Montreal, January 28, 2022
TRANSMISSION BY EMAIL
Mr Benoit Charette
Minister of the Environment and the Fight against Climate Change (MELCC)
Minister responsible for the fight against racism
Minister responsible for the Laval region
675 René-Lévesque Boulevard East, 30th floor
Quebec (Quebec) G1R 5V7
Ms Sonia Lebel
Minister responsible for Government Administration
Minister responsible for Canadian Relations and the Canadian Francophonie
Minister responsible for Democratic Institutions and Electoral Reform
Marie-Guyart Building
Treasury Board Secretariat
875, Grande-Allée Est, 4th floor, sector 100
Quebec (Quebec) G1R 5R8
Subject: Request for a BAPE for the Project of 3 pigsties in the municipality of Saint-Adelphe
Minister, Minister,
Hereby, Eau Secours and Fondation Rivières request that the Office of Public Hearings on the Environment (BAPE) be mandated to carry out a complete study as well as a public consultation of the project to construct three piggeries of 3,999 pigs each in the municipality of
Saint Adelphe.
It is clear that by dividing its project of 11,997 pigs into three, the promoter is trying to circumvent the spirit of the law which stipulates that a project of 4,000 pigs or more must trigger a BAPE. Citizens of the region have already very clearly expressed their concerns about the project and their disappointment at the too short delay in the consultation.. For these reasons, and for those we name below, we ask the Minister of the Environment to use his discretionary power and require a comprehensive evaluation process.
The three projects are located on the same lot, 150 meters away from each other. It is difficult to believe that the environmental impacts, as well as the social impacts of these three projects are different from a single project with 11,997 pigs in the same establishment. This artificial segmentation of the project also goes against the principles of integrated water management by watershed recommended by the Quebec Water Strategy.
Let us recall some of the environmental issues linked to the breeding of pigs in mega-piggery mode as well
than to intensive agriculture more broadly:
- Contamination of nearby surface and underground drinking water sources with nitrates
- contained in slurry (according to a study on the quality of drinking water in seven watersheds with surplus manure and potential impacts on health)
- Flows carrying contamination downstream in the watershed
- Excessive use of fertilizers in neighboring fields to dispose of slurry
- Depletion of groundwater reserves
- Significant production of potent greenhouse gases from livestock and storage
- slurry (Vergé,
- Increased risk of outbreaks of diseases transmissible to humans (BAPE report: the inclusion of pork production in sustainable development. (2003). Opinion 54)
Although the promoter is required to ensure responsible implementation and management of his industry in relation to the environment, this cannot be compared to a BAPE public consultation process which makes it possible to highlight possible issues and to propose appropriate corrective measures. In addition, participation makes it possible to collect relevant information and to hear the concerns of expert organizations, scientists, citizens, elected officials and organizations such as Eau Secours and Fondation Rivières.
Let us also remember that there is a lack of social acceptability regarding this project, which sows concern due to its scale and the promoter's desire to circumvent the BAPE evaluation process. This municipality of barely 900 people will see its daily life altered by this project and it should be able to make a decision, in due form and within a reasonable time frame.
It is therefore our opinion, in the general interest of the citizens of Quebec and to ensure the quality of water resources and the conservation of the environment, that the Minister of the Environment and the Fight against Climate Change triggers the BAPE process.
André Bélanger
Managing Director, Fondation Rivières
Rebecca Petrin
Executive Director, Emergency Water
Photo: Pascal Debrunner/Unsplash
