Letter from the Canadian Environmental Assessment Agency to the Quebec Port Authority re: Environmental Impact Statement

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Document Reference Number: 49

Canadian Environmental Assessment Agency
901-1550 d'Estimauville Avenue
Quebec, QC G1J 0C1

Agence canadienne d'évaluation environnementale
901-1550, ave d'Estimauville
Québec (Québec) G1J 0C1

Via email only

Quebec City, April 12, 2016

Mr. Mario Girard
Chief Executive Officer
Quebec Port Authority
150 Dalhousie Street
PO Box 80, Postal Station Haute-Ville
Quebec City, Quebec G1R 4M8

PURPOSE: Port of Quebec Deep-Water Multipurpose Wharf Project – Beauport 2020 (File number 80107)

Dear Sir:

On March 11, 2016, the Canadian Environmental Assessment Agency (the Agency) received the main report for the Environmental Impact Statement (EIS) and the associated documents for the Port of Quebec deep-water multipurpose wharf project – Beauport 2020 (the Project) prepared by the Québec Port Authority.

After comparing the impact statement with the guidelines for the Project's impact statement, the Agency, in collaboration with the environmental assessment technical committee, determined that the EIS was incomplete and did not fully satisfy the requirements in the guidelines. This information is essential in beginning the analysis of the Project. The environmental impact statement must be resubmitted and include the information and clarifications contained in the following pages, along with all the missing documents that should have been provided with the impact statement.

Below is a list of the sections of the Agency's guidelines in connection with which further information is required in order for the EIS analysis to begin. It is recommended that you consult the description of the sections in the guidelines for details regarding the information requested.

General Comments

As indicated in 4.3.3 of the first part of the guidelines, when relying on existing information to meet requirements of the environmental impact statement guidelines, the proponent will either include the information directly in the environmental impact statement or clearly direct the reader to where it may obtain the information (i.e., through cross-referencing). When relying on existing information, the proponent must comment on how the data were applied to the project, separate factual lines of evidence from inference, and state any limitations on the inferences or conclusions that can be drawn from the existing information.

A reader should be able to read and understand the impact statement without the documents included in its appendix. The enclosed supporting documents should support the analysis and the conclusions of the impact statement.

The evaluation of the project's environmental effects must be adjusted based on new elements provided by the proponent to complete section 6.1 Project setting and baseline conditions of the guidelines. Justification must be given if no information is provided for one of the elements requested in this letter.

The examples given in this request for information are not exhaustive. They are provided for information purposes only. All relevant information that would complete the elements listed in this request must be provided.

Missing Documents

The following documents that are referred to in the impact statement must be submitted before the analysis of the impact statement can begin:

  • CJB ENVIRONNEMENT INC., 2006a. Suivi des migrations de l'avifaune 2006 – Secteur Beauport [Monitoring of the 2006 avifauna migrations – Beauport sector]. December 2006. Report presented to the Port of Quebec, 13 pages + appendix.
  • GROUPE-CONSEIL LASALLE, 2013. Nouvelles infrastructures portuaires – Secteur de Beauport — Avis sur les efforts exercés par les glaces [New port infrastructures – Beauport sector - notice regarding ice efforts]. 16 pages
  • JP LACOURSIÈRE INC., 2015a. Étude de risques technologiques pour le projet d'agrandissement du port de Québec — situation actuelle (avant projet d'agrandissement) [Assessment of the technological risks regarding Port of Quebec expansion project - current situation (expansion design)]. Preliminary report 58 p. + appendices.
  • JP LACOURSIÈRE INC., 2015b. Sommaire analyse de risque technologique — Secteur Beauport [Summary analysis of the technological risks – Beauport sector]. 6 p.
  • RWDI, 2016b. Projet d'agrandissement du Port de Québec, Secteur Beauport, Étude de la qualité de l'air, Produits de la combustion [Port of Quebec expansion project, Beauport sector, study of air quality and combustion emissions]. 42 p. + appendices.
  • RWDI, 2016. Étude de la qualité de l'air – Émissions de poussières [Study on air quality – dust emissions]. Study mentioned in Table 1.1 (page 10).
  • Appendices A to F of the RWDI study, 2016a. Projet d'agrandissement du Port de Québec, Secteur Beauport, Composés organiques volatils (COV) [Port of Quebec expansion project, Beauport sector, volatile organic compounds (VOCs)]. RWDI #1401535. 24 p. + appendices.
  • Board of Nionwentsïo, Huron Wendat Nation. Supplemental study from the Huron Wendat Nation.

