Efficiency without environmental security

The proposed co-operation agreement is designed to streamline impact assessments under a “one project, one review” model. Improved efficiency is a worthwhile goal, however the current framework risks prioritizing speed over environmental protection.

By allowing federal reliance on provincial processes, the agreement introduces a real risk: that national environmental standards, particularly around cumulative impacts, water systems, and biodiversity, may be inconsistently applied or weakened. Federal oversight exists to safeguard issues that extend beyond provincial boundaries. It should not be optional.

Critical Gaps in the Current Approach

- This agreement proposes no meaningful consideration of cumulative effects. Project-by-project assessments fail to capture the broader reality: multiple approvals can collectively degrade watersheds, ecosystems, and biodiversity.

- Water security is not treated as a limiting factor. Despite growing drought conditions and competing demands, the agreement does not explicitly address water scarcity. Approving projects without climate-adjusted water modelling is no longer defensible.

- Fixed timelines (~2 years) can constrain proper data collection, especially for seasonal or long-term environmental processes. Incomplete baselines lead to uncertain outcomes, and permanent consequences.

- Efficiency must be paired with clear environmental thresholds. Without them, success risks being measured by speed rather than sustainability.

- Indigenous participation remains procedural. Consultation alone is insufficient. Equitable decisions require meaningful inclusion of Indigenous governments in decision-making, not just engagement.

What is Needed

To align with modern environmental expectations and global commitments, including the United Nations Sustainable Development Goals, the agreement should include:

- Non-delegable federal safeguards for water, biodiversity, and transboundary impacts.

- Mandatory cumulative and regional assessments in high-impact areas

- Climate and water stress testing as approval prerequisites

- Flexible timelines tied to environmental complexity, not fixed targets

- Indigenous co-governance mechanisms, not just consultation

- Outcome-based accountability, including measurable environmental performance indicators

A streamlined process that does not fully account for cumulative impacts, water scarcity, and climate risk is not truly efficient, it defers costs into the future. This agreement is an opportunity to modernize impact assessment in Canada. With targeted improvements, it can deliver both timely decisions and durable environmental protection. Without them, it risks falling short on both.

Prepared with AI-assisted drafting; reviewed and finalized by the author.