designated “highly vulnerable aquifer.”
Meanwhile, reports of noise are investigated on behalf of the wind power operators by the same companies who prepared the original noise impact assessments for them; one such acoustics firm even boasts that it created the government’s noise assessment protocol.
The fox is not only in the hen house, he built it to ensure easy access.
As Ontario’s new government struggles with all this (Energy Minister Greg Rickford told the Legislature last week that this is a “very difficult” file), there is little to laugh about in Ontario today as the spring winds blow, and families face more sleepless nights.
Citizens thought this power project was gone. Is it? [Photo: Ontario Farmer]
March 6, 2018
Citizens of The Nation are waiting for answers from the Ford government after it was discovered — by accident — that the Ontario Energy Board awarded a 20-year licence to generate electricity to the Eastern Fields wind power project.
Eastern Fields was on the list of 758 power projects cancelled by the Ford government last July, and a check with the Independent Electricity System Operator (IESO) shows that the power developer, U.K.-based RES Canada does not now have a contract.
On the other hand, when both Wind Concerns and community group Save The Nation checked with a Ministry of the Environment, Conservation and Parks officer on the project status, the response was that it is in “technical review.” (This is an onerous process by which civil servants look at boxes on an application and see whether there is a check mark. Important information such as the presence of unstable Leda Clay in the case of the Nation Rise project, need not be assessed, or even known.)
Save The Nation put out the following news release, and is waiting for answers from the Ontario Minister of Energy, Greg Rickford.
In the meantime, says Wind Concerns Ontario president Jane Wilson, the citizens of The Nation lost seven valuable months in which they could have been gathering data on environmental impacts from the wind turbines. Wind Concerns Ontario has government records of thousands of reports about excessive wind turbine noise, which have not been resolved.
For immediate release
How Can a Cancelled Wind Turbine Project Receive a Licence to Produce Electricity?
ST-BERNARDIN – Save The Nation is seeking answers from the Ontario Minister of Energy, Greg Rickford, regarding the issuance of an Electricity Generation Licence to the ‘cancelled’ Eastern Fields industrial wind turbine project. The Ontario Energy Board issued the licence on December 6, 2018, even though Minister Rickford had announced the cancellation of Eastern Fields project on July 13, 2018.
“We were shocked to find out about this licence. We do not understand why or how a cancelled project can be issued a licence to produce electricity for a period of 20 years – until 2038. We’re also extremely disappointed that the Ford government does not seem to follow through with its announcement,” says Julie Leroux, spokesperson for Save The Nation.
Eastern Fields was one of 758 projects identified by Minister Rickford for wind-down on July 13, 2018, following a promise to cancel unnecessary and wasteful energy projects in order to cut hydro rates. “We’re asking Minister Rickford to confirm that this promise has been kept and that Eastern Fields Wind Farm LP is a dead project with no chance of ever moving forward. We also ask him to revoke the useless Electricity Generation Licence EG-2018-0213” adds Leroux.
The Electricity Generation Licence was issued on December 6, 2018. Incidentally, on that same day, the Ontario Government adopted the Green Energy Repeal Act, which will affect other acts and regulations, namely the Environmental Protection Act, the Renewable Energy Approvals Regulation 359/09 and the Planning Act when fully enacted.
Save The Nation is a grass-root movement that has been opposing the Eastern Fields industrial wind turbine project near St-Bernardin in The Nation Municipality and Champlain Township since it was publicly announced in June 2015. Save The Nation is not against green initiatives, but is fiercely opposed to the process that was used for the approval of renewable energy projects in Ontario under the Green Energy Act.
Power that could be produced “like a fly on the flank of an elephant” says energy watcher Parker Gallant
February 4, 2019
Last week, a news article appeared in the Nation Valley News reporting the local Conservative MPP, Jim McDonell’s response to a question asking on why the government hasn’t cancelled the 100-MW Nation Rise wind power project. Mr. McDonell said, “We’ve always been clear: We would cancel any project we could cancel economically,” and he added “… we just can’t spend a billion dollars to cancel a project and get nothing from it.”
The same day, a press release from the Ford government noted that Premier Doug Ford told people attending the annual Rural Ontario Municipal Association (ROMA) conference, that “We’re lowering electricity costs”.
I am at a loss to explain Mr. McDonell’s suggestion that cancellation of the Nation Rise IWT project would cost the same as the McGuinty/Wynne gas plant moves, but that’s what he said. It’s worth a look back at how this power project came into being, as it illustrates the disaster that has been Ontario energy policy for the last 15 years.
The Nation Rise wind project was one of five awarded contracts in March 2016; after that, its history gets really interesting … and very political.
Cost of the project
The Independent Electricity System Operator (IESO) at that time noted the average price for all the projects proposed was $85.90/MWh (or 8.5 cents per kWh). Over 20 years that would produce revenue of about $450 million, or less if their bid was lower than the average.
If the project were cancelled, no court would award them the full contract amount; it is more likely the government would be on the hook for perhaps 5 to10 % of that amount (on the high side).
There is no doubt that cancelling this project would save Ontario citizens hundreds of millions.
Timing of the approval
According to the Environmental Registry the Nation Rise entry for the Renewable Energy Approval or REA is dated May 7, 2018 and indicates it was loaded to the registry May 4, 2018. That is just four days before the writ was drawn up by former Premier Kathleen Wynne, formally announcing the upcoming Ontario election. It was known* the voting date would occur on June 7, yet the REA — a major decision — was given by the Ministry of the Environment and Climate Change (MOECC). At that time, not only were polls forecasting a defeat for the Liberal government, “electricity prices” and hydro bills were a major election issue. The MOECC issued the decision anyway.
