November 10, 2025 Re:…

November 10, 2025

Re: Proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025 (ERO number 025-0909)

Submitted electronically to: Ministry of Environment, Conservation and Parks

To Whom It May Concern:

EDP Renewables North America LLC (EDPR NA), its affiliates, and its subsidiaries develop,
construct, own, and operate wind farms, solar parks, and energy storage systems throughout
North America. Headquartered in Houston, Texas, with 60 wind farms, 27 solar parks, and eight
regional offices across North America, EDPR NA has developed more than 12,000 megawatts
(MW) and operates more than 11,600 MW of onshore utility-scale renewable energy projects.
In Canada, EDPR NA operates two wind farms in Ontario, and one in Alberta, and has several wind, solar, and battery storage projects in development in several provinces.

EDPR NA is submitting these comments with respect to the proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025. EDPR NA strongly supports efforts by MECP to ensure species conservation while also providing greater certainty and a clear framework for project proponents.

Specifically, EDPR NA recommends the following with respect to the proposed regulations:

• Provision of draft regulations and policies for review prior to implementation: Without review of the regulatory text, there is significant uncertainty as to specific requirements which could impact wind farm operations. Such actions could inadvertently impact energy production and electrical reliability in Ontario.

• Enable an adaptive management approach to provide wind operators with flexibility in determining the most efficient and effective approaches to minimize adverse impacts to bats. Impacts from wind energy to sensitive species, including bats, are highly variable and site-specific. Wind operators collect significant wildlife data prior to construction, and during operations of their facilities. Proponents should be able to use this information to develop site-specific mitigation strategies that support flexible and creative approaches to minimize effects on wildlife.

o Specifically, EDPR NA strongly discourages overly prescriptive measures such as minimum cut-in speeds. Considering site-specific data enables operators to utilize approaches such as smart curtailment and adjustments to daily and seasonal measures in order to minimize effects on wildlife and optimize production of zero emission electricity.

• Establish a reasonable timeline for implementation: From the date the regulations and legislation are finalized, EDPR NA recommends a one-year timeline for implementation. This is essential to develop site-specific approaches that align with the new regulations. In the interim, operators should be able to use existing management plans and operate as business-as-usual.

• Continuation of industry engagement: As an active participant in CanREA, EDPR NA recommends continued engagement with CanREA and its partner organizations for issues related to renewable energy and the SCA.

For further discussion on these topics, please contact:

Kendra Kallevig
EDPR NA Senior Environmental Manager
kendra.kallevig@edp.com
+1 346-388-8133

Sincerely,

Christina Calabrese
Senior Director, Environmental
EDP Renewables North America