Alberta's Regulatory Framework for Solar/Renewable Electricity, 2022: Opportunities & Challenges
Introduction
With the 1980 introduction of Bill 228: “Right to Sunlight in the Alberta legislature”, the Alberta legislature has over 40 years maintained regulatory oversight over solar and renewable energy policies.
The world is constantly striving to achieve an affordable, secure, and sustainable energy mix given significant fossil induced environmental and climatic shifts. This article examines and summarizes the present legislative and policy framework for solar/renewable energy growth in Alberta which highlighting opportunities and challenges therein.
?1.0??????The Renewable Energy Act
The Renewable Electricity Act is a broad piece of law aimed at encouraging the usage of renewable energy in the province. Renewable energy resources are defined as any "energy resource that occurs naturally and may be renewed within a person's lifetime, including, but not limited to (i) moving water (ii) wind (iii) earth heat (iv) sunshine, and (v) sustainable biomass," according to the Act.
Importantly, it sets a goal for renewable energy to account for 30% of all electrical energy produced in the province by 2030 - an essential date for driving expansion in the solar industry, albeit without any enforcement methods.
?2.0??????Hydro and Electricity Act
The Hydro and Electric Energy Act specifies the approval process for power plants, which are classified as "facilities for the generation and collection of electric energy from any source." In regulating this procedure, the Act stipulates that no one may construct or operate a power plant without the Alberta Utilities Commission's approval (AUC).
This is the most pertinent step for utility-scale solar developers, and we will focus on four AUC guidelines in particular:
2.1 Rule 007: Applications for Power Plants, Substations, Transmission Lines, Industrial System Designations, and Hydro Development
2.2 Rule 012: Noise Control ("Rule 012");
2.3 Rule 033: Post-Approval Monitoring for Wind and Solar Power Plants (“Rule 033”).
2.4 Rule 024: Rules Regarding Micro-Generation ("Rule 024"); and
2.1??????Rule 007: Applications for Power Plants, Substations, Transmission Lines, Industrial System Designations, and Hydro Development
Preliminary legislative and policy requirements are listed in Rule 007. This rule took effect in September 2021, according to the AUC. The new Rule 007 provides special information and standards for solar power plant applications, as well as a dedicated solar power plant application form.
The revised Rule 007 acknowledges the rapid evolution of solar technology. The AUC shall therefore be notified of the proposed renewable technology type being developed up to 90 days before the project start date.
This time-frame allows for the possibility of technical advancement between initial application and project start date. Rule 007 specifies the information that must be included in a solar power application. Descriptive information about the power plant and collector system, including the number of panels, nominal capacity of each solar panel, and the total power plant capacity in MW, are required from the AUC.
An emergency response strategy is also standard.
A new requirement for a rigorous solar glare study is also significant. For solar projects prior to this guide, the AUC required an assessment of the project's glare, especially that which may damage nearby residents and property, but the study was not precisely controlled.
Solar glare assessment reports for receptors within 800 m of the project boundary and registered and known unregistered aerodromes within 4,000 m must now be submitted by project proponents. The report should contain sun glare predictions.
A table listing the estimated intensity of solar glare at crucial sites along motorways, major roadways, and railways. Included in the list of specifics shall be:
Some of these details are not necessary if a provincial or federal environmental assessment has been completed. In that case, the assessment must be included.
The new Rule 007 also demands an analysis of how the operator will ensure the project has sufficient cash to address decommissioning and reclamation costs at the end of its life cycle.
A signed Renewable Energy Referral Report from Alberta Environment and Parks is also necessary, as is a list of all other government offices from which approval is required.
?Renewable Energy Referral Report – Wildlife Directive for Solar Energy Projects
Referral Reports are part of the AUC power plant approval process. According to Alberta Environment and Parks, they are required by the Wildlife Directive for Solar Energy Projects (the “Directive”). Referral reports are required for new and modified projects.
To guarantee that potential environmental and health impacts of the project are minimized, AEP Wildlife Biologists must submit Referral Reports that describe the mitigation efforts to be undertaken (or have been undertaken) by the project developer. These may include site selection, monitoring, construction, and standard mitigation of wildlife and habitat risks.
Choosing a Site
The Directive focuses on how proponents should choose a site for a solar energy project, as this is the first and most important component in limiting wildlife damage. The Directive stipulates that “solar energy projects shall not be sited in regions of native grasslands, native parkland, old growth forest stands, named water bodies, valley breaks (including coulees), valleys of significant permanent watercourses, and the eastern slopes region”.
