Multiple Failures and Discrimination in this Assessment

PUBLIC COMMENT - ENVIRONMENTAL ASSESSMENT Fast-Acting Natural Gas Power Generation Facility - Salt Springs
Date: February 7, 2026

Executive Summary

I am a Registered Nurse and a seventh-generation resident of Salt Springs, living within 1 kilometre of the proposed facility. I submit these comments to raise four critical concerns.

First, significant deficiencies in public consultation and a failure to meet the standards for meaningful participation under environmental assessment law.

Second, the absence of a health impact assessment despite documented health risks to vulnerable populations.

Third, inadequate justification for site selection and assessment of alternatives, particularly given the disproportionate burden on a small rural community.

Fourth, concerns about compatibility with Nova Scotia's legislated climate commitments and net-zero targets.

Section 1: Public Engagement Deficiencies

1.1 Inadequate Consultation Process

The Environmental Assessment Registration Document was released on December 15, 2025—one week before Christmas—with the comment period spanning the holiday season. This timing significantly reduced public input. The IESO cancelled both scheduled community meetings: first, due to snow conditions; and second, without providing a reason. The meeting scheduled for February 5^th at the West River Fire Hall was cancelled at the last minute by the IESO. The only public meeting the IESO attended was held without adequate advance notice, and they failed to answer basic questions about the Power Plant or provide any pertinent details. The environmental assessment (EA) documents were unavailable to the public at that time, and the IESO refused to answer basic questions, stating that they “didn’t know” because “they were not sure what company would be completing the project”. To safety, health, and environmental questions, they stated, “we can’t answer that at this time” and “we are not sure yet”. This was the IESO's only public community engagement appearance. This limited public engagement has left little time for research into the project's environmental impacts. The impacts on fish, wetlands, wildlife, and community health are profound. 

Direct Notification Failure: I received no direct mail notification despite living within 1 kilometre of the proposed site. Neighbours within 2-5 kilometres also received no notice. Many residents learned of this proposal in January 2026. Residents 2 kilometres from the site learned of the project on January 29, 2026—just 11 days before the comment deadline. Others living within 3 kilometres of the site were still unaware of the project in February—this demonstrates ineffective notice.

Digital Divide: IESO relied primarily on online portals, digital notices, and social media. Pictou County has one of Nova Scotia's most senior populations. Many seniors lack internet access, computer literacy, or access to review a 290-page technical document. This systematically excludes residents without internet access, those with limited formal education, and those with accessibility barriers, making the process discriminatory. There is no process to assist seniors in creating comments, and no accessibility accommodations are in place to assist those with differing abilities in accessing the material and creating comments for the EA process. 

Indigenous Consultation: Engagement with Mi'kmaw communities primarily consisted of emails and voicemails during the holidays and fiscal year-end, when many Indigenous governments are at their busiest with financial reporting. Given that this project is proposed on unceded Mi'kmaw territory and may affect fishing rights and traditional territories, this raises serious concerns about fulfilling the duty to consult.

1.2 Industry Standard Comparison

For comparable projects, proponents typically provide direct mail to all residents within 5 km, hold multiple in-person public information sessions, attend public meetings, provide plain-language project summaries, extend comment periods (60-90 days, avoiding holidays), and provide accessible printed materials. IESO provided none of these.

1.3 Recommendations

I recommend that the Minister require:

• Directly addressed mail notification to all residents within 5 km
• Media exposure that removes false claims that this is a "transition to renewables." Transparency regarding real risks and rationalizations. 
• Minimum five in-person public information sessions with unbiased technical experts with no conflict of interest to explain the project
• Plain-language summary documents made available in print and located in accessible places where seniors can sit down to read, and an accessibility plan to avoid discriminatory community engagement 
• Meetings are in person and live-streamed for full accessibility, with multiple dates and times to accommodate working community members who may work shifts outside typical hours. 
• 90-day comment period not overlapping major holidays and extended due to limited public exposure to the project and details
• Community access to accessible printed materials (we were denied a printed copy for examination) that can be taken home to facilitate various accessibility requirements. 
• Extension of the current deadline by at least 90 days

Section 2: Absence of Health Impact Assessment

2.1 Critical Omission

This EA contains no health impact assessment for a facility that will emit nitrogen oxides, fine particulate matter (PM2.5), sulphur oxides, carbon monoxide, volatile organic compounds, and benzene—a known carcinogen—within 1 kilometre of residential homes, near an elementary school, and near vulnerable populations.

