Thank you for this…

Thank you for this opportunity to comment on EBR #013-3832.
1. The demonstration of need equation needs to be clarified in the amendment. Need locally? provincially? The concept of need requires clarification - what standard for determining need will be applied? The government through the Lieutenant-Governor will make the final determination - could that occur without the consent of the municipalities? Clarification is required - a municipality might not want the development but if the government deems the energy is needed - the government decision overrides the local decision. So in this instance, granting municipalities the final approval power is meaningless. The wording has to make clear that no municipality decision can be overturned by the government. Or the municipality can challenge the existence of need at no cost to the municipality.
2. The EPA sets forth the Appeals process.
2a. Will demonstration of need be incorporated into the rules for appeal? We need changes to the appeals process that level the playing field for the parties to an appeals process. The burden of proof is inappropriate for the type of harm wind plants cause. The review test needs to be material contribution to risk of harm to human health and the wildlife environment.
2b. Tribunals need to be required to determine independently whether the evidence supports a positive finding that engaging in the Project in accordance with the REA will not cause serious harm to human health and/or serious and irreversible harm to wildlife.
2c. Post-turbine witness and local in-situ expert citizens need to be recognized and given the same weight as wind developer experts.
2d. The cost for citizens to appeal needs to be addressed.
2e. Finally, documentation by wind developers to support their approvals needs to be incorporated into the appeals process - widen the scope. Directors have in the past approved project documentation that has found to be incorrect but those appealing have no recourse because currently this documentation is deemed out of scope in an appeal.
Please use this moment as an opportunity to correct these injustices put in place by the previous government.