SUBMISSION: Bill C-69 Impact Assessment Act and Related Discussion Papers

The Business Council has significant concerns with Bill-69 - Impact Assessment Act and with some parts of the two related discussion papers.

Overall, we are concerned that the proposed changes to environmental assessment, the Navigation Protection Act, the National Energy Board and the Fisheries Act will lead to longer and more complex reviews of new projects; greater difficulty securing permits and authorizations for existing facilities and operations; and heightened uncertainty among company managers, project developers, and investors. In our judgement, these legislative and regulatory reforms are more likely to aggravate than to ameliorate Canada’s waning competitiveness and are likely to accelerate outflows of business investment to other jurisdictions.

At a time when productive capital is fleeing the country, the federal government is following a path that will make it harder and more expensive to invest and do business in Canada – particularly in many of our leading export industries. This does not mean we should abandon the goal of continuous environmental improvement. But the process for advancing this goal needs to be measured, deliberate, and incremental. Canada is not in the middle of a “made-in-Canada environmental crisis,” as some activist groups would have us believe. This kind of unwarranted crisis talk, particularly when it is not countered by government leaders, leaves many citizens bewildered and investors discouraged about the prospects for future industrial development in Canada.

With this context, the Business Council submission provides comments on several issues raised in the government’s draft legislation, discussion papers, and technical guidance documents.