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I am
writing today with regards to the above-referenced matters appearing on
Planning Committee’s Agenda for July 6, 2015. The above-referenced matters are proposals for solar energy projects,
primary ground-mounted projects.
Despite the
clear limitations of the Provincial approval process, I nevertheless urge
Planning Committee to consider offering its support for all of the projects
appearing before it on July 6th, 2015. City Council’s endorsement of these solar
energy projects will go a long way with the provincial Ministry of Environment
and Climate Change.
EarthCare Action
Plan: Energy
Although
the City of Greater Sudbury lacks a renewable energy strategy which might guide
decision-makers such as Planning Committee and Council in their consideration
of these solar energy proposals, there are nevertheless some policies which the
City has adopted through the EarthCare Action Plan which are relevant to these
projects, which Planning Committee and Council should strongly consider.
All of
these proposals are in keeping with the City’s stated goals related to
renewable energy and the reduction of greenhouse gas emissions, as stated in
the EarthCare Action Plan: Energy.
Specifically, these new solar energy projects will help achieve the
following Objectives of the Action Plan, to “Increase local supply of energy
derived from renewable sources.”
For this
objective, the EarthCare Action Plan: Energy indicates that City of Greater Sudbury
will promote and facilitate opportunities for energy generation that are
supported by Ontario’s Green Energy Act.
Further, EarthCare partners are tasked with attracting and retaining
corporate investment in local renewable energy projects, and building local
labour capacity in renewable energy, and continuing efforts to generate
renewable energy locally.
The Public Interest
Clearly,
the City of Greater Sudbury has articulated a firm commitment to establishing
renewable energy projects within the City.
Given this past commitment to renewable energy on the part of the City, if
the City should withhold its support of these solar energy projects at this
time, there ought to be a very good reason in the public interest for doing so.
I submit
that there is no good reason for the City to considering withholding its
endorsement of these solar energy projects.
I
understand that concerns have been raised by members of the public, largely
through social media, but also at public meetings related to these energy
proposals. I have also seen support for
these projects on social media sites, but it is my observation that I have seen
more people comment unfavorably than favorably, at least with regards to some of
these proposals.
In this
case, however, public comments should not deter Planning Committee and Council
from following the lead of the City’s excellent public policy as found in the EarthCare
Action Plan: Energy.
Concerns Related to
the Province’s Process
It is my
observation that most of the more legitimate concerns of the public have more
to do with the provincial process for evaluating these proposals than with the
projects themselves – although I have to acknowledge that I have seen concerns
raised about the impacts of these proposals on neighbouring landowners and land
users as well, which I will address further – as well as a number of comments
made publicly which have simply disparaged renewable energy in general, which I
won’t further address.
The
provincial process is, to me, an awkward one.
I would certainly like to have the provision of more technical
information up-fronted as a part of the process. That
being said, technical information pertaining to a number of the issues
identified by the public, including developing in wetlands, developing in the
significant habitat of animal and plant species (which may include the habitat
of endangered species), and stormwater runoff will all be undertaken by the
solar energy project proponents as part of the provincial approval process.
Like the
City of Greater Sudbury, the Ministry of Environment and Climate Change is
charged to look out for the impacts of development on natural heritage features
and ground and surface water. The
provincial approval process for these will restrict development in circumstances
where the habitat of threatened and endangered species is found to be present,
and will address ways of mitigating impacts on other natural heritage features. Stormwater will be managed in ways which are
acceptable to the Ministry of Environment and Climate Change. It should be noted that the provincial
approval process already restricts solar energy projects from developing in
prime agricultural areas, or in areas set aside for industrial and commercial
development, or in areas adjacent to existing residential development, unless
the project can be appropriately buffered.
Solar Energy
Project Location-Based Issues
The ground-mounted
solar energy proposals appearing before Planning Committee on July 6th,
2015, are all located in the City’s rural area (on lands designated “rural” in
the City’s Official Plan). None of these
lands have been identified by the City as areas worth preserving for
agricultural activities (they are not prime agricultural areas - although
agriculture is a permitted use on rural lands).
Neither do any of these lands have designated natural heritage features.
Some lands are impacted by floodplains,
and all of the project lands which are so impacted contemplate development
outside of floodplains. All of the
subject proposals are located in areas outside of the City’s settlement area
boundaries, and none are in areas which have been set aside for residential
development over the lifetime of the City’s Official Plan (although it should
be noted that one proposal is located in the Valley Urban Reserve – on lands
set aside for urban development at some point in the future, beyond the
lifetime of the City’s Official Plan).
Some
members of the public have suggested that some proposals may be within
provincially significant wetlands which have yet to be evaluated by the
province. At this time, the province and
the City have not identified any of the areas as being within a provincially
significant wetland. It the lack of
provincial evaluation is an issue which the province can address through the
provincial approval process.
Public
assertions have also been made that some of the projects contain lands which
include the habitat of threatened and/or endangered species, or other significant
wildlife habitat. As part of the
provincial approval process, each project will look at and address these
issues. At this time, however, there do
not appear to be any flags in the City’s Official Plan which would suggest that
any of these projects are include provincially significant wetlands, the
habitat of threatened or endangered species, or other significant wildlife
habitat.
Similarly,
surface and ground water impacts will be evaluated by the province as part of
the provincial review process.
Again, I
personally would be more comfortable if these issues were to be addressed
upfront in the process, but the province in its wisdom has determined that a
more specific analysis of these and other issues (such as archaeological
heritage) will be addressed later in the provincial process. Given that these issues are all matters of
provincial interest identified in the province’s own policy documents, we
should have some degree of comfort knowing that the province is likely to look
after matters which it has itself flagged as important.