Missing elements under the first part of the guidelines – Background

Section 3.3 Scope of the Factors

Section 3.3.3 Spatial and Temporal Boundaries
  • Spatial boundaries will be defined taking into account the appropriate scale and spatial extent of potential environmental effects, community and Aboriginal traditional knowledge, current land and resource use by Aboriginal groups, ecological, technical and social and cultural considerations.
    • The analysis of the effects must extend to the impact statement zone and the environmental components with which the project might interact. The spatial boundaries must be redefined and justified for each environmental change and each valued component selected.
    • The impact statement zone must be reviewed to include the new spatial boundaries. For example, the impact statement zone should have encompassed more territory in order to take into consideration the environmental changes and potential effects on the valued components such as: water quality in the St. Lawrence and the Saint-Charles River, the shoreline areas of the Bay of Beauport, the effects on wildlife, plants and their habitats.

4.5 Summary of the Environmental Impact Statement

  • The impact statement summary must include an English version.
  • The impact statement summary in French and English must be reviewed following changes made to the impact statement in response to this request for information.

Elements missing under the various sections of the second part of the guidelines – content of the environmental impact statement

Section 1.3 Project Location

  • Several designated environmentally sensitive areas were not identified in the impact statement and were not taken into account in the environmental assessment. The impact statement must identify the designated environmentally sensitive areas and take them into account in evaluating the effects, identifying the mitigating measures, determining the residual effects, determining the cumulative effects and defining the monitoring program, if applicable.
  • A description of the local communities that might be impacted by the project must be provided (e.g. demographic data, location in relation to the project).

Section 2.2 Alternative means of carrying out the project

  • For each alternative, the technical and economic criteria selected must be explained as well as the environmental and social effects, in order to justify the proponent's conclusion in terms of the site selection. For example, the effects on the Bay of Beauport, an important zone for migratory birds, must be evaluated for the different breakwater alternatives that have been studied.
  • In the analysis of the alternatives, all the project components mentioned in the guidelines must be considered such as the storage equipment, the extension of the emergency outlet of the Urban Community of Quebec City, the ship-loading facilities, the extension of the existing railway track, the transhipment, storage and handling areas, the types of cargo stored and the environmental effects of all dredging activities associated with the construction (aquatic environment, noise, atmospheric emissions, anticipated quality of the sediment and dried sediment, sediment storage time on land, effects of dredging on fish and the aquatic environment, etc.).
  • The analysis of each alternative must show that encroachment has been reduced to a minimum, that the sedimentation rate has been minimized and that preference has been given to beneficial sediment use.
  • The four locations analysed must be described by providing information on the biological and physical environments.

Section 3: Project Description

  • The surface area for each planned infrastructure in the zone targeted by the project must be provided as well as the location of the temporary wharf.
  • The use of contaminated sediment in the cement matrix comes with many unknowns and raises concerns regarding infrastructure management and the potential release of contaminants in the medium to long term. If the option of using contaminated sediment in the cement matrix is not possible, the impact statement must:
    • Explain how the unused sediment will be managed onsite (where and how);
    • Present the preferred option for replacing the cement matrix and explain how this option will be constructed.
  • Information on the management of runoff, rainwater and wastewater that might be generated by the project during the construction phase must be included in the impact statement, specifying where it will go and how it will be treated. It must also include a description of the infrastructures that will be put in place and the process used to ensure the physio-chemical quality of the water before it is released into the environment.
  • A map with bathymetric data that shows the location of the project's alternatives along with the boundaries of the proposed site and UTM coordinates must be provided.
  • Ship resupply activities must be described in the impact statement.
  • Information on the management of ballast and bilge water and the management plan for invasive species must be provided.
  • Information on maintenance dredging operations must be provided by providing the following elements: surface area, volume, dredged sediment management and methods.

