Letters July 22, 2026

Restoring Canada’s economic health and reputation as a reliable trading nation

Goldy Hyder – President and Chief Executive Officer, Business Council of Canada

Canada’s Place in the World Economic Strategy Industry and innovation International Trade Resources and the Environment

Letter to the Hon. Dominic LeBlanc, P.C., M.P., President of the King’s Privy Council for Canada, Minister responsible for Canada-U.S. Trade, Intergovernmental Affairs and One Canadian Economy, Minister of Internal Trade, the Hon. Steven MacKinnon, P.C., M.P., Minister of Transport and the Hon. Patty Hajdu, P.C., M.P., Minister of Jobs and Families (Minister).

RE: Policy reform to unlock investment and unleash Canada’s economic potential

Dear Ministers,

The Business Council of Canada (BCC) welcomes the opportunity to provide input as part of the Government of Canada’s consultations on major project approvals, trade and transportation systems and labour relations.

We support the government’s proposed reforms to establish clearer timelines for project decision-making, streamline and improve coordination across federal entities, strengthen the infrastructure and supply chains that connect Canadian production to global markets, and modernize labour frameworks to enhance reliability and resiliency.

The three concurrent consultations work toward a common objective – strengthening Canada’s economy. We don’t see these consultations as separate exercises.

For that reason, rather than responding to each consultation separately, the BCC has deliberately chosen to provide a single submission. We believe these initiatives are best understood as interconnected components of a broader effort to strengthen Canada’s economic capacity and ability to reliably supply commodities critical to the security of its allies and partners.

The BCC believes the government’s reforms should continue to be advanced as a coherent package. Their collective impact will be greater than the sum of their individual parts, and their success will ultimately depend on maintaining that integrated approach through implementation.

The reforms you are proposing will benefit all Canadians through better jobs, higher incomes and greater economic stability. Taken together, they can supercharge the exceptional work done by the government to date to build a stronger and more resilient Canada.

The Economic Imperative

The Prime Minister’s ambition to build the fastest economy in the G7, grow investment by $1 trillion over five years and double our non-U.S. exports over a decade are important goals which we share. However, the challenges can’t be understated.

Canada’s economy is under siege and its capacity to offset external shocks is constrained. A failure to invest in major projects and export infrastructure will leave the country vulnerable and poorly equipped to navigate geopolitical and global economic risk.

An overdependence on one trading partner, complex tax and regulatory systems and ineffective government innovation incentives have held back investment and business dynamism in Canada for years. As a result, businesses are investing too little in machinery, technology, and export-enabling infrastructure. Canadian investment per worker levels are among the lowest in the OECD; on a percentage of GDP basis, Canada invests 6.6 per cent – roughly a full percentage point lower – in infrastructure and strategic sectors compared to peer countries[1]^,[2].

Inefficient project approval regimes and years of underinvestment in trade-enabling infrastructure also mean that the country’s export capacity is being pushed to the max. In addition, Canada’s reputation as a reliable trading partner has been challenged due to recurring labour disputes at ports, railways and airlines. From 2022 to 2025, Canada experienced an alarming 54 work stoppages in federally regulated sectors involving more than 260,000 workers[3].

Our inability to move our goods to customers limits growth, suppresses pricing for Canadian products and constrains the country’s ability to compete in global markets despite its abundant natural resources and agricultural strengths.

Canada is well placed to build a more resilient economy for future generations. However, the potential for long-term negative ramifications is real if Canada does not act now with speed and urgency.

Simplifying Federal Processes for Major Projects

The BCC endorses the government’s plan to permanently accelerate the federal assessment and permitting processes for major nation-building infrastructure. Improvements to streamline timelines will accelerate investments in new projects and at existing facilities and properties.

We support:

Ensuring that federal reviews and final decision-making timelines take no more than one year once a proponent’s information is complete.
Building a “One-Project, One-Review, One-Decision” architecture to eliminate intra- and inter-governmental duplication.
Establishing a centralized Crown Consultation Hub to manage a single, coordinated Indigenous consultation process focused on federal effects and on fulfilling the Crown’s obligations under Section 35 of the Constitution Act.
Assigning project oversight directly to the Canadian Energy Regulator and the Canadian Nuclear Safety Commission for intraprovincial pipeline and nuclear projects.

