A.C. Goddard Hill, B.Sc, MD, CCFP
Alban C.Goddard Hill Medicine
General and Family Physician
306-210 Dundas St East,
K8N K8N 5G8
January 31, 2013
Environmental Review Tribunal
Environment and Land Tribunals
655 Bay St., Suite 1500
Toronto ON M5G 1E5
Re: ERT appeal of MoE
Ostrander Point decision by Prince Edward County Field Naturalists and Alliance to Protect PEC
De Medeiros , Case Coordinator
Please accept this as
notice that I would like to appear as a Presenter at the above mentioned appeal to give an oral presentation which would take
approximately 15 minutes.
Attached are the
contents of my presentation.
Also attached are four
appendices: (i) copy of letter to the Minister of Environment; (ii) copy of a submission to a local publication; (iii)
copy of a summary of health effects of sleep deprivation; (iv) a selection from an article in the Globe and Mail which
refers to a novel use of sleep deprivation.
With respect to
the requirements of Rule 34:
34. No later than four days before the Preliminary Hearing, any
person seeking to be named as a Party, Participant or Presenter shall file with the Tribunal a written request setting out,
(a) whether the person is seeking Party, Participant or Presenter
a statement of the issues and material facts relevant to the subject matter of the appeal that the person intends to present
at the main Hearing. ATTACHED
(i) the person’s participation is likely to make a relevant
contribution to the Tribunal’s determination of whether engaging in the renewable energy project in accordance with
the renewable energy approval will cause serious harm to human health, or serious and irreversible harm to plant life, animal
life or the natural environment; MATERIAL ADDRESSING BOTH ISSUES IS ATTACHED
(ii) the person’s interests may be directly and substantially
affected by the Hearing or its result;
THE PRESENTER CURRENTLY RENTS PROPERTY YEAR ROUND WITHIN FIVE MILES
OF OSTRANDER POINT AND IS A REGULAR VISITOR TO THE AREA.
(iii) the person has a genuine interest, whether public or private,
in the subject matter of the proceeding. AS INDICATED IN THE SUPPORTING MATERIAL
Alban C. Goddard Hill
Attached is my submission to the Environmental Review Tribunal hearing to be held February 8
in Picton Ontario, on the matter of the Ostrander Point Gilead proposal, in support of the Prince Edward County Field Naturalists.
I would be grateful for an opportunity to present this orally, which would take about 15 minutes.
Thank you for your consideration.
Alban Goddard Hill
January 28, 2013
Mr. Chairman, and
My name is Alban
I live in Belleville,
My public interest
is called the ELOERG,
which was formed
in the year 2000.
My submission is
in support of the Appeal
to the Environmental
by PECFN and APPEC.
I would first like
to draw your attention
to a letter which
to the Minister
of the Environment, Mr. Jim Bradley,
regarding the Ostrander
dated January 9,
The letter is attached
to my submission today
as Appendix I,
and it is one of four appendices.
Secondly, as I am
very briefly…. like to address
the human health
implications of IWT’s.
In this regard I
draw your attention
to Appendices III
and IV of my submission,
in the past decade
….there has been a very large increase
in the number of… physician operated Sleep Clinics in Ontario.
There are now literally
hundreds…. of these Clinics,
which are designed
to help patients….. who have Sleep Disorders,
of which there are
number of types.
As a consequence…. much research….. has been done,
and sleep disorders
are now a recognized cause
of a variety of
on both physical
and mental health,
some of them……
One of the common
effects of IWT’s
on people who live
in their vicinity….. is ….
It seems likely,
that some of those people
will suffer some
of the health effects…
which are known
to be caused by ….sleep deprivation……
is a summary, from one source,
of some of the literature
on sleep deprivation.
I know that
the Chief Medical
Officer of Health of Ontario
was asked about
IWT’s….a couple of years ago.
However it is not
the Department of Health
Air Quality in Ontario…..
it is the Ministry
The MoE was created
in 1970 …..for that express purpose….
to regulate ..Air
Quality…..and air pollution…
and therefore, in
my own experience,
the public health
people ......are ..not ….inclined
to address air pollution
issues…..it’s not their job….
although the MoE… got off to a good start ….in 1970…
in the regulation
of Air Pollution ,
their behavior in
this arena ….has consistently been…
I have personally
seen…. half a dozen examples of this
Ontario….in the last 20 years.