Section 5 Aboriginal Engagement and Concerns

  • The impact statement must present sufficiently-detailed and justified information to allow the Crown to understand the project's potential negative effects on the established or potential Aboriginal or Treaty rights of each Aboriginal group considered, to understand the effectiveness of the proposed measures for preventing or mitigating these effects and to document the decisions made under the Canadian Environmental Protection Act (2012) (CEPA 2012). For example, detailed information or a justification if there is a lack of information is necessary in order to:
    • Identify the established or potential Aboriginal or Treaty rights. For each Aboriginal group identified in the impact statement guidelines (second part, section 5), the impact statement must describe the established or potential Aboriginal or Treaty rights, present the points of view of these groups regarding the project's potential negative effects on these rights and explain how the exercising of these rights could be modified if the project goes forward;
    • Identify the measures for mitigating the project's negative effects on established or potential Aboriginal or Treaty rights and how they will be implemented;
    • Identify the effects of the environmental changes on Aboriginals or on established or potential Aboriginal or Treaty rights that have not been completely mitigated;
    • Present the specific suggestions from the Aboriginal groups to mitigate the potential negative effects of the environmental changes on Aboriginal peoples or on their established or potential Aboriginal or Treaty rights;
    • Present the views expressed by the Aboriginal groups regarding the effectiveness of the mitigation or accommodation measures;
    • Identify the changes made to the project design and implementation directly as a result of discussions with Aboriginal groups;
    • Identify how Aboriginal traditional knowledge was incorporated into the environmental effects assessment (physical environment, biological environment and valued components) in the consideration of potential adverse impacts on potential or established Aboriginal or Treaty rights and related mitigation measures.
  • To complete the information required, the proponent must:
    • Consult the " Étude historique et enquête sur l'utilisation huronne-wendat contemporaine [Historic Study and Survey of Contemporary Huron-Wendat Usage]" which was supposed to be sent to the proponent in March 2016. This study must also be included in the appendix of the impact statement;
    • Consult with each Aboriginal group. The Agency has observed that several of these groups are in the process of analyzing the documents provided by the proponent and are therefore likely to provide the additional required information;
    • Any other available information.

Section 6.1 Project Setting and Baseline Conditions

Based on the scope of project described in section 3 (Part 1), the environmental impact statement will present baseline information in sufficient detail to enable the identification of how the project could affect the valued components and an analysis of those effects. The impact statement, as submitted, does not satisfy this requirement. Without detailed information, the Agency cannot undertake an analysis of the project's environmental effects. The following detailed information or justification in the event there is no information is required.

Section 6.1.1 Air Quality, Noise Environment and Climate

The impact statement must present:

  • The boundaries of the airshed likely to be affected by the project and all ambient air data regarding this area;
  • Data from the stations operated by the Quebec Department of Sustainable Development, Environment and the Fight Against Climate Change and the proponent;
  • The direct and indirect sources of air emissions present based on the zones that will be delineated as requested on page two of this letter;
  • The following weather and climatic information: fog data for the entire year as well as humidity and wind data for the months of January to July for all the years considered in the impact statement.
Section 6.1.2 Geomorphology and Fluvial Characteristics

The impact statement must present:

  • The relief of new expanded impact statement zone;
  • A description of the watercourses of the hydrographic network of the expanded impact statement zone (e.g. Beauport River, Moulin Stream, Saint-Charles River and the St. Lawrence River) along with the longitudinal profile, the water levels (during peak flows, low flows and mean conditions) and the hydrological regime (including the watercourses' mean annual flows, mean daily and monthly flows) of the trunks of these watercourses that might be affected;
  • A description of the detailed bathymetry (wharves, beach, entry channel and anchorage areas), making the connection with the bathymetric data provided in the impact statement. The surface and bottom currents must be differentiated.
Section 6.1.3 Soils, Riparian and Terrestrial Environments; Section 6.1.4 Fish and Fish Habitat; Section 6.1.5 Birds and their Habitat

The impact statement must present:

