Wind projects under 2 MW are exempt from the EA process, while those above that threshold must go through an environmental screening. The catch is that anyone dissatisfied with the screening report can ask the ministry to require the developer to conduct a full-blown environmental assessment. This would add substantially to the cost of the project, with the result that its implementation will be delay or stopped.
Joyce McLean, manager of green energy generation for Toronto Hydro Energy Services, calls the low size threshold for wind inappropriate, especially when numerous thermal technologies have higher thresholds. Natural gas plants below 5 MW are exempt, as are cogeneration (combined heat and power) projects below 25 MW. Exemptions are also given for landfill gas projects under 25 MW and waste biomass projects under 10 MW. "This is a zero-emission technology. How can you require a more stringent process for it than for one that has emissions, even if it's a small emission?" she questions.
The wind industry has been lobbying against the 2 MW threshold since the ministry released a draft of the EA regulation a year ago. At that time Jason Edworthy of Vision Quest Windelectric issued an eight-page response to the proposed rules. He argued the low threshold will add significantly to the cost of wind power by putting pressure on the industry to develop only very small, sub-economic projects. Developers of larger projects will carry EA costs that their competitors don't share. "This has the effect of reducing the competitiveness of the wind energy industry, and adversely affecting its ability to compete and participate in the new market," Edworthy says.
Lack of understanding
Now that the final regulation is in place, Edworthy says he's "disappointed that the comments of the wind energy industry were apparently not considered." McLean says she thinks part of the reason the industry's lobbying efforts were unsuccessful is the lack of understanding of wind technology among government officials. "We're hoping those rules will be modified over time as the public and the ministry officials get more acquainted with what wind turbines look like, how they behave and, in particular, what they don't do."
Environment ministry officials explain the differences in exemption levels by pointing out that some technologies are subject to other approval requirements in additional to the EA. Technologies that emit air pollutants, for example, must get permits for that. The lower threshold for wind was chosen to try and capture some of the potential impacts that aren't addressed elsewhere, says the ministry's Elaine Hardy. "With wind there are some issues related to, say, aesthetics that may not be addressed through any other approvals." Public concern about the impact on birds was also a factor, she says.