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Now 2050
The federal government has set ambitious emissions reduction targets with a goal to be net zero by 2050.
But to meet those targets, Canada will require a massive infrastructure buildout and transformation at a speed
and scale never before seen in Canadian history.
Design Note: Maps to be viewed from an angled perspective, with projects to be "popping up" from map, similar to that of this City of Surrey design.
A design note that the "CO2" icon is representing carbon capture utilization and storage, and should demonstrate CO2 going into the ground and not
being released as emissions as the current icon might suggest.
And with Canada’s regulatory systems as they are today, doing so would be impossible.
One of the biggest problems standing in the way of that effort is that Canada has a growing reputation as a
place where major projects can't get built. Review and permitting processes are slow, expensive, fraught with
uncertainty, and worsening with time.
Unless significant improvements are made to the way we operate, it will be virtually impossible to approve—let
alone build—the projects needed to meet our 2030 & 2050 environmental targets.
However, efficient, predictable, and robust reviews can and must become part of Canada's competitive advantage. Here's how.
If Canada wants to attract the investment needed to meet its emissions reduction targets, advance Indigenous
partnership, and generate economic prosperity for Canadians, broad, systemic changes to Canada’s regulatory
and permitting processes will be required.
Design Note: Visual around financial capital, dollar signs may even be a natural representation.
That means addressing challenges throughout the process that will improve the efficiency and predictability of
existing regulatory systems.
Design Note: I want the design of this section to reflect a flow through process. Arrows are not needed to do that, but I want to
communicate the flow from start to finish.
One challenge in describing the project review system is that no two projects traverse the same path through
Canada's review processes. Regulating agencies at the provincial, territorial, and federal levels have different
project review and permitting processes, and any one project may fall under the oversight of multiple agencies.
While not unanimous, proponents generally proceed through Canada's project review processes having
touched each of the following nine stages.
Conditions
Impact Regulator Decision
Pre-Planning Screening Scoping & Permitting Construction
Studies Review Making
Monitoring
Design Note: This is the most central component of the infographic. I have it represented here by blocks just to show there's 9 in a row,
design however you want, but this should be the centrepiece.
Design Note: I would like each "player" to have it's own representative icon that would be displayed next to the name.
As projects proceed, major players are engaged across the review processes, with
responsibility shifting back and forth between the proponent and regulating agencies
depending on the stage.
While this may all seem straightforward, Canada's new Impact Assessment process, for
example, has only had one project make it to the decision-making phase—but it did so by
substituting the federal process for British Columbia's process. Of all the projects
requiring an Impact Assessment, not one has made it past the Impact Studies stage. This
alone is cause for concern.
Design Note: Might be a good opportunity for a call out box here.
Design Note: Some sort of visual to suggest a halting in the process, like a barrier.
Moreover, the rigour, complexity, and timeline uncertainty of those processes are expanding with time, and the deadline for
our emissions reduction targets are rapidly approaching. Proponents report encountering inefficiencies, a lack of
transparency, and unpredictability when it comes to Canada's project review processes, none of which inspire confidence.
And while the intent of regulatory excellence is to enable projects to get built with the best possible designs, poorly
designed and administered processes can just as easily deter investment as they can enable it.
Design Note: I'd like to see a visual here around the proponent. Perhaps a worker experiencing some of the frustrations detailed here at differing points in a project.
For example, in Canada's Impact Assessment Act (IAA) process, proponents move through five phases:
300 600
Decision
Decision
Cabinet
Minister
IAAC Review
does not factor in the time projects have As the process currently stands, the planning phase is
spent suspended or extended, adding
not operating as intended, and is leading to delayed
hundreds of days to one of the shortest
phases in the review process. timelines, missed construction windows, and lost capital
as a result.
Defining Success
If we want to achieve regulatory excellence, we must first create a model regulatory system that
enables us to meet our environmental targets and becomes part of our competitive advantage.
Design Note: This is the goal of this project, so making this standout would be fantastic.
For Canada to be successful, we must develop a long-term vision for regulatory excellence.
Design Note: Unironically lean into Canadian imagery here, I'm thinking Canadian flag/maple leaf sort of imagery
We need a system that reflects the values of Canadians’—mitigating project risk, while simultaneously seizing the benefits of job
creation and economic development.
Canadians want processes that safeguard key health, economic, cultural, and environmental policy objectives. Therefore, we need
a regulatory system that is:
Impartial —with clear, expert-driven, evidenced-based decision making, free from political influence
Comprehensive —with world class reviews, that identify and mitigate important risks, and reflect Indigenous and community concerns
Trusted—by all, including the public, Indigenous rights-holders, and project proponents
Efficient —to the greatest extent possible in both cost and time; and
Predictable —in length, with simple, understandable processes that follow predictable timelines
Only by making pragmatic and thoughtful changes that result in more predictable, timely, and transparent project review and permitting
processes can we meet our environmental ambitions, and sustainably expand the economy.
Participation challenges address Indigenous and community engagement—and the roles, responsibilities, and requirements for each.
Addressing challenges in these nine areas will not only improve investor confidence in the short term, but will help create the conditions
needed to attract capital to Canada to address our emissions reductions and economic prosperity goals in the long-term. If we want to
improve our regulatory systems, we must first look to address the challenges that exist within them.
Indigenous Engagement
Third-Party Intervenors
Cumulative Issues
Government Coordination
Expanding Requirements
Interjurisdictional Tensions
Political Uncertainty
Construction Windows
1 Indigenous Engagement Expectations around Indigenous engagement are unclear, and capacity improvements are needed
3 Cumulative Issues Governments and regulators have difficulty seeing how small issues add up to affect overall processes
5 Expanding Requirements Review and compliance requirements are expanding and not always in scope
6 Interjurisdictional Tensions Interjurisdictional tensions and overlapping processes are impeding project reviews and construction
7 Length of Review Timelines Project review timelines are long, expanding, and not proportional to project risk
8 Political Uncertainty Political and policy preferences are creating uncertain processes
Time is of the essence if we are to build the projects needed in time to meet Canada’s environmental targets. That is why, in the short-
term, Canada should focus on addressing the following four areas to make an immediate impact:
IAA DESIGNATION CRITERA SHORTEN AND SCALE REVIEW TIMELINES
Publish the criteria used by Ministers to Shorten existing review timelines and scale them
designate projects under the IAA according to project complexity
But at the same time, short-term solutions within existing project review frameworks need to be in service of a broader goal—creating a
model regulatory system in Canada that becomes part of our competitive advantage.
With thanks to the Business Council of British Columbia, the Canada West Foundation, and members of the Task Force on
Major Project Development and Regulatory Excellence for their many contributions.