Concerns with IESO's Environmental Assessment

To whom it may concern

We are writing to express significant concerns regarding IESO’s Environmental Assessment Summary for the proposed Salt Springs natural gas generation facility. There are several major gaps in this assessment that make it impossible to understand the real risks to our community. We respectfully ask that you address these issues with IESO when you meet with them.

Lack of Cumulative Impact Assessment

The summary evaluates the Salt Springs project in isolation, despite the simultaneous proposal of a second facility in Marshdale. Cumulative effects on air quality, noise, traffic, emergency response capacity, and ecological disturbance must be assessed together, not separately.

Insufficient Air Quality Analysis

The summary states that emissions will remain within guidelines but provides no modelling data, no worst‑case scenarios, and no analysis of diesel emissions or cold‑start spikes. This level of analysis is inadequate for a project involving fossil‑fuel combustion.

Minimal Consideration of Diesel Backup Risks

Diesel use introduces significant risks, including toxic emissions, spill potential, and groundwater contamination. These risks are not meaningfully assessed or modelled in the summary.

Incomplete Noise Assessment

Noise impacts are described only in general terms. There is no detailed modelling, no consideration of low‑frequency noise, and no assessment of nighttime operation in a quiet rural soundscape.

Limited Wildlife and Habitat Assessment

The summary relies heavily on desktop review and short field surveys. Seasonal limitations, species‑at‑risk considerations, and habitat fragmentation are not adequately addressed.

Groundwater and Well Protection Not Demonstrated

The summary does not include hydrological modelling or analysis of potential impacts on private wells, which are essential to rural communities. Without this information, groundwater protection cannot be assured.

Insufficient Community Consultation

One open house does not constitute meaningful engagement. There is no evidence that community concerns were incorporated into project planning or that residents were given adequate opportunity to understand or respond to the proposal.

Misleading Framing of Greenhouse Gas Impacts

The summary positions the project as supportive of clean‑energy goals without providing a full GHG inventory or comparing emissions to renewable or storage alternatives. This framing is incomplete and potentially misleading.

Generic, Unsupported Narrative Sections

The narrative sections of the EA contain generic, template‑like language that does not appear to be supported by the level of site‑specific analysis required under Nova Scotia’s environmental assessment regulations. This raises concerns about the depth and rigor of the assessment.

Nova Scotia’s Environmental Risk Assessment (released in December 2025)

The summary presents the project as if it aligns with Nova Scotia’s clean‑energy goals, even though natural gas is still a fossil fuel and the assessment does not compare it to renewable alternatives.

Nova Scotia’s own Environmental Risk Assessment shows that we are facing stronger storms, heavier rainfall, more flooding, more drought, and higher wildfire risk — and Pictou County is identified as one of the counties at higher risk. These are exactly the conditions that make diesel‑based infrastructure more dangerous. None of these climate‑driven risks are meaningfully addressed in the EA.

Given these concerns, we respectfully request that the assessment be expanded to include a full cumulative impact analysis, detailed modelling, and meaningful community engagement before any approval is considered. I would also like to note that we are not opposed to peaker plants in principle; however, adequate consideration must be given to where such facilities are placed to minimize impacts on existing communities.

Sincerely,
Lynda & Jim Cormier