Here’s the intro from a white paper from Endura energy, a UGE company. Read the full paper here.
In July and December, 2014, the Ontario Power Authority (now the Independent Electricity System Operator, IESO) issued 224 MW of Feed in Tariff (FIT) 3 contracts for electricity generated using renewable fuels, 69 MW of which were for small (≤ 500 kW) ground mount solar generation (Figure 1).
Small ground mount solar projects for FIT 3 and previous FIT allocations, much like utility scale solar projects (> 500 kW), are subject to strict environmental, archaeological, and cultural siting requirements, enabled by the Green Energy Act, 2009 (GEA). Since the inception of the GEA, obtaining the necessary permits and approvals for all ground mount solar PV projects has been very expensive. Projects were required to comply with Ontario Regulation 359/09 (O. Reg. 359/09) of the Environmental Protection Act (EPA, 1990) and obtain a Renewable Energy Approval (REA). To alleviate the expensive and cumbersome process for small ground mount solar PV, the Ontario Ministry of the Environment (MOE¬¬) introduced in 2012 the Small Ground Mounted Solar Facilities category into the Environmental Activity and Sector Registry (EASR) under Ontario Regulation 245/11 and 350/12 of the EPA.
The EASR is intended for activities or sectors that:
• Pose minimal risk to the environment and human health when regulated and following specific rules
• Use equipment and processes that are standard to the industry or sector with known environmental impacts
The EASR stipulates specific regulations for an activity; applicants who self-register for the EASR are required to follow its rules but are not requir¬¬ed to follow the typical process of such activities in accordance with the REA requirements of under the EPA.
The IESO enforces environmental screening criteria through the FIT rules (Sect. 2); the MOE enforces these through the EASR (Sect. 3). However, lack of consultation between the IESO and MOE leads to varying definitions for common terms and conflicting limits for the same criteria. Both the FIT rules and EASR lack clarity, and experience is required to avoid misinterpretation (Sect. 4).
While the EASR is designed to streamline the application process by amalgamating environmental screening requirements into a single process, only those requirements fulfilled by an REA are replaced by the EASR; compliance with all other government ministries and legislation is still required, and is the responsibility of the project developer (Sect. 4).
The additional screening and permitting requirements should be considered in parallel with the FIT and EASR requirements. They can require a significant amount of lead time and treating them as an afterthought has previously delayed projects. Figure 2 outlines the recommended permitting and approvals process for a ground mount solar PV project, and where to find information herein.
This paper will identify and explain the environmental concerns and siting requirements for small ground mount solar PV projects within the FIT 3 and EASR frameworks, discuss the discrepancies, interpretations, and provide a path forward towards successful project execution.
Read the full white paper here