Environmental Clearance and Authorization: A New Framework for Quebec

The Environment Quality Act1 (hereinafter EQA), the key legislation governing Quebec’s environmental regime, had not been thoroughly reviewed or revised since it was passed in 1972. In June 2015, the Ministère du Développement durable, de l’Environnement et de la Lutte contre les changements climatiques (MDDELCC) tabled a Green Paper to modernize the regime. Its aim was to “give Quebec a more clear, predictable, and effective regime while maintaining the strictest environmental requirements and standards.”2 Its real innovation was the creation of four environmental clearance mechanisms based on four risk levels (very low, low, moderate, and high). The government also wanted to “improve access to information, civic engagement, and transparency.”3

We already knew the project’s main points in June 2015. In the National Assembly on June 7, 2016, MDDELCC tabled Bill 102, An Act to amend the Environment Quality Act to modernize the environmental authorization scheme and to amend other legislative provisions, in particular to reform the governance of the Green Fund (hereinafter called the AEEQA).4 The bill was passed on March 23, 2017, and its amendments will be phased in between March 23, 2018 and late 2018. The AEEQA affirmed the Green Paper’s commitments. However, in view of the details yet to be addressed by regulation, it left many issues unresolved.

On February 14, 2018, MDDELCC issued 24 draft regulations to this end. While most sought only to make regulations consistent, others have substantially changed the way some activities are regulated and helped to implement environmental clearance mechanisms. The two main ones are the Regulation respecting ministerial authorizations and declarations of compliance in environmental matters (hereinafter called the RMADCEM)5 and the Regulation respecting environmental impact assessment and review for certain projects (hereinafter called the REIAR).6

We will review the environmental impact of authorization and clearance mechanisms under the new regulations and address the new provisions on public access to industrial and environmental data. For conciseness, and given the scope of the new regulations, we will focus only on aspects affecting the energy sector. Since the Act to implement the 2030 Energy Policy7 was passed in 2016, Quebec law has treated the mining (solid substances) and petroleum sectors (gaseous and liquid substances) separately. However, given their close relation to the energy sector, our study will include mining issues. Lastly, we should note that at the time of writing, the regulations are still in the consultation stage and subject to change.

1. Authorization Mechanism Based on Risk Level

Section 20 of the new EQA (hereinafter called the NEQA) sets out the Act’s key tenet, namely, that: “No one may emit, deposit, issue or discharge or allow the emission, deposit, issuance or discharge into the environment of a contaminant in a greater quantity or concentration than that provided for by regulation of the Government.”8 Compliance with the Act is now classified by risk level, and the new regulations set out applicable procedures and required information.

See table 1 below.

Table 1 – New Authorization Process by Risk Level

Risk Authorization Accountability Legal and Regulatory Sources
Very low Exemption N/A – NEQA, Subsection 3, S. 31.0.11 and s.
– RMADCEM, Schedule III
Low Declaration of compliance Proponent – NEQA, Subsection 2, S. 31.0.6 and s.
– RMADCEM, Part 3 and Schedule II
Moderate Ministerial authorization MDDELCC – NLQE, Subsection 2, S. 22 and s.
– RMADCEM, Part 2 and Schedule I
High EIARP9 Government – NEQA, Subsection 4, S. 31.1 and s.


1.1 Very Low Risk

Some activities are exempt from ministerial authorization,10 in particular the Environmental Impact Assessment and Review Process or EIARP. Exemptions fall into two categories based on the source of the exemption. Paragraphs 1 to 9 in the NEQA list activities that require ministerial authorization, while Paragraph 10 of the same section authorizes the government to include “any other activity determined by government regulation.” Schedule I of the Regulation respecting ministerial authorizations and declarations of compliance in environmental matters (RMADCEM) identifies these activities, and the first category of exemption is listed in sections II to IX of Schedule III. The second category, in Section X of the Schedule, excludes by regulation some of the activities added by Schedule I of the same regulations.

See table 2 below.

