Comments on the Summary of the Initial Project Description for the Riverside Generating Station Project (Reference No. 89801) 

To the Impact Assessment Agency of Canada, 

I am writing to express my significant concerns regarding the proposed Riverside Generating Station (Reference No. 89801), a natural gas-fueled peaker plant proposed by Atura Power for the former Lambton Generating Station site in St. Clair Township. I have reviewed the summary of the Initial Project Description and ask that the following issues related to air, water, overall health, and available alternatives be given comprehensive and priority consideration during the impact assessment process. 

1. Concerns Regarding Water Quality and the Walpole Island First Nation 

The project's location near the St. Clair River, a vital water resource, is highly concerning, particularly for Indigenous communities. 

Impact on Drinking Water: I am gravely concerned that the Walpole Island First Nation (Bkejwanong Territory) obtains its drinking water from the water system that will be impacted by this peaker plant's water usage and/or discharge. The IA must be required to provide absolute assurance, in consultation with the First Nation, that the project will not compromise the quality or security of their water supply, during all phases (construction, operation, and decommissioning). 

Water Consumption and Discharge: I request full transparency and a rigorous assessment of the plant's anticipated water withdrawal and consumption rates. As a fossil fuel facility, it will require water and wastewater infrastructure. The IA must clearly outline the projected quality and location of all wastewater (liquid effluents) discharge to ensure no contamination of surface or groundwater, which could affect the entire region. 

2. Concerns Regarding Air Quality and Climate Change 

As a natural gas-fueled facility operating in a region already impacted by industrial activity (Sarnia's "Chemical Valley"), the added emissions from this plant are unacceptable. 

Local Air Quality and Smog: The simple cycle gas turbine will emit Nitrogen Oxides, a key precursor to ground-level ozone (smog), and Particulate Matter. I ask the IAAC to critically evaluate the cumulative impact of these emissions on local air quality, given that the area already faces existing air quality challenges. 

Climate Change and Methane Leakage: The Summary must address the long-term impact of locking in a new source of carbon dioxide emissions for a projected 20+ year lifespan. Furthermore, I request a mandatory Life-Cycle Analysis of Greenhouse Gas (GHG) emissions, including an explicit accounting for methane leakage from the entire natural gas supply chain (from fracking, pipelines, and distribution) that will supply this facility. Methane is a highly potent short-term climate pollutant. 

3. Concerns Regarding Overall Human Health and Environmental Justice 

The decision to site a new fossil fuel plant in a fenceline community raises significant environmental justice issues. 

Cumulative Health Impacts: The IA must assess the cumulative effects of this new source of pollution on the health of local residents, especially those in the nearby Indigenous communities and historically burdened low-income neighborhoods. Emissions like particulate matter and nitrogen dioxide are known to be associated with increased rates of respiratory and cardiovascular illnesses, including childhood asthma. 

Mandatory Health Impact Assessment (HIA): Given the existing industrial burden on this location, a standalone, independent Health Impact Assessment (HIA) should be required as part of the federal assessment to adequately predict and address potential negative health outcomes. 

4. Concerns Regarding Project Need and Cleaner Alternatives 

I am concerned that pursuing this natural gas project is unnecessary given the availability of cleaner, more modern alternatives. 

Feasibility of Alternatives: The IA should fully and rigorously assess non-emitting, reliable alternatives to meet Ontario's capacity needs, such as Battery Energy Storage Systems (BESS), and the pairing of renewable energy (solar/wind) with storage. Newer, large-scale battery projects can provide the necessary "peaking" power without the associated air, water, and climate pollution of a gas plant. 

The "Lock-In" Effect: Approving a new fossil fuel facility that will operate until at least 2050 contradicts Canada's stated long-term climate goals and global efforts to rapidly decarbonize electricity grids. This project represents a long-term "fossil fuel lock-in" that will hinder, not help, the transition to a clean economy. 

I urge the Impact Assessment Agency of Canada to fully investigate these concerns and use this public comment period to gather sufficient information to prepare a thorough summary of issues that recognizes the gravity of adding a new fossil fuel generator to this sensitive area. 

Peter Mayhew
Community Engagement Programs Officer