2.2 Respiratory Health

Research on fuel-fired power plants shows significantly higher rates of asthma hospitalizations, acute respiratory infections, and chronic obstructive pulmonary disease among nearby residents. Analyses indicate that pollutants from gas-fired plants contribute to thousands of excess deaths annually, hundreds of thousands of asthma attacks, thousands of new childhood asthma cases, and billions in health costs in places where these plants are situated.

Children exposed to even low levels of PM2.5 face a substantially higher risk of early childhood asthma. Long-term exposure reduces lung function development and causes permanent damage.

Application to Salt Springs: This facility will directly increase pediatric asthma incidence, emergency department visits, COPD progression among elderly residents, and healthcare costs.

2.3 Cardiovascular Disease

Air pollution affects cardiovascular health through systemic inflammation, direct tissue toxicity, accelerated atherosclerosis, elevated blood pressure, and increased blood clotting. Research shows that each incremental increase in PM2.5 exposure is associated with a substantially higher risk of heart attack, ischemic heart disease mortality, and cardiovascular death. Effects occur even at concentrations below current air quality guidelines.

Application to Salt Springs: Nova Scotia and the Atlantic provinces have higher rates of cardiovascular disease than the rest of Canada. Pictou County's aging population faces disproportionate harm. Any increase in PM2.5 and NOx leads to more heart attacks, higher stroke incidence, increased cardiovascular mortality, and strain on rural healthcare resources.

2.4 Cancer Risk

Gas power plant emissions contain multiple carcinogens. Research demonstrates that chronic exposure to benzene increases cancer risk even at low levels. Long-term PM2.5 exposure significantly increases lung cancer incidence and mortality. Studies show exposure to PM2.5 and nitrogen dioxide associates with increased colorectal, prostate, and breast cancer risks, even at concentrations below current guidelines.

Application to Salt Springs: Thirty to fifty years of continuous carcinogen emissions will result in chronic cumulative exposure and elevated cancer risk across multiple organ sites.

2.5 Maternal and Infant Health

Natural gas pollutants pose serious risks to pregnant individuals and developing fetuses. Air pollution is strongly associated with an increased risk of gestational hypertension and preeclampsia—major contributors to maternal and infant mortality. Research consistently links PM2.5, NOx, and VOCs to low birth weight, which predicts infant mortality and later adult disease. Studies of women living near gas plants found significantly increased odds of preterm delivery—the leading cause of newborn death.

Application to Salt Springs: Nova Scotia faces challenges accessing maternity care in rural areas. Pictou County women already have limited prenatal care options and barriers to specialized services. Exposing pregnant women to these pollutants in an area with inadequate maternity care is unacceptable.

2.6 Vulnerable Populations

Pictou County has one of Nova Scotia's highest proportions of residents aged 65+ who face pre-existing conditions, reduced physiological resilience, and fixed incomes that limit their ability to implement protective measures. Children face developing organs, faster breathing rates, and lifetime cumulative exposure. Rural residents experience worse baseline health outcomes, physician shortages, long distances to emergency and specialized care, lower median incomes, and designation as a Health Professional Shortage Area. Research shows that healthcare barriers exacerbate pollution-related health impacts.

2.7 Property Devaluation

Research shows that property values near industrial facilities decline significantly. This devaluation traps residents—especially elderly homeowners on fixed incomes—in homes they cannot sell at fair value. Loss of housing equity deprives seniors of financial resources for healthcare costs or home modifications. This economic burden creates chronic financial stress, which is independently associated with cardiovascular disease, depression, and reduced life expectancy.

2.8 Cumulative Environmental Burden

Salt Springs and Pictou County have already borne decades of industrial pollution from Northern Pulp and Boat Harbour—documented elevated pollution levels, environmental racism affecting Pictou Landing First Nation, and ongoing remediation. This EA evaluates the facility in isolation, failing to account for pre-existing pollution exposure, the combined effects of multiple sources, and the community’s baseline health status. A community already burdened cannot absorb additional emissions without significant consequences.

2.9 Water Security

This plant will require water equivalent to 750 rural households. Salt Springs residents rely on private wells with no alternative source. Extracting large volumes from aquifers can significantly degrade local well water quality. Contamination pathways include process wastewater discharges, fuel storage spills, stormwater runoff, and well-construction failures. Groundwater contamination is effectively permanent remediation is prohibitively expensive and often impossible. This extraction will also affect brook water levels, affecting fish habitat and traditional Indigenous food sources.

