Eastern Lake Ontario Environmental Research Group 2000 (cont'd from eloerg.tripod.com/waupoos)

Cry Me a River over a Few Bats: Submission to Env Review Tribunal, ELOERG, January 2013

Leon Redbone, RIP, June 2019
Ontario Endangered Species Act at risk, letter to Rod Phillips, April 2019
Slide to Extinction, Chris Humphrey, letter to Globe, October 31, 2018
Peter Galbraith, FRCP, obituary, October 2017
White Pines on Death Bed, Bruce Bell, Intelligencer, July 17,2018
Thucydides Trap, letter to Globe, May 2018
Great Lakes toxics down, SUNY Oswego/Clarkson U, April 2018
Machine subversion of democracy, letter to Globe, April 2018
Air Pollution overrides Ancestral Genes, Globe, March 2018
Olympian Cathal Kelly, letter to Globe, March 2018
Environmentalists seeking unemployment, letter to Globe, February 2018
Less is more on Bike Lanes, National Post, January 2018
Tramadol, 10 years on, Globe and Mail, November 2017
White Stripes: Belleville bicycle lanes, letters, November 2017
Occupational Cancers, CCO research results, Globe and Mail, October 2017
Big Pharmoney and Canadian Drug Use Guidelines, Globe and Mail, June 21, 2017, Kelly Grant
Oxycontin, 20 years on, letter to Globe, May 2017
Lake Ontario wind turbines to remain on hold? Feb 2017
Obituary, Raold Serebrin, September 2016
Sartorial slip or signal? letter to Globe editor, October 2016
Weapons of mass distraction, letter to Globe editor, Oct 2016
Point O turbines 99% Down the Drain, CCSAGE, July 7, 2016
Point O turbines Dead and Damned, PECFN, July 6, 2016
Rabid diplomat, letter to Globe, May, 2016
More on bats: rabid rocker? letter to Globe, January 2016
Lighthouses of eastern Lake Ontario, new book by Marc Seguin, March 2016
Continuing corporate windpower malfeasance: Windstream and Trillium Corp, Feb 2016
Amherst Island: the next fine mess, Feb 2016
Valerie Langer: Thirty years of effort pays off on the B.C. coast, Feb 1,2016
Trillium log, 6th annual ELO expedtion, September 2015
Trillium Wind Corp intent on Spoliation of eastern Lake Ontario and Main Duck Isle, June 2015
Turtles rule? Ontario Court of Appeal Decision: Turtlegate, April 2015
Obituaries, Mary Terrance (Luke) Hill, January 2015; Valerie Ingrid (Hill) Kaldes, July 2015
Ontario Court of Appeal turtle hearing, December 2014
Trillium Log, 5th annual ELO expedition, September 2014
Planetary public health manifesto, The Lancet, March 2014
Ostrander Bioblitz, butterfly inventory walk, August 10, 2014
Victory at Cape Vincent: British Petroleum withdraws turbine proposal, February 2014
Stay of execution granted by Ontario Court of Appeal, March 2014
Never say die: Will the Court of Appeal let the Ostrander Phoenix fly free again? March 2014
Divisional Court ruling in Ostrander: turtles belly up, Trojan horses win, February 2014
Lafarge 2020, pushing the air envelope again, Hazardous waste as cement kiln fuel proposal, Jan2014
Another fine mess in Port Hope: municipal waste incinerator proposal, January 2014
Ostrander: fiasco, or snafu? you decide, December 2013
Ostrander rises again, Noli illegitimi carborundum, December 2013
British Petroleum backing off Cape Vincent after a decade of aggression? December 2013
Turbines best Bald Eagles in U.S law, December 2013
SARStock 10 years after, letter to editor, August 2003
Trillium log September 2013: Surfin' USA: Hanging Ten in a Hughes 29
ERT Post mortem: Garth Manning lets it all hang out, August 2013
ERT post mortem: Cheryl Anderson lets it all hang out, August 2013
ERT Post Mortem: Ian Dubin lets it all hang out, August 2013
Great Lakes United turns thirty, goes down, RIP GLU, July 29, 2013
ERT decision, Ostrander turns turtle, goes down, July 3, 2013
PECFN Thankyou, and Appeal for funds, July 6, 2013
Minister of Env on Lake Ontario Off shore wind turbine status, June 2013
Lake Ontario water level control plan, June 2013
Play by Play, Part II, APPEC Ostrander ERT Appeal, June 2013
Ostrander ERT June 2013, Appendix VI, an indirect cause of human morbidity and mortality ?
ELOERG Presentation to Ostrander ERT, Part II, Human Health, May 2013
The Dirty E-Word, Terry Sprague, Picton Gazette, April 2013
Toxics in Great Lakes Plastic Pollution, April 2013
Bill Evans on Birds and Wind farms, April 2013
Mayday, Naval Marine Archive, April 2013
Experimental Lakes Area, Kenora, Closing by Federal Gov't, March 2013
Fishing Lease Phase out on Prince Edward Point, March 2013
Windstream makes $1/2 Billion NAFTA claim, March 2013
Play by Play, PECFN Ostrander ERT Appeal, March 2013
Offshore Wind turbine moratorium 2 years later, The Star, Feb 2013
ELOERG ERT submission on Ostrander: Appendix V: Pushing the Envelope of the MoE SEV, Feb 2013
Wente on Wind and Bald Eagle mugging, Globe and Mail, February 2, 2013
Sprague on Wind and Bald Eagle mugging, Picton Gazette, Jan 25, 2013
Cry Me a River over a Few Bats: Submission to Env Review Tribunal, ELOERG, January 2013
Lake Ontario's Troubled Waters: U of Michigan GLEAM, January 2013
Letter to Minister of Environment re: Ostrander, January 2013
No Balm in Gilead: Ostrander IWT's as Trojan Horses, January 2013
Ostrander Turbines: another Christmas gift by the MoE, Dec 2012
Occupational carcinogens: Ontario Blue Collar breast cancer study, November 2012
Fresh water fish Extinctions, Scientific American,November 2012
Great Lakes Toxics revisited, November 2012
Frack the What ? November 2012
$ 2 1/4 Billion Trillium Power lawsuit knockback Appeal, November 2012
Canada Centre for Inland Waters decimated, October 2012
Birds, Bats, Turbines, and the Environmental Commissioner of Ontario, October 2012
Ecological public health, the 21st centurys big idea? British MedicalJournal Sept1,2012
Trillium log, Sept 2012
George Prevost, Saviour of the Canadas, 1812 - 1814. June 2012
The Victory at Picton: Bicentennial Conference on War of 1812-1814, Differing Perspectives, May 2012
Carleton Island and the 1812, letter to the Globe, October 2011
Queen's Fine Arts Department Succumbs, letter to Principal, December 2011
Mr. Kumar and the Super 30, November 2011
Letters, Articles and Projects from the Nineties
Alban Goddard Hill, web site manager

