Mr. Chair and members of the committee, thank you for the opportunity to appear before you.
I am John Gamble, president and CEO of the Association of Consulting Engineering Companies of Canada. Our 400-plus members assess, plan, design and deliver projects Canadians depend on, from water and transportation to energy and resource development.
My testimony today will concern the project assessment and approval provisions, which we broadly support. ACEC takes no position on the Canada Labour Code provisions of Bill C-39.
Across successive governments, ACEC has advocated for timely, coordinated and transparent regulatory decisions. We believe the bill offers an opportunity to advance that objective. Canada does not just need to build faster; we need to decide faster.
While a regulatory process should not guarantee an approval or outcome, it should provide clear requirements, transparent decisions and confidence in rigorous assessment within a credible time frame. That allows investors, proponents and communities to make informed decisions.
Canada has strategic resources, skilled people and opportunities to strengthen our economy while supporting a global transition to lower emissions. A resource is not a project, and a project does not proceed simply because we call it strategic. It must also be investable. Capital has choices. If proponents cannot assess a project's time, cost and requirements here, opportunities can move elsewhere.
Canada has a world-class consulting engineering industry that implements major projects nationally and internationally. Creating the opportunities to invest here will unlock even more opportunities right here at home. We can start by recognizing that individual projects are often part of a larger infrastructure ecosystem. The bill correctly recognizes this.
The “regions of national interest” offer an opportunity to plan related infrastructure and projects together at a regional scale. Planning at this scale can identify shared infrastructure needs, cumulative impacts and development requirements earlier, supporting investment and coordinated approvals for related projects.
ACEC has long advocated for a national infrastructure corridor, a network of strategically planned multi-use rights-of-way, paired with predictable planning. This is similar to the proposed trade corridors. These should also reflect the same multi-use approach and extend beyond transportation alone.
Even as Canada faces urgent challenges, more efficient approvals must come with a clear commitment to public protection. Risk-based regional assessments can consider related projects together, identify common risks, establish appropriate conditions up front, and let proponents and agencies focus resources on material risks associated with each project's nature and location.
Our professional engineers are accountable under provincial and territorial law. They are required to protect public safety, health, welfare and the environment and to comply with all applicable codes, standards and laws, as the architects and other regulated professionals within our industry do.
These responsibilities complement, but do not replace, public oversight. This matters when the bill potentially permits preparatory work before a decision or allows developments identified through a completed regional assessment to be considered pre-approved, subject to conditions and mitigation.
However, professional oversight must continue. Efficient approvals and strong protections are not competing objectives. Meaningful indigenous consultation, respect for constitutional rights and credible scientific assessment are essential to durable decisions. Bill C-39 offers a framework for progress, but work remains.
ACEC has three recommendations we believe will support the successful implementation of the bill.
First, coordination must work in practice. Responsibilities and requirements must be clear and mutually understood by proponents, regulators and stakeholders. Federal departments must work together with provincial, territorial, municipal and indigenous governments so that delays are resolved rather than transferred elsewhere. In the past, we've recommended a single agency for projects requiring multiple federal approvals. For projects assessed under the Impact Assessment Act, the bill's proposed decision document should identify who is accountable for the federal decision.
Second, credible timelines require capacity across all sectors. With increased investments, both proponents and regulators will need to invest in people, expertise and resources to ensure that the requirements for a complete application—which starts the one-year clock—are understood and agreed upon by all parties. Canada's infrastructure workforce strategy must include engineers, technologists, environmental professionals and project managers. Shorter deadlines alone will not address our challenges.
Third, engineers and other designers must be engaged early. Their expertise helps identify risks, evaluate alternatives, and address technical and environmental challenges early, de-risking projects before problems can become costly to resolve. This includes the regional assessments that must precede setting any region of national interest. Early planning and design help establish realistic scopes, schedules and budgets, reducing costly changes and delays.
Ultimately, the success of Bill C-39 will not be measured simply by whether decisions are made faster but whether those decisions translate into projects' being built. Our industry is here, and we're ready to contribute to Canada's success.
Thank you.