Alberta Utilities Commission Renewable Electricity Generation Inquiry - Module APembina Institute's written submission

Publication - Nov. 22, 2023 - By Jason Wang, Simon Dyer, Ecojustice, Big Spruce Law

On August 3, 2023, the Government of Alberta announced a seven-month pause on approvals for renewable energy projects over 1 megawatt (MW) - including wind, solar, and geothermal, but excluding microgeneration.

As part of the moratorium process, the Alberta Utilities Commission (AUC) issued a notice for parties interested in participating in the AUC inquiry into the ongoing economic, orderly and efficient development of electricity generation in Alberta. The Pembina Institute, in collaboration with Ecojustice and Big Spruce Law, submitted its response to Module A of the inquiry, which is focused on land impact issues, including land use, reclamation and pristine viewscapes.

It is Pembina’s view that renewable energy projects should be held to fair rules informed by regional planning under the Alberta Land Stewardship Act (ALSA) that are consistent with rules for other land uses. It is our observation that in many cases the renewable energy sector is already being held or considered for stricter standards than other land uses that are already having a demonstrably larger impact on values of concern. For example, the Auditor General of Alberta has noted that oil and gas liability management needs substantial reform over and above what has been proposed by the Alberta Energy Regulator.

These issues urgently need to be subjected to the same level of scrutiny as the renewables pause. This inconsistency is especially concerning given the importance of renewables for energy affordability for many of the municipalities interested in these projects, and because renewable energy is an important solution to tackling climate change.


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