Ontario Pumped Storage Hydropower Project

Detailed Permitting Plan
Ontario Pumped Storage Hydropower Project

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Document reference number: 353

September 1, 2026 (version 1.0)

1. Detailed Permitting Plan Agreement & Approval

The following sets out agreed upon timelines for obtaining the federal permits required to begin construction. The proponent's timeline and schedule are outlined in Section 8 Proponent's Anticipated Schedule. Detailed steps and timelines for each permit are provided in Table 1 and Annex A: Detailed Milestones and Timelines for Federal Permits. Note Q1, Q2, Q3, and Q4 refer to calendar quarters.

2. Project Description

TransCanada Energy Ltd. (TC Energy) is proposing to construct and operate a pumped storage hydropower facility located at the Department of National Defence's Army Training Center – Central (ATC-C) (formerly 4th Canadian Division Training Centre) near Meaford, Ontario, on Nottawasaga Bay. As proposed, the project would store excess electricity from the grid by moving water from the bay to a reservoir, that would then be released back to the bay to generate electricity during periods of demand. It will have a production capacity of 1000 megawatts and will operate indefinitely.

3. Purpose of the Plan

The Government of Canada has provided clear direction to federal departments to accelerate decision-making processes for federal authorizations required for projects to get to construction. Federal departments will work together to provide:

• Clarity on permitting requirements, timelines and processes through the development of detailed federal permitting plans
• Transparency through public reporting on the progress of permitting on the Canadian Impact Assessment Registry; and
• A point of contact within the Impact Assessment Agency of Canada and centralized support from the Government of Canada

The purpose of this detailed permitting plan is to identify the federal regulatory instruments including permits, licences and authorizations (collectively referred to as ‘permits') that may be required for the project to commence construction. It also lays out anticipated milestones and timelines and identifies any Indigenous or public consultation that may be a part of the process. It will also provide guidance on the information proponents must provide to inform the process.

To achieve the aforementioned, this document lays out a workplan and timeline to complete the impact assessment and federal permits required to commence construction. It also details what proponents will need to do to support an efficient regulatory process to meet the targets (see Conditions of Participation).

This permitting plan is not a legal document and does not change any existing federal, provincial, or Indigenous legislative or regulatory jurisdiction, right, power, privilege, prerogative or immunity by virtue, nor does it create any new legal powers, duties or legally binding obligations. While this document is meant to guide federal permitting for the project, it is not intended to be exhaustive, restrictive, nor legally binding on any of the parties. As such, nothing in this document should be considered to interfere with or fetter the discretion of federal regulators, carrying out their responsibilities. Regulators' obligations and service standards are described elsewhere. In the event of any inconsistency between this plan and regulators' legal obligations, the latter shall prevail.

4. Conditions of Participation

To meet the target, agreed to with the proponent, for completion of the major project review process, the proponent must be willing and able to meet the following conditions:

• Ready to start: The proponent must be ready to submit application(s) as per the anticipated timelines set out in this detailed permitting plan.
• Provide Comprehensive Applications: The proponent must make best efforts to submit comprehensive applications for federal permits that meet the requirements set out by the responsible departments and agencies.
• Active Participation: Actively participate in the permitting process including providing required information and promptly responding to requests for additional information or clarification from federal departments and agencies or from Indigenous communities.
• Engage with Indigenous Communities: The proponent must follow best practices when establishing relationships and engaging with Indigenous communities and have documented and addressed concerns.
• Public Disclosure: The proponent consents to having the status of its permitting processes, shown on a public permitting dashboard on the Canadian Impact Assessment Registry.

5. Roles and Responsibilities

The roles and responsibilities related to permitting coordination are:

Impact Assessment Agency of Canada (IAAC) will:

• integrate permitting coordination into the impact assessment, where applicable, and seek areas for efficiency between the impact assessment and other federal regulatory processes;
• maintain and update the detailed permitting plan, as necessary;
• provide relevant information from the impact assessment of the project to federal departments to inform their regulatory processes;
• provide a primary point of contact for proponents and federal departments to address issues that may require coordination among multiple departments.
• track the progress of the permitting processes on the public permitting dashboard on the Canadian Impact Assessment Registry;
• act as Crown Consultation Coordinator to facilitate a collaborative approach to Indigenous consultations by federal departments related to permitting; and
• work with federal departments and the proponent to meet the timelines described within this document.