Issues Which are
Non-Substantive and Why
The public
has also identified a number of other issues with these proposals which I
consider to be largely non-substantive – and I hope that Planning Committee and
Council will agree with my analysis.
From what I
have seen of my review of comments on social media sites like Facebook, many in
the public are taking issue with the fact that these solar energy projects will
result in a loss of tree cover. Concerns
with a loss of tree cover are often related to a loss of view from the windows
and backyards of abutting landowners, and a loss of prestige for the City of
Greater Sudbury, as removing trees runs counter to regreening initiatives
underway in our City since the 1970s.
I have been
a big supporter of municipal regreening initiatives. There were many reasons initially identified
with regards to replanting trees and shrubs in our communities. While I was not around at the time that the
regreening initiative began, I can’t believe that one of the purposes of the
initiative was to preserve each and every tree in the City for its own
sake. Indeed, subsequent development
proposals in our City for residential subdivisions, including many in the
former Towns of Valley East and Walden, have led to the destruction of
forests.
Although
preserving tree cover is a worthy initiative, the fact is that Greater Sudbury
has an abundance of forested areas.
These solar energy project proposals are being made because the subject
lands for each proposal are in locations near or adjacent to vital energy infrastructure
needed to connect projects to the grid.
As such, none are located in pristine areas of our City – all of the
sites are in areas which have been subject to some sort of development activity
in the past, whether specifically onsite or within close proximity to the
subject lands.
Further,
the City of Greater Sudbury has never passed a tree-cutting by-law under the
Municipal Act to limit the removal of trees from private property. As such, there is nothing stopping any of the
landowners today from clear-cutting the properties currently being considered
for solar energy use. Clear cutting
these properties can take place today – with or without solar energy
development applications.
Further,
the range of permitted uses in rural areas includes a number of uses which, by
their very nature, will lead to a loss of tree cover.
While I
respect that people are concerned about the loss of vegetation in our
community, I would submit that these proposals are not substantively different
than situations which can occur now on the subject properties as-of-right for
property owners, without any public consultation necessary.
Issues Related to
View Impacts
I
understand that adjacent homeowners may be concerned about the loss of tree
cover on their neighbour’s property. To
address that very issue, the provincial approval process requires the creation
of a buffer area between the solar project and the lot lines of abutting
residential land uses. I understand that
these buffer areas are to include visual buffers as well.
Finally,
concerns have been raised by some members of the public that there are better
locations for these solar energy projects.
I agree with those concerns, as I clearly think that there are a number
of locations in our community which are more suitable for this type of
development than the ones being considered by Planning Committee on July 6th,
2015. However, the same can likely be
said about a number of development proposals which have recently appeared on Planning
Committee agendas. The City (or the
Province for that matter) doesn’t get to be the decision maker in terms of
choosing specific sites for certain kinds of development. Instead, as decision makers (and in this
case, as potential endorsers) the City’s task is to evaluate matters which come
before it, brought to it largely by private land-owning interests.
The onus is
clearly on the development industry in these circumstances to make the case to
the City that the lands can meet the tests of public policy and regulation
before development is allowed to proceed.
In the case of these solar energy proposals, those tests will be
addressed at the provincial level through the Province’s own processes. If the solar energy developers can’t make the
case to the authorized decision-maker that the projects will proceed, than the
Province will have the ability to put a stop to any or all of the projects.
Community Vibrancy
Funds
The
development of any renewable energy projects within the jurisdiction of the
City of Greater Sudbury will lead to contributions made to the City through
community vibrancy funds. As articulated
in the staff report, for a 25 MW project, the City can expect to receive
approximately $60,000 per year in community funding. While this amount is not especially
considerable (and while not all proposals will generate a contribution at that
level), taken over the expected 20-year life of each proposal, vibrancy fund
contributions for a 25 MW proposal would be estimated at $1.2 million – all of
which are in addition to taxes the City currently receives from these rural
lands.
Recap
To recap, I
believe that the City has laid out a clear interest through the EarthCare
Action Plan: Energy in facilitating the development of renewable energy
projects in the City. While I understand
that there have been a number of concerns raised by the public, I believe that
these concerns will either be addressed by the Province through its approval
process, or are lacking in substance.
The City
has before it an opportunity to become the “Solar Capital of Northern Ontario”.
To do so, however, the City must first champion the proposals which are in front
of it. Each of these proposals
represents an opportunity for economic development. On their own, each proposal is limited in
terms of its likely impact on the local economy, but if the City is able to
strategically position itself as being “open for business” to the renewable
energy industry, it is quite likely that the sum of economic development
activity will be greater than its parts.
Admittedly, endorsing these projects would ultimately be just one of the
first steps in the City establishing such a reputation (although in my opinion,
it will go a long way after the City refused to consider any ground-mounted
solar energy projects outside of gravel pits in its 2013 decision related to
solar applications). First steps are,
however, important ones to make.
Subsequent steps would include developing a renewable energy strategy
which includes goals, objectives and timelines for desired outcomes. It could also include an inventory of
priority lands for renewable energy development, or policies to further guide
private renewable energy development applications.
Other
communities are taking a lead. Recently,
Oxford County endorsed a resolution committing itself to being powered by 100%
renewable energy by 2030, opening its doors to economic development activity
from the renewable energy sector.
Certainly Greater Sudbury is equally positioned to enjoy the benefits of
the renewable energy revolution that is underway around the world – but to do
so, we must have the courage to stay the course with our convictions, and the
foresight to plan ahead for our success.
That is why
I believe that the public interest in developing renewable energy as
articulated in the EarthCare Action Plan: Energy is paramount, and that the
City should endorse these projects.
Sincerely,
Steve May
(opinions expressed in this blog are my own and should not be interpreted as being consistent with the views and/or policies of the Green Parties of Ontario and Canada)
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