Comment
On behalf of EDF EN Canada, I submit the following recommendations and comments:
•EDF EN acknowledges that this new proposed regulation would apply to all new non-rooftop solar projects (e.g., not just net metered projects);
•EDF EN supports the protection of prime agricultural lands and appreciates that this new proposed regulation is largely consistent with policies that were adopted as part of the Feed-in Tariff program and Large Renewable Procurement;
•EDF EN is concerned about the process, which requires generators to provide “confirmation” to distributors or transmitters. Will there be a standard form provided to all distributors/transmitters? Are transmitters/distributors equipped and willing to review and process this additional, non-grid related information? Will distributors/transmitters provided acknowledgment that the sites are compliant with the regulation? If so, at what state of development will this acknowledgement be provided? What are the dispute resolution mechanisms if there is a disagreement about the eligibility of a certain site?
•EDF EN is concerned that this blanket approach may not recognize site specific issues or site specific compatibility. For example, sites that may excluded but might have no agricultural value. Or, some sites may be compatible with some agricultural practices: https://cleantechnica.com/2017/11/24/combining-solar-panels-agriculture-makes-land-productive/. Therefore, EDF EN recommends that the regulation include an “exemption process” that would enable municipalities to provide an exemption to generators for specific projects should the municipality deem the site suitable for a proposed non-rooftop solar generation facility.
[Original Comment ID: 212010]
Submitted February 16, 2018 10:30 AM
Comment on
Proposed new regulation to be made under the Electricity Act, 1998
ERO number
013-1916
Comment ID
2794
Commenting on behalf of
Comment status