I regret to say…..that….
43 years after it was formed,
in the regulation
of air pollution
has lost the public trust.
if you really want
to find out
about the health
effects of sleep deprivation
you could learn more…. if you spoke
to any local….
who deals with the
real problems….. of real patients.
Finally, Mr. Chairman,
I would like to
address the implications of IWT’s
for animal populations.
In the UK, the Society
for the Protection of Birds….. BSPB
have recently reported
regarding a British bird called the….. Mistle Thrush.
The Society notes
that whereas in former times
this bird could
be seen and heard
in virtually… every….. British garden….100%.....
in the last few
years, the Mistle Thrush is only
of British gardens….50%
This bird protection
Society is therefore
calling on citizens
to participate in ongoing bird counts
to monitor the problem,
which is that of yet another species ….in decline.
Well, so what?……..Just
another bird in decline.
In the past 50 years
native populations of birds
around the world
have declined by
50 to 75% on average.
So it’s a
and there are many
factors at work.
I myself, and many
of us here today,
have lived long
that we can say
that we have borne witness to this decline….
We have actually
seen it happening.
Locally for example,
in the last dozen years
I have seen the
(so called) Common Tern,
and the (magnificent)
Great Black Backed Gull
disappear from PE
In the UK, the BSPB is one group
which is trying
to do something about the problem
of animal populations
Here in PEC, the
PEC FN, and the PEP BO
are also trying
to do something about it …
recently by focussing
on the effects of IWT’s
However, not everyone
A different recent
view is that of
an editor of a local
His analysis of
the effect of
IWT’s on animal populations was this:
“Cry me a
river….. over a few bats…”
Well, in one way
his take on this is quite appropriate.
We have an emotional
reaction to declining bird populations,
especially when we see images
of magnificent red
tailed hawks, or ospreys,.....or Bald Eagles,
being brought down
by a blade of a giant machine.
we move on….we get over it…
However at a deeper
level, “Cry me a river….over a few bats…”
is a very revealing
because it shows…..a
lack of awareness…
of what is really happening out there
when turbine blades
Each time one of
these animals is killed,
these machines …
have taken us one more step
along the road ….of
our relentless destruction
of Complex …Biological
We are now at the
point in our culture
where we are very
from our natural
We believe that
we can sustain ourselves
with Complex Economic
and Complex Technological
and Complex Mechanical
But our species
is built on a foundation
of Complex Biological
which are made up
of diverse animal and plant populations,
on each other…
part of a….. world wide web.
The diverse populations
in these ecosytems
are in decline.
Native bird populations
are at historically low levels.
Every time an animal
and this becomes
are at these low levels.
Birds, and bats
is lost…. permanently.
And then these animal
populations themselves are lost…. permanently.
But Science has
taught us, on the other hand,
that we cannot get
along without them.
We have arrived
at our present place in human history
because of them.
These Complex Biological
They have Survival
value for us
and we destroy them
at our own peril,
and despite our
great intelligence as a species
in many forms.
Beneath the surface
of Lake Ontario,
we have managed
to wipe out the American Eel population,
and the Whitefish
but that is invisible,
so we don’t get too upset.
Birds, in contrast,
we can see.
The evidence is
staring us in the face.
I would like to
comment on the reported numbers
of animals killed
On Wolfe Island,
which has been designated
an Important Bird Area,
the number of carcasses
averages 1 bird / machine / month.
But there are problems
with this body count,
because, it does
not account for: e.g.
by scavenging carrion eaters,
injured which later die somewhere else,
migrating animals whose path is obstructed,
die in surrounding waters,
name just a few possibilities.
My impression is
that nobody really knows
how many animals
are killed by these blades.
If you work it out,
in one month
the turbine blades
of one IWT slice down through the air
½ million times……500,000 times
You have seen these
blades….they are enormous.
The base of a single
blade stands as high as this room,
and they stretch
out 20 metres…
with a big surface
area, perhaps 50 square metres
And an IBA is called
that for a reason.
congregate there for exactly the same reason
that engineers locate
they are both powered
by the same wind.
