Summary of the matter addressed in the submission:

The Submitter asserts that Canada, and more specifically the province of Québec, is failing to effectively enforce Québec's Environment Quality Act ("Act" or "EQA") and the Regulation Respecting the Burial of Contaminated Soils ("Regulations") by issuing a permit for the use of chemical oxidation to treat PCB-contaminated soils without evidence that the process works.

The Submitter states that a study carried out by experts found no evidence that outside a laboratory context, at a commercial scale, chemical oxidation can reduce PCB concentrations in contaminated soils to meet maximum levels for landfilling set by the Act and Regulations. The Submitter asserts that Canada is failing to effectively enforce its environmental law, in this case, s. 24 of the EQA, which provides that the Minister of Sustainable Development, Environment, and Parks (MSDEP) of Quebec shall, before giving his or her approval to an application for a certificate of authorization, ascertain that the emission, deposit, issuance or discharge of contaminants into the environment will comply with applicable legislation and will not harm the environment.

Names and citations of the environmental laws in question:

The Québec Environment Quality Act and the Regulation Respecting the Burial of Contaminated Soils ("Regulations")

Submitter(s):

Bennett Environmental Inc.