Fast Acting Natural Gas Power Generation Facility – Salt Springs IESO Nova Scotia Project # 25-12223

Fast Acting Natural Gas Power Generation Facility – Salt Springs IESO Nova Scotia Project # 25-12223:

I have many concerns with the proposed Fast Acting Natural Gas Power Generation Facility in Salt Springs Pictou County.

I will be referring to listed sections and pages from the Environmental Assessment Registration Document and Initial Project Description – Plain Language summary.

1. Water use

Nova Scotia had an intense drought in the summer of 2025, and everyone is worried about well water. I live in Salt Springs and experienced an unprecedented drop in my well water, which was not resolved until well into November. 14.5.2 page 45, states the project will need multiple wells to support the facility and groundwater withdrawal can also impact surface water through reduction in baseflows. The proposal indicates a water requirement equivalent to 750 households or approximately 330,000 litres of water per day. This threatens the safety of our private well water.

1.  Habitat loss

1. Wetlands – According to the Nova Scotia Wetland conservation policy, 53 species protected under provincial law are dependent on wetlands for survival. Section 14.7 page 48 states 29 wetlands are identified within the Project Area, 18 further assessed and 11 identified as a potential Wetland of Special Significance (WSS) with 6 designated for alteration. Who is looking out for these species? Either they are protected or they are not? 29 Black Ash trees with historical significance to the indigenous community were identified. On page 50 they will “maximize avoidance of impacts to Black Ash and its supporting habitat” what does this mean and how will it be monitored / measured?  It is suggested that necessary compensation for lost wetland habitat will be implemented. What kind of compensation would this be?

Six Mile Brook – during the biophysical baseline report for the Six Mile Brook Pit Expansion project in 2023, conducted by McCallum Environmental Ltd, juvenile, and adult Atlantic Salmon were the most abundant species in the Six Mile Brook. Fish capture results suggest that brook trout, brown trout and Atlantic Salmon were spawning within the tributary. Atlantic Salmon and brook trout are considered priority species.

Section 14.6.2 page 47states continued groundwater removal from the power plant will lower the water table, directly impacting the habitat’s capacity to support one or more life processes of fish. I am worried about the water quality and quantity changed of the Six Mile Brook.

1. Migratory and local birds – Between April 29^th and July 4^th,2025, 1074  birds were observed during the environmental assessment, representing 74 species. I live in Salt Springs and have participated in Project Feeder watch for five years. In all that time I have only accumulated 16 Winter bird species in my yard in Salt Springs and 76 Summer species on my Merlin app, traveling around the whole province. I believe 74 species in the proposed plant site is a significant amount, for example, I live 4km away from the site and I have never recorded Canada Jay, blackpoll warbler, or boreal chickadee, as found by the environmental assessment. This seems to be a significant site and requires further research to assess the risks. As such in section 14, 10 .3 they had to list 17 (!) mitigating measures to try and reduce effects on avifauna.

Section 19.3-page 61 states habitat loss could reduce potential breeding habitat for species protected under the Migratory Bird Regulations. Clearing of vegetation will be scheduled to occur outside of breeding season. If vegetation clearing must occur during the breeding and nesting season, a pre disturbance nest sweep area search will be included. When the project is contracted how will this be monitored?

Page 53 - Wetland compensation fees may be used to assist with funding wetland-dependent avian research, especially regarding Canada warbler that is found in relatively high densities within the Project Area. Does that make it okay to destroy habitat for species at risk? No!

Section 14.9.2 – “It is likely that wildlife that currently use habitat within the Project Footprint will be displaced by the Project into the surrounding environment.” Where? Where will they go? Look around, habitat loss has occurred throughout this area. The natural world has no where else to go. Do we have to develop every square centimeter of Nova Scotia? 

I propose using an already developed industrial site for this power plant. The current Trenton generating station has access to the electrical grid and lots of water. Renewable natural gas or biomethane sourced from the Pictou County Solid Waste Facility would be an actual alternative moving towards Nova Scotia’s clean power plan. The electrical grid and the Middle River are near this existing industrial site. Priority should be given to existing sites.

Finally, if IESO is putting the onus on a private company to construct, own and run the plant, how are they committed to guaranteeing all of the above mitigation measures they listed under each of the physical and biological factors in section 14? Why is there no agreement in place to hold the company accountable? Will they just let what happens happen and blame the private company? We the people of Salt Springs need more guarantee than that. We need our water rights protected. The avifauna and wildlife need their rights protected. An impact assessment is needed.