The Directive provides varying levels of protection for animal habitats.
Solar energy projects must avoid vital habitat, as defined by the Government of Canada as identified through the federal species at risk regulatory process.
Also, special access zones, vital wildlife and biodiversity zones, and grizzly bear zones must be avoided or minimized when solar energy installations are sited. Among the wildlife zones where solar projects are prohibited are the greater sage-grouse range, the caribou range, and water-bodies containing trumpeter swans.
AEP defines the borders of these areas, which are displayed as maps of important range layers or key wildlife layers on the AEP website.
?“These standards must be followed in the planning and implementation of a solar energy project.” The Directive distinguishes between “best management practices'’ and “practices that may aid in the planning and location of activities."
Project Layout and Pre-Construction Standards
Project layout and pre-construction standards are assessed in the second stage. The Directive demands wildlife and vegetation assessments, setbacks, and timing limits at this stage, all based on current information. Avoid siting near water-bodies, wide poplars, and multi-story, mature mixed-wood forests.
Construction and Operation
Stage 3 deals with mitigation during construction and operation. During this stage, project proponents must develop site- and species-specific construction and operational mitigation plans, including plans for temporary disturbances.
A construction plan must include timing restrictions, noise mitigation, wetland preservation, wildlife movement protection and management, and procedures for preventing and responding to stranded and injured wildlife. The Directive states that all construction activities associated with solar energy projects must minimize habitat disturbance and fragmentation.
Post-Construction
The Directive also specifies post-construction monitoring and management. This monitoring will assess the effectiveness of mitigation efforts and identify any ongoing wildlife risks.
This list is not exhaustive, but it does show the detailed process required to complete a Renewable Energy Referral Report. The Directive, however, only applies to solar projects larger than 1MW.
Urban and federal projects do not require referral reports. In their decision to approve the Edmonton E.L. Smith Solar Power Plant, the AUC states that AEP determined that the Directive did not apply because the project was for an urban area.
?If integrated into an existing anthropogenic footprint, like rooftops, solar energy infrastructure has low impacts on wildlife.
But, given that the E.L. Smith Solar Power Plant is intended for river valley land, this decision is questionable. To properly assess wildlife impacts in urban environments, the Wildlife Directive and how it is administered in natural areas must be amended.
Finally, the Directive's emphasis varies depending on the solar technology proposed. It aims to reduce direct bird-panel collisions. But Concentrated Solar Power (CSP) poses a risk of solar flux injuries, including incineration of birds and feather singeing.
Due to the high levels of wildlife mortality associated with this technology, CSP projects are deemed a higher overall risk. As with most negative impacts, habitat loss is still the main contributor. This research has focused on avian species, but as the number of solar projects grows, it may be necessary to include other species as well.
Solar Power Plant Application Form
This form is part of Rule 007, which was released in March 2021. When describing the power plant and collector system, project proponents need to provide information such as the make, model, and nominal capacity of each solar panel in MW (or total plant capacity in MW). In addition to the solar glare assessment, the application covers other approvals, participant involvement, and other Rule 007 requirements.
Rule 007 also sets out specific application requirements for energy storage projects, including:
A noise impact assessment as set out in AUC Rule 012 is also required for energy storage projects.
Finally, Rule 007 specifies the new participant involvement program for battery storage facilities which sets a notification radius for both urban and rural projects.
2.2 ????Rule 012: Noise Control
AUC Rule 012 addresses noise control in new construction. For a given project, the overall permissible sound level is calculated separately for night and daytime.
Before approving a project, the AUC requires a Noise Impact Assessment to ensure the permissible sound levels have been calculated and respected. In addition, it ensures that the project will not exceed the permissible decibel levels.
2.3??????Rule 033: Post-Approval Monitoring Requirements for Wind and Solar Power Plants
?Rule 033 specifies post-approval requirements for all solar projects. The AEP and AUC require approval holders to submit annual post-construction monitoring survey reports (section 3(3)). The project proponent must submit an annual post-construction monitoring survey report to AEP and AUC within 13 months of the project becoming operational and on or before the same date every year thereafter for which AEP requires surveys.
Approval holders must abide by:
Environmental Protection and Enhancement Act
In addition to the AUC clearance process, the Environmental Protection and Enhancement Act (EPEA) has certain approval criteria. The Alberta government revised the EPEA's Schedule of Activities in 2017 to incorporate wind and solar energy generating.