So inevitably they are both going to be
in the same place….
at the same time
and it seems to
me that ½ million slices
with one of those
sweeping down once
every 1-2 seconds
is going to kill
a lot more
in one month,
in an IBA…. during migration season.
A more honest analysis
that no one really
how many animals
are killed by these machines.
Furthermore we are comparing apples and oranges here,
because I suspect
that Wolfe Island,
is a Less Important
than the South Coast of Prince
and that the kill
rate by machines located here at Ostrander
will be correspondingly
greater, than on Wolfe
One reason that
I say this is because in the 1980’s,
the KFN operated the PEP BO here on PE Pt.
And if you happened
to be standing by the South Bay
at 7 am on a Saturday
or Sunday morning in the 1980’s
you could regularly
see a car load of KFN members
speeding along the
South Bay Road
as they headed to
PE Point….from Kingston.
There were people
and Fred Cooke and Bob Stewart,
and Ron Weir, and Paul Mackenzie…
They were all scientists
and there were all
expert birders by avocation,
and they brought
their science along with them….. to PEPt.
To do their birding
each weekend …these people did not take
the 10 minute trip to Wolfe Island.
Instead, they made
the one hour journey to PE Point.
And there was a
good reason for that.
You have heard from the PECFN
about the amazing
that can be seen
on the South Coast of PE,
and that is what
these KFN people came to see.
For my own part,
for thirty years I have been looking
from various vantage
at South Bay…. and PE Bay ….and PE
and the False Ducks Islands … and Main Duck Island,
and I have been
also been impressed with the importance
of that zone to
these migrating animal populations.
…the great Gilead Power Corporation wants to put
nine huge IWT’s…
right in the middle of the whole complex.
at Ostrander Point
no less, the worst possible place.
And as we now learn,
all completely unncecessarily.
because, as the Environmental Commissioner of Ontario,
has repeatedly documented
in his Annual Report
there are, right
in Energy Conservation
that would render
these machines unnecessary,
and at a fraction
of the cost, right now.
So there are cheaper
and better ways
to solve our energy
and the Commissioner
has given us the blueprint.
So Mr. Chairman,
at Ostrander Point, these machines will:
· make people ill;
· destroy the ecosystems… that sustain us;
· effectively privatize and destroy…. locally rare public land;
I think that….the
people of Ontario deserve
a wiser judgment
in this case
me a river…..over a few bats.”
decision on Ostrander
has been compromised…..
by the documented
pattern of conduct …
by the MoE ….in
the regulation of air pollution
in eastern Ontario …over the past 15 years.
Mr. Chairman, and
Members ot the Tribunal…..
I urge you ..to
Belleville, Ontario February
Appendices I –
V at eloerg.tripod.com/waupoos2012
A. C. Goddard Hill, B
Sc, MD, CCFP
General and Family Physician
306-210 Dundas Street East
Belleville, Ontario K8N
613 968 8692 fax 613 968 5009
January 9, 2013
Honourable James Bradley
by Fax 416 314 6748
Minister of Environment
77 Wellesley Street West, 11th Floor,
Toronto, ON M7A 2T5
Re. Ostrander Point proposal,
Gilead Power Corp
Dear Minister Bradley,
As a former biologist
with the Conservation Authorities Branch, Province of Ontario, and as one with
local knowledge of the natural history of the Long Point-Prince Edward Bay zone of Prince Edward County it is difficult for
me to envision a worse possible location for the siting of industrial wind turbines than Ostrander Point on the Lake Ontario
Ostrander Point is located
immediately south of South Bay and the Little Bluff conservation zone, immediately east of the Miller land trust conservation
property, and immediately west of the Prince Edward Point National wildlife area.
As a consequence it is
an area of high activity for migrating bird species as well as recovering resident species.
Based on the Wolfe Island
experience there is no question that large birds, including raptors, will be felled by these machines in significant numbers.
For the proponent to suggest
otherwise is dishonest.
Minister, as a former
St. Catharines resident I know that you have a long established reputation as someone with a concern for our natural world
and I thank you for your good work over the years.
I urge you to put a stop
to this destructive project.