Table 2 – Sources of Exempt Activities

While there are few energy sector exemptions in the first category, they include:

  • Halocarbon recovery and reclamation projects11
  • Storage of new petroleum products12
  • Maintenance, upgrade, repair, or demolition projects for aspects of an air transport or power distribution network (under certain conditions)13

Exemptions in the second category include:

  • Certain mining activities (staking, geophysical surveys, drilling, etc.) when they are part of a mineral exploration project14
  • The following oil and gas activities:

1° Installation of gas pipelines with a standard rated diameter of less than 300 mm, designed for pressures below 4,000 kPa

2° Geophysical, geological, or geochemical surveys

3° Temporary or permanent closure subject to the standards set out in the Petroleum Resources Act and its regulations15

Despite the exemption for a prior ministerial or government authorization, some exempt activities must be reported to the Minister. This information must include identifying information as well as a description of the activity and its location.16 Failure to notify the Minister can incur an administrative monetary penalty of $500 for an individual or $2,500 in other cases.17

1.2 Low Risk

Low-risk activities are those “that have a minor environmental impact but may require mitigative action.”18 The proponent must “provide a declaration of compliance within 30 days before activity begins . . . and state that it will comply with all project conditions, restrictions, and prohibitions”19 and “is not likely to destroy or otherwise damage a threatened or vulnerable animal species,20 a threatened or vulnerable plant species,21 or a plant or animal species likely to be designated threatened.”22

The declaration must contain the same information as for very low-risk activities,23
and in some cases be signed by a professional or other qualified person in the field.24

Schedule II of the RMADCEM lists low-risk activities and their specific conditions. None of these activities relates directly to the energy sector. In the mining sector, a declaration of compliance can be given for mineral exploration drilling (even in wetlands and water environments)25 if the information for Section 23, Schedule II is included and specified conditions are met.

1.3 Moderate Risk

Projects with moderate-risk activities must obtain ministerial authorization through the following process:

See table 3 below

Table 3

Required Information

First, the proponent must provide the information required under the NEQA (i.e. description of activities as well as and the nature, quantity, concentration, and location of all contaminants that may be released into the environment).26

Then, the RMADCEM27 provides other lists of information to include in an application. These lists fall into two categories. The first (see Section 7) is a “common core” list for all covered activities. The most problematic required information includes:

5° A full list of project activities that require the Minister’s authorization, that need a declaration of compliance, or that are exempt

6° A detailed site description (environmental characteristics, location of all buildings, infrastructure and facilities, presence of protected or threatened plant or animal species, etc.)

7° An interior plan for each building (including production or generating equipment, wastewater and air emission treatment plants, loading and unloading areas, storage sites, discharge or emission points, etc.)

8° a) Nature and methods of the activity (including technical and operational details) for all project phases

12 ° Activity’s expected impact on the environment and the health of humans and other species, and proposed mitigation measures

14° Information and records for related greenhouse gas emissions where applicable (we’ll come back to the Climate Test)

17° When the applicant has used the services of professionals or other qualified people to prepare the project or the authorization request, their names and contact information, a brief description of their mandates, and a statement confirming that their information and records are complete and accurate

These aspects are problematic in terms either of application or lack of clarity. For instance, can the Minister ask the proponent for information on the professionals without breaching confidentiality? Another example: It is hard to gauge the presence of wildlife species within 300 metres of the site because animals, unlike plants, tend to travel and migrate. Also, what facilities need to be listed in the site plan and how much detail is required? Do we include facilities with no environmental impact? Similarly, what is the expected impact on human health (physical or mental)? At the activity site or within a certain radius? We don’t yet know how such information would be used.

The second category, in sections II to XXIII, lists information needed for certain activities.

Note: If the party requesting ministerial authorization has already given the information required under the Environmental Impact Assessment and Review Process, it does not need to be given again for the application to be admissible.28

The Minister will reject applications that do not have all required information.29 The proponent must also send a copy to the municipality in question30 and the documents will be published in the Minister’s new register (we’ll come back to this).

Criteria and Decision

The NEQA provides a non-exhaustive, non-weighted list of authorization criteria31 that includes:

  • Nature of the project and methods used
  • Characteristics of the affected surroundings
  • Nature, quantity, concentration, and location of all contaminants that may be released into the environment
  • Strategic environmental assessment findings, where applicable
  • Project-related greenhouse gas emissions and any required reduction measures (if prescribed by regulation, see the Climate Test section below)
  • The risks and expected impact of climate change on the project and its surroundings, accommodation measures where applicable, and Quebec’s greenhouse gas reduction commitments

In issuing an authorization, the Minister may set further environmental protection conditions, restrictions, or prohibitions if it is felt existing ones are inadequate for the host environment or cannot protect human health or the health of other species.32 While these conditions or restrictions may relate to things listed in Section 25 of the NEQA, they typically concern measures to reduce the activity’s environmental impact.

