Thank you very much, Mr. Chair and members of the committee, for the opportunity to speak with you today.
As the chair said, my name is Peter Gregg, and I'm the president and CEO of Nova Scotia Power. My goal today is to share some perspectives on how the act applies to our hydroelectric generating stations in the field and highlight opportunities to improve regional implementation in Nova Scotia.
We at Nova Scotia Power value the important work done by this committee and the critical role the Fisheries Act plays in protecting aquatic ecosystems. Nova Scotia Power has operated 16 hydro systems across the province for over 50 years, providing renewable energy and reducing our reliance on fossil fuels. These systems are essential to achieving provincial and federal climate goals, including the phase-out of coal by 2030 and reaching net-zero emissions by 2050.
Our relationship with the Department of Fisheries and Oceans is similarly long-standing. It dates back to the 1920s and has included extensive collaboration on fish passage development and modifications, particularly through the 1970s and 1980s. Over the years, we have taken a continual improvement approach to the operation and upgrade of these facilities. For example, we made substantial investments to comply with modern dam safety standards under the Canadian dam safety program, all while balancing environmental considerations and the affordability of electricity for Nova Scotians. Our hydro systems are not just part of Nova Scotia Power's history; they're critical to our future. However, the cost and complexity of achieving the targets I spoke about are considerable.
We see three key challenges in how the Fisheries Act is currently being implemented.
First, the act's focus on individual fish rather than populations has led to costly and time-consuming Fisheries Act authorizations, or FAAs, for almost all hydro-related work. For instance, a relatively short-term maintenance drawdown required an FAA, adding $300,000 in costs related to offset work.
Second, the FAA process itself is lengthy and unpredictable. One dam refurbishment project submitted in 2020 is still awaiting approval. Additional requirements as we await this approval have increased costs by $4.1 million and have delayed critical safety work.
Third, inconsistent regional interpretations of the act have led to significant operational challenges, which include new environmental studies, costly upgrades and regulatory delays. These costs ultimately fall to Nova Scotians and our customers, who already face high energy transition costs.
To address these issues, we recommend refocusing the act to protect fish populations rather than individual fish, and reserving FAAs for high-risk activities. Routine, lower-risk work should be managed through streamlined processes such as codes of practice or letters of advice. We also urge reasonable leniency on grandfathering legacy systems that were not designed with modern regulations in mind. Finally, flexibility should be built into offsetting policies for older facilities that have already undergone significant upgrades.
Nova Scotia Power remains committed to reducing the environmental impact of our operations and supporting the transition to clean energy. With these adjustments, I believe we can find the right balance among safeguarding fish populations, maintaining public safety, advancing decarbonization goals and keeping electricity as affordable as possible for the people of Nova Scotia.
Thank you. I look forward to your questions.