The government body responsible for reviewing a $9-billion natural gas project in Saguenay received a clear mandate from the province: look into the environmental, economic and social impact of Énergie Saguenay locally.
But it was not asked to study the pipeline that will be needed to supply the plant with natural gas.
And it won't take into account the greenhouse gas emissions (GHG) created when the natural gas is extracted in Alberta.
Those questions have nonetheless been front and centre from the onset of Quebec's Environmental Review Board (BAPE) on Énergie Saguenay.
The public hearings that began in October resumed this week, and are being held online until November 4.
The fact that the pipeline will be analyzed separately at a later date has been at the core of criticisms from citizens and environmental groups presenting briefs this week.
"The division is an obstacle to the analysis of this project in its entirety," said Rebecca Pétrin on Monday, director of Eau Secours.
Having to navigate two separate BAPE procedures goes against the interest of citizens for whom the BAPE was created, said Mauricie resident Geneviève Richard.
"It represents twice the effort and time from citizens who want to participate," said Richard on Monday.
GNL Quebec wants to build a natural gas liquefaction terminal on the Saguenay River, where tankers would fill up and ship liquid natural gas (LNG) to European and Asian markets.
It says that by replacing coal and other more polluting energy sources with LNG, it would eliminate 28 million tonnes of GHG annually.
The investment group behind the project has also set up a separate company, called Gazoduq Inc., that is currently going through the steps to have a 780-kilometre pipeline approved to carry the natural gas from Northern Ontario to Saguenay.
Focusing solely on the Saguenay terminal and ignoring the GHG produced at the source, from natural gas wells in Alberta, is like "ignoring the elephant in the room," said Marc Durand, a retired professor of engineering geology, who presented his findings to the commission on Monday.
GNL Quebec estimates about one per cent of its natural gas could leak into the atmosphere during its transit from Alberta to international markets, either during the extraction, transportation or liquefaction stages.
Durand said those leaks — known as fugitive emissions — are more likely to range from four to nine per cent, according to the latest industry estimates he looked at, when taking into account the entire life cycle of the natural gas wells.
"The industry has never been able to prevent fugitive emissions from these wells" once they are shut down, Durand said, when it comes to fracked natural gas.
During the first phase of the BAPE hearings, GNL Quebec said that 85% of the natural gas it would purchase would come from fracking sites in Alberta, include shale gas, making it all the more complicated to control emissions once the wells are shut down, Durand said.
"The government legislation is two decades behind on this."
The CEO of Quebec's Energy Association, Éric Tétrault, said Durand's estimates don't take into account the leaps the Canadian oil and gas industry has made to invest in new technologies.
Tétrault said that Canadian regulations are far stricter than other countries', like Russia, where infrastructure is decaying.
"Fugitive emissions are overall under control. We shouldn't be exaggerating the risks," Tétrault told the BAPE's commissioners on Monday evening.
While Quebec has benefited from its access to hydroelectricity, other countries need a transition period before they can convert from coal to greener energies, Tétrault said.
Quebec now has the opportunity to be at the forefront of that transition, he said.
"It's the greatest gesture Quebec could make to reduce GHGs worldwide."
But the actual impact of Énergie Saguenay has not been clearly laid out, according to the environmental group Équiterre.
On Monday, the director of government relations Marc-André Viau said the first phase of the BAPE hearings, held in October, failed to address some key issues.
On many days when citizens were asking questions on what impact the project would have on global GHG emissions, no experts or government officials were present to answer.
"The GHG were addressed with sweeping statements from the promoter rather than with independent scientific data," Viau said.
After fighting the construction of the Energy East pipeline, abandoned in 2017, Viau said having to discuss the construction of a new pipeline project all over again "feels like groundhog day."
The head of the commission, Denis Bergeron, opened this week's hearings by stating he was given a clear mandate by the Minister of the Environment to look solely into Énergie Saguenay, and that "neither the BAPE nor the commissioners" have the power to criticize that decision, he said.
The office of Environment Minister Benoît Charette has not responded to CBC's requests for comment on this question.