1. Getting FIT
with REA Presenter: Leah Deveaux, BES EA Specialist
On September 24, 2009 the Ontario government proclaimed the Green Energy and Green Economy
Act (GEEA).This piece of legislation introduced several monumental changes to the Ontario renewable
power market including replacing of the Renewable Energy Standard Offer Program (RESOP) with the
newly created Feed-inTariff (FIT) program and replacing the Environmental Assessment (O.Reg116/01)
process with the Renewable Energy Approval (REA) process.
Changes to
Permitting and Procurement
How do FIT and REA
Timelines work together?
The FIT program created milestones that a developer is
required to meet in order to maintain its contract, such as
a minimum three years to commissioning and a Notice
to Proceed (NTP) period no less than six months prior
to the COD of a project. A completed REA is required for
NTP.The REA also has a guaranteed review time of six
months provided the application is complete, ensures an
expedient review. Other agencies also have expedited
review times based on the COD of the project.
How the new regime
has changed development
As can be seen in the above diagram, the FIT and
REA have changed the way in which project work is
completed. Under the old process much of the design
work was left until after the EA was completed.The REA
requires much of this civil work to be part of the final
submission.
What Gaps are left in the process?
• Lack of federal coordination
• Agency confirmation letters required prior to
publication of REA draft documents
• Development processes may be out of synch with the
REA process (i.e.Timing of detailed design work)
• Concerns regarding agency review times
Conclusions
The changes stemming from the GEEA of September 24, 2009 have been positive. While the REA process and the FIT
process are still in their infancies they show positive changes to systems which were ailing.The development process
is adapting to the increased information requirements during the permitting stage; however, the increased consultation
component is one of the more challenging adjustments. Readily available digital information has allowed local residents
and land owners to independently review and assess the impacts of new renewable energy developments.This
ability to better understand the effect on their lands is a significant change that requires the most adjustment by those
undertaking the development process.