Press releases

SEM-26-003: Official filing of William Guindon's observations refuting Canada's request for rejection or postponement

BLAINVILLE (Québec), October 17, 2026 – Less than 24 hours after the Government of Canada filed its official response (exhibit 72-RSP) requesting to terminate or suspend the examination of citizen communication SEM-26-003, William Guindon formally transmitted to the Secretariat of the Commission de coopération environnementale (CCE / ACEUM (Canada–United States–Mexico Agreement)), to the attention of its director of legal affairs Mr. Paolo Solano, his memorandum of Observations refuting point by point Ottawa's procedural maneuver.

THE 7 LEGAL AND FACTUAL MEANS FILED AT CCE

In a memorandum rigorously structured around the ACEUM treaties and the constant jurisprudence of the Secretariat, the author demonstrates why Canada's request for closure or suspension must be entirely rejected:

• • 1. Invocability absent from Article 24.27(4)(a): Canada cannot invoke this article because environmental petition No. 0546 filed with the Auditor General (CEDD/BVG) is neither a judicial or administrative procedure initiated by the Party, nor a quasi-judicial procedure. The BVG has no power to sanction or verify the accuracy of ministerial responses.
• • 2. Guideline 7.5 discretionary and protective: This provision is intended to protect the private remedies of the author of external interference, and not to provide a procedural loophole for the respondent Party. The two approaches are complementary and non-conflicting.
• • 3. Previous decision of the Secretariat (paras. 66-79 of August 17, 2026): The Secretariat has already expressly ruled on the coexistence of approaches and the criterion of reasonable time (decision A24.27(2)(3)/SEM/26-003/62/DET, citing Tijuana, Nazas and Pollution by ships). Going back on it would constitute an unjustified reversal.
• • 4. Fundamental difference in nature and scope: The CCE (Commission for Environmental Cooperation) examination concerns the application of 17 provisions from 5 federal environmental laws (LCOM, RCOM, SARA, Fisheries Act, CEPA). Petition No. 0546 consists of 24 questions of ministerial information without any allegation of failure to implement.
• • 5. Disproportionate burden contrary to the practice of CCE: Requiring the prior exhaustion of simple questions of information would create a disproportionate burden contrary to the objectives of the Agreement and to jurisprudence (Loggerhead turtle, Fairview Terminal, Agricultural burning), particularly with regard to minor citizens acting without legal representation.
• • 6. Postponement to November 10 indefinite: The postponement requested by Canada is by nature indeterminate, since section 22 of the Auditor General Act authorizes ministers to unilaterally extend their response deadline by simple written notice.
• • 7. No enforcement measures for cell 6 on the merits: On the merits, Canada's response does not mention any enforcement measures for federal environmental legislation relating to cell 6 of the Stablex site (paras. 54, 64, 76).

“Environmental petition no. 0546 and citizen communication SEM-26-003 are not rival or contradictory approaches: they are complementary. Canada is trying to transform a simple citizen mechanism for access to information into an international inadmissibility barrier. Section 24.27(4)(a) does not allow a government to use its own delays to silence an alert about cadmium and the destruction of a peat bog. » — William Guindon, author of communication SEM-26-003

CONCLUSION AND REQUEST TO THE SECRETARIAT (ART. 24.28 ACEUM)

The author formally requested the CCE Secretariat to:

• 1. Reject the request to terminate the examination of communication SEM-26-003;
• 2. Reject the request to postpone the examination;
• 3. Continue to review the communication pursuant to Article 24.28(1) of ACEUM with a view to recommending the development of an independent factual record.

Canada's response filed to CCE

BLAINVILLE (Quebec), October 16, 2026 – On the deadline prescribed by Commission de coopération environnementale (CCE / ACEUM), the Government of Canada formally submitted its official response (exhibit 72-RSP) to the Secretariat of the international organization in Montreal, which acknowledged receipt the same day under the signature of its director of legal affairs, Paolo Solano (exhibit 73-REC ). The 15-year-old Quebec teenager William Guindon, author of the citizen communication SEM-26-003, denounces a procedural avoidance maneuver on the part of Ottawa which chooses to invoke its own internal administrative deadlines to try to escape examination of its environmental inaction.

A PROCEDURAL DENITION OF EVIDENCE OF POLLUTION

In a succinct two-page brief, the federal government does not devote a single line to contesting the scientific and environmental findings supported in the citizen file. Its strategy is entirely based on a procedural inadmissibility:

• • Formal request for rejection or suspension: Canada formally requests the Secretariat of CCE to terminate the examination of the communication SEM-26-003 or to suspend its processing.
• • The duplication argument (Petition 0546 to the OAG): Canada claims that the international review is “premature” due to the filing, on June 29, 2026, by William Guindon of environmental petition No. 0546 with the Commissioner of the Environment and Sustainable Development (CESD) of the Office of the Auditor General of Canada.
• • The mandatory ministerial deadline of November 10, 2026: Sent on July 13, 2026 to the ministers of Environment and Climate Change Canada (ECCC) and Fisheries and Oceans Canada (DFO), this petition statutorily obliges federal ministers to table their responses to Parliament within a strict deadline of 120 days (s. 22 of the Auditor General Act), i.e. no later than November 10, 2026 .
• • Guideline 7.5 of the CCE: Canada argues that investigating the international complaint before this date would constitute unnecessary overlap with ongoing domestic remedies.

