The province is now accepting comments on the proposed Green Energy Act regulations that will allow renewable energy approvals to be issued. The biggest issue is the proposed mandatory setback from receptors for all wind turbines, especially when combined with the proposed set back requirements from roads and railways and property lines. These setbacks will block a high percentage of planned wind projects, and especially those close to load. This will increase the need for long-distance transmission lines, which have significant environmental footprints. These setbacks should be subject to reduction through study, like the other proposed setbacks in the regulation.
Other key issues that require clarification or amendment include:Re the Proposed content for the renewable energy approval regulation:
Part I:
1. The proposed definition of “biomass” excludes “non-organic waste”. This requires clarification.
Part II:
2. The MOE proposes to simply return applications for approval that are under consideration in the Ministry when the Act is proclaimed, requiring the applicant to start from scratch. Apparently, they don’t even get their application fee back. This seems unfair.
3. The proposed nine-month deadline for completion of ERT appeals seems too long.
Part III:
4. The requirement to give public notice of any application in a 1.5 km radius is impractical in urban and other densely occupied areas.
5. There is an urgent need for clarity on what “accommodation” the province will require proponents to provide for First Nations.
6. It is unclear what sort of advice the proponent is intended to provide to the Minister on the environmental impacts of renewable energy projects.
7. Need a clear definition of “sensitive” water bodies.
Part IV:
8. It is unclear how cumulative effects will be calculated, and what counts as “planned”. This could have a severe effect on good planning by encouraging a “gold rush”, first-come first-served approach to turbine siting.
Proposed amendment to environmental assessment regulation 116/01:
9. This amendment suggests that all transmission lines will now be exempt from environmental assessment. This would certainly make it easier to site and build transmission lines, but what equivalent process will control environmental impacts?
Ministry of natural resources draft approval requirements:
10. The province must clearly define the “scope” of a renewable energy project. if water crossings, roads, associated transmission lines etc. are to be exempt from environmental assessment, it is essential to make sure they are properly examined as part of the renewable energy approval.
11. There should be a more stringent test for renewable energy development in provincial parks and other special and protected areas.