These changes widened regulatory oversight of activities related to the development, operation, and reclamation of these projects. Larger solar projects are not specified as either mandatory or exempt under the EPEA. Nonetheless, the Director may require environmental reviews for solar projects.
The Activities Designation Regulation includes “a plant that produces thermal electrical power (greater than 1 MW)” in the definition of power plant. This definition could include solar projects, particularly concentrated solar power and thermal power plants.
Conservation and Reclamation Regulation
The EPEA and its regulations set land conservation and reclamation requirements. Conservation is "planning, managing, and implementing an activity to protect the essential physical, chemical, and biological characteristics of the environment." Equipment, buildings, and structures are removed; contaminated land and water are decontaminated; land surface is stabilized; contours are maintained; structures are constructed; and other operations as required by law. Operators must conserve or reclaim specified land and obtain a reclamation certificate unless exempt.
These rules apply to "specific land." Conservation and Reclamation Regulation defines specified land as land with a renewable energy project, including solar projects. The Regulation defines operator as the person who conducted the activity, the statutory authorization holder, a working interest participant, the surface lease holder, the successor, assignee, executor, administrator, receiver, receiver-manager, trustee, or principal agent of the above.
Reclamation certificates may be required for renewable energy projects, but they are exempt if they qualify as micro-generators under the Micro-Generation Regulation and if their total footprint is less than 1 hectare.
In September 2018, the "Conservation and Reclamation Directive for Renewable Energy Operations" released the accompanying regulations which amongst others include:
Achieving equivalent land capability is defined as “the ability of the land to support various land uses after conservation and reclamation is similar to the ability that existed prior to an activity being conducted on the land.” After obtaining a reclamation certificate, the operator remains liable for environmental protection orders issued in relation to the specified land for 25 years. However, a renewable energy reclamation certificate application has specific requirements.
Appendix D of the regulation contains a checklist for all information needed before a reclamation certificate is issued. The Conservation and Reclamation Regulation includes a financial security system. This allows requiring security during project approval to ensure reclamation is completed.
Specifically, the amount required must be sufficient to ensure completion of conservation and reclamation on the specified land, as determined by the Director. The financial security regime in the regulation is unclear for solar projects. Solar projects are not specifically exempted nor required.
Financial security is required for projects that:
These don't mention solar or renewable energy projects. While the Regulation recognizes that not all activities are covered by the above lists, it allows the Minister to declare them so. This allows the Minister to require security for a solar/renewable project.
Micro-Generation Regulation
The Micro-Generation Regulation regulates generating units that:
This rule also allows for net-metering, where consumers are credited for any excess electricity produced and sent to the grid. Activating a micro-generating unit depends on a project proponent and wire-service provider agreement.
With the exception of party disputes, the AUC approves most micro-generation projects. It is not possible to appeal an AUC decision.
In 2017, this Regulation was amended to allow small micro-generators under 150 kW to be credited for electricity sent back to the grid at retail rates. Larger projects would not have qualified previously. Large micro generators, 150 kW and above, are credited for electricity sent back to the grid at the hourly wholesale price.
The size of applicable micro-generators has been increased from 1 MW to 5 MW, and they can now serve two or more sites on the same customer's property. These changes expanded who qualifies for the Regulation's programs, allowing more people to generate their own renewable energy.
AUC Rule 024 applies to micro-generators in conjunction with this Regulation.
2.4??????Rule 024: Rules Respecting Micro-Generation
Rule 024 specifies AUC requirements for micro-generators.
The micro-generating unit is designed to meet all or part of the customer's total energy consumption, and its nameplate capacity is less than 5 MW. Qualifying projects can be connected to the interconnected electric system without AUC approval.
To be exempt from AUC approval, the project's construction and operation must not directly affect another person, have no adverse environmental impact, and comply with Rule 012 noise requirements. Micro-generating units are not subject to the standard AUC process, but they must still notify and consult with stakeholders and send an owner-approved micro-generation notice.
The owner must accept or dispute the notice within 14 days. In a dispute, the AUC decides on project approval. The owner must notify the unit customer within 14 days and file a complaint with the AUC, which has 30 days to decide whether the unit qualifies as a micro-generator.