Federal departments will:

• conduct permitting as per their respective legislative or regulatory requirements;
• provide information relating to the regulatory and statutory responsibilities of their department;
• review information provided by proponents during the impact assessment and update information on permitting as appropriate;
• determine, to the best of their ability, whether a permit is required under their respective legislation, based on the information provided by the proponent;
• provide feedback as to what information must be provided to support sound and timely regulatory decisions;
• carry out Indigenous consultation, as well as any public consultation, as required;
• notify IAAC of issues that arise and any changes in anticipated timelines, as early as possible;
• maintain communication with the proponent through applicable regulatory or permitting processes; and,
• work with IAAC and the proponent to meet the timelines described within this document.

The Proponent will:

• prepare the appropriate applications for the permits required for the project to commence construction and submit applications as per the anticipated timelines set out in Table 1 and Annex A;
• provide required information and respond to any requests for additional information or clarification from federal departments or IAAC;
• support IAAC and federal departments during Indigenous consultations;
• liaise with IAAC and federal departments on anticipated schedules for applications and any issues that may arise and notify IAAC and relevant federal departments as soon as possible to any changes in anticipated submission dates (for example, notification 90-30 days prior to any changes is preferable);
• notify IAAC and federal departments of any major or substantial changes to project design, as early as possible;
• be aware of changes to legislation that may change the need for a permit;
• fulfill the conditions for participation; and
• work with IAAC and federal departments to meet the timelines described within this document

6. Federal Permits that may be required to start construction

Information about federal permits that may be required for construction can be found in Table 1. These permits will be tracked on the public permitting dashboard on the Canadian Impact Assessment Registry.

The list of permits needed for construction is based on information provided by the proponent, may not be exhaustive and is subject to change. The Government of Canada may revise the plan to accommodate any changes to the project or in response to new information from the proponent, federal departments or other participants in the impact assessment or permitting process. Proponents should be aware that other federal legislation or regulations may apply to their project, including permits that may be required after construction has begun or which have requirements to follow throughout the life of the project.

This document will be updated by IAAC, as necessary, based on a review of the impact statement submitted by the proponent.

Federal departments are prohibited from issuing permits until a positive decision statement is issued by the Minister to the proponent, under section 8 of the Impact Assessment Act. The proponent, however, is encouraged to develop federal permit applications and/or apply for federal permits concurrently with the impact assessment. Information and consultation requirements for permits may be completed at the same time as the impact assessment and the same information may, in many instances, be used to inform both processes. Collecting and providing permitting information during the assessment process may expedite subsequent federal decisions, should the impact assessment decision be positive.

7. Engaging and Consulting with Indigenous Communities

The proponent is expected to begin engaging with Indigenous communities as early as possible to establish meaningful relationships built on respect, trust, and collaboration. Refer to Guidance for proponents: Early engagement with Indigenous Peoples in impact assessments under the Impact Assessment Act - Canada.ca for additional resources. This includes Indigenous communities that may be affected by specific components of a permit (i.e., affected based on the location of a fish habitat compensation plan).

By engaging Indigenous communities early on, proponents develop an understanding of concerns and an ability to address them at the outset. This proactive approach also promotes ongoing dialogue, where concerns and mechanisms to address these concerns can be integrated into projects. This approach also helps identify potential issues before they become significant challenges and creates an environment where Indigenous communities can be involved in shaping the future of projects. The proponent is also encouraged to provide the requested information to federal departments as early as possible to allow these regulatory bodies to begin consulting with Indigenous communities on permitting processes as early as possible.

Federal departments, along with the Crown Consultation Coordinator, will work together to ensure a collaborative and coordinated approach to consulting with Indigenous communities. The Crown consultation coordination process will, with input from Indigenous communities, aim to reduce the consultation burden and duplication for Indigenous communities across regulatory and permitting processes.

The Indigenous Engagement and Participation Plan (IEPP) describes the possibilities and methods for meaningful engagement and consultation with Indigenous communities who may be affected throughout the impact assessment process.

8. Proponent's Anticipated Schedule

TC Energy (TCE) proposes a phased approach to providing information required to inform federal permitting decision making for the Ontario Pumped Storage Hydropower Project. The approach would occur in three phases to align with development of the Project's footprint and assessment of potential effects associated with that footprint. TCE intends to submit Information and Studies chapters and associated technical data reports as they become available, as opposed to submitting all materials at once. TCE has set the following schedule for submission of permit applications and its target for start of construction. Note Q1, Q2, Q3, and Q4 refer to calendar quarters.

