The Privy Council Office

Government of Canada

Submitted electronically to: engagement@pco-bcp.gc.ca

Response to ‘Getting Major Projects Built in Canada - Discussion Paper on Proposed

Legislative, Regulatory, and Policy Reforms’ (July 22, 2026)

Dear Privy Council Office,

We are writing as early-career researchers affiliated with the Blue Carbon Canada (BCC) program, where we conduct research on the role of coastal and marine ecosystems in supporting Canada’s climate action, biodiversity conservation, and sustainable development goals. We have reviewed the Government of Canada’s discussion paper Getting Major Projects Built in Canada, and are deeply concerned about the implications of several proposed legislative and regulatory changes.

We recognize that Canada faces significant challenges related to its economic competitiveness, trade, energy security, and transition to a lower carbon economy. Improving coordination and reducing unnecessary inefficiencies in project review processes are worthwhile goals, especially in pursuit of a clean energy transition. However, accelerating major project approvals should not come at the expense of the critical environmental safeguards, scientific review processes, and public engagement mechanisms that protect our ecosystems and communities.

In particular, we are deeply concerned by the proposals to:

●      Compress timelines for environmental review and consultations with Indigenous Peoples;

●      Exempt certain major projects from impact assessment requirements;  

●      Allow project approvals and construction activities to proceed before environmental and safety reviews are complete;

●      Expand reliance on habitat offsetting as compensation for avoidable environmental impacts;

●      Create exemptions that would significantly weaken protections for species at risk.

Together, these proposed reforms risk undermining the scientific rigor, transparency, and accountability that environmental review processes are intended to provide. Impact assessments are not administrative hurdles. They are essential tools for identifying environmental and societal risks, evaluating cumulative impacts, assessing long-term trade-offs, and ensuring that projects proceed in a manner that minimizes potential harms. Weakening or bypassing these processes drastically increases the likelihood that such harms will be overlooked or inadequately addressed.

Canada must uphold its commitments to nature

We support the government’s vision of Canada as a domestic and international leader in protecting, restoring, and valuing nature as set out in A Force of Nature: Canada's Strategy to Protect Nature 2026 (hereafter Nature Strategy) [1]. The Nature Strategy frames conservation and economic development as complementary and not competing priorities. Yet the proposed reforms laid out in the major projects' discussion paper seem to directly contradict this framing, eliminating key elements of the environmental impact review process that would make sustainable development possible.

Central to the Nature Strategy is the mitigation hierarchy, which states that development should first avoid impacts, then minimize or mitigate them, and only offset what remains through protection or restoration elsewhere. However, the increased flexibility for habitat offsetting outlined in the proposal would invert this hierarchy, elevating offsetting from a last resort to a higher priority instrument. This is not only inconsistent with best practices outlined by biodiversity conservation science, but also with the government's own stated commitments.

The Nature Strategy also outlines measures to streamline permitting by mapping nature, identifying key biodiversity areas, and using regulatory input to improve project design to avoid and minimize environmental impacts. But the proposed reforms could allow development to proceed without a clear understanding of risks to biodiversity, and without the scientific input that project design depends on.

Furthermore, the Nature Strategy pledges to strengthen protection and recovery of species-at-risk, the number of which has increased by 188% since 2003. Yet the conditions for proposed exemptions to the species-at-risk jeopardy test are so ambiguously defined that they could be far too broadly applied, putting these species at further risk. This sets out a dangerous precedent at a time when many species at risk are already facing rapidly intensifying climate change impacts and other sources of disturbance.

In light of these concerns, we strongly urge the government to uphold the values and goals of the Nature Strategy by continuing to follow the mitigation hierarchy, maintaining transparent and thorough environmental impact assessments, and upholding strong protections for species-at-risk.

Canada must follow through on its climate change goals

As researchers working on the science to support natural climate solutions in Canada, we are particularly concerned about how the proposed reforms would impact Canada’s ability to meet its own climate commitments.  Like other parties to the Paris Climate Accord and subsequent agreements, Canada has committed to drastically reducing its emissions and enhancing carbon uptake through both technological and nature-based solutions. Yet many of the >15 major projects under consideration [2] —including pipelines, transmission corridors, offshore energy terminals, and associated infrastructure—have the potential to directly or indirectly impact forests, grasslands, wetlands, and other coastal habitats that currently function as valuable long-term carbon sinks. Much of the carbon stored in these ecosystems has been accumulating for over centuries to millennia, and once lost, will not be recoverable within the time we have left to fight the climate crisis. Through our own work within BCC, we have found that coastal ‘blue carbon’ ecosystems—including seabed sediments, tidal marshes, and seagrass meadows nationally hold >10 Gt of carbon, the majority of which is considered under- or unprotected by current spatial protections [3, 4, 5]. These ecosystems are therefore directly exposed to the types of coastal and nearshore development being proposed.

Without a rigorous environmental review process, the full impacts of these projects on Canada’s natural carbon stores and long-term climate mitigation capacity cannot be adequately identified or considered.

Compressing assessment timelines further increase the likelihood that these impacts are overlooked. At a time when Canada should be rapidly scaling its renewable energy sector and reducing its greenhouse gas emissions from industries and natural ecosystems, development decisions must be informed by a full accounting of their impacts on both built and natural assets.