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Small Scale Generation Regulation
The Small-Scale Generation Regulation (SSG Regulation) is designed to bridge the gap between micro-generation and utility-scale projects. The purpose of this Regulation is to allow "neighbors, community groups, municipalities, agricultural societies, rural and urban co-ops, universities, schools, Indigenous communities and other groups to partner on small-scale renewable energy projects".
It defines renewable energy is defined as: "Electricity generated from EcoLogo-certified products or solar, wind, hydro, fuel cell, geothermal, biomass, or other sources, if the emissions intensity of the electric energy produced or the total energy produced from the production of electrical and thermal energy is less than 418 kg of CO2e per MWh." Proponents can apply as either a small-scale or community generating unit under the regulation.
Qualifying as a Small-Scale Generating Unit
?To be considered small-scale, a project must:
(i)???????????be an eligible generating unit;
(ii)?????????use only renewable or alternative energy;
(iii)????????be part of an interconnected electrical system or located in an isolated community (as defined by the Isolated Generating Units and Customer Choice Regulation); and
(iv)????????ensure the distribution system has enough hosting capacity at the interconnection point to accommodate the generating unit.
Unlike community-based generators, small-scale generators are limited by distribution capacity. Although the Regulation leaves the criteria for small scale generation units vague, a statement from the now defunct Energy Efficiency Alberta indicated that there is no size limit. The only limit is distribution system capacity.
Small-scale generator owners must apply to the distribution owner for their service area where their plant is to be located. The distribution owner must review the application to determine if the generator is small-scale. If the distributor doesn't approve the generating unit as small scale, the AUC must decide within 30 days of receiving a "notice of dispute."
Unlike the micro-generation approval process, only disputes go to the AUC, speeding up the application process. Once a generating unit qualifies as a small-scale generating unit under the Regulation, the distribution owner is responsible for connecting it to the distribution system and installing a meter at the interconnection point.
The distribution owner must meter units within its service area and ensure the meter data manager provides the data to service providers, load settlement agents, and the ISO.
Qualifying as a Community Generating Unit
A project's benefits to the community must be shown to qualify as a community generator. Social, economic, and/or environmental benefits include training and development, endowment fund contributions, and community infrastructure development. A project proponent can apply to the AUC with a community benefits agreement or statement.
?Community benefits agreement:
A community benefits agreement is a legally binding contract between a small-scale power producer and a community group that confers social, environmental, or economic benefits to the community group. When the community group does not have an equity stake in the generating unit but receives other benefits from the project, a community benefits agreement is required.
?Community benefits statement:
A community benefits statement is a written statement from a small-scale power producer. The statement must refer to a small-scale generating unit owned by the community group and list its social, environmental, or economic benefits. This is a requirement for projects where the unit owner is not a partner.
?Community group:
The Regulation defines a community group as a co-op, school board, board of a public post-secondary institution or private college, Indigenous band, Metis settlement, municipal authority, society, incorporated congregation, irrigation district, agricultural society, condominium corporation, registered charity, or association under Companies Act or Rural Utilities Act. After achieving CGU status, the project gains benefits.
Once approved, the distribution owner must purchase a meter (maximum one per facility) for any community generating units not located in an isolated community.
Any community generating unit within an isolated community must purchase a meter (maximum one per facility) and pay for any system reliability upgrades.
In return, the ISO compensates the AUC with an ISO tariff or fee based on the AUC's compensation amount. In Alberta, the ISO is AESO.
The AUC has designated several community-based projects as CGUs. Following the submission of a community benefits agreement signed by Three Nations Energy, the Athabasca Chipewyan First Nation, Mikisew Cree First Nation, and Fort Chipewyan Metis Local 125, the project was deemed a community generating unit in early 2020.
The AUC used this agreement, along with ATCO's confirmation that the project was a small-scale generator, to grant it community unit status and the corresponding benefits. Solar projects in Innisfail, Oyen, Vulcan, and on the Peavine Metis Settlement have also been approved as CGUs. Observers have noted a lack of clarity about what a community benefits agreement or community benefits statement entails.
AUC documents are redacted, and approval decisions lack explanation, according to Professor Nigel Bankes.
AUC Rule 007
For solar /renewable energy and community projects, the AUC published a new Rule 007 in 2021 as provided above. The new Rule includes requirements for small-scale CGU applications.
Application must include quantity, make, model, and total capacity of eligible generating unit. Proponents must include a legal description of the location and indicate if the generating unit is in an isolated community.
The project proponent must also indicate if AUC approval is needed and, if not, why an exemption should be made. If the generating unit doesn't need AUC approval because it's a small power plant under Hydro and Electric Energy Regulation, the project proponent must confirm that it complies with the regulation.
