1. Under the proposed…

1. Under the proposed regulation, the following types of renewable energy generation facilities would not be permitted to be connected to the distribution system or the transmission system.

  a. Non-Rooftop Solar PV Facilities proposed to be sited less than 15 metres from the facility property boundaries.

  What is the justification for placing such restrictive limitations on Solar PV facilities?  Under the current OBC many structures can be placed as close as 1.2m from property boundaries.  One area where Solar PV can be a real benefit is when it is installed on solar carports in parking lots. Parking lots are otherwise low value space and adding solar carports can increase the economic value of that land for the land owner while at the same time having a positive environmental impact.  To impose a 15m setback would greatly limit where solar carports could be implemented.

 We strongly oppose this restriction.

 However, declaring that solar carports are to be considered rooftop solar instead of Non-Rooftop would alleviate this issue altogether.

  b. Non-Rooftop Solar PV Facilities and Wind Facilities proposed to be connected to a residential dwelling.

  Seeing as Solar PV facilities do not generate any noise why treat them differently than say, a shed.  While it may be reasonable to add height restrictions in order to prevent an individual from installing a 40ft tall tracker in their backyard why would we place this restriction on residential properties?  Many people dislike their  neighbour’s shed, pool, deck or gazebo for various reasons and yet individuals are free to install these features without restriction.  Why should installing a Solar PV system be any different.  As an example, it is certainly possible for an individual to install a ground mounted solar hot water system in their backyard to heat their pool.  Why treat solar PV differently?

 Also, many homes have a small carport/lean to at the side of their home.  These are often extremely close to the property line.  Why should it matter if the roof is conventional wood joist construction with asphalt shingles versus aluminum rails and solar panels as the deck surface? Does the adding of walls and a roof under the solar panels to call it a garage fundamentally change the impact of the solar panels to the site?

 We strongly oppose this restriction.

  c. Non-Rooftop Solar PV Facilities over 10 kW proposed to be located on properties within prime agricultural areas, as defined in the Provincial Policy Statement and designated in an official plan.

  While it is understandable that the Government wants to protect prime farmland from endless sprawl this proposal is far too restrictive.  The current EASR guidelines that allow up to a 500kW Solar PV system to be installed on up to 3ha of land would be a far more well balanced approach.  This restriction would essentially ban all farmers from installing ground mounted PV systems.  That would be to trample upon their property rights and freedoms to use their land as they wish.

 We strongly oppose banning all ground mounted PV from prime agricultural land.  The current EASR rules (500kW/3 ha limits) are reasonable and should be kept.

  d. Non-Rooftop Solar PV Facilities over 10 kW proposed to be located on a property that is not captured by an official plan for which the prime agricultural area designation process has been completed.

  We strongly oppose banning all ground mounted PV from prime agricultural land.  The current EASR rules (500kW/3 ha limits) are reasonable and should be kept.

  Here are some other thoughts to put in perspective when considering using farm land for solar PV

  •Farm land is already used for non-food production, Ontario grows about 10,900 acres of sod each year (4,411 hectares).  Surely having clean, healthy air to breathe is a more noble endeavour than having a ready-made pretty lawn.

 •There are a number of agricultural uses that can co-exist amongst the ground mounted solar trackers we typically use, although recent rule changes have forced development onto Class 4 and lower soils which are marginal agricultural lands.

 •When the productivity of these systems has ended, the land can be returned to its original state more easily after solar development than most other types of development.

  http://www.omafra.gov.on.ca/english/crops/facts/info_sodprod.htm

[Original Comment ID: 212047]