Enter subhead content here

A.C. Goddard Hill, B.Sc, MD, CCFP

Alban C.Goddard Hill Medicine Professional Corporation

General and Family Physician

306-210 Dundas St East,

Belleville, ON   K8N K8N 5G8

January 31, 2013

Environmental Review Tribunal

Environment and Land Tribunals Ontario

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

Attention:  Paul De Medeiros , Case Coordinator

Dear Sir,

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 status;  PRESENTER

(b) 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

(c) whether

(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

Sincerely yours,

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
Belleville, Ontario                            January 28, 2013



Mr. Chairman, and Honoured Guests,



My name is Alban Goddard Hill.


I live in Belleville, Ontario.


My public interest group


is called the ELOERG,


which was formed in the year 2000.


My submission is in support of the Appeal


to the Environmental Review Tribunal


by PECFN  and APPEC.




Mr. Chairman,


I would first like to draw your attention


to a letter which I wrote


to the Minister of the Environment, Mr. Jim Bradley,


regarding the Ostrander proposal


dated January 9, 2013.


The letter is attached to my submission today


as Appendix I, 


and it  is one of four appendices.



Secondly, as I am a physician


I would…. 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,



Mr. Chairman,


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 effects….


on both physical and mental health,


some of them…… quite serious.




One of the common effects of IWT’s


on people who live in their vicinity….. is ….


sleep disturbance.


It seems likely, therefore,


 that some of those people


will suffer some of the health effects…


which are known to be caused by ….sleep deprivation……


Appendix III… 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


which regulates Air Quality  in Ontario…..


it is the Ministry of Environment.



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 ,


more recently…


their behavior in this arena ….has consistently been…


Regressive…. and ……Devious.



I have personally seen…. half a dozen examples of this


in Eastern Ontario….in the last 20 years.



I regret to say…..that…. 43 years after it was formed,


in the regulation of air pollution


the MoE…. has lost the public trust.



Mr. Chairman,


if you really want to find out


about the health effects of sleep deprivation


you  could learn more…. if you spoke  


to any local…. General Practitioner


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 their observations


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 being seen


in …..half…. 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 global phenomenon


and there are many factors at work.


I myself, and many of us here today,


have lived long enough now


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 Bay.



In the UK, the BSPB is one group


which is trying to do something about the problem


of animal populations in decline.




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 is concerned.



A different recent view is that of


an editor of a local newspaper.


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.



But…we grieve…. we move on….we get over it…



However at a deeper level, “Cry me a river….over a few bats…”


is a very revealing statement


because it shows…..a lack of awareness…


a denial….


of  what is really happening out there


when turbine blades kill animals.



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 ….Systems .



We are now at the point in our culture


where we are very distanced….very separated….


from our natural environment.


We believe that we can sustain ourselves


with Complex Economic Systems,


and Complex Technological  Systems,


and Complex Mechanical Systems.


But our species is built on a foundation


of Complex Biological Systems,


which are made up of diverse animal  and plant populations,


all interdependent on each other…


Ecosystems…..all 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 goes down,


genetic information is lost,


and this becomes critical


when populations are at these low levels.


Birds, and bats die…. permanently.