• TCE has been undertaking baseline environmental studies since 2019. Depending on the exact requirements identified in the forthcoming Tailored Information and Studies Guidelines, TCE anticipates beginning to submit draft Impact Statement documentation to the IAAC in Q1 2027, with the submission of the final Impact Statement anticipated in Q1 2028.
• TCE anticipates providing draft permits for the following items in proximity to the filing of supporting effect assessment documentation:
  • Species at Risk Act
  • Fisheries Act
  • Canadian Navigable Waters Act
• Phase 1 – Comprehensive draft permit applications submitted in Q2-Q4 2027. These applications will include technical information currently available at time of submission, including information on the footprint of the Project and the Project's approach to constructing and operating said facilities. As part of this phase, draft permits would present potential mitigation options, and if applicable, potential compensatory measures to address identified effects stemming from the assessment of effects found in the draft Impact Statement documentation and associated technical reports.
• Phase 2 - Provide an update on any Project footprint and construction methodology changes that result from the completion of Front-End Engineering and Design (FEL3) to be completed in Q4 2027. This phase would also see revisions to draft permit applications that would incorporate feedback generated during Phase 1 from regulators and external stakeholders, as appropriate, including additional details on mitigation measures and anticipated levels of compensatory measures. This phase would occur in Q2 2028, approximately 4 months after TC Energy has submitted a complete Impact Statement.
• Phase 3 - Provide final versions of any necessary permit application materials, considering any feedback developed during Phase 2 from regulators and external stakeholders and detailed in the Impact Assessment decision issued by the Minister of the Environment, Climate Change and Nature. As such, this phase would occur in Q4 2028, approximately 1 month after the IA decision is issued.
• TCE has filed for an Interim Licence under the Dominion Water Power Act alongside the submission of the Initial Project Description in March 2026. TCE anticipates providing a number of updates to this application on engineering and commercial aspects of the Project.
• TCE has been working with DND regarding the footprint of the Project, and different approaches to the construction and operation of the Project within ATC-C since 2020. TCE has been providing updates to DND on specifics of the Project during this time, aligning with advancement of engineering of the Project. TCE expects to provide more refined Project specifications as it completes Front-End Engineering and Design (FEL3) over the next 18 months.
• TCE aims to commence construction of the Project in late Q2 2029, with initial works focusing on the establishment of temporary construction support facilities and unexploded explosive ordnance (UXO) clearance. Once these activities have been advanced, TCE will commence construction of the Reservoir and Main Access Tunnel.

9. Contact Information

During the impact assessment, the proponent should direct any inquiries to the IAAC office designated for administering the impact assessment of the project.

For the Ontario Pumped Storage Hydropower Project, please contact:

Impact Assessment Agency of Canada
Ontario Regional Office
55 York Street, Suite 600
Toronto, ON M5J 1R7
Phone: 416-952-1576
Email: Nottawasaga@iaac-aeic.gc.ca

If a Decision Statement with conditions is issued, allowing the project to proceed, the proponent should continue to direct permit inquiries to the appropriate federal department conducting the permitting process.

Inquiries related to the coordination of federal permitting may be directed to the IAAC Permitting Coordination Team at permitting.coordination.permis@iaac-aeic.gc.ca

Department of National Defence contact:

• Meaford Project Management Office
  Director General Portfolio Requirements
  Assistant Deputy Minister of Infrastructure and Environment (ADM (IE))
  Email: psp4cdtcconsultationspspci4div@forces.gc.ca

Crown-Indigenous Relations and Northern and Arctic Affairs Canada contact:

• Dominion Water Power Act
  Water Management Division
  Email: lfhc-dwpa@rcaanc-cirnac.gc.ca

Department of Fisheries and Oceans contact:

• Fish and Fish Habitat Protection Program
  Ontario and Prairie Region
  Winnipeg, Manitoba
  Email: FisheriesProtection@dfo-mpo.gc.ca

Environment and Climate Change Canada contact:

• ECCC welcomes focused and collaborative conversations between SARA Permitting Officers in ECCC's regional offices and the proponent if additional information is required. In Ontario, please reach out to: wildlifeontario@ec.gc.ca

Transport Canada contacts:

• Transport Canada Environmental Programs
  Ontario Region
  Email: enviroont@tc.gc.ca
• Transport Canada Navigation Protection Program
  Email: nppont-ppnont@tc.gc.ca

Natural Resources Canada contact:

• Explosives Regulatory Division
  National Headquarters
  Ottawa Ontario
  Tel.: 1-855-912-0012
  Email: ERDmms@nrcan.gc.ca

Table 1 – Federal Permits that may be required to begin construction

Annex A – Detailed Milestones and Timelines for federal permits

Notes:

• One of the inputs for the Minister of National Defence Determination is the outcome of the Impact Assessment. Sequencing and coordination of decisions between DND and IAAC will be required.

