Thank you for the opportunity to comment. The Repeal of the GEA and restoration of planning authority to municipalities going forward is welcomed in general. Grandfathering of existing negative aspects IS NOT in the public interest and perpetuates significant harm to the detriment of the current government and the citizens who voted for change. My understanding is that the siting regulation primarily affects siting of solar projects and continues to exempt LRP from restrictions on siting; including on prime agricultural land during transition. It is very difficult to effectively comment on the proposed Siting Regulation as it appears to be dependent upon the outcome of the proposed Transitional Regulations ERO-4265 which targets pre-construction projects and continues to remove municipal controls from operational projects. The proposed transition period seems targeted to Nation Rise Wind Farm which has not yet started construction (pre-construction). Relevant comments can be found in ERO 013-4265 and should be considered applicable to this ERO 13-4288 As such, I understand this ERO 4288 will remove the exemption from municipal control for new renewable energy projects going forward but retains them during the transition period proposed under ERO 13-4265, however; o Wind turbines should never have been allowed on prime agricultural lands in the first place as regulations did not require proponents to fully assess underlying geological factors including soils such as Leda clay, eskers and fragile aquifers o Even though the final foot print may be smaller than large scale solar an assessment of longer term damage from industrial wind farms on prime agricultural lands is not properly considered e.g. from petrochemical contamination, turbine fires, compaction to roads, access ways, crane pads and the environmental risk from bore holes, tons of cement in foundations, rebar, and transmission lines which proponents, in the case of Nation Rise Wind Farm
anyway, propose to leave in place forever despite municipal input that they must be removed. o Prime agricultural land is a rapidly dwindling but essential resource for food security in a rapidly growing world population. Despite the transition period and recognition of those operational wind projects already built, no new, no projects under review, no pre-construction projects, nor any expansion of existing wind projects can be allowed to be built on Class 1, 2 or 3 prime agricultural lands, as also identified in submissions placed under ERO 013-4265. It is highly recommended that this ERO 13-4288 be clarified and reposted for a minimum 45 day period in order to achieve its reason for being, considering the uncertainty around applicability to operational wind projects already built but expanding, already built but undergoing major maintenance activities, projects under review, projects defined as approved yet pre-construction and the impact to Class 1, 2 or 3 prime agricultural lands from not only the final residual footprint but also during construction of roadways, crane pads, aquifers, waterways, drainage, etc. during construction, operation, expansion, repowering, or major maintenance or restoration activities including unplanned or unforeseen events such as fires or lightning strikes.
Moving forward, a simple solution would be to immediately call a moratorium on all pre-construction renewable energy projects, thereby eliminating the need for transitional regulations for this aspect. o Put developers on notice to not incur any additional expense and compensate developers for their investment in the pre-construction project to date and get on with business o Review and renegotiate existing contracts with an eye to not only strong enforcement of current infractions but importantly retrofit and establish current noise guidelines, tools, training and processes including for low frequency and infrasound.
Submitted January 18, 2019 9:26 AM