Amendments to the Renewable…

Amendments to the Renewable Energy Approvals Regulation- O Reg 359/09 ERO# 013-3800:
Criteria for Demonstrating Demand –
• This process needs to focus on total net demand across the system. Large-scale proposals for companies to generate electricity for their own use and net-metering will create reductions in demand on provincial system, leaving the province with more costly stranded production. This extra cost will be reflected in the Global Adjustment, and electricity users will be required to cover this added cost. This would pose undue hardship on our citizens, farms and other businesses, and industries.
• Since Ontario’s base generation system is already largely free of carbon emissions, promotion of large-scale, private renewable generation should be deferred until the added capacity is actually required.

Impact on the Environment -
• Current set-backs for wind turbines need to be increased based on learning from complaints from existing projects, new research into wind turbine noise, and actions other jurisdictions have taken to protect the health of people living near the projects.
• The current review process outlined in Regulation 359/09 needs to be completely reviewed to ensure that these goals of protecting the environment will be achieved.
• The very limited public consultation process needs to be completely revamped to bring it in line with the government’s commitment to openness and transparency.
• Changes to the Environmental Protection Act are required to expand the scope for appeals of REA decisions and the standards for successful appeal need to be made more realistic:
1. Add grounds for appeal reflecting the requirement from ERO# 013-3800 that “the benefits of the energy outweigh the impacts to the environment”.
2. Allow municipalities to appeal based on the impact of the project on the economy of the municipality and/or the impact on infrastructure managed by the municipality.
3. Modify wording to replace “will cause” with wording that aligns with EPA Section 12 which requires only “reasonable and probable grounds” for the director to take action.