Notes:

• There are two possible timelines for the granting of the Interim Licence outlined in the table above. The administrative licence process is outlined in steps 12A to 14A, and the regulatory licence process is outlined in steps 12B -15B. See Table 1 for more details.
• Although the administrative DWPA licence process could be finalized within 1.5 years a Ministerial decision cannot proceed before the Impact Assessment Ministerial Decision has been made.
• STEP 5: If the Minister of ISC decides a public hearing is necessary, CIRNAC will coordinate with IAAC to plan a date, time, and place for it to be held. The Proponent must attend to hear and speak to the issues addressed by the public. Following the public hearing, the Minister of ISC will make a public interest decision based on the feedback received for the application.
• STEPS 12A-14A and 12B-15B: Timelines could be longer due to the potential requirement of a land use agreement/Real Property instrument with the Crown.

Notes:

• GENERAL:
  • This timeline is precautionary, based on the anticipated timelines of the proponent and should be reviewed/revised in consultation with ECCC when the need for a SARA permit has been confirmed.
  • The 90-day service standard for issuing a SARA permit does not apply when a decision under IAA is required.
  • ECCC encourages proponents to submit clear and complete permit applications at least 6-8 months prior to the anticipated start of activities that require a SARA permit Submitting an application as early as possible in the impact assessment process allows opportunities to identify potential issues and consider solutions.
    • Note that the proponent has indicated that they will be submitting an application earlier in the IA process than the typical 6-8 months.
  • A SARA permit cannot be issued until the IAA process has concluded.
• STEPS 2 and 3: ECCC will commence reviewing the application when submitted. Depending on response to questions, Steps 2 and 3 may not require the full allocated time.
• STEP 4: The length of time for IC, if required, is not expected to take a year, but may occur at some point during that time, once ECCC has sufficient information to consult.
• STEP 5: Allowing 3 months for Ministerial review and formation of opinion under SARA s.73

Notes:

• This timeline assumes that no additional field work or baseline data collection is needed to support DFO's review of the application.
• A one-year timeframe is generally sufficient for reviewing a complete and adequate application (as per the Schedule 1 requirements of the Authorizations Concerning Fish and Fish Habitat Protection Regulations) and decision making. However, for a project with this scope and complexity the review may take more than a year to complete
  • Note that the proponent has indicated that they will be submitting an application earlier in the IA process (see Section 1)
• The above timeline is based on an estimate of two rounds of additional information.
• A FAA approval cannot be issued until the IAA process has concluded.
• The 90-day legislated timeline may be delayed or be ceased to accommodate Indigenous consultation as needed.
• The 60-day and 90-day legislated timelines may be shortened depending on completeness of application and required documents.

Notes:

• This timeline is for a single application that covers all works.
• An approval typically can take up to 12 months after application submission.
  • Note that the proponent has indicated that they will be submitting an application earlier in the IA process (see Section 1) than the required 12 months
• A CNWA approval cannot be issued until the IAA process has concluded.
• The timing of steps 6 and 8 can be flexible and are dependent on when proponent has final drawing to be included in the posting. The duration of certain important steps described may vary depending on the proponent's response time and indigenous consultation.

Annex B – Detailed DND Information Requirements

Impacts on human health, safety, emergency management, equipment, infrastructure, or operations that may impact DND land or interfere with Canadian Armed Forces (CAF) health and safety, operations or communications must be provided so DND can assess impacts to CAF operations and understand impacts to DND personnel. The following information must be provided by the proponent either through the Impact Statement or directly to DND (note that a formal request for review in writing must be submitted to DND in relation to each of the information requirements):

