October 20, 2025
The Business Council of Alberta (BCA) is pleased to provide ideas and recommendations to the Government of Canada in response to its “One Project, One Review” draft co-operation approach paper.
BCA is a non-partisan, non-profit policy organization composed of the province’s largest enterprise chief executives and leading entrepreneurs. Our members represent the majority of Alberta’s private sector investment, job creation, exports, and research and development. We are dedicated to building a better and more prosperous Alberta within a strong Canada.
The new federal government’s agenda to build one Canadian economy—the strongest in the G7—is ambitious. Its focus on getting big projects built and attracting capital is a welcome change in direction and tone from recent years. Passing the Building Canada Act and its red tape reduction efforts are steps in the right direction, but much more needs to be done to get Canada back on track. Our organization is committed to assisting the federal government in building upon these early steps.
As part of that commitment, BCA is in the later stages of drafting a major report which includes a comprehensive set of recommendations aimed at creating a single, predictable, and expedient impact assessment review and permitting process for all major projects triggering an Impact Assessment Act (IAA) review. Whereas BCA’s previous work on impact assessment focused on making tweaks to improve existing IAA processes without requiring major legislative changes, this new report will propose structural changes to the Act that can meet the urgency of the new government’s efforts to get big projects built quickly.
Notably, our forthcoming report contains recommendations to promote a major projects assessment and permitting system that truly accomplishes the “one project, one review” ideal. In fact, it takes things a step further by suggesting the attainment of a “one project, one review, one decision” ideal whereby provincial and federal governments would recognize the processes and decisions of the best-placed jurisdiction and regulatory body in charge of a review.
However, doing so will require the federal government to take leadership to acknowledge the stringency of provincial review and permitting processes by automatically deferring reviews to be conducted under those processes when appropriate.
The following recommendations, while best understood within the broader context of our forthcoming report, provide a window into BCA’s thinking about how to best achieve “one project, one review, one decision”:
Ensure a review is conducted by the proper jurisdiction before the IAA process begins
The first and most important step to reduce legislative and regulatory duplication in project reviews is to ensure the most appropriate jurisdiction is responsible for leading those review and decision-making processes. Ideally, a major project will only be reviewed under one jurisdiction’s legal framework, and the resulting decisions will automatically be respected by all jurisdictions involved.
To achieve this goal, we propose that major project reviews be led by the jurisdiction most closely responsible for regulating the full lifecycle of the project/activity. We call this the Responsible Lifecycle Regulator Model (RLRM).
If a project’s lifecycle regulator is a provincial body, and/or if the activity is predominantly regulated at that level, then that province’s project review regime should be responsible for leading the entire review.
In these cases, the federal role in reviewing impacts should be limited to the narrow aspects of a project that require federal decisions (i.e., permitting), or, if requested, federal expertise/advice. The federal government would abide by the processes established in the provincial government’s legislated review framework, including its permitting process and its approach to Crown-Indigenous consultation, and the overarching public interest determination would be left to the provincial decision-maker.
The reverse should also be true. When a project clearly falls under federal review (e.g., projects falling on federal lands, crossing provincial or international borders, etc.), provincial processes should likewise fold into the federal IAA review scheme. Provinces would contribute their expertise where their discrete decisions are needed within a federal process.
Importantly, the determination of which body will lead major project reviews must be made early in the process. Under existing and proposed federal substitution/cooperation agreement mechanisms this decision is made during the IAA’s Planning Phase. We believe it needs to be made before a project enters the IAA process at all.
Recommendations
- Revise the IAA legislation and the Physical Activities Regulations to reflect the RLRM by ensuring the best-placed jurisdiction to regulate an activity’s lifecycle is responsible for leading the entire project review under their own legislation.
Develop a standardized federal-provincial cooperation agreement—and take unilateral federal action:
Under our proposed RLRM, more major projects would fall under provincial review legislation by default. This means that federal support of, and cooperation within, provincial review regimes will be crucial for getting projects built quickly. Likewise, commitments from provincial governments to streamline their involvement within federally led impact assessments will be vital.
Those efforts to streamline, coordinate, and eliminate duplication are best achieved through explicit federal-provincial cooperation agreements. We believe that, in the interests of simplicity and transparency, these agreements should be standardized across the country under a Federal-Provincial Project Assessment Coordination Plan developed by the federal government in consultation with the provinces. That standardized plan should:
- Set out the conditions under which a project is automatically designated as falling under federally- or provincially-led review processes;
- Clarify how each order of government will abide by and support reviews led by the other, including how they conform to the other’s review requirements, timelines, and permitting/Indigenous consultation plans; and
- Make all such determinations based exclusively and objectively on the RLRM approach described above.