Lastly, the RMADCEM has procedures to amend33 and renew34 an authorization. An authorization may need to be amended if a change occurs that could increase the activity’s environmental impact.35 The procedure consists mainly of explaining the nature of the change and its environmental impact. However, proponents must also provide accurate and updated information and data.36 Proponents applying for ministerial authorization often lack precise data on, for example, GHG emission levels, whether they are based on assumptions and estimates, etc. When updating an application, the proponent may no longer provide only these estimates. In the event of a large disparity between real data and estimates submitted for ministerial authorization, is there accountability? At the very least, we suspect no authorization is granted.37 The Minister could also impose new conditions and restrictions.38

Covered Activities

As noted earlier, Section 22 of the NEQA has a preliminary list of moderate-risk activities that need ministerial authorization. These include:

1° Operation of an industrial plant

2° Any removal of water, including work and projects where this is required

3° The building, modification, or expansion of a water management or treatment facility, and the setup and operation of any other water treatment equipment or device to prevent, reduce, or stop the release of contaminants into the environment or a sewer system

4° Any project, construction, or other activity in wetland or water environments

5° Management of hazardous materials

6° Setup and operation of equipment or devices to prevent, reduce, or stop the release of contaminants into the atmosphere

7° Building and operation of a waste disposal facility

8° Building and operation of a waste diversion facility, including storage and treatment of waste materials for this purpose

9° Any construction on the site of a now-decommissioned waste disposal facility, or any project to change the use of such a site

10° Any other activity determined by government regulation

If a project has other activities that may release contaminants into or change the quality of the environment, the following must also be authorized:

1° Construction of an industrial plant

2° Operation of an industrial plant other than those covered in Paragraph 1°, Subsection 1

3° Use of an industrial process or procedure

4° Increased production of a product or service

Paragraph 10, Section 22 of the NEQA authorizes the Minister to add activities, and there are more than 31 additional activities in Schedule I of the RMADCEM. Things indirectly affecting the energy sector include: bulk water removal;39 quarries and sandpits;40 road infrastructure construction or modification;41 ditch, drainage, or sewer projects;42 contaminated soil (including disposal, storage, and treatment sites);43 and combustion equipment.44

Activities directly affecting the energy sector include the following:


Under the RMADCEM, all mining activities need ministerial authorization.45 The proponent must also provide the additional information listed in Section XI.46

Oil and Gas

1° Stratigraphic sounding

2° Well drilling and re-entry

3° Well completion

4° Fracturing or fracking

5° Tests for hydrocarbon extraction and underground tank use

6° Well workover

7° Pipeline construction or use

8° Any other oil and gas-related activity47

This includes specific information from Section 40 of the RMADCEM, including technical programs for each project phase, initial site and soil characteristics, soil production and detection programs, and, most importantly, notice of public consultation.

Oil and Coal Processing

1° Oil refinery

2° Petrochemical manufacturing and processing plant

3° Industrial gas manufacturing and processing plant

4° Oil processing plant

5° Coal/charcoal production and processing plant48

Power Transmission, Transformation, and Storage

Any project involving:

1° The construction, relocation, and operation of a control or transformer station and a system to store electricity at a voltage of 120 kV or higher

2° The construction and relocation of power transmission and distribution lines with a voltage of 120 kV or more and of other high-voltage lines that are longer than 2 km.49

Power Generation

Any project to build, operate, or upgrade:

1° A wind farm or a wind turbine with a capacity of at least 100 kW

2° A solar power plant with a rated capacity of at least 10 kW

3° A fossil fuel power plant

4° A hydro-electric power plant

This does not include the replacement or modification of technical equipment for such plants if it does not lead to management changes.50

Climate Test

The RMADCEM requires ministerial authorization for any person planning to, among other things:

4° Develop a mine with a daily ore extraction capacity of at least 2,000 metric tonnes

5° Build an ore processing plant with a daily capacity of at least 2,000 metric tonnes

6° Use equipment, a process, or a facility for oil and gas exploration

10° Use equipment or a process to make hydrogen from natural gas or other fossil fuels

11° Use equipment to process natural gas

14° Make and process biogas when the equipment’s daily capacity is at least 30,000 cubic metres of methane51