  • Data, justifications and references to one or more studies for assessing previous landslides in the project zone;
  • The identification, description and mapping of all environments present in the new impact statement zone, including those that are highly anthropized;
  • The information pertaining to the ecological functions of the wetlands presented in the document in Appendix A of the impact statement;
  • As for the plant and wildlife species:
    • All species that could be present or that have been observed (e.g. plant species with a special status, wildlife) and their habitat (potential or confirmed) must be identified and described;
    • The abundance, distribution and diversity of these species must be indicated;
    • Species of a social, economic, cultural or scientific significance as well as invasive alien species must also be identified and described.
  • A complete description of the wildlife. It must be based not only on the observations made during surveys but also on a literature review, databank analyses, species lifecycles and the potential habitats present. The results of a map turtle and snapping turtle survey are provided in the impact statement. Information on the mammals, amphibians, reptiles and other wildlife components that might potentially be present (other than fish and birds) must be provided;
  • A characterization of the fish populations, placing particular emphasis on the species of interest for that sector (e.g. habitat needs, biology, lifecycle, rarity of nearby habitat, known movements in the estuary, scope of the home range);
  • An overview of the abundance, distribution, and life stages of migratory and non-migratory birds in the area (including waterfowl, raptors, shorebirds, marsh birds and other land birds), and species composition for each season.
6.1.6 Other Species at Risk

The impact statement must:

  • Update and justify the list of all potential or known federally and provincially listed species at risk and species classified by the Committee on the Status of Endangered Wildlife in Canada that may be affected by the project (fauna and flora).
    • Provide a complete list of all species designated by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) that are listed in Schedule 1 of the Species at Risk Act. This list will include those species in the risk categories of extirpated, endangered, threatened and special concern.
    • Provide an analysis of the potential presence of these species taking into account the new species that were placed on the schedules of the Species at Risk Act and those being studied by COSEWIC.
    • This update and justification must be based on existing data and literature as well as surveys to provide current field data. Given that the analysis provided in the impact statement is more than 10 years old (CJB Environment, March 2005), surveys might be required following the update to the analysis for the potential presence of species at risk.
  • Provide any published studies that describe the regional importance, abundance and distribution of species at risk.
  • Describe residences, seasonal movements, movement corridors, habitat requirements, key habitat areas, identified critical habitat and/or recovery habitat (where applicable) and general life history of species at risk that may occur in the project area, or be affected by the project.
Section 6.1.7 Aboriginal Peoples
  • It is mentioned that the Aboriginal peoples do not harvest in the impact statement zone. However, fishing activities conducted elsewhere and that depend on fish resources present in the port sector are not described (e.g. use of migratory fish such as Atlantic sturgeon). The impact study must describe:
    • Fish, wildlife, birds, plants or other natural resources of importance for traditional use (for Aboriginal peoples identified in section 5.1);
    • Geographic areas where fish, wildlife, birds, plants or other natural resources are harvested;
    • Frequency, duration or timing of traditional practices.
Section 6.1.8 Human Environment

In order to complete the characterization of the cultural, asset and archaeological heritage, the impact statement must include a study of the subaquatic archaeological potential.

Section 6.2 Predicted Changes to the Bio-Physical Environment

Section 6.2.1 Changes to the Atmospheric Environment

The impact statement must:

  • Provide an estimate of the concentrations of expected contaminants for the main contaminants, including: total suspended particulates, particulates smaller than 2.5 microns (PM2.5), particulates smaller than 10 microns (PM10), carbon monoxide (CO), sulphur oxides (SOx), nitrogen oxides (NOx), nickel and all other atmospheric contaminants from mobile or fixed sources including metals and metalloids. All potential sources of air contamination associated with the project must be taken into account (e.g. trucks, trains, ships, handling areas, etc.).
  • Present a model for the atmospheric dispersion of the main expected contaminants including the contaminants listed in the point above, volatile organic compounds and greenhouse gases.
  • Provide a comparison of the expected air quality with Canadian ambient air quality standards for fine particulates and ozone and the Quebec standards and criteria for atmospheric quality stemming from the Regulation respecting the quality of the atmosphere.
  • Include an analysis of the project's effects on air quality in terms of volatile organic compounds. The document in Appendix A was provided to that end (RWDI 2016a) and it is quoted in the impact statement, but the results must be included in the impact statement.
Section 6.2.2 Changes to Geomorphology and Fluvial Characteristics

