Position Paper on Unconventional Shale Gas Extraction (Fracking) in Nova Scotia
Nova Scotia Salmon Association (NSSA)
Introduction
The Nova Scotia Salmon Association (NSSA) is a conservation organization formed in 1963 with its
main objective being the protection and conservation of wild Atlantic salmon. The Association has a
direct membership of 350 individuals with an additional 3,500 through 23 provincial affiliate or river
groups. The NSSA is the regional council of the Atlantic Salmon Federation.
Over the years NSSA has been active on various fronts. It forms part of the Provincial Invasive Species
Committee and is represented on the Inner Bay of Fundy Recovery Program. It is a leader in bringing
two levels of government and various river groups together to save the wild Atlantic salmon in the
Southern Uplands of Nova Scotia (Zone 20/21). It has instigated an Acid Rain Mitigation Program on
the West River Sheet Harbour. The latter is a 10 year liming project which is the only one in North
America. The total cost over the 10 years, over $750,000, has, to date, been totally funded by nongovernmental organizations.
NSSA operates the “Adopt a Stream Program”. This is funded by the anglers of NS and also by a
partnership with the NS Liquor Corporation. This program supports 23 river groups to enhance and
protect rivers and riparian habitat. To this end the program contributes over $400,000 annually, not
including “in kind” contributions.
The Association was an intervener during the proceedings of the North West Natural Gas Pipeline and
the Alton Liquid Gas Project.
Our current understanding of the Unconventional Shale Gas Extraction Process is essentially that
contained in the document Primer on the Process of Hydraulic Fracturing prepared as a supporting
document to the Nova Scotia Hydraulic Fracturing Independent Review and Public Consultation
Process.
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Position Paper on Unconventional Shale Gas Extraction (Fracking) in Nova Scotia
Nova Scotia Salmon Association (NSSA)
Basically, we understand the gas extraction process to include;

the injection of fluids under pressure into deep shale gas wells to open existing rock fractures
and create new ones;

the extraction of natural gas through these fractures; and

the recovery of a variable quantity of the injection fluids as flowback.
As the injection fluids contain various types and quantities of generally undisclosed chemical additives
and the flowback fluids will contain these contaminants as well as others extracted from the shale,
including Naturally Occurring Radioactive Materials, salty brines, organic materials and various
metals, depending on the rock formation being fractured.
Based on this level of understanding, the NSSA has several concerns with the extraction of
unconventional gas at a commercial scale. We understand that much exploration work is required prior
to commercial development, but we feel that a precautionary approach must be taken to ensure
adequate protection of Nova Scotia's fragile Atlantic salmon resource. This includes the fish
themselves through all stages of their life cycle and their supporting habitats, both freshwater and
marine.
Contrary to industry assurances and platitudes, we feel there is a need for further environmental
assessment of the gas extraction process specific to Nova Scotian geology and greater disclosure of the
materials used and issues that have arisen from previous extraction developments in other jurisdictions.
NSSA Position
The NSSA takes the position that water is a finite and non-renewable resource. The quantity of water
on earth is fixed and is recycled through the hydrologic cycle. Of the total quantity of water on earth,
only a limited portion is suitable for the support of life. Once a quantity of this water is removed from
the cycle, either through deep injection for gas extraction or contaminated by some process, it is lost
forever.
Point 1
As stated in the Primer document, hydraulic fracturing is a water intensive process, with large
withdrawals potentially required. Additionally, there are quantities of unknown chemicals and
additives that have the potential to be released into the environment, with unknown but likely severe
consequences. Water resources are already stressed in Nova Scotia, where several watercourses and
aquifers already have extraction permits well beyond sustainable levels, particularly in agricultural
areas. Add in the current and future effects of climate change, and it becomes clear that we need to
ensure that we put measures in place to adequately conserve our water resource.
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Position Paper on Unconventional Shale Gas Extraction (Fracking) in Nova Scotia
Nova Scotia Salmon Association (NSSA)
The NSSA feels that more must be done to address the recycling of flowback water to reduce the need
for large volumes of water extraction. There is also a need for the industry to develop a chemical
recycling process to reduce the possibility of release through such events as holding pond failures.
These measures must be in place prior to commercial scale development of unconventional gas
extraction.
Point 2
Whether real or perceived, the shale gas extraction industry seem to operate in a world of secrecy and
non-disclosure. There are reports of drinking water contamination and numerous lawsuits settled out of
court with non-disclosure conditions. This does nothing to allay the concerns of those who may be
adversely affected by gas extraction. There seems to be a lack of information specific to the geology of
Nova Scotia and the potential for aquifer and/or surface water contamination.
The NSSA feels that the industry needs to be more open about a number of factors prior to the
development of any commercial scale gas extraction in Nova Scotia. Specifically, Nova Scotians have
the right to know what chemicals are being used and the true potential for cross aquifer contamination.
We feel this can best be addressed by a strategic type environmental assessment that has ample
opportunity for public input and consultation on the development of a gas extraction industry in Nova
Scotia. As well, project specific environmental assessments must be completed for individual
development projects.
Point 3
Nova Scotia has a legacy of the remnants of past resource extraction industries. These range from
abandoned mine tailings piles leaching heavy metals and acidic runoff to our watercourses, abandoned
dams and damaged watercourses from past and present forestry practices, abandoned underground and
open pit mines that need long term remediation and monitoring, and a host of other liabilities.
Prior to the development of a shale gas extraction industry in Nova Scotia, the NSSA feels that a proper
post-production and decommissioning and abandonment plan be in place and that adequate financial
resources be put aside by the industry to ensure that this wind down of the industry can be properly
executed with the Nova Scotian taxpayers footing the bill and suffering the consequences of a further
impaired environment.
Conclusion
In closing, the NSSA requests that the precautionary approach to the development of this resource be
implemented. We understand that exploratory work is required to determine if a viable gas extraction
industry if possible in Nova Scotia. However, we would expect that no commercial development be
undertaken until our concerns as described above and those of other stakeholders are properly and
adequately addressed.
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Position Paper on Unconventional Shale Gas Extraction (Fracking) in Nova Scotia
Nova Scotia Salmon Association (NSSA)
In particular, we expect that the protection of salmon and other aquatic species and their supporting
habitats be given due consideration and receive adequate protection should commercial scale gas
extraction proceed.
As evidenced by our past involvement with natural gas projects, as stated in the introduction, the NSSA
is not anti-development in principle, but we do expect that development happen in a manner which
protects or enhances the Atlantic salmon and fish habitat in Nova Scotia. As such, we are more than
willing to work with industry to ensure the most sustainable development possible of our natural
resources possible.
The Nova Scotia Salmon Association (NSSA)
Submitted April 30th 2014
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