Comment
I am a bat biologist from western Canada. I am encouraged to see the inclusion of mitigation to reduce bat mortalities, however, it looks like monitoring is not required for the common approach. How will you know if it is effective and whether additional mitigation is needed without monitoring? Similarly, the custom approach requires monitoring but there is no indication on how efficacy will be evaluated. Monitoring mortality is necessary, with clear guidelines on how the mortality data will be used to potentially modify mitigation. Further mitigation should include shutdown during periods of high mortality, such as during the fall migration period. Setting, and settling for, an inadequate level of mitigation will not conserve bat populations.
Submitted February 4, 2025 12:25 PM
Comment on
Regulatory changes under the Endangered Species Act to extend application of conditional exemptions to newly listed species and update the conditional exemption for the operation of wind facilities
ERO number
019-9411
Comment ID
125106
Commenting on behalf of
Comment status