Battery sector | No BAPE for many flagship projects

The battery industry is emerging from the shelter of the Office of Public Hearings on the Environment (BAPE). In addition to Northvolt, factories of General Motors (GM), Ford, Nemaska ​​Lithium, Nouveau Monde Graphite and Lithion Technologies escape independent public scrutiny. Voices are calling for a study on the ecosystem to have an “overall view” of its impacts.

The only exception in the case of Northvolt: the portion of its $7 billion megaproject, which straddles Saint-Basile-le-Grand and McMasterville, concerning battery recycling will be examined by the BAPE, an impartial body of the Quebec government. With regard to the other flagship projects of the Legault government’s strategy, which will essentially see the light of day in the Bécancour industrial park, it is only in the event of expansion that the BAPE procedure could be initiated, observed The Press.

“This means that we really need a framework that would make it possible to assess the cumulative impacts of an industry,” explains Camille Cloutier, lawyer at the Quebec Environmental Law Center (CQDE). What this will change to our territory, our economy, to natural environments, we must look into this. »

Other large-scale projects are expected in the battery sector. Last fall, the Legault government claimed to have 15 billion ads in its pipeline. If everything goes as planned, the value of investments in the Quebec strategy could approach 30 billion in the medium term. The Press was able to confirm that GM, Ford, Nemaska ​​Lithium, Nouveau Monde Graphite and Lithion were not subject to the BAPE mechanism. The Legault government did not want to confirm this information, even if this entire mechanism falls under its control. By email, the Ministry of the Economy, Innovation and Energy simply responded that “this request must be addressed” to companies. At the time these lines were written, the Ministry of the Environment, the Fight against Climate Change, Wildlife and Parks (MELCCFP) had not responded to questions from The Press.

The manufacturing of cathode materials – the positive pole of a lithium-ion battery – and the refining of critical minerals are carried out through complex industrial processes that involve chemicals. Added to this is the construction of these new complexes, which can have an impact on the biodiversity of the environment where they are built.

In the case of Northvolt, it was reports that allowed the public to learn that the construction of the battery cell complex was going to affect 13 hectares of wetlands on this 170 hectare site. This information would have been publicly released up front in the event of an independent public review.

A company can offer a BAPE or the government can require it. Otherwise, it is the Regulation relating to the evaluation and examination of the environmental impacts of certain projects which decides. This mechanism notably requires the promoter to present an impact study and also provides for the holding of public consultations. This is where the public and organizations can intervene. The organization transmits its recommendations to the government, which is not, however, required to follow them.

Under the ceilings, for now

The projects announced with great fanfare by the Legault government over the past two years are below the threshold for being subject to an independent environmental assessment.

For example, the cathode materials factories announced by GM and Ford – projects respectively estimated at 600 million and 1.2 billion whose construction is underway – are counting on production thresholds of 33,000 metric tons and 45,000 respectively. metric tons. Since last July, the ceiling has been raised to 60,000 tonnes by the Legault government. This decision benefits Northvolt, since the part of its project concerning the production of cathodes expects a maximum production of 60,000 metric tons.

50% owned by the Quebec state, Nemaska ​​Lithium is in a similar situation. Its lithium hydroxide plant – essential in the manufacturing of lithium-ion batteries – is banking on an annual production of 34,000 tonnes, which is below the trigger threshold of 40,000 metric tonnes set by the Regulation for a “metallurgy” project. extractive”.

A BAPE procedure would essentially be required in the context of an expansion phase where production would exceed the limits of the regulatory framework in force. GM could almost double the pace without an independent review.

“A BAPE review that happens later in the process while the project is well underway, will it have as much impact on the government? asks M.e Cloutier. The question is valid. Ideally, the BAPE arrives as early as possible in a project. »

Nemaska ​​Lithium and Nouveau Monde Graphite have particularities since they each rely on two components: mining and transformation. These two companies were unable to avoid the BAPE procedure for the mining aspect. The deposits are located in Whabouchi (Nemaska ​​Lithium) and Saint-Michel-des-Saints (Nouveau Monde Graphite).

Even if its hydroxide production plant is not subject to BAPE examination, Nemaska ​​Lithium devotes a section of its website to a “voluntary environmental and social assessment process”. It includes documents prepared at the company’s request on the impacts of the lithium hydroxide project on themes such as biodiversity.


Since several projects are well underway, the biologist and general director of the Society for Nature and Parks (SNAP Quebec), Alain Branchaud, believes that the time has come, for Quebec, to carry out a “strategic environmental assessment”, a process that would look at the battery sector as a whole rather than on a case-by-case basis.

“We could use this mechanism to say ‘what is the best way to position ourselves with the least impact on the environment and with socio-economic benefits,’” he says. The projects can continue, but there may be parameters that could change since they are carried out over several years. This allows us to see the big picture. »

Strategic environmental assessment is used to evaluate the strategies, plans and directions of the government and public organizations, while the main role of the BAPE is to look at specific projects. Tuesday, the MELCCFP had not responded to questions from The Press sent the day before to find out if Quebec had looked into the environmental impacts of the battery industry as a whole.

Learn more

  • 15 billion
    Total value of projects announced to date in the Quebec battery sector

    The press

    Year of founding of the Office of Public Hearings on the Environment

    Government of Quebec


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