2.10 Healthcare System Capacity

Nova Scotia faces severe healthcare workforce shortages, particularly in rural areas: shortages of primary care physicians, limited specialist access concentrated in Halifax, emergency department overcrowding, and long diagnostic wait times. Pictou County residents face transportation barriers, time costs, and difficulties with care coordination.

Pictou County faces significant maternity care challenges: limited obstetricians, distance to comprehensive services, no local certified midwives, and limited access to paediatric specialists. Women in maternity care deserts have higher rates of conditions, increased pregnancy complications, and higher mortality risk.

Adding pollution exposure that increases the burden on respiratory, cardiovascular, cancer, and maternal-infant health, where healthcare capacity is already inadequate, is particularly harmful.

2.11 Social Cost and Environmental Justice

Analyses of comparable facilities indicate that the social cost of carbon ranges from billions to tens of billions of dollars over the operational life. Health-related damages, including mortality, hospitalizations, cancer cases, and maternal-infant outcomes, total tens of millions annually. Local residents bear costs through illness and lost work. The healthcare system bears costs through emergency visits and hospitalizations. Taxpayers bear costs through publicly funded healthcare. The proponent externalizes these costs.

This project focuses on environmental health risks for a small, vulnerable, rural population already burdened by industrial pollution; worsens social determinants through property devaluation, water insecurity, and healthcare barriers; and excludes affected residents through inadequate consultation.

2.12 Recommendations

I recommend that the Minister require:

• Comprehensive Health Impact Assessment, including baseline health data, cumulative risk assessment that accounts for the Northern Pulp legacy, vulnerable population assessment, healthcare capacity analysis, property value impact assessment, water security assessment, and social cost calculation
• Independent public health review with epidemiologist evaluation and peer review
• Alternative location analysis identifying sites with less human and environmental impact

Section 3: Inadequate Site Selection and Alternatives Assessment

3.1 Absence of Site Selection Justification

The EA fails to demonstrate why this location was selected or what alternative sites were considered. The justification is limited to proximity to existing pipeline and transmission infrastructure. This narrow rationale ignores residential proximity, rural community character, environmental justice, and availability of alternative sites that would not impose concentrated burdens on a small rural population.

3.2 Disproportionate Burden on a Rural Community

Salt Springs is a small, rural residential community. Residents have built multi-generational lives here, with the reasonable expectation that this area would remain residential and agricultural. Siting this facility here imposes disproportionate burdens:

Scale of Impact: A facility connected to the provincial grid concentrates all environmental, health, and economic burdens on approximately 200-300 nearby households.

Rural Vulnerability Amplified: Salt Springs residents have no municipal water supply if wells are contaminated, limited access to healthcare to address pollution-related illness, lower median incomes, reduced capacity to relocate or install protective measures, an aging population with higher baseline health vulnerability, and property values that decline more severely in rural areas where industrial proximity contradicts community character.

Violation of Rural Character: This community has historically been residential and agricultural. Introducing heavy industrial infrastructure fundamentally transforms community character and violates the reasonable expectation that rural residential areas will remain free from industrial development.

Compounded Injustice: Salt Springs has already endured decades of industrial pollution from Northern Pulp. Siting another major pollution source here compounds the historical environmental injustice.

3.3 Failure to Assess Alternative Locations

The EA does not disclose which alternative locations were identified and evaluated, what criteria were used to compare potential sites, whether locations with existing industrial zoning were considered, whether sites farther from residential areas were evaluated, whether locations with municipal water supply were assessed, or how residential proximity, well water dependence, and population health were weighted in site selection.

Industry-standard practice requires a comprehensive site-selection analysis that compares multiple locations across environmental, social, economic, and technical criteria. This EA provides no such analysis.

3.4 Alternative Site Characteristics

Alternative locations exist that would achieve the same energy goals while avoiding concentrated harm:

Existing Industrial Zones: Nova Scotia has established industrial areas with existing buffer zones where industrial operations are expected, residential proximity is limited, municipal water supply is available, and land use is already designated for industrial purposes.

Previously Disturbed Sites: Locations with existing industrial infrastructure would avoid introducing new pollution into clean residential areas, eliminate the need to transform rural residential character, and concentrate industrial activities rather than dispersing them into new areas.

Non-Residential Areas: Locations that are significantly distant from homes, schools, and communities would eliminate direct health impacts on vulnerable populations, avoid property devaluation, reduce the risk of well-water contamination, and protect rural residential quality of life.