The impact statement must:

  • Provide a description of the changes in the physicochemical quality of the water based on expected contaminant concentrations, turbidity and oxygen content for all phases of the project. If no changes are expected for some of these criteria, a justification must be given.
  • Compare the projected water quality with the Canadian Environmental Quality Guidelines, the Canadian Drinking Water Guidelines, the Guidelines for Canadian Recreational Water Quality and the Quebec criteria for surface water quality.
  • Describe and analyze the project's effects on the water's thermal regime.
  • Describe and analyze the effects of resuspension of contaminated sediment on the aquatic environment for all project phases, taking into consideration that the three contaminated sediment zones were identified in section 7.1.11.1 of the impact statement.
Section 6.2.3 Changes to Soils and Riparian and Terrestrial Habitats

The impact statement must:

  • Evaluate the project's effects on the ecological functions (losses and changes) of the wetlands that might be affected by the project, taking into account the objectives of the Federal Policy on Wetland Conservation.
  • Provide a description of the project's effects on the critical habitat or frequentation by special-status species that appear on the federal and provincial lists. This description must be included even when special-status species have not been surveyed at the site (e.g. Victorin's water hemlock, Victorin's gentian, map turtle, snapping turtle) since the territory affected by the project represents potential habitat or residence of these species.
  • Describe and analyze the project's effects on changes to key habitat for species important to Aboriginal current use. Given that certain species important to Aboriginals are migratory (e.g. striped bass, Atlantic sturgeon, lake sturgeon) the project's effect on the habitat of these species must be placed in context with the regular use of resources by the various Aboriginal groups even when these groups do not have any traditional, commercial or recreational activities in the expanded impact statement zone for the project or the sector of the watercourse that is under the proponent's management.

6.3 Predicted Effects on Valued Components

6.3.1 Fish and Fish Habitat

The impact statement must contain the following information:

  • Any potential unbalances in the food web in relation to baseline conditions;
  • The anticipated changes in the composition and characteristics of the populations of the various fish species, including shellfish and forage fish and special-status species included on the federal and provincial lists;
  • An examination of how project construction timing correlates to key fisheries windows for freshwater and anadromous species, and any potential impacts resulting from overlapping periods. Periods suitable to the construction are mentioned in the impact statement in relation with certain periods that are sensitive to the fish, but the documentation regarding the proposed periods must be completed.
  • Document any modifications in migration or local movements (upstream and downstream migration, and lateral movements) following the construction and operation of works (physical and hydraulic barrier). For example, the presence of works could create obstacles for movement or influence current speed or water depths.
Section 6.3.2 Birds and their Habitat

The impact statement must:

  • Present the various habitat uses by birds (nesting, feeding, migratory stop, wintering, etc.) in the description of the direct effects (e.g. mortality, loss of habitat) and the indirect effects (e.g. noise and light disturbances) of the project on migratory bird habitat during the construction and operating phases.
  • Describe and analyze how the presence of new works (wharf and breakwater) will affect migratory bird habitat, namely the bay and the Beauport flats, identified as an important bird conservation area.
  • Present an analysis of the effects on each of the special-status species included on the federal and provincial lists and among the species classified by COSEWIC, as well as the critical habitat or frequentation of these species, taking into account the characterization requested in section 6.1.6 of the guidelines.
Section 6.3.3 Aboriginal People

The impact statement must:

  • Detail the information regarding the description and analysis of how changes to the environment caused by the project will affect the current uses of lands and resources for traditional purposes. To support its evaluation, the proponent is invited to consult the guide " Technical Guidance for Assessing the Current Use of Lands for Traditional Purposes"[1] available on the Agency's website. For example:
    • Explain how the effects on fish habitat can have an impact on use of the resource by Aboriginal peoples outside the impact statement zone.
    • Lake sturgeon and Atlantic sturgeon individuals that might be affected by the project are part of migratory species that can be fished outside the impact statement zone by Aboriginal groups such as the Kahnawake Mohawk, the Abenaki and Maliseet. These fish populations are known to cover a lot of area within their home range.
Section 6.3.4 Other Valued Components (other than those in sections 6.3.2. and 6.3.3)

The Quebec Port Authority project involves the use of federal lands. Under subsection 5(2) of CEAA 2012, the proponent must also:

  • Describe and analyze the potential effects of the project on terrestrial flora and fauna for each habitat unit and not only the surveyed species.
  • Describe and analyze the potential effects of the project on special-status species included on the federal and provincial lists, as well as the critical habitat or residence of those species.

