Bill C-39 Committee on Oct. 26th, 2026

[Emmanuelle Toussaint, President and Chief Executive Officer, Québec Mining Association]

Mr. Chair, members of the committee, thank you for inviting our association to testify before you.

My name is Emmanuelle Toussaint. I am the president and chief executive officer of the Association minière du Québec, or AMQ. With me is Stéphanie Tremblay, who is the sustainability lead.

Founded in 1936, the Quebec Mining Association represents the entire mining ecosystem in Quebec, including all operating mines, exploration and development companies and suppliers of goods and services. The association's mission is to promote the development of a responsible, committed and innovative Quebec mining industry.

From the outset, I want to state clearly that the AMQ supports Bill C‑39. The proposed measures to regulate time frames and decisions, to better coordinate the authorities of the various federal departments and to designate regions of national interest are important to our members and can have concrete effects on the ground.

In the current geopolitical context, we must focus on what we control. We don't control the tariffs, the price of minerals or the fact that the refining of several critical minerals is concentrated in the hands of a very small group of countries. What we control are our own rules, such as the time it takes to approve projects, the coordination between our governments and the predictability of our decisions. That is exactly what Bill C‑39 aims for.

Let's not forget that our industry is already an economic pillar. The activities of AMQ member mining companies and their suppliers supported more than 15,000 direct jobs and more than 51,000 direct, indirect and induced jobs in 2022. The industry contributed $12 billion to the GDP in 2022 and relies on 3,800 suppliers. The industry's activities have also generated more than $2.6 billion in fiscal and parafiscal revenue for Quebec City and Ottawa.

These benefits are very real, and new projects could expand on them. According to a new study we recently conducted, 45 advanced mining projects would represent up to $609 billion in potential spending in Canada, including $577 billion in Quebec, if they were all carried out. Over 70% of these investments are in critical and strategic minerals, and the rest are primarily in gold and iron.

That's a decades-long potential. However, mining capital is mobile. A good, high-quality deposit does not guarantee that investment will be made here. I must stress that fast-tracking does not mean weakening environmental or social requirements. It means better organizing government work, avoiding duplication and making decisions within clear and predictable time frames. It typically takes 15 to 20 years from the discovery of a deposit to the development of a mine. We're talking about investments of $1 billion to $4 billion. Fast-tracking, simplification, transparency and accountability are essential for mining projects to move forward.

Our support comes with a few recommendations, which are contained in our brief.

First, the proposed one-year time frame must allow for measuring a project's actual progress. Clear criteria are needed to determine whether an application is complete. There has to be a follow-up of the preceding period. Suspensions must also be justified and limited to new, relevant and necessary information. Otherwise, the time frames may simply be moved upstream. Departments also need to have the resources to work in tandem.

Second, there is consultation with indigenous communities. Developing mining projects relies on good relationships with these communities. It is important to have a consultation plan specific to each project that is aligned from the outset with Quebec's process and that specifies the communities to be consulted, the purpose of the consultation and each party's responsibilities. This will prevent communities from being consulted several times on the same issues.

Third, there is coordinating with Quebec and ending overlap. Coordination among federal departments is great, but it doesn't resolve overlap between the two levels of government. That is why we are asking for a formal agreement between Canada and Quebec to implement the “one project, one assessment, one decision” approach while complying with the conventions.

Fourth, a mine cannot move forward without roads, power lines, railways and ports. Designating regions of national interest has to involve planning projects and infrastructure at the same time, for both mining projects and communities. More than three-quarters of the projects studied are in northern Quebec and Abitibi-Témiscamingue. There are also other significant projects on the Côte‑Nord and in Saguenay—Lac-Saint-Jean. National interest must cover the entire value chain, not only extraction but also processing, refining and recycling.

Fifth is implementation. Habitat credit and offset regulations under the proposed Fisheries Act amendments need to be published quickly. Projects that are already under way must also be able to choose the new regime without repeating the steps that have already been taken.

In short, Bill C‑39 is a step in the right direction. We're not asking for less rigour; we're asking for processes that are better organized, more predictable and better coordinated.

Thank you for your attention. We are available to answer your questions.

[The Chair, Liberal, James Maloney]

Thank you very much.

Mr. Albas, you have six minutes.

[Dan Albas, Conservative, Okanagan Lake West—South Kelowna, BC]

Thank you, Mr. Chair.

Thank you to all our guests for being here. I'll start with Ms. Toussaint.

Ms. Toussaint, you said that making decisions within a clear time frame was important for you and for your association. We agree. Conservatives support Bill C-39's objectives of faster project decisions. However, the statutory one-year period that's found in part 1 only provides certainty if proponents know exactly when it begins. You said yourself that the incentives are to push much of the information collecting outside of the one-year timeline.

Under the so-called “Groundhog Day” proposed section 19, essentially it becomes an open-ended amount of time where the responsible authority gets to decide whether an application is complete. If that happens, the advertised one-year statutory promise is null and void. Would you support an amendment requiring government to determine, within a fixed period, whether an application is complete, so that the one-year timeline approval is actually meaningful?