The success of the reforms depends on two important and interconnected factors.

First, a revised assessment process will require a substantive shift in how project proponents and regulators work together. Information and consultation requirements will need to be tightly scoped and focused on clear federal jurisdiction and in areas where there is the real potential for significant environmental effects. Regulators will need to be empowered to narrow the scope of assessments so that they can be completed within one year.

Canada’s industrial community has extensive experience with developing major projects with some of the highest environmental standards in the world and in cooperation with numerous Indigenous communities. The BCC believes that regulators can leverage this experience to approve projects within one year without compromising Canada’s reputation as a responsible producer of energy and resources.

Second, the effectiveness of any reforms will depend on federal-provincial/territorial cooperation. While cooperation agreements with several provinces are now in place, reducing regulatory duplication will require a renewed spirit of cooperative federalism, especially for projects spanning more than one province or territory.

To ensure the reform agenda delivers meaningful outcomes, we encourage the government to focus on the following:

Make timelines real and enforceable

The proposed one-year timeline is an important step forward. But the government needs to ensure those timelines are meaningful, and that reviews are focused on matters of federal jurisdiction.

Over the one-year review period, progress at each stage should be transparent and available to the public. Equally important is the question of accountability when timelines are not met.

The proposed Federal Review Coordinators should have the authority to enforce timelines and resolve interdepartmental issues when necessary. We recommend the creation of binding service standards, including deadlines, for departments and permitting authorities. This will help ensure government-wide accountability and help ease bottlenecks caused by interdepartmental delays.

Relevant departments and agencies must have clear government direction that their mandates are to deliver project outcomes without compromising environmental credentials.

A stronger dialogue between governments and the private sector is also needed to ensure that what proponents are required to produce pre-decision is reasonable and aligns with what regulators require to reach a decision within one year.

Make the Crown Consultation Hub resilient to judicial review

One of the most complex challenges facing Canada is balancing constitutional obligations with major economic development objectives. Historically, proponents are obliged to meet different federal requirements through multiple consultations with affected Indigenous communities for the same project, often stalling progress, increasing costs and creating consultation fatigue. The creation of a centralized one crown consultation process or “Crown Hub” can help fix this structural weakness.

The BCC supports the initiative. However, the framework must be designed in a manner that is resilient to judicial review and focused on federal jurisdiction. To make it more resilient, the framework should clearly identify relevant rights holders and affected communities, in concert with the Crown’s Section 35 obligations.

Additional guidance will also be necessary to improve clarity on roles, timelines and accountability for both proponents and Indigenous communities. Importantly, the Crown Hub will need to be properly empowered and resourced to ensure confidence from Indigenous communities, the public and investors alike.

Reduce the number of projects requiring federal approval

Canada has historically over-scoped the types of projects that require federal approval and permitting. We offer three recommendations.

First, the BCC recognizes that considerable efforts have been made by the federal government and the Impact Assessment Agency of Canada (IAAC) to pare back the number of projects it reviews and to create cooperation agreements with provinces so that they have more scope to regulate within their jurisdiction. While Quebec and Saskatchewan remain outliers currently, we encourage the government to advance its efforts to create cooperation agreements in these provinces.

Second, the government should raise production-based thresholds to ensure that projects with potentially material impacts to the environment require federal assessment and approval. The government should amend the Physical Activities Regulations to reduce the number and types of projects subject to federal approval and/or permitting, and to ensure that provinces play the primary role in regulating projects within their jurisdictions.

Third, the BCC believes that Canada can strengthen its economy in the near term by unlocking the full potential of projects situated at existing industrial locations or brownfield sites. Approval processes should be streamlined for projects occurring in locations where a proponent has already received an environmental certificate or is the owner of an existing asset, right of way or corridor. There are meaningful differences in environmental and social impact between brownfield and greenfield projects that should be recognized by Canada’s approval and permitting systems.

Streamlining efforts should be made across approval systems, outside of the Impact Assessment Act and where there is clear exclusive federal jurisdiction, such as railway projects subject to approval under the Canada Transportation Act.

