To: Ministry of the…

To:
Ministry of the Environment and Climate Change
Transferred to - Ministry of the Environment, Conservation and Parks

New regulation under the Environmental Protection Act to close the White Pines Wind Project
ERO number - 013-3835
Notice type Regulation Act - Environmental Protection Act, R.S.O. 1990
Posted by Ministry of the Environment and Climate Change
Transferred to - Ministry of the Environment, Conservation and Parks
Notice stage - Proposal
Proposal posted - October 17, 2018
Comment period - October 17, 2018 - December 1, 2018 (45 days) Open
File # EBR -013-3835
Comments on the consultation draft Ontario Regulation to be made under the Environmental Protection Act Closure of the White Pines Wind Facility and the draft Technical Requirements for the Closure of the White Pines Wind Facility
----------------------------------------------------------------------------------------------------------------------------

This communication is directed to the above Draft Regulation File

This communication address's key omission issues of the Draft Technical Requirements - Closure of the White Pines \Wind Facility Document - EBR 013-3835.

The Government draft document addresses numerous decommissioning items which are relevant - but does not go far enough in setting timelines for the decommissioning process.

WPD prepared the 9 sites for Turbine installation over a 4 month period and installed and fully complected 4 Turbine installations and 5 partially erected installations within a 1 month period.

As directed by the Government's Bill #2 these sites are to be decommissioned.

If the Turbine components could be delivered to the sites and installed over a 1 month period - surely they could be dismantled and removed from Prince Edward County within a 1 to 2 months period of time.
This decommissioning should start immediately and be completed before the ERT deadline of April 1st - "Do not Construct and do not Disturb Banding Turtles" time period.

The Government Environmental Protection Act Draft needs to specify a definite period of time for the removal of the Turbine components.
This is absolutely critical - for the optics of the decommissioning draft to be an acceptable document.

Once the 4 Turbines are lowered, the components from all 9 sites removed and the sub stations removed from PEC - I suggest that a longer period of time (1 year or less) be granted for the restoration of habitat, access roads, crane pads, turbine foundations, geotextile materials, soil uncompacted - to their natural state or agricultural purposes - and their pre construction condition.
PEC roads agreements must be adhered to as set out by the ERT and the PEC Municipality.
A strict concern and monitoring for the Natural environment, species at risk, and agreements by Municipal and Provincial Governments must be addressed and agreements adhered to.

Failure to do so by WPD should result in significant penalties to the Corporation.
And if WPD does not undertake this decommissioning as scheduled, the Government must initiate this decommissioning schedule at WPD's expense.