The Gazoduq pipeline project Terms of Reference

The Hon. Jonathan Wilkinson
Minister of Environment and Climate Change
House of Commons
K1A 0A6

July 14, 2020

RE: Consultation on the draft Terms of Reference of the Integrated Review Panel for the Gazoduq Project

Dear Minister Wilkinson,

I am writing today to provide feedback on the draft Terms of Reference of the Integrated Review Panel for the proposed Gazoduq project, the natural gas pipeline running between North Eastern Ontario and Saguenay, Quebec. I am grateful for this consultation opportunity.

Ultimately, I am opposed to all new climate change infrastructure, including the Gazoduq project. If we are to respect the 2018 Intergovernmental Panel on Climate Change Report, it is essential that we transition away from fossil fuel infrastructure as quickly as possible. The concept that natural gas is a “clean” fuel has long been debunked, because of its extremely carbon-heavy extraction methods. Below, I specify three core issues with this project.

Fragmented nature of the project

This project is being reviewed as a singular entity when it should be viewed as one part in a large and interconnected chain of production. The Impact Assessment Agency of Canada (IAAC) may be reviewing the impacts of this specific pipeline, but they are not reviewing the upstream and downstream impacts that are necessarily connected. For example, LNG extraction, tanker traffic, and terminal design, and LNG liquefaction have been left out of the assessment.

Although the project’s Terms of Reference mandate for the consideration of climate change effects, this requirement is not enough if the project is not reviewed holistically.

Environmental impact

Along with the carbon-intensive practice of fracking to extract LNG, a natural gas pipeline releases methane emissions through accidental leaks and the use of gas-powered turbines for moving the gas along the pipeline. In a climate crisis, it is nonsensical to spend billions of dollars for infrastructure that will contribute so heavily to our greenhouse gas emissions.

This project also puts at greater risk an already at-risk ecosystem: the Gulf of St. Lawrence. Just this July, the Newfoundland and Labrador Supreme Court ruled that there must be greater oversight with regards to extractive projects in the Gulf of St. Lawrence. I believe that tanker traffic should fall under similar oversight requirements. A gas spill in this precious ecosystem could decimate the Gulf, including the region’s already endangered Beluga whales.

Consultation with Indigenous peoples

As with most fossil fuel projects, consultation with Indigenous peoples is complex, and consent is inconsistent. Based on submissions from First Nations, including the Mitchikanibikok Inik, I am concerned to see that consultation has yet to be effectively completed.

In addition, as the courts have consistently reminded the Canadian government, consultation does not necessarily imply consent. I hope that moving forward the IAAC will commit to its duty to consult under the Charter of Rights and Freedoms and respect the needs and rights of individuals First Nations located on the proposed pipeline route.

I am also concerned by a clause (7.10) in the Canada-Quebec cooperation agreement that does not require the BAPE Panel to consult with Indigenous groups regarding this project. It is the constitutional duty for the federal government to consult with Indigenous nations, and so should it be that of the BAPE Panel.

Thank you again for this consultation opportunity and for your consideration.


Elizabeth May, O.C.
Member of Parliament
Saanich-Gulf Islands
Parliamentary Leader of the Green Party of Canada