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Request to subject the Northvolt project to an independent environmental assessment

Rivière Richelieu par Gilles Croteau

 Quebec, January 19, 2024

Mr Benoit Charette
Minister of the Environment, the Fight against
Climate Change, Wildlife and Parks
Marie-Guyart Building
675, boulevard René-Lévesque Est, 30th floor
Quebec (Quebec) G1R 5V7
minister@environment.gouv.qc.ca

Minister,

Hereby, 180 environmental organizations, community groups, unions, citizen groups and individuals ask you to recommend to the government that Northvolt's lithium battery plant project, planned for McMasterville and Saint-Basile-le-Grand, be subject to to an independent environmental assessment.

This independent environmental assessment can take different forms. Under section 31.1.1 of the Environmental Quality Act, you can recommend to the government to subject the Northvolt project to the environmental impact assessment and review procedure, including the holding of public hearings led by the Office of Environmental Public Hearings, since the environmental issues that the project may raise are major, and public concerns justify it. You can also ask to carry out a strategic environmental assessment of the entire battery sector, so that each project in this expanding sector is not evaluated individually.

We are concerned by the great lack of transparency shown by the parties involved in this project since its infancy. Environmental and citizen groups and the media are deprived of documents or receive heavily redacted ones and they obtain, at best, incomplete information. Because of the opacity surrounding this project, we do not know the substance of the exact avoidance, mitigation and compensation measures that are planned.

The haste with which this major project is being carried out also worries us. The perception that the Regulation relating to the evaluation and examination of the environmental impacts of certain projects has been modified specifically to the Northvolt project greatly harms the social acceptability of the project and undermines public confidence. This is reinforced by the government's tendency to modify the rules surrounding environmental assessments to accelerate certain projects, such as the adoption in 2020 of the Act concerning the acceleration of certain infrastructure projects.

We are also of the opinion, as are the analysts of your ministry, that the site chosen for this project is of particular importance for biodiversity. The project site includes several wetlands, of which an area of 153,732 m2 is likely to be affected by the work. According to the terms of your ministry, the site plays the role of intermediary between two important forest areas, namely the Saint-Bruno and Saint-Hilaire mountains. There are 21 threatened or vulnerable species in Quebec, and at least 13 species listed in Appendix 1 of the Endangered Species Act, including the bank swallow which has experienced a decline of 99 % in its population since 1970. The site also constitutes a breeding area and a migratory stopover for 142 species of birds. We therefore insist that the energy transition is necessary, but that it cannot be achieved to the detriment of biodiversity.

While Quebecers' concerns about this project continue to grow, environmental authorizations have already been issued, tree felling work has already been observed and the destruction of wetlands sheltering the habitats of species in precarious situations is imminent. An independent environmental assessment is the best way to analyze the concerns of civil society and scientists. It is also the best way to take some time out to ensure the protection of the environment and the relevance of the projects, and if they are authorized, to carry out projects that respect the standards and identify whether there are realistic solutions to minimize their impacts on the environment.

Thanking you for your collaboration, please accept, Mr. Minister, our best regards.

  • Alice-Anne Simard, general director, Nature Québec
  • Alain Branchaud, general director, SNAP Quebec
  • Chantal Levert, general coordinator, Quebec Network of Environmental Groups
  • Rébecca Pétrin, general director, Eau Secours
  • Sabaa Khan, Executive Director, Quebec and the Atlantic, David Suzuki Foundation
  • Caroline Poussier, Acting Director General, Quebec Environmental Law Center
  • Colleen Thorpe, Executive Director, Équiterre
  • André Bélanger, general manager, Fondation Rivières
  • Karel Ménard, Director General, Quebec Common Front for Ecological Waste Management

Photo: Richelieu River, Gilles Croteau

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