About Canadian Renewable…

About Canadian Renewable Energy Association (CanREA)

CanREA is the leading national industry association advocating for wind energy, solar energy, energy storage and behind-the-meter solar & storage solutions in support of a reliable, affordable, and non-emitting electricity system.

CanREA's network of about 350 companies represent all parts of the value chain to develop and operate wind, solar and energy storage technologies across Canada.

CanREA Comments

CanREA and its members support the government's overarching objective to facilitate a registration-first approach while maintaining strong environmental safeguards.

CanREA and its members support the government's objectives to:
- Drive species protection and conservation while taking into account social and economic considerations, including the need for sustainable economic growth in Ontario.
- Help speed up project timelines and provide greater certainty for proponents, while protecting species.
- Reduce regulatory hurdles, facilitating faster approvals for development projects.
- Provide a reasonable, balanced approach to protecting species in Ontario.
- Establish a framework for setting clear expectations and rules for proponents to follow, ones that are focused on those activities that are most likely to have a direct negative impact on species.
- Follow a simplified, streamlined process.
- Establish a new Species Conservation Program to support voluntary initiatives like habitat restoration that protect and conserve species.
- Consider updated methods for species protection that align with current scientific understanding and technological advancements, aiming for more effective conservation strategies.

CanREA is generally supportive of environmental regulatory certainty for streamlined, cost-effective development and operation of non-emitting electricity resources such as wind, solar and energy storage. Together with our Indigenous and community partners, our industry benefits from clear and balanced processes, timelines and expectations for everyone involved.

CanREA respectfully cautions that any prescriptive rules or measures with respect to wind energy facilities would cause significant negative financial and energy production impacts on wind energy facilities and electricity reliability in Ontario. The province is entering a crucial period of electricity reliability needs where it is actively seeking new, cost-effective electricity generation resources like wind power.

An adaptive management approach provides wind facility operators with flexibility to determine the most efficient and effective approaches to minimize adverse effects on wildlife, including smart curtailment, non-curtailment, variable cut-in speeds, adjustments to daily and seasonal timing windows, deterrents, and other effective site-specific approaches, while mitigating significant negative impacts on energy production. This will enable modern, flexible, creative, and innovative approaches to minimize effects on wildlife.

CanREA Recommendations

When developing its registration-first approach, MECP should enable modern, flexible, innovative approaches to minimize adverse effects on bat species, allowing facility operators to register for the potential impact to migratory bats, and develop a site-specific mitigation strategy that is specific to their facility (see adaptive management approach outlined above).

CanREA strongly recommends that any prescriptive rules or measures with respect to wind energy facilities would have negative impacts on wind production and electricity reliability in Ontario, and should not be included in any proposed regulations.

CanREA strongly recommends that government allow sufficient time for our industry to review and comment on any potential draft regulations or policies before implementation. Following additional opportunities for direct engagement, any specific proposed draft regulatory language should be posted to the ERO for a second round of public review and comment. Or if it is determined that a second round of review is not possible due to timing constraints, CanREA requests the opportunity to review detailed draft regulatory language, with the goal to avoid any unintended consequences.

After the regulations and legislation have been finalized and posted (currently anticipated to happen in Q1 2026), existing facility operators should have at least one year to conduct expert professional assessments and develop site-specific approaches in order to determine and implement their optimal path forward (e.g. Q1 2027). In the interim period, existing facilities should be allowed to operate in a business-as-usual state.