I commend the efforts to…

I commend the efforts to impose operational mitigation on all wind power facilities, new and existing, for the protection of bats in general (most prominently the Hoary Bat, Silver-haired Bat and Eastern Red Bat). Operational mitigation is considered to be the single most effective way to reduce bat mortality at wind power facilities, although it is not 100% effective at all locations and there are other options that are less explored. For any new facilities, it is important to site them to avoid broad landscape areas (i.e. lakeshores, forested ridges, etc) where high incidence of migratory bats are likely to occur. Without wind power guidelines - how will this be managed for new development?

The repeal of the Green Energy Act presents challenges in how wind power facilities can be developed (currently there is no new development of commercial-scale wind power facilities in Ontario), managed or monitored - a great deal of guidance is now missing. It is critically important to not only implement operational mitigation, but to monitor the effectiveness of this to ensure that bat mortality has ACTUALLY been reduced. Will mortality monitoring be required for all facilities retrofitted to meet these new conditions?

The suggestion to use 'live time acoustic monitoring' may not be appropriate. This is derived from a very small number of examples in the USA where proprietary technology was used and that technology is available only to those few USA companies (Normandeau and West have little representation in Ontario) - which could result in undue commercial favoritism if it is required at a broad scale. Another example is radar-based systems in Europe, which are highly sensitive (and not used much in North America). Smart curtailment can include many variables in a SCADA system, so these should be reviewed for each project that submits a proposal to follow the 'custom approach,' with or without the live bat monitoring. The ReBat system is prone to extensive miss-classification where non-bat noises are recorded as bats. How would this approach address a conflict of the data input - such as bats detected (true or not) during wind speeds higher than 7 m/s? This is likely to happen very frequently.