The EA provides no evidence that such alternatives were evaluated or that they were rejected in favour of a site within 1 kilometre of residential homes.

3.5 Unjust Distribution of Costs and Benefits

The proponent selected this location to minimize capital costs by locating near pipeline and transmission infrastructure. This decision externalizes enormous costs onto Salt Springs residents, who receive no corresponding benefits.

Costs Imposed: Health impacts from 30-50 years of exposure to air pollutants; property devaluation, trapping residents in declining home values; loss of well-water security and the risk of permanent aquifer contamination; destruction of rural residential character; and psychological stress from living near an industrial pollution source.

Benefits Received: Electricity serves the provincial grid, not local needs. Operational employment is estimated at 10-15 jobs. Construction employment is temporary. No community benefit agreement has been disclosed.

Economic gains accrue to the proponent and distant ratepayers, while health, environmental, and economic costs are concentrated entirely on Salt Springs.

3.6 Rural Communities Warrant Greater Protection

Rural communities face compounding vulnerabilities that warrant protection in site selection decisions.

Limited Political Voice: Small populations have less political representation and influence. Salt Springs cannot mobilize the same level of organized opposition as urban neighbourhoods.

Infrastructure Dependence: Rural residents rely on private wells. Industrial contamination risks are catastrophic because no alternative water supply exists.

Healthcare Access Barriers: Rural communities face severe healthcare workforce shortages. Adding pollution exposure to settings where healthcare access is already inadequate compounds the harm.

Economic Vulnerability: Rural median incomes are lower than in urban areas. Property values represent a larger share of total wealth. The capacity to relocate or absorb financial losses is more limited.

Expectation of Environmental Quality: Rural residents accept limited services and longer travel distances in exchange for environmental quality, clean air and water, and freedom from industrial development. Violating this fundamental expectation undermines the basis on which rural residents have built their lives.

3.7 Alternative Energy Solutions

Beyond alternative locations, the EA inadequately evaluates alternative energy technologies:

Clean Energy Portfolios: Combining solar, wind, battery storage, energy efficiency, and demand flexibility can meet the same grid needs. Utility-scale solar costs are dramatically lower than those of fossil fuel alternatives. Battery storage costs have fallen by 89% since 2010. These alternatives avoid all local health and environmental impacts.

Distributed Generation: Smaller-scale renewable installations distributed across the province eliminate the need for large centralized facilities while providing grid resilience and avoiding concentrated environmental impacts.

Demand Management: Energy efficiency programs and demand response can reduce peak electricity needs. The EA provides insufficient analysis of whether improved demand management could obviate this project.

3.8 Economic Risks

This facility faces significant economic risks: volatile gas prices expose ratepayers to unpredictable fuel costs, stranded asset risk as renewable costs continue to decline and climate policies tighten, potential carbon pricing that could render the facility uneconomical, and difficulty securing financing as investors divest from fossil fuels.

The economic analysis does not account for true costs because it externalizes health and climate damages. Health damages alone cost tens of millions over the facility's lifetime. Climate damages add billions in social costs. When these externalized costs are internalized, renewable alternatives become overwhelmingly economically superior.

3.9 Recommendations

I recommend the Minister require:

• Comprehensive Site Selection Analysis documenting all alternative locations considered, the evaluation criteria applied, and the comparative assessment, with particular attention to why a rural residential community was selected over existing industrial zones
• Environmental Justice Analysis assessing whether this site selection disproportionately burdens a small rural community and violates the principles of fair distribution of environmental risks
• Alternative Site Assessment evaluating locations with existing industrial zoning, established buffer zones, municipal water supply, and minimal residential proximity
• Rigorous Clean Energy Portfolio Alternative Evaluation to determine whether renewable energy combinations can achieve equivalent grid reliability at comparable or lower cost
• Full Lifecycle Cost Accounting that internalizes health and environmental damages, property devaluation, and risks of well water contamination
• Assessment of Distributed Generation and Demand Management Alternatives

Section 4: Climate Compatibility Concerns

4.1 Provincial Climate Law

Nova Scotia's Environmental Goals and Climate Change Reduction Act requires 80% renewable electricity by 2030 and net-zero emissions by 2050. This gas plant may be inconsistent with these binding legal obligations.

4.2 Fossil Fuel Lock-In

IESO proposes operations beginning in 2030, with an operational lifespan of 30-50 years. This facility would burn fossil fuels until 2060-2080, locking in fossil fuel dependence, creating stranded asset risk, committing ratepayers to long-term fossil fuel costs, and occupying land and grid capacity that could support renewable generation.

