DEMONSTRATING DEMAND:The…

DEMONSTRATING DEMAND:The criteria for demonstrating demand indicate that the government is proposing to accommodate a changing marketplace for electricity production. (As indicated in the Nov.2017 roll-out of the former Liberal Government's Long Term Energy Plan (LTEP).
The REA process will now apply to generation facilities operated by a diverse group of owners such as manufacturing entities who want to generate their own electricity.
Even though new projects will likely focus on solar energy, the proposed changes will also affect any new wind turbine projects.
• The 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 the provincial system, leaving the province with more costly stranded production, which must still be paid for and if excess to demand, is sold below cost to our neighbours to the south, who can then entice Ontario Industries to leave Ontario to access our made-in-Ontario electricity generation, for significantly less cost and without paying taxes on it.

• Since Ontario’s base-load generation (hydro, nuclear) is already largely free of carbon emissions, (and even nuclear waste will soon have the potential to be re-used), promotion of large-scale, private renewable generation should be deferred until the added capacity is actually required.
• The requirement to demonstrate demand should also apply to increases of nameplate capacity at individual sites within projects. If there is no need for the power, there is little need to retrofit older turbines, (on existing sites too close to neighbouring properties), with turbine generators of increased capacity. Until energy storage becomes more viable, (and even the best facilities are only working on 24hours of storage capacity), Industrial Wind Energy Generators should not be encouraged, except as an experiment in very remote regions without other forms of readily available electricity, and with the surrounding communities protected from any and all harm.

EXISTING CONTRACTS:Projects should be fully compliant with the terms of the REA before any changes to ownership are approved as without compliance, the original proponents can sell the project and distance themselves from being held accountable for problems which arise. With each change of ownership, the original contracts become less likely to be followed/ harder to enforce. This focus on compliance should include proper handling of complaints regarding the operation of existing turbines, which must be resolved to the satisfaction of residents as required by the REA. The Unifor/CAW turbine is just one example of this difficulty meeting the REA noise requirements and the negative impact on many area residents and local residents are only faced with 1 turbine, rather than the multiple turbines located elsewhere within 3km of a receptor.

IMPACT ON THE ENVIRONMENT
The current noise limits and set-backs are not sufficient to protect the health of nearby residents.
Numerous problems with the current REA process indicate that changes will be required to achieve this objective.

Concerns:
• Current set-backs for wind turbines need to be increased based on learning from complaints from existing projects, new research into wind turbine noise (revisions to the International Electrotechnical Committee/ Canadian Standards Association - IEC/CSA 61400-11-2013 have not yet been required and the next Canadian upgrade was due in 2018), and actions other jurisdictions have taken to protect the health of people living near projects.
• The current review process outlined in Regulation 359/09 needs to be completely revamped 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 critical on many issues, and in particular to expand the scope for appeals of REA decisions (while the standards for successful appeal need to be made more realistically achievable.)
• 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 realistically achievable.