Section 6.4 Mitigation

The impact statement must:

  • Be reviewed to make sure that each of the mitigation measures is described in a manner that avoids ambiguity. When a compensation plan is suggested as a mitigation measure, the compensation plan must be described in sufficient detail to allow for an analysis of its potential for reducing the negative effect. Here are some examples of measures that need to be reviewed:
    • In section 10.5.3 of the impact statement – Construction Phase: "Although the dredging work should not have an impact on water quality in terms of the drinking water intakes, the municipalities will be notified of the period when the dredging work will take place in order to ensure effective communication and monitoring. In the event of an observed incident (high turbidity as a result of the work), they will be informed as quickly as possible and the APQ will ensure the implementation of the measures required to guarantee the rapid mitigation of the situation." For this measure, it is not possible to determine the threshold that would trigger the implementation of a mitigation measure and the mitigation measure itself is not described.
    • In section 8.1.3 – Mitigation Measures (wetlands): "Due to the loss in wetlands estimated at 0.03 ha, the APQ is looking at a compensation package in this regard." Based on this information, it is not possible to complete an analysis that would make it possible to evaluate if the compensation plan suggested would reduce the negative effects on the wetlands.
  • Describe the project's environmental protection plan and its environmental management system, through which the proponent will deliver this plan. The concordance table in the impact statement refers to section 7.1.12; however, this section does not satisfy the requirement.
  • Identify who is responsible for the implementation of these mitigation measures and the system of accountability.

6.5 Significance of the Residual Effects

  • The residual effects, even if very small or deemed insignificant (described as an "insignificant significance of residual effects" in the impact statement) must be described.
  • The environmental impact statement will then provide an analysis of the significance of the residual environmental effects that are considered adverse, using guidance described in section 4 of the Agency's reference guide" Determining Whether a Project is Likely to Cause Significant Adverse Environmental Effects."[2] It will contain clear and sufficient information to enable the Agency [or review panel], technical and regulatory agencies, Aboriginal groups and the public to review the proponent's analysis of the significance of effects.
  • Where possible, use relevant existing regulatory documents, environmental standards, guidelines or objectives in order to analyze the evaluation of the residual effects based on the various elements (e.g. magnitude, geographic extent, duration, frequency, etc.). Although certain policies and laws associated with the effects on the various valued components are mentioned in the impact statement, environmental standards and/or objectives, such as the maximum emission or release levels for certain hazardous agents into the environment were not indicated.
  • Indicate the probability (likelihood) that significant residual negative effects (listed in the impact statement as the "importance of the significant residual negative effects) will occur, and describe the degree of scientific uncertainty related to the data and methods used within the framework of its environmental analysis.

Section 6.6 Other Effects to Take into Account

Section 6.6.1 Effects of the Environment on the Project

The impact statement must:

  • Complete all situations where the environment could cause effects on the project, including severe weather conditions and the following external events: drought, subsidence.
  • Provide data and references and analyze the potential for landslides and subsidence.
Section 6.6.2 Effects of Potential Accidents and Malfunctions

The impact statement must:

  • The proponent will identify the probability of potential accidents and malfunctions related to the project, including an explanation of how those events were identified, potential consequences (including the environmental effects as defined in section 5 of CEAA 2012), the plausible worst case scenarios and the effects of these scenarios. For example, detailed information is required to determine:
    • The risk of collision between oil-tankers and/or ships transporting other hazardous materials, the risk of collision between cruise ships and/or ships transporting hazardous materials.
Section 6.6.3.Cumulative Effects Assessment