[Emmanuelle Toussaint]

Yes, what we're asking for is that the government better regulate what is upstream and ensure that proponents know exactly whether their application is considered complete and what is expected of them. Afterwards, the time frame countdown can actually begin.

That is, in fact, one of our recommendations. We need to clarify what is upstream. It is all well and good to try and ensure that there is a predictable one-year time frame, but we have to make sure, once again, that it is not moved forward without proponents knowing more about whether their application is complete.

[Dan Albas, Conservative, Okanagan Lake West—South Kelowna, BC]

Thank you very much.

Ms. Guibord, you mentioned earlier that there's an amendment you'd like to the Fisheries Act. Could you please submit that in writing to the committee, so we can take a look at it at length? I don't have time to do it right now.

I just asked the question about the Groundhog Day clause, where a proponent can go back to the responsible authority every day and say, “Here's another study,” and the responsible authority can say, “We need another study before we decide that it's complete and begin the one-year clock.”

Do you agree that this needs to be addressed, and would you support an amendment that would give a fixed timeline for that to begin?

[Josée Guibord]

For our members, and coming from an investor-owned developer, we see the importance largely around not having an open-ended end to the process. As a developer, we can control certain amounts of the development and the initial preparation in preparing for the application. We're more concerned that it not be open-ended and that we have a clear timeline from application, from acceptance, to delivery of the decision.

[Dan Albas, Conservative, Okanagan Lake West—South Kelowna, BC]

Thank you very much.

Ms. Exner-Pirot, I have the same question for you. Right now, regarding that completeness clause, proposed subsection 19(4), where the responsible authority gets to decide when you can proceed on the clock, do you think that gives the responsible authority too much power?

[Heather Exner-Pirot]

Some of the concerns I've heard from various industry associations and companies were about how there's a lot of front-loading with this. Everyone appreciates the one-year timeline. Even if it were 14 or 16 months, it's such an improvement from before. It doesn't have to be exactly 365 days. However, there are some concerns about how much front-loading goes on the beginning. For some of the smaller projects, maybe particularly in mining, that get invested at different milestones and different stages, that may be an issue.

I think anything that provides that clarity for companies of what is completeness would be welcome.

[Dan Albas, Conservative, Okanagan Lake West—South Kelowna, BC]

Thank you.

I would like to follow up with that. The BCA—the Building Canada Act—obviously gives the government a tremendous amount of power, but that process is very much a closed shop, meaning that no one knows how it gets on there. Is it a premier who makes the recommendation to the minister, or is it a lobbyist?

One of the strengths of Bill C-39 is that the regulator gets to be a single window. They do a review of it. It's almost the complete opposite of the BCA.

Could there not be a place, in your mind, where the responsible authority who sees the project in its totality could make a recommendation to have the minister responsible for the BCA look at it as a potential national interest project? Then, second to that, they could actually say that you could exempt certain parts of it to speed up that process even further. Now, the decision lies with the minister, but then you would have an expert regulator who would be somewhat away from the lobbyist and politics of the day.

Would you support an amendment that would allow that to happen?

[Heather Exner-Pirot]

I would say a lot of the concerns about Bill C-5 were that it allowed for picking winners and losers and political choices of what moves ahead. I think one of the advantages of Bill C-39 is that it makes it a bit more of a level playing field for everybody. I think, in general, across legislation, across time, we should be trying to depoliticize our regulatory processes. This has been at least a two-decades-long process of adding political oversight, vetoes and ministerial discretion. As much as we can make it depoliticized and just rules of the game, I think it's an improvement.

[Dan Albas, Conservative, Okanagan Lake West—South Kelowna, BC]

Again, having a process where the regulator would just make a recommendation using their expertise and then the cabinet, obviously, where there is political accountability, would make the final decision.... Would that marry the two systems that don't exist right now with Bill C-5 and Bill C-39?

[Heather Exner-Pirot]

It may very well be better than what's currently on offer. I would go one step further. I'd rather not have nationally determined projects at all. I think you set the playing field. I think all projects, frankly, are in the national interest.

[Dan Albas, Conservative, Okanagan Lake West—South Kelowna, BC]

That's fair.

[The Chair, Liberal, James Maloney]

Thank you.

You're right on time, Mr. Albas. Well done.

Mr. Louis, go ahead.

[Tim Louis, Liberal, Kitchener—Conestoga, ON]

Thank you, Chair.

I want to thank the witnesses, all the amazing women, for your informative opening statements. I really appreciate that.

I will start with Ms. Exner-Pirot.

You talked about the need to get things built and shipped. You talked about being a strong international trading partner. You talked about Canada's competitiveness. We've heard from other witnesses and yourself about the investment challenges that proponents face, including duplication, sequencing and uncertainty around how long federal decisions will take. From the perspective of investment, how important is the time to a decision, whether it's a yes or a no?