A.C. Goddard Hill
5 page doc attachment
Appendix II (see No Balm In Gilead article,left
Wikipedia, the free encyclopedia, as copied January 31, 2013
Sleep deprivation is the condition of not having enough sleep; it can be either chronic or acute. A chronic sleep-restricted state can cause fatigue, daytime sleepiness, clumsiness and weight loss or weight gain. It adversely affects the brain and cognitive function. Few studies have compared the effects of acute total sleep deprivation and chronic partial sleep restriction. Complete absence of sleep over long periods is impossible for humans to achieve (unless they suffer from fatal familial insomnia); brief microsleeps cannot be avoided. Long-term total sleep deprivation has caused death in lab animals.
Generally, sleep deprivation may result in:
In 2005, a study of over 1400 participants showed that participants who habitually slept few hours were more likely to
have associations with diabetes type 2. However, because this study was merely correlational, the direction of cause and effect between little sleep and diabetes
is uncertain. The authors point to an earlier study which showed that experimental rather than habitual restriction of sleep
resulted in impaired glucose tolerance (IGT).
Effects on the brain
Sleep deprivation can adversely affect the brain and cognitive function. A 2000 study, by the UCSD School of Medicine and the Veterans Affairs Healthcare System in San Diego, used functional magnetic resonance imaging (fMRI) technology to monitor activity in the brains of sleep-deprived subjects performing simple verbal learning tasks. The study showed that regions of the brain's prefrontal cortex, an area that supports mental faculties such as working memory and logical and practical ("means-ends") reasoning, displayed more activity in sleepier subjects. Researchers interpreted this result as indicating that the brain of the average
sleep-deprived subject had to work harder than that of the average non-sleep-deprived subject to accomplish a given task,
and from this indication they inferred the conclusion the brains of sleep-deprived subjects were attempting to compensate
for adverse effects caused by sleep deprivation.
The temporal lobe, which is a brain region involved in language processing, was activated during verbal learning in rested subjects but not
in sleep-deprived subjects. The parietal lobe, not activated in rested subjects during the verbal exercise, was more active when the subjects were deprived of sleep. Although
memory performance was less efficient with sleep deprivation, greater activity in the parietal region was associated with
better short term memory.
A 2001 study at Chicago Medical Institute suggested that sleep deprivation may be linked to serious diseases, such as heart
disease and mental illness including psychosis and bipolar disorder. The link between sleep deprivation and psychosis was further documented in 2007 through a study at Harvard Medical School and the University of California at Berkeley. The
study revealed, using MRI scans, that sleep deprivation causes the brain to become incapable of putting an emotional event
into the proper perspective and incapable of making a controlled, suitable response to the event. Sleep deprivation may have
been the underlying cause of the overdose deaths of celebrities Heath Ledger and Anna Nicole Smith.
A study tested 17 right-handed civilian males, between the ages of 21–29 years (mean 24.7 ± 2.8 years), with no history
of medical, neurological, psychiatric, or sleep disorder conditions. Their histories also included 7–8 hours of nightly
sleep on a regular basis, no nicotine use, and low caffeine use (less than 100 mg/day). The negative effects of sleep
deprivation on alertness and cognitive performance suggest decreases in brain activity and function, primarily in the thalamus,
structure involved in alertness and attention, and in the prefrontal cortex, a region sub-serving alertness, attention, and
higher-order cognitive processes.
This study used a combination of positron emission tomography (PET) and Fluorine-2-deoxyglucose (FDG), a marker for regional
cerebral metabolic rate for glucose (CMRglu) and neuronal synaptic activity. A time series design was used, with progressive
sleep deprivation as the independent variable. Repeated measures of absolute regional CMRglu, cognitive performance, alertness,
mood, and subjective experiences were collected after 0, 24, 48, and 72 h of sleep deprivation. Additional measures of alertness,
cognitive performance, and mood were collected at fixed intervals throughout the sleep deprivation period. These measures
were included to place the performance results associated with the PET scans in the context of the circadian rhythm of cognitive
performance, as well as to impose a moderate-to-heavy near continuous workload on the subjects as might be anticipated in
a real-world sustained operation.
