Public Comment Submission – Bécancour Port Terminal Expansion (B6 Wharf)

I have reviewed the Summary of the Initial Project Description for the Bécancour Port Terminal Expansion Project – B6 Wharf, and I am submitting the following  comments as a member of the public and an expert in environmental assessment for large scale marine, oil, and gas related infrastructure. My observations are based on the adequacy of baseline data, the scientific validity of impact predictions, and the degree to which the proposed project aligns with federal requirements under the Impact Assessment Act. Based on the information available, I believe several critical gaps must be addressed before IAAC can determine the significance of environmental effects or decide whether a full federal impact assessment is required.

1. Sediment Quality Characterization Is Insufficient for an Oil and Gas Relevant Port Expansion

After reviewing the sediment section, I am concerned that the analysis is incomplete for a project of this magnitude. Only one sediment sample near Wharf B3 is discussed, and broader results for the B6 dredging footprint are still pending. For a port that handles or is connected to industries handling petroleum related commodities, this level of characterization is inadequate. Industrial sediments often contain PAHs, PCBs, metals, petroleum hydrocarbons, and PFAS, and these contaminants are rarely distributed uniformly. With more than 373,000 m³ of sediment to be dredged, there is a substantial risk of mobilizing contaminants. I believe IAAC should require a full CCME compliant dataset, depth profiling, and geostatistical mapping, along with a formal dredged materials management plan similar to other St. Lawrence port reviews. Without this, it is impossible to assess re suspension risks or downstream ecological effects.

2. High Risk Interaction with Aquatic Species at Risk Requires Detailed Technical Assessment

The presence of several SARA listed species, such as Eastern Sand Darter, Hickorynut Mussel, Northern Brook Lamprey, and Channel Darter, warrants a higher level of analysis than what is included in the IPD. These species are extremely sensitive to sedimentation, substrate changes, hydrodynamic shifts, and underwater noise. The absence of sediment plume modelling, vibration analysis, eDNA surveys, and benthic mapping is a major gap. From my experience, projects of this type usually require species specific impact pathways and acoustic modelling to understand effects on sensitive organisms. I believe these studies must be completed before IAAC can evaluate risks to species at risk.

3. Dredging Volumes Are Large Enough to Alter Hydrodynamics and Bed Shear Stress

The dredging footprint is large enough to alter the hydrodynamic system of the freshwater St. Lawrence estuary. More than 373,000 m³ of sediment removal will influence shear stress, turbidity cycles, and erosion depositional patterns. Suspended sediments can remain in the water column for several tidal cycles, affecting downstream habitats and aquatic vegetation beds. In my view, it is problematic that the IPD does not include hydrodynamic modelling using tools such as Delft3D or MIKE21. These models are needed to predict plume behaviour, assess potential impacts on fish habitat, and evaluate cumulative interactions with the 2023–2033 maintenance dredging program.

4. Infill of 65,000 Square Metres of Aquatic Plant Beds Represents Permanent Habitat Loss

The conversion of 65,000 m² of aquatic plant beds into storage area represents a significant and irreversible loss of high value littoral habitat. These vegetation beds support juvenile fish, benthic organisms, and migratory birds. Removing them could reduce fish breeding and ecosystem productivity for years. I believe IAAC should require a functional habitat assessment and compensation aligned with federal standards for high ecological value wetlands, which typically require a three to one replacement ratio. The ecological implications here are not minor, and they need to be fully quantified.

5. Migratory Bird Assessment Is Insufficient for a Project Adjacent to Two WFGAs

Given the proximity to two Waterfowl Gathering Areas, I am concerned that the migratory bird assessment is too general. Pile driving, heavy machinery, and night lighting can disturb staging waterfowl and migratory species. The IPD does not include noise modelling, light spill modelling, or seasonal timing assessments. These components are essential for understanding behavioural disruption during critical migration periods. I believe IAAC should require quantitative modelling, species sensitivity analysis, and timing restrictions based on both spring and fall migrations.

6. Greenhouse Gas Emissions Have Been Underestimated and Misclassified

The IPD estimates 88 tonnes of CO₂e per year for operational emissions but excludes approximately 179,000 tonnes of CO₂e from project induced vessel traffic. Under the Strategic Assessment of Climate Change, project induced emissions must be included, particularly where new port capacity directly increases vessel throughput. I believe the proponent must provide a full GHG inventory, including maritime emissions, electrification potential, and a credible 2050 alignment plan. The current estimates significantly understate the true climate footprint of the project.

7. Cumulative Effects Assessment Is Missing for Navigation, Habitat Loss, and Indigenous Rights

One of my strongest concerns is the absence of a cumulative effects assessment. The addition of 34 vessels per year, combined with the ongoing maintenance dredging program, new industrial development in the battery sector, and historical shoreline alteration, creates compounding pressures. Navigation related noise, turbidity, vessel strikes, and erosion do not occur in isolation. These cumulative pressures can significantly affect Indigenous fishing access and ecological integrity. I believe IAAC should require a cumulative effects analysis that integrates regional navigation modelling and long term habitat loss.

8. Indigenous Impacts Require Quantitative Analysis and Co Developed Approaches

Although the summary acknowledges potential effects on Indigenous communities, the assessment does not quantify impacts on fishing, navigation, cultural use, or access. There is no mapping of traditional use areas, no harvest modelling, and no assessment of whether noise or habitat loss could disrupt culturally important species such as northern pike or striped bass. Because striped bass is endangered, even small pressures can threaten recovery. I believe the assessment must be co developed with the affected Nations, incorporating Indigenous knowledge and spatial use mapping, and establishing monitoring and compensation designed collaboratively, not unilaterally.

9. The Alternatives Assessment Is Too Narrow to Satisfy the IAA Requirements

While the IPD outlines five structural options for the wharf, it does not evaluate broader alternatives that could reduce environmental harm. There is no assessment of alternative locations for the storage area, options that avoid the loss of aquatic vegetation beds, or designs that minimize dredging. Section 22 of the Impact Assessment Act requires a full examination of alternative means and alternative locations that are technically and economically feasible. I believe the proponent should revisit this section and incorporate ecological, hydrodynamic, climate, and Indigenous rights considerations, not just structural engineering differences.

Based on my review, I believe the project, as currently described, is likely to result in several adverse environmental effects, particularly related to fish and fish habitat, migratory birds, aquatic vegetation, and Indigenous rights. The permanent loss of productive habitat, the scale of dredging, the sensitivity of SARA listed species, and the exclusion of project induced vessel emissions all point to potentially significant impacts that cannot be fully evaluated with the information provided. In my view, the gaps in baseline data, modelling, and impact prediction are substantial enough that a full federal impact assessment is warranted. This level of review is necessary to protect ecological integrity, uphold Indigenous rights, and ensure transparent decision making.