• The full project footprint at all stages (including the road to potential marine access). Note any changes in the project footprint scope including overland flow for the spillway and transmission infrastructure beyond what is provided in the AIP may change the scope of the DND IAA S. 82 EED or change CAF effects and cause delays with a Minister of National Defence determination. DND cannot reasonably assess the impacts on CAF without the proponent providing a more fulsome design. See DNDs Federal Advice Authority Record for comments on the project footprint provided in the IPD. The Project footprint also includes, but not limited to:
  • Marine Access and Dock plans including dock location, access road route, and shoreline infrastructure
  • Detailed information on the spillway design for the pumped storage reservoir, including the anticipated flow paths of discharged water, identification of all required associated infrastructure, and an assessment of potential environmental, hydraulic, and downstream impact considerations
  • Mapped location and detailed description of transmission infrastructure and alignment on DND land plans
  • Flood inundation mapping in accordance with applicable dam safety guidelines or other applicable guidelines for a range of design and extreme events, delineating flood and overflow extents, depths, velocities, and arrival times, and identifying potential impacts to downstream populations, infrastructure, and environmental receptors
• Develop an all-hazards emergency preparedness and response framework consistent with applicable dam safety and occupational health and safety guidelines, addressing credible emergency scenarios including health, fire, security, and external hazards, and defining roles and responsibilities, communication protocols, and coordination with relevant authorities.
• Security plan consistent with recognized dam safety guidelines and DND security requirements, including a systematic assessment of potential security threats (e.g., unauthorized access or trespass onto DND lands or training areas, vandalism, theft, sabotage, criminal activities, and cyber threats). The plan shall establish mitigation and response measures such as controlled access points, physical barriers, monitoring and surveillance systems, intrusion detection, and security personnel protocols. It shall also include specific provisions for construction site security management, including site access controls, contractor compliance, and material and equipment protection, as well as comprehensive incident management procedures covering detection, reporting, response, investigation, and coordination with DND and law enforcement agencies
• Develop and implement a Construction Sequencing Plan aligned with DND requirements that clearly defines the sequence, timing, and location of all construction activities, including Temporary Construction Elements (TCE). The plan shall identify potential constraints and conflicts with DND lands, training areas, and CAF operations, and shall include provisions for advance notification, access coordination, and scheduling to minimize disruption. The plan shall also outline a coordinated approach for the sequencing of relocation, protection, or modification of DND infrastructure, ensuring compatibility with ongoing CAF operational and training requirements
• Any air quality impacts, including air pollution mitigation and monitoring plans
• Any noise and vibration impacts, including mitigation and monitoring plans
• Any lighting and traffic impacts, including mitigation and monitoring plans
• Water quality impacts in relation to drinking water, including mitigation and monitoring plans
• Prepare an assessment of potential radio frequency (RF) and electromagnetic (EM) interference associated with all project components and activities, including construction and operations, that may affect Canadian Armed Forces (CAF) communications systems and infrastructure. The proponent shall identify sources of interference, evaluate potential impacts, and establish mitigation measures, monitoring protocols, and coordination procedures with DND to ensure the continued reliability and integrity of CAF communications
• Surface water management (including precipitation and snow melt) and any changes to water runoff caused by the project and mitigation.
• Any climate resilience issues and mitigation strategies.

NOTE: The Q1 2026 submission of information on the Project Footprint of all components on DND land is insufficient. Key information remains outstanding, including CAD and GIS files, geolocated spillway location and associated infrastructure, transmission line routing and corridor requirements, access points and access routes, and other project components that may affect DND lands and operations. Where a proposed footprint differs from or extends beyond the footprint established in the approved AIP, DND treats it as a new land-use request requiring further assessment and, potentially, amendments to existing agreements or additional approvals, and timelines. The absence of this information may result in delays to DND's review process and could affect overall project timelines. DND will continue to work collaboratively with TC Energy as project design progresses and additional information becomes available.

Annex C – Detailed Species at Risk Act Permit Information Requirements

Species at risk and their habitat

The proponent must address requirements for each species at risk listed as extirpated, endangered or threatened on Schedule 1 of SARA, if the species or its habitat are likely to be in the project area or study areas. Specifically, the proponent must consider the potential impacts to each of the following species at risk, which are confirmed or have the potential to be present, and any other listed species that are found prior to submission of the SARA permit application:

• Butternut (endangered);
• Western Chorus Frog, Great Lakes/St. Lawrence – Canadian Shield population (threatened);
• Little Brown Myotis, Northern Myotis, and Tri-coloured Bat (endangered);
• Red-headed Woodpecker (endangered);
• Monarch (endangered);
• A plant species at risk (endangered)

To note: should a species in the project area or study areas become listed during project operations/decommission, a SARA permit application may also be required.