Of note, the federal government’s involvement in provincially-led reviews and permitting should only extend as far as when federal expertise or decision-making is required and/or requested by a province for federal aspects of that project.
Provinces should be strongly encouraged to sign on to the proposed Coordination Plan. However, even if they do not, the federal government can still take unilateral action to do its part to avoid review duplication. A cooperation agreement isn’t needed for the federal government to recognize that a project ought to be reviewed solely under a provincially-legislated and led process. And the federal government can take initiative to help speed up provincial processes when its assistance or expertise would help.
We believe this sign of goodwill will inspire provinces to agree to sign, but even if they choose not to, they will still benefit from the federal government’s firm commitment to eliminate duplicative processes.
To be clear, any unilateral action taken by the federal government to reduce duplicative processes must respect and accept provincial jurisdiction over a review. In a sense, they should be unilateral commitments to ensure it is not reviewing projects that ought to be reviewed by a province (according to the RLRM), and that the federal government will help keep a provincial process running at pace when federal expertise or permitting decisions are needed within that province’s legislated review process.
In BCA’s forthcoming IAA report, we propose streamlined federal review and permitting processes that will achieve final decisions within 24 months, which is in line with federal political promises. Since the focus of this report is federal legislation, we will not make recommendations on project review timelines under provincial legislation. However, we do think that every jurisdiction in Canada should aim to meet or improve upon this two-year goal.
Recommendations
The federal government should:
- Draft, in consultation with the provinces, a standardized Federal-Provincial Project Assessment Coordination Plan. This plan would define review cooperation/substitution processes at a high level and support the proposed RLRM, including promises from each jurisdiction to:
- adhere to the legislated requirements of the jurisdiction leading the review, including that regime’s timelines;
- not conduct parallel major project review processes outside the legislated authority of the jurisdiction leading the review;
- accept the decision of the statutory decision-makers of the regime leading the review, including final decisions; and
- abide by, and not frustrate or hinder, the permitting and Indigenous consultation plans of the jurisdiction leading the review.
- Coordinate and make available federal expertise when requested by provincially led review processes, and ensure this federal expertise is fully cooperating according to the timelines and scope determined by the provincial/territorial jurisdiction leading the review and is non-duplicative.
- Provide funding and other needed resources to provincially led reviews to ensure they have the capacity to coordinate and execute reviews that include truly federal aspects that require federal expertise or permitting decisions.
- By request, assist in the development, coordination, and execution of the provincial review regime’s permitting and Indigenous consultation plans.
Of note, BCA’s forthcoming report will include more detail about the role various federal authorities should play in coordinating federal involvement under provincially led review processes.
Remove legislative roadblocks to substitution/cooperation with provinces
For the federal government to recognize the validity and stringency of provincial reviews—and to truly attain the “one project, one review, one decision” ideal—changes to the IAA are needed.
This is true whether our proposed RLRM model is implemented or not. As currently drafted, the IAA creates roadblocks to reaching substitution agreements. The fact that British Columbia is the only non-Indigenous jurisdiction that has been able complete a substituted review after more than half-a-decade of IAAC reviews is evidence of this difficulty.
BCA recognizes that the Substitution to a Harmonized Process, which was added to the Act in 2024 as section 31(b), takes a step in the right direction. This clause adds some flexibility to create a single, shared review process as set out in a cooperation agreement and project-level arrangements, including the ability to conduct an assessment along a province’s own timelines.
However, substitutions under section 31 are still limited by caveats in later sections of the Act. For example, section 33(1) sets out a long list of conditions that another jurisdiction’s review must meet for a substitution to be approved. To meet these conditions, a provincial review has to be of the same stringency and have many of the same decision-making structures as the IAA itself.
And if, as we recommend, the RLRM is adopted and projects are automatically substituted to the appropriate jurisdiction before the IAA process begins, the caveats in s. 33 may still pose a barrier to substitution and any other cooperation agreements established to enact cooperation under the RLRM.
Unless the federal government is willing to take leadership and recognize the legitimacy and sufficiency of existing provincial review processes, the “one project, one review, one decision” ideal will remain out of reach, and proponents will continue to choose to scale back projects to avoid triggering a federal impact assessment in the first place.
Recommendations
- Remove the conditions in the IAA, particularly in s. 33, that make it needlessly difficult to recognize review substitutions with provincial jurisdictions.
Conclusion
Thank you for considering our recommendations as the Agency continues to deliberate on the best ways to reduce regulatory duplication and initiate streamlined reviews. Our forthcoming report, which we will share at our earliest opportunity, will include many more comprehensive recommendations to help advance broader federal government efforts in these areas.
We look forward to continuing to work with you to build a stronger and more competitive Canada and would welcome the opportunity to meet to discuss these priorities further.