The proposal to create Federal Economic Zones can be helpful on this front. It can be used to confirm areas with preexisting industrial activity and environmental approvals that can expand in concert with the economic demands of the area, while balancing important environmental and socio-economic considerations. A strong and transparent approach to define these zones will need to include meaningful engagement with Indigenous communities, industry and relevant stakeholders.

Leverage federal expertise

The Business Council supports the government’s intentions to address all federal approval and permitting requirements in a single decision document. It holds the potential to create a more efficient decision-making process that fosters interdepartmental collaboration and innovation in regulatory execution.

Legislation should include clear criteria that make explicit when and how Ministerial and/or Governor in Council powers can be exercised for setting conditions or fast-tracking approvals. This should include transparent rules for when the Minister can refer a determination to the Governor in Council.

We also welcome the proposal to assign relevant projects to the Canada Energy Regulator and the Canadian Nuclear Safety Commission. Both regulators offer world-class expertise and a proven track record of regulating projects successfully and in compliance with Canadian law and constitutional requirements.

Trade and Transportation

As a trade-dependent country, Canada must invest in infrastructure that improves its ability to move goods and resources to global markets. Efficient transportation networks are essential to maintaining Canada’s competitiveness as a major exporter.

Diversifying Canada’s export base at scale requires multiyear capital investments by the public and private sectors in infrastructure. As an example, increasing Canada’s trade volumes by 10 per cent would require an additional 650 million tonnes of goods to be moved through the system, which is roughly four times more than what transits through the Port of Vancouver in a year. The scale of investment required is significant.

As noted in the government’s discussion paper, Canada’s transportation system has been slipping in global performance for years. Investment in infrastructure lags in comparison to OECD peer countries including Australia, Spain, the Czech Republic and Sweden.

The BCC endorses the government’s plan to enhance investment and modernize transportation-sector legislation and regulations.

We support:

Efforts to advance alternative ownership models of Canadian transportation and logistics assets including in airports, ports and other public assets.
Eliminating persistent regulatory bottlenecks and administrative burdens that slow down gateways and corridors.
Materially improving government-to-government planning processes and investment opportunities in supply chains across Canada.
Improving multi-modal logistics coordination to move goods to international markets faster and cheaper.
Enhancing port governance and modernizing their ability to generate revenues and invest.
Fostering critical investments through the National Trade Corridors and Arctic Infrastructure Funds; and
Adding supply chain efficiency language into the Canada Transportation Act to ensure that future policy decisions focus on enhancing supply chains rather than focus narrowly on specific modes of transportation.

To ensure this reform agenda delivers meaningful outcomes, we encourage the government to focus on several design considerations.

Use economic returns to guide infrastructure decisions

We encourage the government to be disciplined in the execution of its programs and to ensure that its investment decisions are driven by a project’s ability to generate future revenue streams and enhance productivity.

Advance alternative ownership models

To enhance efforts to bolster governance and investment in export infrastructure, the BCC encourages the government to assess alternative models of ownership of port assets, much like what it has announced for airports in the Spring Economic Update.

Canadian pension plans and other institutional investors are fully prepared to invest in these assets but are discouraged from doing so by lengthy and often duplicative regulatory processes, short concession terms, and an aversion to user-pay systems, among other impediments. This represents a missed opportunity for Canada. In countries such as India, Brazil, Australia and the United States, institutional investors are deploying billions of dollars to finance projects such as power transmission lines, desalination plants, railway systems and highways.

Federal Labour Policy

The right to collective bargaining is foundational to Canadian labour relations, and the BCC unequivocally respects it. The vast majority of collective agreements in the federal sector are settled through voluntary negotiations — a testament to the ability of employers and workers to negotiate in good faith and reach outcomes that work for both sides. The best collective agreements are those voluntarily negotiated between employers and unions at the bargaining table, and the BCC firmly believes in the primacy of that process.

However, the right to strike — while constitutionally protected under section 2(d) of the Canadian Charter of Rights and Freedoms — is not absolute. Section 1 of the Charter expressly permits reasonable limits on Charter rights where the government can demonstrate that such limits are “justified in a free and democratic society.” What the current framework lacks is adequate tools to protect against economic harm to the national interest when collective bargaining fails in critical sectors. The country needs modern labour frameworks that prevent disputes from paralyzing Canada’s economy and undermining its credibility as a reliable trading partner.