4.3 Annual Emissions

This facility will emit 325,594 tonnes of CO2 equivalent annually—equivalent to approximately 29,700 U.S. households per year.

4.4 Misleading Characterization

IESO characterizes this project as supporting the clean energy transition. Natural gas is a non-renewable fossil fuel and a significant greenhouse gas source, incompatible with net-zero targets. Characterizing fossil fuel combustion as "clean" or "transitional" while proposing 50-year operations is misleading.

4.5 Upstream Methane Emissions

Beyond direct combustion emissions, natural gas infrastructure contributes substantial methane leakage during extraction, pipeline transport, and processing. Methane is 84 times more potent than CO2 over 20 years. These upstream emissions significantly contribute to climate impacts yet are excluded from the assessment.

4.6 Inadequate Alternatives Assessment

The EA inadequately assesses alternatives. Battery storage is dismissed without rigorous analysis. Demand management receives insufficient consideration. Additional renewable generation receives limited evaluation. The EA presents gas generation as inevitable without conducting a genuine evaluation of non-fossil alternatives.

4.7 Recommendations

I recommend the Minister:

• Assess whether this EA is compatible with provincial climate law
• Require rigorous alternatives assessment evaluating non-fossil options, including battery storage, demand management, and additional renewable generation
• Apply a climate test to determine whether this project advances or undermines Nova Scotia's climate goals

Conclusion

Primary Concerns:

Public Consultation: The timing and methods did not provide an adequate opportunity for meaningful participation by affected residents, particularly vulnerable populations. Indigenous engagement is lacking.

Health Impact Assessment: The absence of a health impact assessment that considers all social determinants of health means decision-makers lack information to understand the potential health consequences for children, older residents, pregnant individuals, and others near the facility.

Site Selection and Alternatives: The EA fails to justify why this small, rural residential community was selected to bear these burdens, what alternative locations were considered, and why clean energy alternatives were not pursued.

Climate Compatibility: The proposal's alignment with Nova Scotia's legislated climate commitments requires evaluation.

Recommended Actions:

1. Enhanced Consultation: Extended comment period, direct-mail notification within 5 km, multiple in-person sessions, and plain-language, accessible materials. IESO is required to attend scheduled meetings. External experts who are unbiased and available to disseminate knowledge to community members in a fair and accessible process.
2. Comprehensive Health Impact Assessment: Baseline community health data, vulnerable population risk assessment, cumulative impact assessment of the Northern Pulp legacy, property value impacts, and water security analysis. Un-biased health experts available to provide peer-reviewed analysis with no conflict of interest.
3. Complete Site Selection and Alternatives Analysis: Comprehensive evaluation of alternative locations, including existing industrial zones, environmental justice analysis, rigorous Clean Energy Portfolio assessment, full lifecycle cost accounting with internalized health and climate damages, and distributed generation and demand management alternatives
4. Climate Compatibility Analysis: Assessment of whether this project advances or undermines provincial climate goals

Final Statement

As a seventh-generation resident of Salt Springs and a healthcare professional, I believe these concerns warrant careful consideration.

Salt Springs is a small rural community that has long served as a residential and agricultural area. We have built our lives here with the reasonable expectation that this area would remain free from industrial development. We have already borne decades of industrial pollution from Northern Pulp and Boat Harbour.

The fundamental question remains unanswered: Why must this small rural community bear concentrated burdens—health risks, property devaluation, risks of water contamination, and loss of rural character—when alternative locations with industrial zoning, established buffers, and municipal water supply exist across Nova Scotia, and when renewable energy technologies are now cost-competitive and avoid all local health impacts?

The scientific evidence on health impacts from similar facilities is clear. Alternative sites exist. Renewable energy is economically viable. Nova Scotia has made binding climate commitments.

A small rural community should not be sacrificed for the economic convenience of a proponent seeking to minimize capital costs. Environmental justice requires a fair distribution of risks and benefits—not the concentration of all burdens on a vulnerable population while benefits flow elsewhere.

Salt Springs residents deserve meaningful participation in decisions that will affect us, our children, and our grandchildren for generations.

Respectfully submitted,

Lori McCullough, RN BScN, RCT, ENP, ENC(C)
Graduate Student, Master of Nursing: Nurse Practitioner, Dalhousie University
Seventh-generation resident, Six Mile Brook, Salt Springs, NS
Living on the unceded territory of the Mi'kmaw Peoples