A noted 2002 University of California animal study indicated that non-rapid eye movement sleep (NREM) is necessary for turning off neurotransmitters and allowing their receptors to "rest" and regain sensitivity which allows monoamines (norepinephrine, serotonin and histamine)
to be effective at naturally produced levels. This leads to improved regulation of mood and increased learning ability. The
study also found that rapid eye movement sleep (REM) deprivation may alleviate clinical depression because it mimics selective serotonin reuptake inhibitors (SSRIs). This is because the natural decrease in monoamines during REM is not allowed to occur, which causes the concentration
of neurotransmitters in the brain, that are depleted in clinically depressed persons, to increase. Sleep outside of the REM
phase may allow enzymes to repair brain cell damage caused by free radicals. High metabolic activity while awake damages the enzymes themselves preventing efficient repair. This study observed the
first evidence of brain damage in rats as a direct result of sleep deprivation.
Animal studies suggest that sleep deprivation increases stress hormones, which may reduce new cell production in adult brains.
Effects on growth
A 1999 study found that sleep deprivation resulted in reduced cortisol secretion the next day, driven by increased subsequent slow-wave sleep. Sleep deprivation was found to enhance activity on
the hypothalamic-pituitary-adrenal axis (which controls reactions to stress and regulates body functions such as digestion, the immune system, mood, sex, or energy usage) while suppressing growth hormones. The results supported previous studies, which observed adrenal insufficiency in idiopathic hypersomnia.
Effects on the healing process
A study conducted in 2005 showed that a group of rats which were deprived of REM sleep for five days experienced no significant
changes in their ability to heal wounds, compared to a group of rats not deprived of "dream" sleep. The rats were allowed deep (NREM) sleep. However, another study conducted by Gumustekin et al. in 2004 showed sleep deprivation hindering the healing of burns on rats.
Attention and working memory
Among the numerous physical consequences of sleep deprivation, deficits in attention and working memory are perhaps the
most important; such lapses in mundane routines can lead to unfortunate results, from forgetting ingredients while cooking to missing a sentence
while taking notes. Working memory is tested by such methods as choice-reaction time tasks.
The attentional lapses also extend into more critical domains in which the consequences can be life-or-death; car crashes and industrial disasters can result from inattentiveness attributable to sleep deprivation. To empirically measure the magnitude
of attention deficits, researchers typically employ the psychomotor vigilance task (PVT) which requires the subject to press a button in response to a light at pseudo-random intervals. Failure to press the
button in response to the stimulus (light) is recorded as an error, attributable to the microsleeps that occur as a product
of sleep deprivation.
Crucially, individuals' subjective evaluations of their fatigue often do not predict actual performance on the PVT. While
totally sleep-deprived individuals are usually aware of the degree of their impairment, lapses from chronic (lesser) sleep
deprivation can build up over time so that they are equal in number and severity to the lapses occurring from total (acute)
sleep deprivation. Chronically sleep-deprived people, however, continue to rate themselves considerably less impaired than
totally sleep-deprived participants. Since people usually evaluate their capability on tasks like driving subjectively, their evaluations may lead them to the
false conclusion that they are able to perform tasks that require constant attention when their abilities are in fact impaired.
Impairment of ability
The dangers of sleep deprivation are apparent on the road; the American Academy of Sleep Medicine (AASM) reports that one in every five serious motor vehicle injuries is related to driver fatigue, with 80,000 drivers falling
asleep behind the wheel every day and 250,000 accidents every year related to sleep, though the National Highway Traffic Safety Administration suggests the figure for traffic accidents may be closer to 100,000. The AASM recommends pulling off the road and taking a 15- or 20-minute nap to alleviate drowsiness.
According to a 2000 study published in the British Medical Journal, researchers in Australia and New Zealand reported that sleep deprivation can have some of the same hazardous
effects as being drunk. People who drove after being awake for 17–19 hours performed worse than those with a blood alcohol level of .05 percent,
which is the legal limit for drunk driving in most western European countries and Australia. Another study suggested that performance begins to degrade after 16
hours awake, and 21 hours awake was equivalent to a blood alcohol content of .08 percent, which is the blood alcohol limit for drunk driving in Canada, the U.S.,
and the U.K.
In addition, as a result of continuous muscular activity without proper rest time, effects such as cramping are much more
frequent in sleep-deprived individuals. Extreme cases of sleep deprivation have been reported to be associated with hernias, muscle fascia tears, and other such problems commonly associated with physical overexertion.
A 2006 study has shown that while total sleep deprivation for one night caused many errors, the errors were not significant
until after the second night of total sleep deprivation. However, combining alcohol with acute sleep deprivation results in a trebled rate of driving off the road when using a simulator.