Section 64 of the RMADCEM requires the proponent of a project undergoing the Climate Test to provide certain information (e.g., GHG quantification report, GHG reduction measures, and “evidence that greenhouse gas reduction has been considered and optimized in the choice of variant.”).52

Of course, “a project’s greenhouse gas emissions and measures to reduce them are considered when reviewing an application [for ministerial authorization].”53

Comments and Feedback

First, the term “quantification report” suggests the Minister requires exact data rather than just a model. Second, consideration of these factors does not necessarily mean a project will be cancelled based solely on GHG emissions. Third, while there must be a report for each phase, i.e. “all stages of a project, including planning, construction, operation, closure, and post-closure,”54 this does not consider GHG emissions from third-party activities (e.g., gas use made possible by construction of a pipeline). Fourth, those who emit 25,000 metric tonnes of GHG per year already have similar requirements under the Regulation respecting mandatory reporting of certain emissions of contaminants into the atmosphere.55 Lastly, we wonder if it makes sense to subject renewable (clean) energy producers to the Climate Test. Why aren’t they exempt?

1.4 High Risk

The environmental impact assessment and review process is for projects with “complex or large-scale activities that raise serious environmental or social concerns and require mitigation measures”56 and whose acceptability depends in part on a public process. No proponent may conduct activities set out in the REIAR without following the environmental impact assessment and review process and obtaining government approval.57 The new procedure improves environmental protection by covering more activities and ensures a more transparent process through access to information, greater public participation, etc.

Unlike with lower-risk activities, the authorization process is determined largely by the NEQA rather than a regulation. While REIAR provides some assessment process details, its greatest contribution is the list of covered activities.

Activities relating directly to energy include:

2. Dams and breakwaters

7. Natural gas or biomethane re-gasification or liquefaction facilities

– The coverage threshold for a natural gas liquefaction facility is a daily capacity of 100 cubic metres58

8. Oil and gas pipelines

– Pipelines that are at least 2 km long are covered unless they are in an existing right-of-way that serves the same purpose, are less than 300 mm in diameter, and have a pressure below 4000 kPa59

9. Power transmission lines and transformer stations

– Does not include transmission lines located in or next to a road or railway right-of-way60

10. Power generation

– Does not apply to solar panels installed on the roof of existing infrastructure61

12. Oil and gas exploration and development62

13. Oil, gas, and coal processing63

37. Certain greenhouse gas emissions64

– Facility emitting 100,000 metric tonnes or more per year of greenhouse gas (CO2 equivalent)65

The government may occasionally subject non-listed activities to the EIARP when:

1° It feels that the project may raise significant environmental issues and public concerns warrant it

2° The project will involve a new technology or type of activity with a major projected environmental impact

3° It feels the project will pose serious climate change issues66

See table 4.

Comments and Feedback

An interesting aspect of the authorization process is that when decisions concern oil and gas, the government must consider the Régie de l’énergie.86 However, the article does not note the degree to which its decision must be in line with that of the Régie.

The government may also, in the “public interest,” exclude a project from the impact study87 without defining what the public interest is.

The Minister may exclude information or data on industrial processes, national security, or the location of threatened or vulnerable species from public consultations.88 The term “industrial processes” is not defined and we have no criteria for excluding such information.

Lastly, as the environment is an area of shared responsibility,89 other authorities may have jurisdiction over projects covered by the EQA. The Minister may consult with these authorities to coordinate environmental assessment procedures.90

2. Right of Access to Industrial and Environmental Information

The Minister keeps a register of declarations of compliance, ministerial authorizations,91 and projects requiring an EIARP,92 which includes each application (issuance, modification, renewal, etc.) and all supporting documents.93 The Minister’s diligence94 will help to make all these records accessible to the public.95 Information on administrative penalties96 and convictions97 is also recorded and available to the public,98 as was the case under the old system. The aim of creating and publishing the register is to give the public all information needed to determine a project’s issues and form an opinion, especially during public consultations and impact studies.99

However, information is not published if it is likely to, among other things,100 impede an investigation101 or undermine national security,102 or if it concerns a weapon or method that may be used to commit a crime or offence.103 When applying for ministerial authorization, project proponents can identify information they consider an industrial or commercial secret but must explain why.104 The Minister will have complete discretion to approve or reject the application. The onus is on the proponent to identify and, most importantly, defend and justify each exemption, though the new EQA and regulations provide no definitions or criteria. An Act respecting access to documents held by public bodies and the protection of personal information105 provides such criteria106 but the government has not wished to refer to them.