Reviewing the Canada Labour Code is a pragmatic and timely response to recent destabilizing supply chain stoppages. Structural predictability in labour relations is critical to the government’s stated objectives of strengthening supply chains, attracting investment, and building trade-enabling infrastructure. When collective bargaining fails in supply chain-critical sectors, the federal government must be equipped to protect the national interest and economic security — not by eliminating the right to strike, but by strengthening the structured process that precedes it.

We support:

Strengthening direct bargaining, conciliation, and cooling-off processes to ensure that negotiations are conducted efficiently and in good faith, that maximize opportunities for settlement before economic pressure is applied.
Extending the 72-hour strike/lockout notice periods for activities critical to Canada’s economy and the supply chains that serve it — recognizing that in sectors like rail, ports and air, the current notice period represents only the minimum time required to safely wind down complex, continuous operations for transporting goods and people.
Creating a new “Special Mediator” role to intervene and facilitate resolution in cases where parties are deadlocked and the national interest is at stake, including the ability to assess the issues in dispute, provide informed recommendations, and submit a transparent public report to the Minister on the status of negotiations and potential outcomes. During this period, the right to strike is suspended.
Creating new statutory authority for the Governor in Council to compel binding arbitration in limited instances where collective bargaining has been attempted and exhausted, including the Special Mediator step, and in circumstances where a strike or lockout will significantly harm the national interest — consistent with section 1 of the Charter, which permits proportionate limits on Charter rights to safeguard compelling public objectives.
Enhancing training frameworks for workers facing displacement from automation and AI, and resolving labour mobility and standards harmonization across jurisdictions.
Eliminating the ability ofgovernment-mandated paid medical leave to be stacked on top of similar pre-existing paid leave entitlement.

Disruptions across Canada’s supply chains have outsized and cascading impacts on the national economy and Canada’s standing as a trading nation. The 2024 simultaneous railway work stoppages at CN and CPKC paralyzed the country’s supply chain networks and created an economic shock that lowered annualized GDP by 0.4 per cent in the span of just one week[4]. When ports, rail, and airlines shut down, farmers cannot move grain, miners cannot ship potash, manufacturers lack critical inputs, and retailers face inventory shortages. Employers across the economy are forced to curtail operations and, in many cases, furlough employees who bear no part in the underlying dispute.

The BCC strongly urges the government to act on the recommendation of the Industrial Inquiry Commission on West Coast Ports to create geographical certification. As currently structured, the two voluntary coast-wide negotiation structures could collapse. This fragmented bargaining structure increases the likelihood of labour instability at B.C.’s ports at a time when Canada is seized with diversifying its trading relationships in the Asia Pacific.

When negotiations fail and supply chain paralysis sets in, Canada loses — economically, reputationally, and strategically. The right to strike, while constitutionally protected, does not confer an unlimited license to hold the national economy hostage. In this regard, we fully support the creation of new powers that will allow Cabinet to refer unresolved disputes to arbitration in limited cases where all reasonable avenues for settlement have been exhausted and the harm to the national interest is demonstrable.

Such measures are consistent with the Charter’s framework for proportionate limits on fundamental rights.

Conclusion

Protecting and expanding Canada’s economic reach through exports and new trading partners is more than an economic imperative. It is essential for sovereign resilience and strategic capacity.

Canadian oil, natural gas, critical minerals, agricultural products and other commodities are highly sought after worldwide. The challenge is not global demand. Rather, the constraint is capacity. Canada’s potential to produce, process, move and transport its resources competitively to diverse markets has been held back by stagnant investment conditions, regulatory malaise and underperforming supply chains. The question now is whether we can deliver. The BCC thinks Canada can.

Real, demonstrable policy change is urgently required to overcome structural challenges and to unleash Canada’s full economic potential.

We applaud the government for taking action to introduce policies to position Canada as a competitive investment market capable of unleashing economic opportunity. The proposed reforms should move forward as a coherent package designed to overcome the structural challenges that continue to hold back Canada’s potential and threaten its economic security.

Now we urge it to move quickly to introduce legislation as soon as possible to restore Canada’s economic health and reputation as a reliable trading nation.

The BCC and its members stand ready to work with the government to achieve its stated goals concerning economic growth and trade diversification.

Yours very truly