Sandbox for Subsurface Technologies

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Bill 17, titled An Act to amend the Act respecting natural gas storage and natural gas and oil pipelines in order to authorize the implementation of a pilot project relating to the exploration for underground reservoirs or certain fluids, or their operation or exploitation, introduces a framework allowing Québec to authorize limited pilot projects involving underground reservoirs and certain naturally occurring fluids.

The amendments establish that underground reservoirs, including pore spaces, and fluids other than water and minerals contained in fluids that occur naturally beneath the topsoil are considered part of the domain of the State. This clarification provides the government with authority over these underground resources and creates a legal basis for research, testing, and innovation initiatives involving their exploration or use.

Under the new Chapter XVII.1, the Québec government may authorize pilot projects lasting up to five years, with the possibility of a two-year extension. Before approving a project, the government must consult affected local communities, including municipalities and Indigenous communities.

Each approved pilot project must define the territory involved, the activities permitted, the underground reservoir or fluid targeted, and the rights, standards, and obligations that apply. The government may establish requirements that differ from existing provisions of the Act or regulations, provided that these variations do not compromise public health and safety, property security, or environmental protection. This flexibility is intended to allow experimentation while maintaining safeguards.

The legislation also introduces monitoring, reporting, and transparency requirements. Pilot projects must specify oversight mechanisms and identify information that participants must provide to the Minister. The government may determine which breaches of pilot project requirements constitute offences and establish penalties. Maximum fines may reach $1 million for individuals and $6 million for other entities, with penalties varying depending on the seriousness of the violation.

Bill 17 also establishes access rights for project operators. A person authorized to carry out a pilot project may access the relevant territory, but written permission from private landowners or State lessees is required before entering private property or conducting work. Notice requirements include obtaining authorization at least five days before access and at least 30 days before performing work.

Environmental protections are included through restrictions on protected areas. Underground reservoirs and naturally occurring fluids located beneath protected areas registered under Québec’s Natural Heritage Conservation Act cannot generally be included in pilot projects. However, the Minister may permit certain activities involving these resources after consulting the Minister responsible for sustainable development and environmental protection.

Quebec (17/2026) July 14, 2026
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.