The National Sleep Foundation identifies several warning signs that a driver is dangerously fatigued, including rolling
down the window, turning up the radio, trouble keeping eyes open, head-nodding, drifting out of the lane, and daydreaming.
At particular risk are lone drivers between midnight and 6 a.m.
Sleep deprivation can negatively impact performance in professional fields as well, potentially jeopardizing lives. Due
largely to the February 2009 crash of a regional jet in Buffalo, NY, which killed 50 people and was partially attributed to pilot fatigue, which caused the
FAA to review its procedures to ensure pilots are sufficiently rested. A 2004 study also found medical residents with less than four hours of sleep a night made more than twice as many errors
as residents who slept for more than seven hours a night, an especially alarming trend given that less than 11% of surveyed
residents were sleeping more than seven hours a night.
Twenty-four hours of continuous sleep deprivation results in the choice of less difficult math tasks without decreases
in subjective reports of effort applied to the task. Naturally caused sleep loss affects the choice of everyday tasks such
that low effort tasks are mostly commonly selected. Adolescents who experience less sleep show a decreased willingness to engage in sports activities that require effort through fine motor
coordination and attention to details.
Great sleep deprivation mimics psychosis: distorted perceptions can lead to inappropriate emotional and behavioral responses.
Astronauts have reported performance errors and decreased cognitive ability during periods of extended working hours and wakefulness as well as due to sleep loss caused by circadian rhythm disruption
and environmental factors.
Microsleeps occur when a person has a significant sleep deprivation. The brain automatically shuts down, falling into a sleep state for
a period that can last from a second to half a minute. The person falls asleep no matter what activity he or she is engaged
in. Microsleeps are similar to blackouts and a person experiencing them is not consciously aware that they are occurring.
An even lighter type of sleep has been seen in rats that have been kept awake for long periods of time. Local regions went
into periods of short (~80 ms) but frequent (~40/min) NREM-like state. Despite the on and off periods where neurons shut off,
the rats appeared awake, although they performed worse at tests.
In rats, prolonged, complete sleep deprivation increased both food intake and energy expenditure with a net effect of weight
loss and ultimately death. This study hypothesizes that the moderate chronic sleep debt associated with habitual short sleep is associated with increased
appetite and energy expenditure with the equation tipped towards food intake rather than expenditure in societies where high-calorie
food is freely available.
Several large studies using nationally representative samples suggest that the obesity problem in the United States might have
as one of its causes a corresponding decrease in the average number of hours that people are sleeping. The findings suggest that this might be happening because sleep deprivation could be disrupting hormones that regulate glucose
metabolism and appetite.
The association between sleep deprivation and obesity appears to be strongest in young and middle-age adults. Other scientists
hold that the physical discomfort of obesity and related problems, such as sleep apnea, reduce an individual's chances of getting a good night's sleep.
Sleep loss is currently proposed to disturb endocrine regulation of energy homeostasis leading to weight gain and obesity.
A reduction of sleep duration to 4 hours for two consecutive nights has recently been shown to decrease circulating leptin
levels and to increase ghrelin levels, as well as self-reported hunger. Similar endocrine alterations have been shown to occur
even after a single night of sleep restriction.
In a balanced order, nine healthy normal-weight men spent three nights in a sleep laboratory separated by at least 2 weeks:
one night with a total sleep time of 7 h, one night with a total sleep time of 4.5 hours, and one night with total sleep deprivation
(SD). On a standard symptom-rating scale, subjects rated markedly stronger feelings of hunger after total SD than after 7-hour
sleep (3.9 ± 0.7 versus 1.7 ± 0.3; P = 0.020) or 4.5 h sleep (2.2 ± 0.5; P = 0.041). Plasma ghrelin levels were 22 ± 10% higher
after total SD than after 7 h sleep (0.85 ± 0.06 versus 0.72 ± 0.04 ng mL(−1); P = 0.048) with intermediate levels
of the hormone after 4.5 h sleep (0.77 ± 0.04 ng mL(−1)). Feelings of hunger as well as plasma ghrelin levels are
already elevated after one night of SD, whereas morning serum leptin concentrations remain unaffected. Thus, the results provide
further evidence for a disturbing influence of sleep loss on endocrine regulation of energy homeostasis, which in the long
run may result in weight gain and obesity.