The impact statement must:

  • Explain and clearly justify the methodology used to assess the cumulative environmental effects and their significance. The Agency recommends to the proponent to consult and use the methodology described in the Operational Policy Statement entitled ‘' Addressing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, 2012"[3] and the one in the guide entitled ‘' Technical Guidance for Assessing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, 2012"[4].
  • Redefine the spatial and temporal boundaries. For example:
    • The lower temporal boundary found in the impact statements starts in 2017 whereas the evaluation of the cumulative effects must also take into account projects and activities that were completed in the past (before 2017).
    • The spatial boundaries must take into account the navigation zone under the proponent's jurisdiction (e.g. the zone between Île d'Orléans and the Quebec Bridge).
  • For each valued component, provide an analysis of the cumulative effects regardless of the significance level of the residual environmental negative effect, which includes:
    • The justification of the choice of valued component, the environmental negative effects and the associated mitigation measures, including an evaluation of the cumulative environmental effects for each species at risk;
    • Adjust the evaluation of the cumulative effects based on each valued component described in sections 3.3.2 (first part) and 6.6.3 (second part) in the guidelines;
    • The spatial and temporal boundaries;
    • The past, present and future sources of effects cumulated with those of the proposed project.
      • For example:
        • Provide more documentation regarding the various phases of backfilling and dredging since the 1960s in the sector included between the mouth of the Saint-Charles River and the Bay of Beauport, including the surface areas and volumes dredged and discuss their impacts.
        • Clarify if an evaluation of the cumulative effects is needed for the construction of the dolphin (wharf sector 50) since the impact statement refers to it several times in the plans and appendices.
        • Evaluate the potential cumulative effects that can result from the reconstruction of the Île d'Orléans Bridge. This evaluation must take into account namely the valued components such as "fish and their habitat" and "Aboriginal peoples" (e.g. the fishing for migratory fish).

Section 8.1 Monitoring and Section 8.2 Follow-up Program

The impact statement must:

  • Clearly identify and distinguish the monitoring items from those of the follow-up program in their respective sections.
  • Adjust the monitoring and follow-up programs in light of the changes made in the previous sections.

Please resubmit an impact statement and a summary in English and French, including the information described in this letter. The Agency has 15 to 30 days to review a new impact statement or a version of an impact statement that has been heavily amended in order to determine if the guideline requirements have been satisfied. After this period, the Agency will notify you if any additional information is required to make the impact statement compliant with the guidelines or if the impact statement contains sufficient information for the technical analysis by the environmental assessment committee and the public consultation period on the impact statement to begin. You may be sent questions and comments on any of the submitted information at a later date. Please send information by email at celine.lachapelle@ceaa-acee.gc.ca.

If you require clarification regarding this request for information, feel free to contact me by telephone at 418-648-7833 or by e-mail at the mentioned above address.

Yours sincerely,

<Original signed by>

Céline Lachapelle
Project Manager, Quebec Regional Office

cc:
Benoit Lacasse, Natural Resources Canada
Suzie Thibodeau, Environment and Climate Change Canada
Louis Breton, Environment and Climate Change Canada
Brigitte Cusson, Environment and Climate Change Canada
Martin Petit, Transport Canada
Étienne Frenette, Health Canada
Martin Blouin, Fisheries and Oceans Canada
Gontrand Pouliot, Fisheries and Oceans Canada
Sophie Bérubé, Fisheries and Oceans Canada
Patricia Hébert, Laurentian Pilotage Authority
Simon Tétreault, Infrastructure Canada
Julie-Anne Marcoux, Infrastructure Canada
Pierre Michon, Quebec Department of Sustainable Development, Environment and the Fight Against Climate Change
Michèle Tremblay, Quebec Department of Sustainable Development, Environment and the Fight Against Climate Change

[1] Refer to the Agency's guide at the following address: www.canada.ca/en/environmental-assessment-agency.html

[2] See Agency website: www.canada.ca/en/environmental-assessment-agency.html

[3] See Agency website: www.canada.ca/en/environmental-assessment-agency.html

[4] See Agency website: www.canada.ca/en/environmental-assessment-agency.html

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