Proponents must confirm that the unit is a small-scale generating unit and explain how the community group meets the regulatory definition. Finally, project proponents must verify the existence of a community benefits agreement or statement and describe the benefits received by the community group.
The AUC website states that "the development process of the community generation portion of the Regulation will not be addressed in the current discussions." Therefore, an AUC process for this is yet to be released.
AUC Forms
For small scale generation, the AUC published two forms in December 2019: Small Scale Generation Application Form and Small-Scale Generation Notice of Dispute Form.
Small-Scale Generation Application Form is needed to indicate interest in a project. Required information includes:
The Distribution Owner must complete the Small-Scale Generation Notice of Dispute Form in the event of a small-scale generating unit dispute. The form requires distribution owner, dispute, and application form info. For both forms, visit the AUC website.
The AUC released the CGU application form in March 2021 as part of Rule 007. The form is available now, but the Rule became effective in September 2021.
Required details include a description of the generating unit, its quantity, make, model, and total capacity in MW, its location, including the legal description, whether it's in an isolated community, and confirmation that it needs AUC power plant approval.
The application form details CGU eligibility. The form specifies that the project proponent should describe how the community group associated with the generating unit meets the definition of community group in the Regulation; the benefits received by the community group, including the category each benefit falls under (i.e., social, environmental, economic); ownership details; and a detailed breakdown of the project's meter equipment costs.
Municipal Government Act
Municipal Government Act (MGA) outlines municipal duties, powers, and functions. The MGA includes promoting environmental well-being among a municipality's purposes. Further, the MGA allows all municipalities to pass bylaws and regulate planning and development.
Edmonton and Calgary have expanded city charter powers.
The MGA states that municipalities may pass bylaws for municipal purposes including "the safety, health, and welfare of people and protection of people and property". Environmental bylaws that go beyond provincial requirements are allowed under Canadian municipal powers.
Edmonton and Calgary City Charter Regulations include authority to make bylaws for the "well-being of the environment," including "climate change adaptation and greenhouse gas emission reduction."
A municipality may (and must) make statutory plans. Intermunicipal, municipal, area structure, and redevelopment plans are examples.
A city can make non-statutory plans for planning and development. In terms of development, each municipality passes a Land Use Bylaw that covers zoning and permits.
While municipal plans can set planning priorities, an AUC license, permit, approval, or authorization trumps any municipal statutory plan.
Contrary development permits are overridden by a condition of a license, permit, approval, or other authorization granted by the Lieutenant Governor in Council or a Minister.
3.0??????Laws that Facilitate Solar/Renewable Growth
A healthy solar/renewable market requires a clear regulatory framework, but we also need to involve more people in solar/renewable energy production. This section focuses on PACE programs, which encourage solar installation.
Property Assessed Clean Energy (PACE)
PACE programs “allow property owners and developers to access long-term financing for energy efficiency, water conservation, renewable energy, and resiliency measures.”
PACE benefits include that:
PACE allows property owners to borrow money for renewable energy or energy efficiency installations. PACE's administrator covers the loan, which is repaid through property taxes.
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PACE programs run with the property, so the owner who benefits from upgrades pays for them. Only Ontario, Nova Scotia, and Alberta have PACE legislation, and the Alberta program is still in its infancy.
4.0??????Growth of Solar/Renewable Regulations in Alberta
The Alberta government passed Bill 10: An Act to Enable Clean Energy Improvements in 2018, amending the Municipal Government Act to allow for a PACE-like program (Alberta's Clean Energy Improvement Program).
The upfront costs of each energy system are paid for by municipalities, and the property taxes are repaid. The Alberta program allows loans to run with the property.
The MGA allows municipalities to create clean energy improvement tax bylaws that detail each PACE program. Once a municipality has passed a clean energy improvement tax bylaw, individual property owners may apply to the program administrator for a clean energy improvement project on their property.
After the program administrator approves an improvement, the municipality and property owner can enter into a clean energy improvement agreement. A clean energy improvement agreement lays out how the property owner will pay back the loan through property/municipal taxes. ?Details of this program are in the Clean Energy Improvements Regulation.
This regulation allows the Minister to designate a program administrator and calls on them to create a list of renovations, adaptations, or installations for which clean energy improvement agreements may be made. They're also responsible for creating a list of Qualified Contractors eligible to do the work.