Sleep deprivation can be used as a means of interrogation, which has resulted in court trials over whether or not the technique
is a form of torture.
Under one interrogation technique, a subject might be kept awake for several days and when finally allowed to fall asleep,
suddenly awakened and questioned. Menachem Begin, the Prime Minister of Israel from 1977–83, described his experience of sleep deprivation as a prisoner of the NKVD in Russia as follows:
In the head of the interrogated prisoner, a haze begins to form. His spirit
is wearied to death, his legs are unsteady, and he has one sole desire: to sleep... Anyone who has experienced this desire
knows that not even hunger and thirst are comparable with it.
Sleep deprivation was one of the five techniques used by the British government in the 1970s. The European Court of Human Rights ruled that the five techniques "did not occasion suffering of the particular intensity and cruelty implied by the word torture
... [but] amounted to a practice of inhuman and degrading treatment", in breach of the European Convention on Human Rights.
The United States Justice Department released four memos in August 2002 describing interrogation techniques used by the
Central Intelligence Agency. They first described 10 techniques used in the interrogations of Abu Zubaydah. Among them included
sleep deprivation. Memos from May 2005 introduced four more techniques and confirmed the combination of interrogation methods
were not constituted as torture under United States
The question of extreme use of sleep deprivation as torture has advocates on both sides of the issue. In 2006, Australian
Federal Attorney-General Philip Ruddock argued that sleep deprivation does not constitute torture. Nicole Bieske, a spokeswoman for Amnesty International Australia, has stated the opinion of her organization thusly: "At
the very least, sleep deprivation is cruel, inhumane and degrading. If used for prolonged periods of time it is torture."
The specific causal relationships between sleep loss and effects on psychiatric disorders have been most extensively studied
in patients with mood disorders. Shifts into mania in bipolar patients are often preceded by periods of insomnia, and sleep deprivation has been shown to induce a manic state in susceptible individuals. Sleep deprivation may represent
a final common pathway in the genesis of mania, and sleep loss is both a precipitating and reinforcing factor for the manic
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Globe and Mail Newspaper, January 31, 2013
(selection from) Can You Ever Argue About Torture?
Kathryn Bigelow is the woman
in the hot seat. The American director of the notorious new movie Zero Dark Thirty is being hammered on all sides
by politicians, outraged journalists and human-rights activists for its torture scenes. They say the film is morally bankrupt
because it “normalizes” torture, instead of condemning it……………
So when I went to see the film,
I was expecting the worst kind of gut-wrenching brutality. But what I saw, please forgive me, wasn’t all that bad. It
doesn’t touch the extreme violence of your average Quentin Tarantino movie or much of the pornographic violence that
spews from Hollywood. The lengthy interrogation scenes show
slaps, punches, sleep deprivation, food deprivation, waterboarding, sexual
humiliation (nakedness) and being locked up inside a small box. All of this is pretty close to the facts, according to those
who know. It’s what was known as “enhanced interrogation,” although a better name would be “torture
ERT Ostrander submission
although the MoE got off to a good start in 1970 in the regulation of Air Pollution, more recently their behavior in this
arena has consistently been Regressive and Devious.”
Decision on Ostrander has been compromised by the documented pattern of misconduct by the MoE in the regulation of air pollution
in eastern Ontario in the past 15 years.”
Pushing the Envelope of the SEV
- Dirty Tricks: The Christmas Party Trick.
On two occasions,
in December 2006 (Bath, Lafarge), and in December 2012 (Ostrander, Gilead) , the MoE announced a Director’s Approval immediately before the Christmas and New Years break, during which a two week period was allowed for Appeal of the decision.
