We are in full support of…

We are in full support of the listing of Eastern Red Bat, Hoary Bat, and Silver-haired bat as endangered under the SARO list. This listing is supported both by COSSARO and COSEWIC.

Cut-in speed
While there is no national or international standard for cut-in speeds, scientific research has shown that higher cut-in speeds during periods of migration decreases bat mortality drastically. As the full extent of bat mortality is not known and is higher than collected data can show, a precautionary approach with a cut-in speed of 7 m/s seems reasonable. The custom approach to minimize adverse effects on bat populations would allow for flexibility if the proponent can show that at a lower cut-in speed bat mortality is reduced below an acceptable proportion. We support this precautionary approach with the given room for flexibility when certain conditions are met. However, capacity of wind energy is projected to increase. A consistent cut-in speed will decrease bat mortality per turbine, but with number of turbines in Ontario increasing, bat mortality relative to total bat population is projected to continue to increase. Measures should be proposed to keep bat mortality as a proportion of the best available and up to date estimates of population size at a sustainable level as this industry grows. Sustainability of industry growth needs to be assessed and cut-in speed may have to be increased in the future to keep bat mortality at an acceptable level to sustain healthy bat populations. We recommend applying Alberta’s Sullivan model (unpublished as of yet) to project bat population dynamics and risk levels with increasing wind energy development.
Wind speed measurements can differ between ground and rotor swept zone height (the typical height that migratory bats fly at). It is important to clarify that the measurement of wind speed at the turbine blade height determines whether a turbine needs to be shut down in relation to bat biology.
We are in support of not providing offset or compensatory options (like habitat compensation) for the protection of migratory bats against the threat posed by wind energy facilities. The dominating threat to Ontario’s migratory bats is direct mortality caused by wind turbines. While it is important to maintain suitable and required natural habitat for these bat species, natural habitat is not known to be a limiting factor in the conservation of these migratory bats at this time. As such, providing compensatory natural habitat will do nothing to decrease migratory bat mortality caused by wind turbines and as such will not be an effective conservation measure to aid in the recovery of these bat species.
“... the avoidance of mortality must always be the first option while compensation/offset of the acceptable impacts that remain after the implementation of the mitigation hierarchy should be seen as the last resort.” Peste et al. 2015. How to mitigate impacts of wind farms on bats? A review of potential conservation measures in the European context. Environmental Impact Assessment Review, 51, February 2015: 10-22.

Monitoring
3 years of post-construction monitoring should be the minimum requirement. Anything less than 3 years increases the risk of collecting data in years during which weather patterns, bat activity, and bat mortality are not representative of long-term trends. If not already clarified, it should be stated that monitoring needs to coincide with at least the established period of May 15 to October 15 during which migratory bats are present (if not year-round).
Wind facilities are required to conduct monitoring and prepare monitoring reports. There needs to be a quality control mechanism in place to enforce and verify that data was collected, analyzed, and reported in a scientifically sound and rigorous manner. Additional modeling of population trends should be done to determine whether 7 m/s is sustainable considering what is known about Ontario’s migratory bat populations and forecasted wind energy development.