The information below is required to support the assessment of a permit application for the Ontario Pumped Storage Hydropower Project. This specific guidance is in addition to generic guidance which can be found at: https://www.canada.ca/en/environment-climate-change/services/species-risk-public-registry/permits-agreements-exceptions.html

• Baseline information
• Effects to species at risk and their habitat
• Assessment of alternatives
• Mitigation measures
• Jeopardy

Baseline information

With respect to Butternut, the proponent must consider to the extent applicable:

• identify all Butternut found within the project area and include:
  • the location of all Butternut individuals (saplings, seedlings, mature and dead/dying trees) using latitude / longitude – decimal degrees;
  • a Butternut health assessment for each Butternut, following Ontario provincial standards, including photos of the tree during the leaf on period; and
  • a habitat characterization of the areas supporting Butternut within the project area.
• with respect to the broader area assess the contribution of Butternut at the project site to local and regional Butternut populations (e.g., population numbers, existence of hybridity, existence of putatively canker resistant trees) including an assessment of the extent of natural reproduction relative to the local study area (LSA) and regional study area (RSA).

With respect to Western Chorus Frog and its habitat, the proponent must consider to the extent applicable:

• provide details of survey methodology, referencing established protocols where appropriate, including:
  • a description of the autonomous recording unit (ARU) recording schedule.
• include mapping at an appropriate scale that shows, within the PA:
  • the locations of formal surveys/point counts, deployed ARUs, and surveyor tracks (where available, to evaluate overall observer coverage);
  • all known Western chorus frog breeding features (e.g., vernal pools, wetlands, ruts) and associated overwintering areas and dispersal habitats, consistent with habitat descriptions found in the species' residence description and recovery strategy under SARA;
  • all Western Chorus Frog breeding observations, including breeding call codes and whether observations were made using ECCC recommended breeding survey methods (Draft Western Chorus Frog Detection Survey Protocol for Ontario – Blazing Star), opportunistic observations or with ARUs; map should note whether mapped points represent observer location or estimated breeding observation location (based on breeding calls); and,
  • Western Chorus Frog observation and habitat information in relation to the project area, existing roads, DND infrastructure, proposed relocation of DND infrastructure, and any other features of potential relevance to connectivity and use of Western chorus frog habitat.
• include a table(s) of Western Chorus Frog survey/incidental observation data that includes the following information:
  • survey protocol/methodology for each observation (e.g. Draft Western Chorus Frog Detection Survey Protocol for Ontario – Blazing Star, point counts, incidental observations, ARUs);
  • for formal surveys/point counts, table should identify whether Western Chorus Frogs were detected or not;
  • breeding call code of any Western chorus frog detections, and the direction/distance of any detections, where known;
  • location of survey station/observer location (decimal degrees or UTMs);
  • location of breeding observation/breeding feature (where known or estimated);
  • date, time, weather (temperature, wind, cloud cover), and noise information at the time of the survey;
  • any information that may relate to the survey results (other species detected, ice cover, frog activity at reference sites, etc.); and
  • any additional information prescribed/collected as part of the survey.
• Summarize the number of breeding features, surface area, depths (approximate or measured), vegetation present and any other habitat related observations relevant to breeding success (e.g., presence of buckthorn).

With respect to Little Brown Myotis, Northern Myotis, and Tri-coloured Bat, the proponent must consider to the extent applicable:

• describe species with the potential to be present based on a desktop analysis and include any results of surveys undertaken to confirm individual species occurrences using the project area;
• describe the source of the species at risk data, including survey design, sampling protocols, and data handling;
• provide information on species presence, species richness, and activity level as well as mapping at an appropriate scale that shows the following, within the project area:
  • any hibernacula and maternity roosting habitat consistent with habitat descriptions found in the species' recovery strategy under SARA and as outlined in Bat and Bat Habitats: Guidelines for Wind Power Projects, 2011; and
  • habitat information in relation to the PA, existing roads, DND infrastructure, proposed relocation of DND infrastructure, and any other features of potential relevance to use of Little Brown Myotis, Northern Myotis, and Tri-coloured Bat overwintering or maternity roosting habitat.
• describe results of surveys undertaken as outlined in Bat and Bat Habitats: Guidelines for Wind Power Projects, 2011;
• describe results of surveys undertaken using ARUs.
• when using recognized standards, provide details of any modifications to the recommended methods and rationale for these modifications; and
• indicate who was consulted in the development of the baseline surveys (e.g., federal/provincial wildlife experts, specialists, and local Indigenous communities).
• describe the general life history (e.g., overwintering, pup rearing, swarming, foraging) that may occur in the project area, or be affected by the project; and
• identify critical periods (e.g., overwintering, maternity roosting/ pup rearing, swarming), biologically appropriate setback distances, or other restrictions related to these species.

