This is an appeal on “matters other than law”. Accordingly, you are not bound by precedent nor by the efforts of counsel for the Approval Holder, Windlectric Inc., and counsel for the Government to limit your authority to consideration of errors or to the narrow test required at the ERT to demonstrate “serious harm to human health; or serious and irreversible harm to plant life, animal life or the natural environment”. You are wrongfully advised by counsel for the opposing parties that even Government policy and political risk are irrelevant to this matter and that you don’t even have the authority to request the Director to require a modification to the project to reflect critical changes or to impose mitigation measures which Tribunal members accepted as essential. Please do not be guided by lawyers’ efforts to limit your authority. Your mandate is much broader than the restrictive views expressed by opposing counsel in the responses to APAI’s appeal.