WCS Canada Comment: Ontario Conditional Exemptions
Holroyd, S., Lausen, C., O'Connor, C., Olson, C., Palmer, L, & Ray, J.
WCS Canada's comments on changes under the Endangered Species Act, extending the application of conditional exemptions to newly listed species and update the conditional exemption for the operation of wind facilities.
Key points
- Ontario’s regulatory changes through ERO 019-9411 would extend conditional exemptions in O. Reg. 242/08 (under the provincial Endangered Species Act) to newly listed species at risk, including three endangered migratory bat species. The track record of implementation of these conditional exemptions streamline approvals but lack the oversight needed to ensure they minimize harm.
- The effectiveness of conditional exemptions in protecting species remains unproven due to the absence of enforcement, monitoring, and attention to cumulative impacts. A 2021 Ontario Auditor General review highlighted critical gaps in the ESA’s approval process, showing that these issues must be addressed to improve outcomes for species at risk.
- Wind energy is essential for addressing climate change, but it is now the leading cause of direct mortality for migratory bats. Strengthening oversight, improving data collection, and implementing adaptive management strategies are necessary to prevent further declines while supporting the energy transition away from fossil fuels.
- Preventing further harm to at-risk species requires more than well-intentioned conditions—it demands thoughtful design and meaningful oversight. The measures we propose are reasonable, achievable, and necessary to avoid short-term decision-making that leads to inevitable long-term costs for biodiversity.
Recommended citation
Holroyd, S., Lausen, C., O'Connor, C., Olson, C., Palmer, L, & Ray, J. (2025). WCS Canada Comment: Ontario Conditional Exemptions. Wildlife Conservation Society Canada [WCS Canada]. https://wcscanada.org/resources/wcs-canada-comment-ontario-conditional-exemptions/
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Metadata
- Title
- WCS Canada Comment: Ontario Conditional Exemptions
- URL
- https://wcscanada.org/resources/wcs-canada-comment-ontario-conditional-exemptions/
- Published
- 2025-02-10
- Author(s)
- Holroyd, S., Lausen, C., O'Connor, C., Olson, C., Palmer, L, & Ray, J.
- Publisher
- Wildlife Conservation Society Canada [WCS Canada]
Bats
Bats are the world’s only flying mammal.
Western Bats
WCS Canada's Western Bat Program is committed to protecting bats and bat habitats in Western North America.
Safer wind power for bats
An estimated 1 million bats are now being killed by wind turbines annually in North America – a number that will continue to rise as more wind turbines are constructed.