Genetic information 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 Systems…


these Ecosystems…sustain us.


They have Survival value for us


and we destroy them at our own peril,


and despite our great intelligence as a species


this destruction continues apace,


in many forms.



Beneath the surface of Lake Ontario, for example,


we have managed to wipe out the American Eel population,


and the Whitefish population,


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 by IWT’s.



On Wolfe Island,


which has been designated an Important Bird Area,


the number of carcasses collected


averages  1 bird / machine / month.



But there are problems with this body count,



because, it does not account for:   e.g.


carcasses stolen by scavenging carrion eaters,


or….. animals injured which later die somewhere else,


or….. exhausted migrating animals whose path is obstructed,


which then die in surrounding waters,


………to 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


 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.


Migrating birds congregate there for exactly the same reason


that engineers locate IWT’s there…


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 million slices


with one of those huge blades


sweeping down once every 1-2 seconds


is going to kill a lot more


than…one bird in  one month,


especially….. in an IBA…. during migration season.



A more honest analysis would be


that no one really knows


how many animals are killed by these machines.




Furthermore  we are comparing apples and oranges here,


because I suspect that Wolfe Island, while important,


is a Less Important Bird Area,


than the South Coast of Prince Edward County,


and that the kill rate by machines located here at Ostrander


will be correspondingly greater,  than on Wolfe Island.



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 road


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 like


Martin Edwards, and  Fred Cooke  and Bob Stewart,


 and Ron Weir, and Paul Mackenzie…


They were all scientists by vocation


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 migratory populations


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 points  


at South Bay…. and PE Bay ….and PE Point


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.


But ….now …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, Mr. Miller


has repeatedly documented in his Annual Report


there are, right now,


existing opportunities 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 problems,


and the Commissioner has given us the blueprint.



So Mr. Chairman, in conclusion,


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


than “Cry me a river…..over a few bats.” 



Furthermore, Mr. Chairman,


the Director’s 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…..


for these… four…. reasons,


I urge you ..to reverse…this…very wrong…Decision.


Mr. Chairman.

Belleville, Ontario                            February 15, 2013

Appendices I – V at eloerg.tripod.com/waupoos2012



Appendix I


A. C. Goddard Hill, B Sc, MD, CCFP

General and Family Physician

306-210 Dundas Street East

Belleville, Ontario                K8N 1W3

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, Ferguson Block

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 north shore.


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.


Sincerely yours,


A.C. Goddard Hill


Eloerg.tripod.com/waupoos                                                          5 page doc attachment





Appendix II   (see No Balm In Gilead article,left website column)



Appendix III


Sleep deprivation


Selections From 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.[1] It adversely affects the brain and cognitive function.[2] Few studies have compared the effects of acute total sleep deprivation and chronic partial sleep restriction.[2] 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.[3] Long-term total sleep deprivation has caused death in lab animals.[4]

Physiological effects

Generally, sleep deprivation may result in:[5][6]


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.[15] 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).[16]

Effects on the brain

Sleep deprivation can adversely affect the brain and cognitive function.[17] 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.[18] 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.[19]

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.[citation needed] 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.[20]

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.[21]

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.[21]

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.[22]

Animal studies suggest that sleep deprivation increases stress hormones, which may reduce new cell production in adult brains.[23]

Effects on growth

A 1999 study[24] 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.[25] The rats were allowed deep (NREM) sleep. However, another study conducted by Gumustekin et al.[26] 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;[2] 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.[2]

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.[27] 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,[28] though the National Highway Traffic Safety Administration suggests the figure for traffic accidents may be closer to 100,000.[29] The AASM recommends pulling off the road and taking a 15- or 20-minute nap to alleviate drowsiness.[28]

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.[30] 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.[31]

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.[32] However, combining alcohol with acute sleep deprivation results in a trebled rate of driving off the road when using a simulator.[33]

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.[34]

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.[35] 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.[36]

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.[37][38]

Great sleep deprivation mimics psychosis: distorted perceptions can lead to inappropriate emotional and behavioral responses.[39]

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.[40]


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.[41]

Weight gain/loss

In rats, prolonged, complete sleep deprivation increased both food intake and energy expenditure with a net effect of weight loss and ultimately death.[42] 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.[1]

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.[43][44][45] The findings suggest that this might be happening because sleep deprivation could be disrupting hormones that regulate glucose metabolism and appetite.[46]

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.[47]



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.[54]

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.[55]

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.[56]

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 law.[57]

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.[58] 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."[59]

Mental illness

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 state.


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Appendix IV


Globe and Mail Newspaper, January 31, 2013


Margaret Wente


(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 lite.”……………


Appendix V                                               ERT    Ostrander submission


“Unfortunately, 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.”


“The Director’s 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


  1. 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.


  1. 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 2008)


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.


  1. The  Fred Fairman Revelation:


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 been completed.


  1. The Myth of Continuous Monitoring:


A repeated 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.


  1. 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? 


Source testing 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:


Failure to call public health physicians as witnesses to Air Pollution public  hearings and public meetings.


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



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Eastern Lake Ontario Environmental Research Group