How would a predictable one-year federal decision window change Canada's competitiveness for capital?

[Heather Exner-Pirot]

I would say obviously we have great geology. Everyone appreciates that. We have a pretty good workforce. Like I said, our Achilles heel has always been our regulatory system. Investors have said we're “uninvestable”. Like I said, I heard people call Bill C-69 the “Don't Invest in Canada Act”. It's slow. That is the general reputation—that it's slow.

I think we'll always be a little slower than some other jurisdictions, but as one colleague from Saskatchewan said to me, if you're going to be slow, you better be good. We need very good systems that are predictable and are transparent.

That one-year timeline is what has gotten everyone in the Canadian oil and gas industry particularly excited for pipelines, where that does feel like a huge improvement. We've seen so much capital flow to the United States because it does get deployed faster. You get a return on investment faster. Being able to compete with that is going to be a boon for our Canadian resource and energy sector.

[Tim Louis, Liberal, Kitchener—Conestoga, ON]

Thank you for that.

Following up on that, how about starting earlier when we're talking about regions of national interest? The bill proposes assessments that could examine cumulative environmental, social, economic, health and indigenous rights impacts across an entire region. That would help identify suitable development areas and even no-go zones in advance. Then, proponents have to enter a region with clear expectations, potentially reducing that regulatory uncertainty while supporting environmentally informed development planning.

How could doing regional assessments and cumulative-effect work, before individual proponents arrive, improve investment certainty and environmental planning in resource-rich industries?

[Heather Exner-Pirot]

I think it's a very interesting idea from the legislation. Everyone is trying to figure out what regions we're thinking about here and what kinds of projects.

One that is comparable is the Alberta heartland industrial zone, which is obviously not federal, but it may be a comparable situation where you have an area zoned for this. It's been able to attract a lot of petrochemical investment, a lot of data centres, precisely for that reason. It was already zoned. Investors already knew they could move in quite quickly. I think expanding that model to areas under federal jurisdiction is very promising.

[Tim Louis, Liberal, Kitchener—Conestoga, ON]

Thank you very much.

Turning to Electricity Canada, we talk about energy sovereignty and building our electrical grids east-west, as opposed to north-south with our southern neighbours. You've done research that found additional interprovincial interties could reduce outage risks by almost 70% during extreme weather.

Since Bill C-39 would make the Canada Energy Regulator the lead federal review authority for interprovincial transmission projects, how would those reforms help accelerate and construct the new interties and help build our energy independence?

[Josée Guibord]

Thank you.

As we said, we support the bill, and we think that it helps increase collaboration. It simplifies the processes, and it speeds up the approval of that transmission. Making the Canada Energy Regulator the single assessor for international and designated interprovincial power lines, with decisions due within one year of a complete application, is definitely an improvement.

We recognize, as you said, that there are benefits to transmission across the country. We recognize that building more transmission will create a better system and continue to maintain our clean, affordable and reliable electricity system. Building that transmission will help us achieve energy security—that reliability you mentioned—and the integration of renewables across the sector and across our country.

[Tim Louis, Liberal, Kitchener—Conestoga, ON]

Thank you very much.

I'll turn to the Québec Mining Association.

When we talk about critical minerals and how essential they are for transmission lines, batteries and nuclear supply chains, do you feel that this bill could enable mines that will help us build a cleaner economy as well?

[Emmanuelle Toussaint]

Critical minerals are essential for the energy transition and also for the social and economic transition. We know that there are many countries that have those resources.

I would add, however, that there are other projects that are not necessarily for critical minerals—like for iron and gold. Those projects are also important. Quite often, those mines are polymetallic. That means that it's possible to have silver, copper and many other minerals.

Once again, I think that Bill C‑39 will fast-track projects, reassure investors and ensure that projects can get off the ground. This is extremely important. The fact is that only a small number of projects manage to see the light of day. For example, there are currently more than 1,100 exploration projects in Quebec, but only about 50 projects are sufficiently advanced, and there is no certainty that they will be realized.

Having available infrastructure, whether for transportation or electricity, is a major component. One of the really attractive aspects of Bill C‑39 is having regions of national interest. It's clear that we have large mining regions. Being able to truly facilitate the completion of these projects, but also ensure that the mines that are already in operation can continue to operate, is really essential, especially if clean electricity is available.

[Tim Louis, Liberal, Kitchener—Conestoga, ON]

Thank you.

[The Chair, Liberal, James Maloney]

Go ahead, Mr. Ste-Marie.

[Gabriel Ste-Marie, Bloc, Joliette—Manawan, QC]

Thank you, Mr. Chair.

Greetings to all the witnesses and thank you for being here.

My first question is for Ms. Toussaint.

You said it would be better to have stronger alignment between Quebec City and Ottawa to limit overlap. If, as the government says, an assessment could be conducted within one year, would it suit your industry if the Quebec Bureau d'audiences publiques sur l'environnement, or BAPE, conducted the impact analysis?