WHAT CANADA DOES NOT DISPUTE: UNREFUTED SCIENTIFIC FACTS

Legal examination of Exhibit 72-RSP reveals what Ottawa has chosen to keep quiet:

• • Cadmium up to 320 times the standards: The critical exceedances documented in connecting waterways and the documented discharge of 1,300 liters of effluent (certified by Bureau Veritas) are not the subject of any government denial.
• • Destruction of 278,000 m² of wetlands: The encroachment for Cell 6 of Stablex, condemned by report BAPE 371 and imposed under gag order by Loi 93 (L.Q. 2025, c. 7), remains without federal ecological justification.
• • Zero proof of authorization or inspection: The federal government has not produced any proof of ministerial authorization issued under section 36(3) of the Fisheries Act or the Species at Risk Act (SARA).

“Environmental petition no. 0546 and citizen communication SEM-26-003 are not rival or contradictory approaches: they are complementary. Canada is trying to transform a simple citizen mechanism for access to information into an international inadmissibility barrier. Section 24.27(4)(a) does not allow a government to use its own delays to silence an alert about cadmium and the destruction of a peat bog. » — William Guindon, author of communication SEM-26-003

“Before an international body, silence is an admission. Canada did not deny a single milligram of cadmium, did not dispute a single square meter of destroyed peatland, and could not produce a single valid federal authorization for Cell 6. Had the government enforced its laws, it would have proven so in two pages. Instead, it asked to close the file.” — William Guindon

NEXT STEPS: ARTICLE 24.28 AND NOVEMBER 10 CALENDAR

In accordance with article 24.28 of the ACEUM, the file now enters its substantive examination phase:

The CCE Secretariat must determine whether Canada's response provides satisfactory clarification or whether the alleged violations justify recommending to the Ministers of the Environment of Canada, the United States and Mexico the development of an independent Factual Record. At the same time, William Guindon is awaiting the mandatory written response from federal ministers to Petition 0546 by November 10, 2026.

15-year-old calls on Canada to enforce its own environmental laws

BLAINVILLE (Quebec), October 9, 2026 – In seven days, Canada will have to officially respond to communication SEM-26-003 filed by William Guindon, a 15-year-old Canadian teenager living in Blainville. The Secretariat of the Commission for Environmental Cooperation (CEC) deemed this communication admissible within the framework of the Canada–United States–Mexico Agreement (ACEUM) and Canada's response is expected no later than October 16, 2026. The young person accuses the federal government of not enforcing its own environmental laws in the Stablex file, in Blainville.

The communication concerns the activities of cell no. 6 of Stablex Canada Inc., a hazardous materials burial project in the Grande Tourbière de Blainville (Great Blainville Peat Bog) sector, on the site of the former Camp Bouchard. The land of cell no. 6 (lot 6 695 053 of the Quebec cadastre) was expropriated from Ville de Blainville (City of Blainville) by Loi 93 (L.Q. 2025, c. 7). William Guindon denounces the threats posed by this project on endangered species and on the wetlands of the Grande Tourbière de Blainville and Lockhead Creek, in the Mille-Îles River sector, as well as the inaction of the authorities. He alleges failure to apply the Fisheries Act, the Species at Risk Act, federal rules on migratory birds and the Canadian Environmental Protection Act.

REMINDER OF THE FACTS

• • August 17, 2026: the Secretariat of the CCE judges the communication SEM-26-003 admissible under Articles 24.27(2) and (3) of the ACEUM and requests a response from Canada — expected before October 16, that is to say in seven days.
• • September 25, 2026: the Secretariat of the CCE confirms that “since 1994, this is the first time that an author has indicated to us that they are a minor when submitting a file to the CCE”.
• • Federal inspection report no. 402462402 (April 2025): an unmarked 10 m protection zone along a watercourse, heavy machinery observed 5 m from this watercourse and invasive exotic species not controlled on the site.

“When a 15-year-old asks questions of public interest, he is met with procedural barriers. Yet when faced with industrial contamination risks to our wetlands, authorities turn a blind eye to strict law enforcement.” — William Guindon

“I do not fault Ottawa for doing its job poorly: I fault it for playing dead. Before the law, a minister's silence is not bureaucracy — it is abdication.” — William Guindon

“They passed a law under gag order at 4 a.m. because they knew that in broad daylight, their project could not stand up to scrutiny. They shut down domestic courts at night, so I turned on international law by day.” — William Guindon, au sujet de la Loi 93

“The federal military left a heavy environmental legacy on this site for decades. Today, Ottawa is allowing millions of tonnes of industrial residues to be landfilled directly alongside a peatland of immense ecological value. The peatland must not be used as a sacrifice zone.” — William Guindon, au sujet du site de l'ancien Camp Bouchard

William Guindon is available for interviews starting this week.

“On October 16, it’s not me who takes an exam. It is the Government of Canada that must explain to the whole world why it refuses to enforce its own environmental laws. » — William Guindon

• • Positive determination by the Secretariat (August 17, 2026): Consult on cec.org ↗ ↗
• • Revised communication from William Guindon (July 16, 2026): Consult on cec.org ↗ ↗
• • Analytical annex and supporting information (102 p.): Consult on cec.org ↗ ↗
• • Official archive and high resolution PDF: Download the press release (official PDF) ↗ ↗