Comment 1: The following…

Comment 1:

The following phrase, and words to the same effect, should be removed from the draft Technical Requirements:

“unless the Company and the landowner have a written agreement that provides for another arrangement”

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.
Erection of an industrial plant to generate electricity is not a permitted use of agricultural land. It was accomplished only because the Ministry of the Environment issued a Renewable Energy Allowance under the former Green Energy Act. Now that the REA has been cancelled and the GEA is about to be repealed, the existing IWTs are illegal and must be removed.

Comment 2:

4.4.2 of the draft Technical Requirements provides Prince Edward County with the option to permit distribution lines to remain in place on municipal roadways. There should be provision for the Municipality to conduct studies at the expense of the Company to determine whether removal would be the preferable course of action.

Comment 3:

6.1 To the list of items to be protected from damage, add “wells, dams and ground waters”.

6.11 To the water courses to be protected from contamination, ad “wells, dams and ground waters”.