BluEarth Renewables Inc…

BluEarth Renewables Inc. Submission on Proposed Legislative and Regulatory Amendments

1. General Support
BluEarth Renewables Inc. operates several wind and solar facilities in Ontario and broadly supports the proposed legislative and regulatory amendments to enable the Species Conservation Act.
We support the approach to balance species protection with social and economic needs by streamlining processes and reducing regulatory hurdles, enabling faster project approvals while safeguarding biodiversity. The framework establishes clear, science-based rules for activities most likely to harm species, introduces a simplified compliance process, and launches a voluntary Species Conservation Program to support initiatives such as habitat restoration. Updated methods and technological advancements will guide more effective conservation strategies, ensuring sustainable growth alongside environmental stewardship.

An adaptive management framework affords wind facility operators the discretion to implement the most efficient and effective measures to mitigate adverse impacts on wildlife. These measures may include smart and non-curtailment strategies, variable cut-in speeds, adjustments to operational timing windows, deterrent technologies, and other site-specific solutions, while ensuring that significant reductions in energy production are avoided. This approach promotes flexibility, innovation, and evidence-based practices to achieve wildlife protection objectives.

2. Proposed Registration Regulation
BluEarth strongly recommends that the government provide adequate time for our organization to review and provide feedback on any draft regulations or policies prior to implementation. Following further opportunities for direct engagement, any proposed regulatory language should be posted to the Environmental Registry of Ontario (ERO) for a second round of public consultation. If a second review period is not feasible due to timing constraints, BluEarth requests the opportunity to examine detailed draft regulatory language to help prevent unintended consequences.

Given the short timelines for proposed implementation, it will be challenging for BluEarth to implement any potential regulations immediately, given the complexity of these facilities. BluEarth recommends that, once regulations and legislation are finalized and posted (currently anticipated in Q1 2026), existing facility operators be granted a minimum of one year to complete professional assessments and develop site-specific strategies to determine and implement the most appropriate compliance pathway (e.g., by Q1 2027). During this transition period, existing facilities should be permitted to continue operating under current practices. This approach ensures operational stability, allows for thorough expert analysis, and provides regulatory certainty—helping operators make informed, effective decisions without disrupting ongoing energy production.

5. Proposed Transition Regulation
BluEarth supports this proposed regulation. We believe it is important that existing permits for our operational facilities be respected and continue to provide protection to species at risk under the existing ESA framework.

-BluEarth Renewables
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