CUSMA Treaty & CEC
ACEUM (CUSMA / USMCA)
Canada–United States–Mexico Agreement
It is the major commercial and legal treaty that binds Canada, the United States and Mexico since 2020 (replacing NAFTA). Its Chapter 24 prohibits the three countries from weakening or ignoring their own environmental laws to favor a company.
Why it matters: Thanks to this international treaty, citizens can hold a government accountable when it fails to enforce its environmental laws.
CUSMA Treaty & CEC
CCE (CEC)
Commission de coopération environnementale
Official international organization created by Canada, the United States and Mexico, headquartered in Montreal. Its independent Secretariat reviews citizen complaints when one of the three states fails to effectively enforce its environmental laws.
Why it matters: This is the international documentary body reviewing William Guindon's submission SEM-26-003.
CUSMA Treaty & CEC
SEM-26-003
Submission on Enforcement Matters (year 2026, file No. 003)
This is the official file number given by CCE (Commission for Environmental Cooperation) to the legal complaint filed by William Guindon regarding the expansion of Stablex and the destruction of Grande Tourbière (Great Peat Bog) de Blainville (“Landfill of hazardous materials in Blainville”).
Why it matters: It is the very first submission in 32 years of history (1994–2026) initiated by a minor citizen to pass the admissibility stage.
CUSMA Treaty & CEC
Article 24.27 of ACEUM
Submissions on Enforcement Matters (Admissibility & Party Response)
Rule of the ACEUM (Canada–United States–Mexico Agreement) treaty which allows any citizen to file a complaint before the CCE (art. 24.27(1)), sets the criteria for validity (art. 24.27(2)) and allows the Secretariat to oblige the government concerned to respond officially within 60 days (art. 24.27(3) and (4)).
Why it matters: On August 17, 2026, the CEC determined that William's submission met all criteria under Article 24.27 and required Ottawa to respond.
CUSMA Treaty & CEC
Article 24.28 of ACEUM
Factual Records and Secretariat Determination
Once the government responds, Article 24.28 gives the CCE Secretariat 60 days to analyze the response and decide whether to recommend to the Ministers of the Environment of the three countries (Canada, United States, Mexico) the opening of a thorough investigation called a “Factual File”.
Why it matters: This is the current stage of dossier SEM-26-003, with the deadline set for December 15, 2026.
CUSMA Treaty & CEC
Factual Record
Independent international investigation by the CEC
This is the in-depth investigation report carried out by the scientific and legal experts of the CCE. It is triggered if at least 2 of the 3 member countries vote for its opening. He publicly exposes all the facts about non-compliance with environmental laws.
Why it matters: This is the primary goal of submission SEM-26-003: bringing full scientific and international light to the Stablex case.
Institutions & Exhibits
Exhibit 72-RSP
Official Response of the Party (Government of Canada)
Official code of the brief filed by the Government of Canada on October 16, 2026 before the CCE. In this document, Ottawa attempts to close or postpone the SEM-26-003 file by invoking the existence of a simple citizen petition to the Auditor General.
Why it matters: The very next day (October 17, 2026), William Guindon filed a 7-point legal brief demonstrating that a citizen petition is not a judicial proceeding that blocks the CEC.
Institutions & Exhibits
Exhibit 73-REC
Official Acknowledgment of Receipt by the CEC Secretariat
Official act by which the CCE Secretariat confirms having received Canada's response (72-RSP) on October 16, 2026 and begins the 60-day countdown provided for in Article 24.28.
Why it matters: This document officially sets the starting point of the timeframe leading to December 15, 2026.
CUSMA Treaty & CEC
Guideline 7.5 (SEM Procedures)
Criterion defining a “pending judicial or administrative proceeding”
Official rule of CCE which specifies that a government can only request the cessation of a CCE investigation if it itself conducts a real trial or a binding inspection capable of resolving the problem, and not when a citizen has simply asked questions in a petition.
Why it matters: This key argument dismantles Ottawa's defense in exhibit 72-RSP.
Laws & Procedures
Loi 93 (Projet de loi 93)
Loi concernant le projet d'agrandissement du lieu d'enfouissement de Stablex à Blainville
Special law adopted under gag order by the government of Quebec on March 28, 2025. It forces Ville de Blainville (City of Blainville) to sell its wooded and humid land to the American company Stablex and dismisses the unfavorable conclusions of BAPE (Québec Bureau of Public Environmental Hearings).
Why it matters: This special statute stripped citizens and the municipality of their ordinary remedies in Quebec, prompting action at the federal and international levels.
Laws & Procedures
Parliamentary gag order
Exceptional legislative procedure suspending normal debate rules
Mechanism by which a majority government cuts short the debates of deputies and public consultations at the Assemblée nationale (National Assembly of Québec) to have a law adopted in a few hours.
Why it matters: Bill 93 was forced through under gag order on March 28, 2025 despite opposition from the City of Blainville, the MMC, and scientific experts.
Institutions & Exhibits
BAPE (Report 371)
Bureau d'audiences publiques sur l'environnement — Inquiry Commission No. 371
Independent public organization in Quebec responsible for informing and consulting citizens on major projects. In its Report 371 published in September 2023, the BAPE concluded that the Stablex Cell 6 project in the peatland should not be permitted in its proposed form.
Why it matters: Le gouvernement a ignoré l'avis scientifique indépendant de son propre organisme en adoptant la Loi 93.
Institutions & Exhibits
BVG & CEDD
Office of the Auditor General of Canada & Commissioner of the Environment et au développement durable
Independent institution of the federal Parliament in Ottawa which verifies the work of ministries and manages the register of citizen environmental petitions.