With respect to a plant species at risk, the proponent must consider to the extent applicable:

• Identify all individuals found within the Project Area and include:
• Location (latitude/longitude – decimal degrees);
• Health condition of plants; and
• Evaluation of the extent of natural reproduction and any factors that are favouring or inhibiting natural reproduction.

With respect to Red-headed Woodpecker, the proponent must consider to the extent applicable:

• Map any observations of Red-headed Woodpecker within the Project Area and include location (latitude/longitude – decimal degrees).
• Map any observations of nesting or roosting cavity trees used by Red-headed Woodpecker in the Project Area.
• Identify any observations of breeding activity by Red-headed Woodpecker within the Project Area.

With respect to Monarch, the proponent must consider to the extent applicable:

• Conduct surveys throughout the Project Area based on established methodology (e.g., Mission Monarch);
• Map any observations of Monarch within the Project Area and include location (latitude/longitude – decimal degrees); and
• Map the location of any milkweed within the Project Area.

Effects to species at risk and their habitat

With respect to Butternut, the proponent must consider to the extent applicable:

• identify whether each Butternut within the proposed project area would need to be removed, or whether any works would take place within the dripline of the tree, or a distance of 12cm per cm of dbh, or 2 metres, whichever is greater;
• identify any changes to tree cover and competition from other species that may affect Butternut, either positively or negatively;
• identify the impacts of removal of Butternut at the project site on natural regeneration within the LSA and RSA; and
• describe effects related to potential introduction of invasive species, or due to the increase in the spread and prevalence of diseases or pests.

With respect to Western Chorus Frog, the Proponent must consider to the extent applicable:

• identify and map the area and location of each habitat type (i.e., breeding, dispersal and overwintering) that will be lost or impacted, either directly or indirectly, as a result of building and operating the Pumped Storage Project. This should be done, and mapped, in relation to the existing habitat within the project area;
• Quantify the amount of each habitat type lost or impacted, either directly or indirectly, as a result of building and operating the Pumped Storage Project.
• determine whether the Project is expected to result in a reduction of connectivity, and identify any anticipated effects on the local population due to changes in connectivity with a rationale for the conclusion;
• include an assessment of cumulative effects that includes consideration of past, current and future land uses including the relocation of DND infrastructure that would be necessitated by creation of the Pumped Storage Project reservoir and associated infrastructure; and
• describe effects related to potential introduction of invasive species, or due to the increase in the spread and prevalence of diseases or pests.

With respect to Little Brown Myotis, Northern Myotis, Tri-coloured Bat the Proponent must consider to the extent applicable:

• provide an assessment of potential adverse effects on bat individuals and roosting habitat in the project area; and
• describe the potential effects (e.g., direct removal related to construction or vibration through deep blasting) to hibernacula in the project area (for Little Brown Myotis, Northern Myotis, and Tri-coloured Bat).

SARA s.73(3)(a) – Alternatives

The proponent must:

• provide a description of the alternatives to the activity (construction of the project) that are technically and economically feasible to achieve the project purpose;
• prioritize reasonable alternatives that optimize the avoidance of impacts to species at risk (SAR), taking into consideration the requirements of the Species at Risk Act (SARA) s73(3); and
• present the rationale for selecting the proposed project over other options, taking all of the above into consideration.

In order to be consistent with section 73(3)(a) of SARA, which states "all reasonable alternatives to the activity that would reduce the impact on the species have been considered and the best solution has been adopted", the assessment of project alternatives should meaningfully take into account the reduction of negative impacts to SAR and aim to minimize them.

The proposed project may have potentially significant impacts to SAR, in particular Butternut, and it is important that the consideration of alternatives to the project be undertaken in a manner that gives appropriate weight to species at risk considerations. If the project is authorized and requires a SARA permit, appropriate consideration of SAR issues in the consideration of project alternatives during the IA process will allow the s.73(3)(a) element of the SARA permitting process to focus on alternative means for implementing the project at the approved site. To inform a robust assessment of precondition 73(3)(a) and to ensure that the best alternative has been selected for species at risk, ECCC will require a detailed analysis of alternatives to the activity (construction of the Project) that addresses:

1. Alternatives to construction of the Project, i.e. in terms of other locations and other forms of construction. These alternatives should be considered in isolation and cumulatively (i.e., a combination of techniques).
2. Of the reasonable alternatives, the best option from a species at risk perspective.