The new regulations have not made the regulatory framework more “clear and effective” as the government had promised. While the old system had just two mechanisms and made an assessment for each project, environmental compliance is now determined for each activity within a project. This makes regulations and procedures more cumbersome for the proponent, who must now:

  1. Break the project down into its separate activities, from planning to post-closure
  2. List all activities that may release any “contaminant whose presence in the environment is prohibited by regulation or likely to harm human life, health, safety, well-being or comfort, cause damage, or otherwise hurt the environment, ecosystems, living species, or property”107
  3. Classify these activities by risk level108
  4. Follow the applicable authorization process

This “activity-based” approach requires more regulations. These clearance and authorization mechanisms address many key energy industry activities, including the protection of water sources and wetlands, which are well covered by the new framework (through legislative changes,109 the RMADCEM,110 and the REIAR111). Proponents must also consider the new regulatory framework for “industrial facilities.”112 Lastly, any transformation of the environmental impact assessment process will involve legislative113 and regulatory114 changes to BAPE’s jurisdiction and hearing rules, which must of course be closely reviewed by the project proponent.

*Ludovic Fraser is a Quebec lawyer specializing in regulatory law for the energy sector, with a focus on electricity trading. He holds an MBA and a master’s degree in energy law.

  1. Environment Quality Act, LRQ, c Q-2 (EQA).
  2. Quebec, Ministère du Développement durable, de l’Environnement et de la Lutte contre les changements climatiques, “Green Paper – Modernizing the Environmental Authorization Scheme Under the Environmental Quality Act”, (Gatineau: June 2015), online: <http://www.mddelcc.gouv.qc.ca/autorisations/modernisation/livreVert.pdf>.
  3. Ibid at 13.
  4. Bill 102, An Act to amend the Environment Quality Act to modernize the environmental authorization scheme and to amend other legislative provisions, in particular to reform the governance of the Green Fund, 1st Sess, 41st Leg, 2017.
  5. Regulation respecting ministerial authorizations and declarations of compliance in environmental matters, (2018) GOQ II, 480 [RMADCEM].
  6. Regulation respecting environmental impact assessment and review for certain projects, CQLR, c Q-2, r 23 [REIAR].
  7. An Act to implement the 2030 Energy Policy and to amend various legislative provisions, LQ 2016, c 35, s 207.
  8. Environment Quality Act, CQLR, c Q-2, s 20 (NEQA).
  9. Environmental Impact Assessment and Review Process.
  10. NEQA, supra note 8, s 31.0.11.
  11. RMADCEM, supra note 5, s 5, Schedule III.
  12. Ibid, s 8, Schedule III.
  13. Ibid, s 11, Schedule III.
  14. Ibid, s 37, Schedule III.
  15. Ibid, s 38, Schedule III.
  16. Ibid, s 86.
  17. Ibid, s 90.
  18. Supra note 2 at 37.
  19. NEQA, supra note 8, s 31.0.6.
  20. Covered by the Regulation respecting threatened or vulnerable wildlife species and their habitats, CQLR, c E-12.01, r 2.
  21. Ibid, r 3.
  22. Covered by the List of plant and animal species likely to be designated threatened or vulnerable, CQLR, c E-12.01, r 5.
  23. RMADCEM, supra note 5, s 82.
  24. NEQA, supra note 8, s 31.0.7.
  25. RMADCEM, supra note 5, Schedule II, s VII.
  26. NEQA, supra note 8, subs 23(1).
  27. RMADCEM, supra note 5, Part I, c II.