The Government of Alberta dissolved Energy Efficiency Alberta (the original program administrator) in June 2020. Since then, the Alberta Municipal Services Corporation (“AMSC”), a subsidiary of the Alberta Urban Municipalities Association, has taken over as program administrator for the Clean Energy Improvement Program.
The AMSC will help municipalities pass necessary bylaws, ensure projects are properly installed, and pay Qualified Contractors for their work.
Devon, Rocky Mountain House, and Canmore have all passed a Clean Energy Improvement Program bylaw by spring 2021. Devon and Rocky Mountain House launched their programs in summer 2021.
Dissolution of the Balancing Pool
The Balancing Pool, a corporation formed in 1998 that helped Alberta transition to a deregulated electricity market, is being dismantled. Alberta never had a Crown utility company for electricity generation, distribution, and sale unlike many provinces in Canada. Even though the government controls electricity prices through power purchase agreements (PPAs). However, a crisis ensued when TransCanada, AltaGas, and Enmax ended their PPAs early in 2016. The companies’ said government moves, combined with low power prices, made contracts unprofitable. The Balancing Pool stepped-in to pick up their slack, and managed the agreements until the PPAs expired on Dec. 31, 2020.
Aside from managing PPAs that electricity companies wouldn't run, the corporation is tasked with assisting small-scale power generators in getting their power to market, running and financing a utility payment deferral program, and resolving any legal or commercial disputes from PPAs.
Balancing Pool profited from electricity it sold for 15 years. It gave Albertans $4.6 billion in monthly power bill credits from its profits. Following its dissolution, most generators will sell their generated power directly to the grid. The rate rider could end as early as 2027 or as late as 2030, according to the organization. The government hasn't decided when the Balancing Pool will close permanently.
5.0??????Financial Incentives
Municipal & Provincial Financial Credits
Different Alberta municipalities offer financial incentives for solar projects. Listed below are a few of them:
Banff: Solar Photovoltaic Production Incentive. This is a post-install rebate of $750/kW installed solar capacity up to 7.5kW.
In Brazeau County, a rebate program offers $0.75/watt up to $10,000 for grid-connected solar panels.
Canmore residents can apply for a 3 kW solar electric system for residential or commercial projects.
In Edmonton, a residential solar energy system costs $0.40/watt up to 40% of the eligible system costs or $4,000.
Medicine Hat residents can get $1.00/watt up to $6,000 for residential utility customers.
The Alberta Municipal Solar Program was established by the province. This program provides municipalities with up to $1.5 million in rebates or 30% of eligible expenses. The Municipal Climate Change Action Centre manages it and has completed installations in Medicine Hat, Mayerthorpe, Bon Accord, and others.
Federal Programs
The federal government offers a few programs to promote solar/renewable energy.
The Emerging Renewable Power Program
The Emerging Renewable Power Program is a federal initiative designed to reduce the risks associated with new renewable energy projects. It aims to increase the share of emerging renewables in Canada's electricity supply.
In January 2019, the program announced funding for a new solar farm near Suffield. While tracking the sun's daily trajectory, this project will create 23 MW of generating capacity. The federal government pledged $15 million o this project over two years.
?The Canadian Renewable and Conservation Expense
Changes to the Income Tax Regulations have been made at the federal level. These updates lowered the accelerated capital cost allowance for certain clean energy generation and energy conservation equipment. This regulation encourages clean /solar energy investment through income tax incentives.
Expenditures that qualify as Canadian Renewable and Conservation Expenses can be fully deducted in the year incurred, or carried forward indefinitely to future years. ?
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References:
1)?????Kauffman R., Here Comes the Sun-Solar Law in Alberta, August 2021.
2)?????https://www.cbc.ca/news/canada/edmonton/alberta-is-moving-to-dissolve-the-electricity-balancing-pool-here-s-why-that-matters-to-you-1.6417863?
Senior Biologist & Project Manager, P.Biol., Authenticating Wetland Professional (Alberta Wetland Policy)
1 年Please provide the page number of the Wildlife Directive from where you've stated and quoted: The Directive stipulates that “solar energy projects shall not be sited in regions of native grasslands, native parkland, old growth forest stands, named water bodies, valley breaks (including coulees), valleys of significant permanent watercourses, and the eastern slopes region”. Here's a screen shot of the very first standard in the Wildlife Directive for Alberta Solar Energy Projects, containing a similar sentence, which does not state "shall".