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Opportunity to give input in AUC inquiry

October 18, 2023

Until November 22, the AUC are accepting comments for Module A of their inquiry into Alberta’s renewable energy development. This module addresses land types to be developed, the effect on pristine viewscapes, mandatory reclamation security requirements, and development on Public or Crown Land.

AWA supports responsible renewable energy development, which will help to reduce greenhouse gas emissions and improve the health of Albertans. However, AWA believes that renewable energy development must proceed in a fashion that respects and protects wildlife, landscapes and health. The AUC inquiry presents an opportunity to direct future renewable energy projects towards responsible development.

For future renewable energy projects, we would like to see:

  • Siting that avoids sensitive habitats, high biodiversity areas, and migratory pathways. To facilitate responsible siting, a clear, comprehensive analysis of suitable areas and prohibited lands should be compiled to direct renewable energy power plant placement.
  • Establishment of a research program with sufficient funding aimed at identifying bird and bat migration paths, understanding the ecological impacts of renewable energy projects and addressing other gaps in knowledge. In the absence of adequate information, proposals should err on the side of caution and avoid disturbing native grasslands, parklands and foothills habitat. Wind and solar farms should avoid ridge tops, wetlands and fields known to be important to migrating species. Zones of influence should be established around key biodiversity areas and biosphere reserves where development is severely restricted.
  • In the absence of a comprehensive land suitability analysis, Environmental Impact Assessments should be mandatory for large projects (with a contract capacity greater than 5 megawatts) under Schedule 1 of the Environmental Assessment (Mandatory and Exempted Activities) Regulation.
  • Industry remains responsible for any maintenance, clean-up and remediation costs. Development should minimize the impact on landscapes, and reclamation following construction is needed to restore lands to a functional condition capable of supporting biodiversity. To ensure sufficient funds for reclamation work, liabilities need to be recognized and funds set aside before the reclamation stage. These funds should be required prior to construction, and held in a fashion that protects funds from bankruptcy proceedings and guarantees they are used for reclamation.
  • Wildlife mortality is monitored extensively and reports on wildlife mortality are made publicly available. Where wildlife mortality is extraordinarily high, projects take mitigation measures, and if mitigation is unsuccessful, the project is reduced or shut down and lands remediated to a functional ecosystem.
  • Brownfields and already disturbed lands should be prioritized for development. Development on Public or Crown lands should be avoided, especially where Public Lands include grassland, parkland or foothills habitat. These habitats are already underrepresented in Alberta’s protected areas, and are facing many threats from agriculture, industry and urban expansion. Given that these lands protect many of Alberta’s species-at-risk, we cannot afford to lose more of these habitats.

Anyone who is interested in commenting on the AUC Inquiry can do so through the comment matrix here: https://www.auc.ab.ca/comment-matrix-for-inquiry-submissions/; or by adding submissions through AUC’s eFiling system under Proceeding 28501.

The love of wilderness is more than a hunger for what is always beyond reach; it is also an expression of loyalty to the earth, the earth which bore us and sustains us, the only home we shall ever know, the only paradise we ever need – if only we had the eyes to see.
- Edward Abbey
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