  28. RMADCEM, supra note 5, subs 7(2).
  29. NEQA, supra note 8, subs 23(4).
  30. Ibid, subs 23(5).
  31. Ibid, s 24.
  32. NEQA, supra note 8, s 26.
  33. RMADCEM, supra note 5, ss 68, 69.
  34. Ibid, c IV.
  35. NEQA, supra note 8, s 30.
  36. RMADCEM, supra note 5, subs 68(1), para 6-7.
  37. NEQA, supra note 8, s 31.0.3.
  38. Ibid, subs 30(2).
  39. RMADCEM, supra note 5, Schedule I, s I.
  40. Ibid, s III.
  41. Ibid, s XVIII.
  42. Ibid, s XXI.
  43. Ibid, s XXVII.
  44. Ibid, s XXXI.
  45. Ibid, s II.
  46. Ibid, s XI.
  47. Ibid, s 6.
  48. Ibid, s 10.
  49. Ibid, s 21.
  50. Ibid, s 22.
  51. Ibid, Schedule IV.
  52. Ibid, s 64, 7, para 14.
  53. Ibid, subs 63(3). Also see subs 24(5).
  54. Ibid, s 3.
  55. Regulation respecting mandatory reporting of certain emissions of contaminants into the atmosphere, RLRQ Q-2, r. 15.
  56. Supra note 2 at 29.
  57. NEQA, supra note 8, s 31.1.
  58. REIAR, supra note 6, Schedule 1, s 7(1).
  59. Ibid, s 8.
  60. Ibid, s 9.
  61. Ibid, s 10.
  62. Ibid, s 12.
  63. Ibid, s 13.
  64. Ibid, s 2.
  65. Ibid, s 37.
  66. NEQA, supra note 8, s 31.1.1.
  67. Ibid, s 31.2.
  68. REIAR, supra note 6, s 3.
  69. Ibid, s 4. The time frame may be 45 days in some cases.
  70. NEQA, supra note 8, s 31.3.
  71. Ibid, s 31.3.1.
  72. REIAR, supra note 6, s 8.
  73. NEQA, supra note 8, subs 31.3.1(2); REIAR, supra note 6, s 8.
  74. Ibid, s 31.3.3.
  75. Ibid, subs 31.3.4(3).
  76. If it seems clear that there will be a public hearing, the consultation phase will be bypassed. Ibid, subs 31.3.5(6).
  77. Ibid, s 31.3.5; REIAR, supra note 6, s 10-14.
  78. Ibid, s 31.3.4.
  79. NEQA, supra note 8, subs 31.3.5(5); REIAR, supra note 6, s 15.
  80. REIAR, supra note 6, subs 17(1), para 1.
  81. Ibid, subs 17(1), para 2.
  82. Ibid, subs 17(1), para 3.
  83. NEQA, supra note 8, s 31.3.6.
  84. Ibid, s 31.0.3, 31.3.7.
  85. Ibid, s 31.5.
  86. Ibid, s 31.5.
  87. Ibid, s 31.7.4.
  88. Ibid, s 31.8.
  89. Gérald A Beaudoin, La constitution du Canada : Institutions, Partage des pouvoirs, Charte canadienne des droits et libertés, 3rd ed (Montreal : Wilson & Lafleur, 2004) at 359.
  90. NEQA, supra note 8, s 31.8.1.
  91. See NEQA, supra note 8, ss 23, 23.1; RMADCEM, supra note 5, s 6.
  92. REIAR, supra note 6, s VI.
  93. NEQA, supra note 8, ss 118.5-118.6.
  94. Ibid, s 118.5.3.
  95. Ibid, s 118.5-118.5.3; RMADCEM, supra note 5, s 8.
  96. Ibid, s 118.5.1.
  97. Ibid, s 118.5.2.
  98. Ibid, s 118.5.3.
  99. See ss 31.3.1 and 31.3.2 of the NEQA, supra note 8, on impact assessments.
  100. NEQA, supra note 8, s 118.5.3.
  101. An Act respecting access to documents held by public bodies and the protection of personal information, CQLR, c A-2.1, s 27.
  102. Ibid, s 28.1.
  103. Ibid, s 29.
  104. NEQA, supra note 8, s 23.1; RMADCEM, supra note 5, s 6. Section 31.9 of the NEQA is similar for public consultations.
  105. Supra note 101.
  106. Ibid, ss 23-24.
  107. NEQA, supra note 8, s 20.
  108. RMADCEM, supra note 5, s 7, para 5.
  109. Via the NEQA (s 46 in particular) and other laws.
  110. Water bulk removal, management, or treatment, RMADCEM, supra note 5, ss III, IV; NEQA, supra note 8, s 22.
  111. Including wetland/water environment projects and river or lake diversions, REIAR, supra note 6, Part II, ss 1-2.
  112. NEQA, supra note 8, subs 22(1), (2), par. 2 & s III; RMADCEM, supra note 5, s II.
  113. See NEQA, supra note 8, c II.1.
  114. Quebec, Rules of procedure for public hearings of the Bureau d’audiences publiques sur l’environnement.

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