Thank you, Mr. Chair.
My name is Dennis Darby. I'm the president and CEO of CME, the national voice of about 1.85 million workers, for about $210 billion in real GDP every year, and the sector that has built this country's prosperity.
For many years, manufacturers have watched Canada fall behind its peers in terms of capital investment in plants, technology and automation, which has been called a productivity crisis by no less than the deputy governor of the Bank of Canada. Over the last decades, we've seen projects stalled; private investment, large infrastructure and processing projects leaving; and timelines stretched.
The fragility of our industrial sector, which we represent, was acutely demonstrated with the imposition of unjustified tariffs by the U.S., shining a light on our dependence but also on our lack of domestic capacity to capitalize on our store of resources from transportation to processing.
We want to be very clear. We are cautiously optimistic about Bill C-39. The government is proposing to do what we've been advocating for over decades, which is to build faster with greater certainty. It's a necessary effort to improve our competitiveness. We've called for faster, more predictable and more coordinated project approvals for years. As federal project assessment and permitting regimes have become more complex in the last decade, we have to act.
The government has faced mounting criticism of duplication and a lack of coordination across federal entities. Following the lead of the Building Canada Act, Bill C-39 proposes to consolidate federal decision-making by reducing the number of departments and agencies involved in decisions and establishing a mechanism for consolidating those decisions into a single document. The proposed one-year timeline for key federal decisions is particularly important, because investment decisions depend not only on regulatory standards, but also on certainty, predictability and speed. Our understanding is that Bill C-39 would cut many of the IAAC's evaluation timelines in half to achieve that 365-day target from end to end. This is a substantial improvement, and manufacturers support it.
Provisions supporting electricity transmission, nuclear development and energy infrastructure are critical for industrial growth and expansion. Access to reliable, affordable energy is critical for manufacturing. Very little new industrial capacity to mine, process or manufacture can happen without that reliable source of energy.
The bill recognizes that infrastructure, energy systems, transportation corridors and industrial supply chains are essential.
The digital trade provisions are important for modernization to help reduce administrative burdens and improve efficiency. Many manufacturers are managing complex cross-border supply chains. If you can reduce friction, it will help.
However, our optimism is somewhat measured, and I'll tell you why.
We have seen good legislation underperform before. Manufacturers remember it. The success of this legislation will depend on its implementation. Timelines written into the legislation will matter only if federal departments and regulators have the staffing, the resources, the coordination mechanisms and the decision-making discipline required to meet them. It's not a small ask. Multiple federal entities do not suddenly start coordinating because a bill passes. This is not to mention the coordination that will be needed at the provincial level. Manufacturers will be looking to ensure the accelerated timelines translate into real-world reductions in approval delays with no additional procedural complexity.
Our biggest concerns are what we call the completeness question when it comes to major project reviews and how government defines when a project is considered complete. There is a risk that significant amounts of work could be pushed earlier into the process, resulting in a shorter form of review but not necessarily a shorter timeline. For example, if the one-year clock starts only after years of front-end preparation, we're not that much further ahead.
Bill C-39 proposes to expand the scope of the Building Canada Act to enable the designation of regions of national interest. Our understanding is that this would include transportation and energy corridors, telecommunications networks and industrial regions. This is exactly the kind of strategic thinking we think we need to grow our economy, especially in the current environment. However, we want to see a credible and detailed plan on how this will actually deliver.
There is one more thing the committee should hear from us on this, and we want to say it clearly. Nobody wants to be tied up in court because of the actions of this bill. Litigation does not build pipelines or move goods. It delays everything for everyone, and getting the information will be important.
Of course, we support meaningful indigenous consultation and partnership, but continued uncertainty or duplication in the consultation process could still undermine project timelines and investor confidence.
We know indigenous consultation is guaranteed under the law. In the same way, the ability of the government to intervene to protect Canada's national interest on work stoppage also needs to be looked at very carefully, with a minimum amount of possibility that, in fact, we inadvertently end up delaying projects for reasons we don't need.
Get the consultation right. Get the labour framework right. Please don't give reasons for organizations to go to the courts, because that would be a terrible outcome.
This is a positive and important shift toward a more execution-focused industrial policy framework. We are very much encouraged by the government's recognition that Canada must build faster to compete. We're ready to help, and we look forward to moving this ahead.
