Boralex would like to…

Boralex would like to provide feedback as requested on a segment of the noted regulatory reform proposed with ERO 025-1134.

Within the Permit to Remove section of this proposal the MNR is soliciting feedback on the details and applicability of a “permit-by-rule” process for tree removal on crown-land for non-forestry activities.

We agree that a permit-by rule process to allow for self-registry if certain conditions are met would help to reduce schedule uncertainty and administrative burden for the MNR for low-risk activities where impacts will be minimal. To align with the intention of the other active EROs including 025-1078 and 025-1361 and 025-1141 to reduce duplication and lengthy administrative processes for renewable energy pre-development work, we suggest a good candidate for permit to remove permit-by-rule is tree removal needed for geotechnical and hydrogeological testing sites and met tower sites as well as trails needed to reach these locations. These are temporary works and tree removal can be minimal. Allowing for flexibility in the placement of these trails can additionally allow for judgement to be made on site to find the lowest impact pathway to the location to account for on site conditions at the time of the work.