Why it matters: Federal Petition No. 546 on law enforcement in Blainville was registered with the OAG/CESD.
Laws & Procedures
Environmental Petition No. 546 (Article 22 LVG)
Official petition under section 22 of the Auditor General Act
Right provided by federal law allowing a citizen to ask formal questions to federal ministers about the environment. Ministers have a legal obligation to respond in writing within 120 days, but this mechanism does not provide the power to order work to stop.
Why it matters: Ottawa attempted to portray this simple request for written answers as a “domestic proceeding” to avoid the CEC investigation.
Ecology & Chemistry
Cadmium (Cd)
Highly toxic and bioaccumulative heavy metal
Industrial metal dangerous to fish, wildlife and human health, which does not degrade in nature. In a sample from the Ministry of the Environment (MELCCFP) taken on December 2, 2023 from the effluent linked to Stablex activities, cadmium reached 320 times the acute toxicity threshold for aquatic life.
Why it matters: Depositing a deleterious substance into water frequented by fish is governed by section 36(3) of the federal Fisheries Act.
Ecology & Chemistry
Cell 6 (Stablex)
Nouveau bassin géant d'enfouissement de déchets industriels dangereux
This is the name given to the Stablex expansion project aimed at digging a huge landfill site for millions of tons of hazardous waste treated until 2065, directly in the heart of a wooded and humid sector of the Grande Tourbière de Blainville (Great Blainville Peat Bog).
Why it matters: Sa construction entraînerait la destruction irréversible d'environ 278 000 m² de milieux humides et forestiers d'intérêt écologique.
Ecology & Chemistry
Peat bog (and wetland)
Millennia-old ecosystem formed by the accumulation of sphagnum moss and organic matter
A bog is a real natural sponge that has formed over thousands of years. It filters water, prevents flooding, cools the air and shelters rare plants and animals. Unlike a tree plantation, a peat bog destroyed by mechanical excavators cannot be recreated artificially.
Why it matters: The Grande Tourbière de Blainville is one of the most precious ecological jewels of Greater Montreal's North Shore.
Ecology & Chemistry
Carbon sink
Réservoir naturel qui capte et emprisonne le CO₂ de l'atmosphère
Peatlands store proportionally much more carbon than forests. When a peatland is drained and dug, the carbon trapped for centuries is released into the atmosphere in the form of greenhouse gases, worsening climate change.
Why it matters: Protecting the Grande Tourbière de Blainville is a concrete action in the fight against global warming.
Laws & Procedures
Fisheries Act — Section 36(3)
Federal prohibition against depositing deleterious substances into fish-bearing waters
Very powerful Canadian law, section 36(3) of which strictly prohibits the discharge of any toxic or harmful substance into waters where fish live, or in any place from which this substance risks flowing into these waters.
Why it matters: It is one of the three major federal statutes at the heart of submission SEM-26-003 (particularly regarding cadmium and ammonia discharges).
Laws & Procedures
SARA (SARA)
Species at Risk Act (S.C. 2002, c. 29)
Federal law that protects endangered animal and plant species in Canada and their critical habitat, with the possibility for the federal government to adopt a safety net or emergency order when the province does not protect them.
Why it matters: Several at-risk species depend on the forest and wetland habitats of the Grande Tourbière de Blainville.
Laws & Procedures
LCOM (MBCA)
Migratory Birds Convention Act, 1994
Federal law resulting from an international treaty that prohibits destroying nests, eggs and migratory birds or degrading protected areas during nesting.
Why it matters: Deforestation and wetland habitat destruction directly threaten federally protected migratory birds.
Institutions & Exhibits
MELCCFP
Ministry of the Environment, the Fight Against Climate Change, Wildlife and Parks (Quebec)
This is the Quebec Ministry of the Environment. It was its own laboratory analyzes and internal technical opinions which documented the severe cadmium exceedances and the very high ecological value of the peat bog.
Why it matters: The scientific evidence cited in dossier SEM-26-003 comes directly from official ministry data.
Institutions & Exhibits
ECCC & MPO
Environnement et Changement climatique Canada & Pêches et Océans Canada
The two federal government departments in Ottawa responsible for enforcing the Fisheries Act (pollution section), the Species at Risk Act (SARA) and the Migratory Birds Act (MBA).
Why it matters: Submission SEM-26-003 specifically addresses the inaction of these federal departments in Blainville.
Laws & Procedures
Forced expropriation
Forced taking of property rights by the State
Normally used to build a school, a hospital or a public road, expropriation was here imposed by the Loi 93 (Bill 93) to wrest from the Ville de Blainville natural land that it wanted to protect, in order to transfer it for landfill purposes by a private company.
Why it matters: The City of Blainville and the Montreal Metropolitan Community (MMC) vigorously challenged this precedent in court.
Civic Rights
Adultism & Civic Capacity
Discrimination or prejudice against young people based on their minor status
Adultism consists of underestimating or dismissing a person's speech, intelligence or legal actions simply because they are under 18 years of age. However, the UN Convention on the Rights of the Child (art. 12) guarantees the right of young people to be heard in decisions that affect their future.
Why it matters: At ages 14 and 15, William Guindon proved before the CEC that a minor citizen can rigorously lead an international legal proceeding.
Ecology & Chemistry
Leachate & Process water
Contaminant-laden residual liquid formed when rainwater percolates through waste
When rain or groundwater comes into contact with buried or processed materials, it picks up heavy metals (like cadmium) and other chemicals. This water must be rigorously treated before any discharge.
Why it matters: Exceedances measured at effluents and in the receiving water network are at the center of citizen and scientific concerns.