12/06/2011

AMO Written Submission to the Ministry of Energy and the Ontario Power Authority (OPA). December 6, 2011.
The Association of Municipalities of Ontario (AMO) represents Ontario’s municipal governments and advocates on behalf of those governments and their property tax payers and citizens. AMO well understands the needs of municipal governments. As the second largest energy consuming sector in the province with annual spending of over $1 billion and as hosts for energy projects, the municipal sector has a significant stake in planning for future energy generation, conservation, and related infrastructure. Municipal leaders have to consider energy projects in terms of how they impact on municipal bottom line as consumers, the property tax base, system efficiencies, concerns from residents, as well as other social or environmental policy objectives.

The mission of the FIT Program is clear – to foster the growth of renewable energy projects that use cleaner sources of energy and to remove barriers to renewable energy projects and a green economy. The OPA and the Ministry are looking to the FIT review process in terms of the sustainability of the program, consider new technologies, improve public consultation, review the approvals process, and enhance municipal participation. This submission addresses all five areas with suggestions meant to refine both the FIT and the approvals process that supports it. We would be remiss not to first comment on the division among municipal governments on the planning and approval process. For some, the removal of municipal planning authority is significant, whereas others feel ill equipped to conduct the reviews necessary or appear before the Ontario Municipal Board (OMB) or other adjudicators to defend their positions.