On behalf of Neoen Canada,…

On behalf of Neoen Canada, we are pleased to submit our comments on the above noted proposal by MNR to amend regulations under the Public Lands Act to streamline access to Crown lands in Ontario for certain low risk, short term activities (Mobile wind testing equipment, geotechnical/hydrogeological investigations, environmental monitoring equipment and short term bridges).

General support

• We strongly welcome MNR’s progressive thinking in this initiative. The proposed amendments reflect a more efficient, modern regulatory framework that is aligned with the interests of low impact renewable energy development while continuing to respect environmental stewardship.
• We particularly appreciate the inclusion of low risk occupations of Crown lands without requiring full written site specific authorizations, provided conditions are met (including registration of location).
• We believe that streamlining processes in this way will enable earlier stage feasibility work to proceed more smoothly, reducing transactional and timing burden for industry while still preserving appropriate oversight and restoration obligations. This is consistent with the Province’s objective of supporting renewable energy development and economic growth while protecting natural heritage.
• From Neoen’s perspective, earlier access to Crown lands for initial investigative work is critical to de risking potential sites, enabling timely interconnection and procurement deliverables, particularly under procurements administered by the Independent Electricity System Operator (“IESO”). We note the proposal recognises IESO procurements as a driver.

Recommended addition: temporary meteorological (“met mast”) structures

While we support the proposed framework as drafted, we respectfully suggest that MNR consider explicitly including temporary meteorological measurement structures (commonly known as “met masts” or LiDAR/so¬lid mast configurations) within the ambit of the proposed low risk occupations. Our rationale is as follows:
• In the context of wind (and solar) projects, the installation of met masts or LiDAR rigs is an essential early stage investigative step. Conducting wind resource measurement, validation of site conditions, and data‐gathering often requires placement of a tower or rig on Crown land prior to full lease or licence of occupation being secured.
• These structures are typically short term (often 12 24 months or less), removable, low footprint, and temporary in nature; as such, they align with the definition of “low risk, short term uses that do not involve structures being permanently affixed to public lands” as described in the proposal.
• By explicitly referencing met mast / LiDAR rigs in the regulation or associated guidance as a permitted activity under the streamlined regime, MNR would provide greater clarity and certainty to proponents and review staff alike — reducing unintended delay or ambiguity in the permitting/registration process.
• From a risk‐management perspective, requiring registration, site restoration and responsible use (as per the general conditions proposed) is fully appropriate for met mast installations. These align with the restoration and liability provisions captured at section: “site restoration following the completion of an occupation … occupiers must maintain continuous compliance … liability and responsibility for the use and occupation of public lands.”