Montréal, March 26, 2026 – The Centre québécois du droit de l’environnement (CQDE) is sounding the alarm regarding the review of Bill 11, whose stated objective is to reduce the regulatory and administrative burden, often referred to as red tape. In particular, the introduction of several last-minute amendments making substantial changes to the environmental protection framework – without having been subject to genuine public debate – is causing concern among these environmental law specialists.
Bill 11 falls into the category of omnibus legislation, amending no fewer than 61 laws and 13 regulations affecting a wide range of sectors. However, following public consultations, several batches of amendments were tabled in recent days, proposing major changes to various laws, some of which were not discussed during the consultations regarding the bill. The adoption of such far-reaching amendments without proper public debate undermines the democratic legitimacy of the reforms. The CQDE strongly deplores this legislative approach, which bypasses an essential step in the legislative process.
Among the most concerning last-minute amendments are those made to the Environmental Quality Act (EQA), the cornerstone of Québec’s environmental regulatory framework. (The bill would allow for the extension of certain industrial operating authorizations from five to ten years (by amending section 31.18). However, the frequency of renewal for these authorizations is a key lever for adapting operating conditions to evolving scientific knowledge, integrating the best available technologies, and better managing environmental risks.
The bill also extends the validity of all previously issued operating authorizations by two years and postpones the deadlines associated with the standards and conditions included therein.
The validity of the operating authorization for the Horne Smelter in Rouyn-Noranda is further extended following the introduction of a specific amendment.While the standard is set to be lowered to 15 nanograms per cubic metre by 2027, this amendment pushes the deadline back to 2033, disregarding the public health recommendation to reach a limit of three nanograms per cubic metre. This measure effectively delays the achievement of arsenic emission reduction targets by several years.
“These amendments go far beyond the stated objective of the administrative simplification bill. At the last minute and without informed dialogue on issues that would have required rigorous and transparent review, the government is proposing to allow more pollution without debate. All this while measures aimed at protecting the environment and public health have been eroded for over a year,” emphasizes Geneviève Paul, Executive Director of the CQDE.
The CQDE strongly condemns this legislative approach, which is part of a troubling trend marked by increased reliance on omnibus bills, short timeframes between their introduction and public consultations, and the late introduction of major amendments.
-30-
