Northvolt’s major industrial project recently sparked a lot of reaction in the media and revealed some confusion regarding environmental assessment practices in Quebec. According to many journalists and columnists, taking the environment into account in such a project would only come down to the analyzes carried out by the Bureau d’audiences publique sur l’environnement (BAPE). The reality of practice is more diversified and benefits from a variety of actors.
The BAPE is not the only actor, does not make decisions and does not intervene in all files subject to the environmental assessment procedure. The minister may mandate the BAPE to hold public hearings when an impact study has been submitted and analyzed by a series of experts from different ministries, consultations have already been carried out on the project by the initiator and when one or more requests for hearings, by the community, are made.
Without an impact study, it is difficult for the public to have enough information on the project to decide whether it is relevant to request that the BAPE intervene in order to provide another, independent perspective on the project. The impact study and its summary are also the main documents studied and evaluated by the BAPE during its investigation.
It is incorrect to say that the BAPE remains the main means and one of the only ways, for the population, to participate in the evaluation of projects and to express themselves. In fact, consultation is mandatory when an impact study is carried out. It is encouraged upstream of the study in order to improve and optimize the design of the project. We sincerely believe that the BAPE public hearing process is very useful and, in certain cases, essential.
However, the organization intervenes at the end of the process. It is much easier for a promoter to adapt his project to take into account citizen concerns when they are expressed early. This requires, of course, openness and exchanges on both sides, which is encouraged by the impact study process. This practice is very frequent and widespread.
Some initiators will even go so far as to prepare an impact study voluntarily with the aim of ensuring that they fully capture all the issues of their project by consulting the community, to propose mitigation or compensation measures and thus to improve their project. The impact study is an excellent planning and decision-making tool.
It is not the BAPE which can be perceived as an obstacle by certain project initiators, but rather the environmental assessment process as a whole, which can lead to public hearings if the issues of the project justify it or if it There is a request to this effect.
The BAPE exam, in itself, is not long or difficult. It only lasts four months for a public hearing, three for a targeted hearing and two for mediation. The impact study takes on average 18 months, which is not that long. The BAPE report is not the only report that helps the government decide. The Ministry of the Environment, the Fight against Climate Change, Wildlife and Parks also produces an environmental analysis report, and the impact study, prepared by the initiator, is always a reference document. precious. The government therefore bases itself on these three documents to make its decision at the end of the environmental assessment process, and not only on the BAPE report.
The government has also found even more agile ways to allow certain projects to be carried out “rapidly”, while subjecting them to a so-called accelerated environmental assessment procedure (e.g. the Act concerning the acceleration of certain environmental projects). infrastructure). Without being perfect, this law at least has the merit of offering more transparency and making decisions based on an impact study.
The different stages of an industrial project are also governed by an environmental authorization system as well as by regulations regarding land use and town planning and the protection of agricultural land. This explains, for example, that in the case of the Northvolt project, environmental assessments were carried out in particular to determine the presence of wetlands and threatened species on the site.
But this system is not public, it intervenes piecemeal, it does not require consultation and it does not allow us to understand overall the issues of the project for the environment and society. Furthermore, let us remember that the government already has the legal mechanisms to subject, if it deems necessary, a project to the environmental assessment procedure.
We understand the industry’s concern about wanting to complete its projects quickly. A concrete way for the government to avoid or better limit debates on a particular project would be to exercise its right conferred by Chapter V of the Environmental Quality Act and to order a strategic environmental assessment of the sector. battery. We could thus assess all of the environmental and social issues linked to the development of this new sector in Quebec, determine its consequences and agree on the actions required so that the emergence of this new sector takes place under considered and concerted conditions for the best benefit. of Quebec society.