The Gull Island Environmental Assessment Is Fifteen Years Old.
The only environmental assessment of Gull Island was completed in 2011. Since then the project has grown, the science has moved, and the Grand River—known on government maps as the Churchill—is once again at the centre of a multi-billion-dollar agreement. Grand Riverkeeper Labrador is asking the provincial and federal governments to pause, commission a new and independent assessment, and only then decide whether Gull Island is in the long-term interest of Newfoundland and Labrador.
Published 14 September 2026
What the 2026 Agreement proposes
On 17 August 2026, Newfoundland and Labrador Hydro, Hydro-Québec and Churchill Falls (Labrador) Corporation signed the Definitive Cooperation and Implementation Agreement. It replaces the 1969 contract, sets new power purchase agreements running to 2077, funds upgrades and new transmission at Churchill Falls, and commits to a feasibility study for wind development in Labrador.
The largest piece of new construction is a dam at Gull Island, downstream of Churchill Falls on the Grand River. The Agreement gives its capacity as approximately 2,250 or 2,700 megawatts depending on the final design. The reservoir behind it would be roughly 230 kilometres long. That figure is worth sitting with: the Agreement describes the reservoir by its length, not by the area of land it would put under water.
Most of the public conversation so far has been about money—what the province earns, what Québec pays, what Ottawa guarantees. Those are real questions and others are asking them well. Our concern is with what the river and the people who live along it would carry, and with how little of that has been examined.
Why the Gull Island environmental assessment is out of date
A Joint Review Panel assessed the Lower Churchill Generation Project and reported in August 2011. Muskrat Falls was built first. Gull Island was not, and fifteen years later it is being revived under a different agreement, a different owner-operator and a larger design.
Here is the part that deserves more attention than it has had. The 2011 panel anticipated exactly this situation. It recommended that an expiry date be set on Gull Island’s environmental approval, so that if the project were delayed, a fresh review would be required before it could proceed. Both the Government of Canada and the Government of Newfoundland and Labrador rejected that recommendation, and the province stated that any release would cover the entire Lower Churchill project as proposed.
So the panel that studied this river said, in writing, that an approval this old should not be relied on indefinitely. Governments overruled it. We are asking them to reconsider—not because the law compels a new assessment, but because the people who did the original work said it would be needed.
What has changed since 2011 is not minor. Climate science has advanced. So has the understanding of greenhouse gases released by reservoirs, of how mercury moves through flooded landscapes and into food, and of how river regulation alters downstream systems. Energy markets look nothing like they did. Wind and solar have gone from marginal to mainstream. And the project itself is bigger than the one that was assessed.
What the summary leaves out
Newfoundland and Labrador Hydro published a summary of the Agreement. It is a document about megawatts, dollars and jobs. It calls the package the largest clean energy investment in North American history.
It does not mention the land the reservoir would flood. It does not mention methane. It does not mention methylmercury in fish and country foods. It does not mention traditional land use, or the places along the river that matter to people. It does not mention Labrador’s coastal communities. Environmental review appears once, as something the federal Major Projects Office could help coordinate.
We do not think this is an oversight. What a document leaves out tells you what its authors consider relevant to the decision. On the evidence of the summary, the river itself is not part of the calculation.
Methane, mercury, and the food web
Is hydropower “clean and green”?
Hydroelectricity is routinely described as clean, renewable and zero-carbon. The peer-reviewed literature is less certain. When land is flooded, the organic matter in soil and vegetation breaks down underwater and releases greenhouse gases, including methane—which traps more than eighty times as much heat as carbon dioxide over a twenty-year period. A global synthesis of reservoir emissions estimated that reservoirs account for roughly five per cent of human-caused warming, and later work has shown that the climate impact varies enormously from one facility to another, which is precisely why each one needs to be measured rather than assumed.
How are emissions measured?
Emissions for these projects are currently estimated using a modelling tool, not measured at the reservoir. Until they are measured, we do not think anyone should be calling them clean and green.
What is the link between flooding and mercury in food?
Flooding also changes how mercury moves. Bacteria in newly flooded soil convert mercury into methylmercury, a neurotoxin that accumulates as it moves up the food web, so that concentrations are highest in the fish and animals people harvest. Researchers at Harvard modelled this for Muskrat Falls and projected that average methylmercury exposure among Inuit living downstream would roughly double after flooding. Gull Island was one of the twenty-two Canadian hydroelectric projects that study assessed.
We want to be precise about what that means, because the point is easily twisted. Country foods are central to health, culture and food security in Labrador, and research has shown that steering people away from them causes harm of its own. The problem is not the food. The problem is a project expected to contaminate it, proceeding without measuring what it would do.
What other effects do dams cause?
Dams change the water in quieter ways too. They trap sediment and nutrients that would otherwise reach the estuary and the ocean, including dissolved silica, which the diatoms at the base of the marine food web depend on. These effects are well-documented globally. None of them have been assessed for Gull Island using current, site-specific evidence.
Lessons from Muskrat Falls
Muskrat Falls went billions over budget, and ratepayers are still carrying it. A provincial commission of inquiry found the project was allowed to proceed on assumptions that were never adequately tested, and that government failed in its duty to protect the interests of the province’s residents.
What is optimism bias and how does it affect this proposed project?
This is not unique to Labrador. Researchers who have studied large dams worldwide have found that actual costs run far above forecasts often enough to call the case for building them into question. The pattern has a name—optimism bias—and the remedy is independent scrutiny before commitments are made, not after.
Gull Island alone is estimated at more than $29 billion before financing, with a federal guarantee behind the debt. The people of Newfoundland and Labrador have already paid once for a megaproject whose numbers were not independently tested. Asking for that test now is not obstruction. It is the lesson of the last one.
What we’re asking for
We are not asking governments to walk away from every part of this Agreement. We are asking them to stop short of final commitment until Gull Island has been properly examined.
Updating the impact assessment to account for current climate science
That means a new and comprehensive impact assessment of the whole project—dam, reservoir, turbines, transmission and associated infrastructure—together with a regional assessment of cumulative effects across the Grand River system. It means using current climate science, with site-specific analysis of methane and of mercury and methylmercury in aquatic food systems. It means meaningful participation by Indigenous peoples and by all Labrador communities, with funding so people can actually take part. It means strong federal oversight where federal jurisdiction applies, and no shortcuts through approvals granted fifteen years ago. It means independent review of the cost, market and reliability assumptions. And it means an honest comparison against the alternatives—wind, solar, storage and conservation—which have become far cheaper and faster to build since 2011, and which remain the lowest-cost new generation available.
The Grand River is not simply a source of electricity. It is a living river system, a watershed, a habitat, a source of food and livelihood, and an essential part of Labrador’s natural heritage. It has already been dammed twice. Before it is dammed again, someone should have to show their work.