As the original appellant…

ERO number

013-3835

Comment ID

11167

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

As the original appellant against the REA granted to WPD White Pines in 2015, I have a strong interest in ensuring that the remains of this ill-advised project are fully removed from the fragile Prince Edward County south shore.

Draft Technical Closure Document

4.2.1, 4.3.1, 4.4.1, etc. Unless the Company and the landowner have a written agreement that provides for another arrangement ….
The above phrase, and words to the same effect, should be removed from the draft Technical Requirements.
This phrase allows the Company and the landowner to opt out of the following obligations otherwise imposed by the draft Technical Requirements:
4.1.4 removal of salvageable turbine components from the site;
4.2.1 removal of the foundations for the turbines and transformers;
4.3.1 removal of the crane pads;
4.4.1 removal of underground collector lines on private land;
4.6.3 removal of the concrete foundations for substations;
4.7.5 removal of new access roads and restoration of pre-existing access roads;
4.8.1 removal of any storage area;
5.1.3 restoration of natural features;
5.2.2 de-compaction of agricultural lands.

These provisions essentially permit the Company and landowners to leave the existing turbines intact. That is not acceptable, and contravenes article 2.1 of the draft Technical Requirements, which reads as follows:
"For greater certainty nothing in this document relieves the Company of any obligations arising from any other statute or by-law, including, without limitation, obtaining all necessary permits, licenses and approvals required under the Building Code Act, 1992, Highway Traffic Act, Environmental Protection Act and the Endangered Species Act, 2007."

This is also inconsistent with, and more lenient than, the wpd White Pines decommissioning plan which should describe the bare minimum of requirements. [File No. 160960594 June 2012, Section 3; http://canada.wpd.de/fileadmin/pdfs/WhitePines/WPWF%20(1-41-013)_DPR_28…],

These provisions are also not within the intent of Bill C2 which received royal assent on July 25, 2018.

If the wording is not changed, will the public be informed of all the other “arrangements” between the landowners and the corporation? Without that knowledge, the public have no knowledge that the required restoration is performed.