Under SARA, "reasonable alternatives" are those that are biologically, ecologically, technically, or socio economically feasible. The Minister will assess whether the option retained provides the best conservation outcome for the affected species at risk.

To meet this requirement, proponents should begin early to:

• describe alternative activities, designs, equipment, or processes considered and the rationale for selection;
• identify alternative locations outside the species' range or critical habitat and explain why they were rejected;
• identify alternative timelines to avoid sensitive periods and explain why they were rejected;
• describe alternatives for each project activity, where applicable; and
• explain why the current proposal represents the best solution.

SARA s.73(3)(b) - Mitigation measures

The Proponent must demonstrate the use of the mitigation hierarchy to select appropriate mitigation measures and describe the measures for mitigating potential effects on species at risk individuals, their residences and their critical habitat, including:

• describe the proposed mitigation measures for potential adverse effects on species at risk individuals, their residences, and their critical habitat, include the justification, based on scientific data, for the proposed measures;
• provide an account of how the Project and mitigation measures are consistent with the recovery strategy / action plan for the species. Mitigation measures must be compatible with any applicable recovery strategy and action plan and be described in terms of the effectiveness of each measure in avoiding negative effects;
• describe mitigation measures to reduce the risk of harmful, destructive, or disruptive activities in sensitive times and places of importance to species at risk;
• describe measures to prevent the release of harmful substances into waters or areas frequented or occupied by species at risk; and
• provide mitigation measures for effects on habitat, aligned with the hierarchy of mitigation measures and justify moving from one mitigation option to another.

With respect to Butternut, the Proponent must:

• describe all reasonable alternative means of carrying out the Project that would avoid the adverse effects of the Project on Butternut;
• describe how these alternative means have been considered, and provide a rationale to confirm that the best solution has been adopted to mitigate adverse effects on Butternut;
• describe all feasible measures that will be taken to minimize the adverse effects of the project on Butternut and its habitat, such as:
• minimize the footprint of the development and consider alternate locations and/or configurations where the habitat is already disturbed;
• design and implement offsets for effects to Butternut and habitat, as determined appropriate through technical discussions with ECCC, to be hosted by the Proponent;
• that consider: the Operational Framework for Use of Conservation Allowances (Minister of the Environment, 2012); and
• identify how avoidance and mitigation measures are consistent with the federal recovery strategy and how they meet the population and distribution objectives for the species.

With respect to Western Chorus Frog, the Proponent must:

• identify what alternative means of carrying out the project were considered that would minimize impacts to Western Chorus Frog;
• describe all feasible measures that will be taken to minimize the adverse effects of the project on Western Chorus Frog and its habitat;
• for areas of breeding, dispersal and overwintering habitat, provide an account of how the proposed avoidance and mitigation measures will minimize impacts to Western Chorus Frog and its habitat;
• identify proposed offset plans for any impacts that cannot be avoided or mitigated including the creation of replacement habitat, consistent with the Government of Canada's Operational Framework for Use of Conservation Allowances; and
• identify how avoidance and mitigation measures are consistent with the federal recovery strategy and residence description for the species.

With respect to Little Brown Myotis, Northern Myotis and Tri-coloured Bat the Proponent must:

• describe all feasible measures that will be taken to minimize the adverse effects of the project on SAR bats and their habitat;
• describe the effectiveness of the mitigation measures; and
• identify how avoidance and mitigation measures are consistent with the federal recovery strategy and residence description for the species.

With respect to Red-headed Woodpecker, the Proponent must:

• describe all feasible measures that will be taken to minimize the adverse effects of the project on Red-headed Woodpecker and its habitat;
• identify how avoidance and mitigation measures are consistent with the federal recovery strategy and residence description for the species; and
• identify offsetting plans for any impacts to red-headed woodpecker individuals, or trees used by Red-headed Woodpeckers for nesting or roosting (i.e., residences under SARA that are afforded year-round protection), or changes to landcover that may negatively impact nesting or foraging by red-headed woodpeckers.

SARA s. 73(3)(c) – Jeopardy

The proponent must describe, after considering the alternatives and mitigation measures as described above, how the proposed project will not result in jeopardy to any of the species affected by the project.