Is the power needed?
In 2015 (before the IESO called for more wind power proposals) Ontario had a huge surplus of generation. Our net exports (exports less imports) were 16.8 TWh (terawatt hours) or enough to supply almost 1.9 million average households (over 40% of all Ontario households) with their electricity needs for a full year. It cost ratepayers an average of 10.14 cents/kWh to generate that power which was sold for an average 2.36 cents/kWh, representing a cost of $1.3 billion to Ontario’s ratepayers.
Due to the highly intermittent nature of output from wind turbines, the IESO’s projections of long-term capacity use only 12% of the nameplate capacity for wind power installations when calculating their contribution to overall capacity. So for Nation Rise, the IESO is projecting that the useable contribution of the project will be 105,120 MWh — just .0765% of the IESO’s forecast power consumption of 137.4 TWh. That is a fly on the flank of an elephant, in my estimation.
Cancellation of Nation Rise would not affect the long-term supply of electricity for the people of Ontario.
Worse, adding more capacity, particularly from an intermittent source, could result in more spilling of hydro, more curtailment of wind power generation, additional nuclear shutdowns or steam-off, all of which would drive Ontario’s electricity bills rates higher.
Property value loss
The property losses in value caused by the presence of 33, 650-foot industrial wind power generators throughout the countryside in the Nation Rise project will be in the tens of millions of dollars according to a study which notes: “Using research completed recently by a land economist with the University of Guelph and published in Land Economics, Wind Concerns calculates that overall, the property loss for houses within 5 km of the 33 planned turbines could be $87.8 million. Using other research that is less conservative, however, the property value loss could be more than $140 million.”
A loss of either magnitude would impact North Stormont’s realty tax base leading to either significant drops in revenue for the township or realty tax increases as a multiple of the COL (cost of living).
And then there’s the water
One condition among many in the REA given to EDP/Nation Rise was related to identifying and mapping all water wells in the project area within a set range of any proposed equipment, meteorological tower or wind turbines. This was due to concerns about construction activities on the local aquifer. While EDP identified 444 wells, the community group says there are more than 800 homes within the immediate project. Water wells in other areas of Ontario and elsewhere have become contaminated allegedly due to drilling and vibrations from wind turbines. There is significant concern about contamination of the wells, and the assessment taking place.
North Stormont is dairy farm country, and each farm operation uses thousands of litres of water every day — what would be the effect on these businesses, and Ontario’s food supply, if suddenly, the water wells were not functioning?
Who is EDP?
EDP (parent of EDPR) is a Portuguese utility company partially owned by two of the Chinese government’s companies; China Three Gorges (23.27%) and CNIC Co., Ltd., (4.98%) and the former has been trying for several years to acquire the balance of the shares. That attempt is speculated to be off; however, a recent NY Times article suggested otherwise, based on discussions with Portugal securities regulator CMVM.
Where is democracy?
North Stormont, where the Nation Rise wind project is planned, declared itself an “unwilling host” in 2015, well before the award of the contract or the issuance of the REA. The people perhaps relied on promises made by former energy minister and Ottawa Liberal MPP, Bob Chiarelli, when in 2013 he declared: “It will be virtually impossible for a wind turbine, for example, or a wind project, to go into a community without some significant level of engagement”. Despite their council passing the unwilling host motion, and also joining the 117 Ontario municipalities demanding a return of local land-use planning for energy projects, the IESO still granted Nation Rise the contract.
There are many questions about this project and many reasons why it simply isn’t needed. Cancelling this contentious project is a perfect way to lower future electricity costs, directly.
*The Toronto Star reported in an article dated October 19, 2016 the next Ontario election would be on June 7th, 2018
What it looks like: Tree clearing for turbines in Prince Edward County [Photo: Alliance to Protect Prince Edward County]
At its first mandatory Community Liaison meeting held this past week in Crysler, Portugal based power developer EDP announced that construction will begin soon on the 33-turbine, 100-megawatt wind power project that will cover the communities of Finch, Crysler and Berwick.
In a story published by the Cornwall Standard-Freeholder EDP spokesperson, Toronto-based Ken Little, said that the first step will be clearing of trees, and construction of access roads for the turbines.
While the turbine type and size was not specified in documents filed with government at the time of application for the Renewable Energy Approval, Little said they will be German-built machines, built to a maximum height of 200 metres or 656 feet.
The Peace Tower in Ottawa in 321 feet.
Little was also asked if the company will be employing local workers during construction, but he said he could not guarantee that.
He did say that there will be a $300,000 benefit to the municipality.
Wind Concerns Ontario, however, estimates the property value loss for properties exposed to the noise and visual effects from the huge turbines could be in the millions, which could in turn have the effect of forcing the municipality to raiser taxes.
The power project could be operating by December of this year. It is estimated to cost the people of Ontario more than $380 million over 20 years; the Independent Electricity System Operator (IESO) said in its power supply forecast last fall that Ontario does not need any new power generation at this time.
Community group Concerned Citizens of North Stormont launched an appeal of the power project based on concerns about the impact of turbine construction and operation on the aquifer in North Stormont, which is designated as “highly vulnerable” and on safety and health concerns. The appeal was dismissed but the group said recently it is considering all other option, including a further appeal.