- In the “What Were They Thinking?” category:
In the Decision
by the ERT (April 4, 2007) in the citizen’s Application for Leave to Appeal in Dawber v. Director MoE, in the Bath, Lafarge application to burn tires: the Tribunal
noted that: “under the Env Bill of Rights 1993 it appears that there is
good reason to believe that no reasonable person, having regard to relevant law
and government policies, could have made the Decisions dated December 21, 2006 (to
grant the two certificates of approval) to Lafarge Canada Inc.”S
In the subsequent
appeals of the ERT decision by Lafarge to the Ontario Divisional Court and later
the Ontario Court of Appeal, the Divisional Court noted that it would only make a finding against the Decision of the regulator
if the actions of the regulator in making the Decision could be described as : egregious;
bungled; or betraying the public trust. The Divisional Court
did in fact make such a finding (June 2008), although they did not indicate which
of the three epithets pertained. The Court of Appeal agreed. (November
However it is clear
that Directors of the MoE are not unreasonable people, otherwise they would not hold such a position. Therefore one must conclude
that the Director, at least in that particular case, was marching to a drummer
other than the MoE Statement of Environmental Values. In that case presumably the different drummer was the interests of industry
which the regulator had placed ahead of their own SEV ethic.
- The Fred Fairman
In the course
of research by citizens in the Bath case, the late Dr. Fred Fairman (retired professor of mathematics
, Queen’s University) discovered that the MoE had for some time been allowing Lafarge to surreptitiously import hazardous
waste from New York State to be burned in the Lafarge cement kiln, this without the appropriate public approvals process having
- The Myth of Continuous Monitoring:
practise by the MoE when approving applications for facilities which release
toxic industrial air emissions was to reassure the public that there would be
Continuous air emissions monitoring in place, with Strict, Stringent, Rigorous and Robust standards, for the protection of the public health. These public pronouncements were repeatedly made by the MoE in Trenton, 2000 (Norampac
Steam Reformer), Bath 2005 (Lafarge cement kiln), and Clarington 2010 (Covanta municipal waste incinerator).
While it was technically
true that air emissions monitoring in these cases was Continuous, this was a very misleading and deceptive statement which
could easily be misinterpreted by the public. Although various less hazardous emissions would indeed be monitored continuously
in these operations, when it came to more hazardous emissions such as Particulate Matter, Heavy Metals, and chlorinated organic
poisons, monitoring would actually only be done as 3 X 3 hour stack tests on one day each year. This amounts to monitoring
over 1/1000 of the year, which could better be described as Rare monitoring, or statistically speaking, no effective monitoring
at all. It certainly was not continuous monitoring.
It was also revealing
that the MoE persisted in this method of public reassurance in the Clarington case despite the revelations and fallout from
the Lafarge case of five years before.
- Smoky Stacks and the Three Bears: Mama Bear, Papa Bear and Baby Bear;
or: Why use a superior method when you can
use an inferior one?
vs POI vs AAQC methods of industrial air discharge monitoring.
In the 1990’s
and before, the standard of practise for air discharge monitoring from a polluting smokestack in Ontario was to do POI, Point
of Impingement, testing, in which air samples were taken at the property limit of the facility
to measure contaminant fallout from the stack. This could be described as a “Simple but rather Ineffective”
system. In his 2005/06 annual report ECO recommended, based on Env Canada recs,
that the MoE move to Source testing, which uses direct measurement of chemical
discharges by in-stack probes, and which could be described as a “Simple and Effective” method of monitoring.
However the MoE instead chose to proceed with their initiative to abandon POI in favour of AAQC, the Ambient Air Quality Criteria
method. This uses computer models to predict deposition of contaminants in the
region surrounding sources of pollution, and requires no chemical sampling at all. It could be described as a “Complex
and Ineffective” method of regulation.
It is also noteworthy
that despite the observations of the Tribunal in Dawber, and by the ECO, there remains as of today no absolute limits on chemical
air discharges in Ontario (Guidelines A7 and A8), so the solution for air pollution in Ontario continues to be that of dilution.
6. An Apple a Day keeps the Doctor away:
call public health physicians as witnesses to Air Pollution public hearings and
In the course of
public hearings and public meetings regarding Air Pollution issues at Oakville (West Lincoln, OWMC hazardous waste treatment
facility, Joint Board,1994), Cornwall (MMR pcb hazardous waste incinerator ERT 1999), Trenton (Norampac steam reformer, public
meeting, 2000), Bath (ERT, 2006), Clarington (Covanta incinerator, public meeting
2009), and apparently Ostrander (2013 ERT) no public health physicians have ever been called by the MoE to appear as Witnesses.
Given the lack of expertise of the MoE in human health, this is inappropriate.
Alban Goddard Hill February 16, 2013