Canada must honor its international agreements

Importantly, the proposed reforms place Canada’s domestic policy direction in conflict with its own stated leadership on international biodiversity, climate, and sustainable development commitments. Canada has positioned itself as a leader in biodiversity conservation through its role in securing the Kunming-Montréal Global Biodiversity Framework [1], in ocean-based climate action by signing onto the Blue NDC Challenge [6], and in long-term decarbonization through the Canadian Net-Zero Emissions Accountability Act [7] and its updated industrial carbon pricing trajectory [8]. Through the United Nations 2030 Agenda for Sustainable Development, Canada has also committed to advancing a shared global framework for a more sustainable, equitable, and resilient future. Canada’s own 2023 Voluntary National Review of the Sustainable Development Goals identified climate action, partnerships, transparency, accountability, and policy coherence as essential to advancing this agenda, and recognized resilient ecosystems as central to carbon storage, emissions reductions, and climate adaptation [8]. Weakening environmental assessment and regulatory safeguards would directly undermine these priorities by reducing the evidence and accountability needed to ensure major projects align with SDG 13 (climate action), SDG 14 (life below water), SDG 15 (life on land), and SDG 16 (strong institutions).

Further, the case for these reforms has been framed almost entirely in economic terms without considering the cost of ignoring Canada’s immense natural capital.  Canada’s own ecosystem accounts show that ocean and coastal ecosystems already provide measurable economic value, with carbon sequestration, wild fish and seafood, and nature-based tourism alone contributing at least $7.1 billion in 2023 alone [9]—just a fraction of the services these ecosystems provide. Fast-tracking major projects by weakening environmental safeguards therefore would risk more than environmental harm; it undervalues the natural capital that already supports communities and regional economies.

We urge Canada’s government to not trade away the long-term resilience of our diverse ecosystems, and the services and values Canadians derive from them, for short-term project approval timelines.

Canada must follow through on its reconciliation commitments

Finally, despite all being settlers or visitors on Indigenous lands, we believe reconciliation is the work of all peoples who call Canada home. We are therefore deeply concerned that compressed review and decision-making timelines will weaken opportunities for meaningful consultation and engagement with Indigenous rightsholders. In Canada, Indigenous groups and communities have been disproportionately impacted by extractive and natural resources development for generations, while being systematically excluded from decisions affecting their inherent rights. The Government of Canada’s endorsement of the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) [10] and the following Royal Assent of the United Nations Declaration on the Rights of Indigenous Peoples Act (UNDA) [11] represent important steps towards reconciliation and cooperative, fair democracy in Canada. We generally support some of the intentions put forward in the discussion paper around engaging with Indigenous communities in a meaningful way, early in the review process, and addressing issues with consultation fatigue. However, despite these good intentions, we believe some of the proposals have the potential to undermine Canada’s commitments under UNDA.

Canada has a constitutional duty to consult Indigenous Peoples when considering measures that might adversely impact their potential or established Aboriginal or treaty rights. The UNDA Action Plan 2023-2028 [12] states that Indigenous peoples must have the opportunity “to participate in and to positively influence federal decision-making processes with adequate time and supported by adequate resources”. A one-year deadline for all reviews and decisions is incompatible with this standard and risks rushed, inadequate consultation that deepens consultation fatigue among Indigenous Peoples. The UNDA Action Plan further commits Canada to developing guidance on engaging with Indigenous peoples on natural resource projects consistent with Article 32(2) of UNDRIP, which calls for free, prior and informed consent, prior to the approval of any project affecting their lands or territories. The government's proposal directly contradicts UNDRIP by allowing project approval and construction to commence before environmental and safety reviews are complete. This implies that construction could begin before Indigenous communities are properly consulted as a part of the review process, continuing Canada’s shameful legacy of excluding Indigenous Peoples from decisions impacting their rights, lands and waters.

We strongly urge the Government of Canada not to set aside years of progress towards its reconciliation commitments. Beyond being ethically wrong, doing so is likely to lead to further legal challenges, distrust, and delays that these reforms purport to avoid.

Conclusion

As Canada seeks to reduce its greenhouse gas emissions and maintain its position as an environmental leader, it is essential that we maintain robust environmental policies and evidence-based regulatory frameworks to ensure that major projects proceed in a manner consistent with long-term climate, biodiversity, and sustainability goals. We respectfully urge the Government of Canada to not weaken the critically needed environmental safeguards we have in pursuit of short-term economic gains. Canada can support responsible economic development and the clean energy transition without compromising the scientific and legal safeguards that protect our ecosystems and communities.

Thank you for your time and consideration.

Sincerely,

Dr. Jennifer McHenry - Senior Postdoctoral Fellow, Department of Biology, University of Victoria

Dr. Kylor Kerns – Postdoctoral Fellow, Department of Forestry and Conservation Sciences, University of British Columbia

Matthew Csordas – PhD Candidate, Department of Biology, University of Victoria

Madeleine Fry – MSc Student, Department of Forestry and Conservation Sciences, University of British Columbia

Bryce O’Brien – PhD Student, Department of Biology, University of Victoria

Dr. Miao Li – Postdoctoral Fellow, Department of Biology, University of Victoria

Vanessa Valenti – Research Technician, Department of Zoology & Biodiversity Research Centre, University of British Columbia