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ACEC-Canada and ACEC-NB speak out on behalf of industry on Bill C-69


Over the past month, the Senate Committee on Energy, the Environment and Natural Resources has hosted hearings across the country to hear from Canadians on Bill C-69, the Impact Assessment Act. ACEC-Canada John Gamble and ACEC-NB Executive Director Christy Cunningham were invited to testify to the Committee in Saint John on April 25th on behalf of the consulting engineering industry. Read what recommendations they put forth to ensure greater clarity.



Christy Cunningham:


Thank you, Madam Chair and members of the Committee for allowing us to offer our perspective and input on Bill C-69.

My name is Christy Cunningham, Executive Director of the Association of Consulting Engineering Companies – New Brunswick. I am also an environmental geoscientist with many years of experience completing environmental impact assessments. With me is John Gamble, President and CEO of the Association of Consulting Engineering Companies - Canada.

Our associations represent the voice of consulting engineering here in New Brunswick and across Canada. Nationally, we represent over 400 companies that provide engineering and other professional services across the country and internationally. Our members offer independent, unbiased advice to private and public sector clients. They frequently work with proponents to help them make informed decisions on projects, from conceptualization through to delivery.

We applaud the government’s review of the regulatory system because we agree, status quo is not a solution, for the government, proponents or stakeholders. Improved transparency and clarity in the environment assessment process is needed. However, we also need to express our industry’s concerns regarding the lack of clarity with Bill C-69 in its current iteration and its potential contribution to the ‘cumulative impact’ of regulation on investment in projects in Canada.



Large resource projects and even some public ones require significant capital investment. Proponents need to make informed decisions when projects have lifespans of years and decades. While a firm “no” is preferable to an indefinite “maybe”, the best outcome is when environmental assessments allow projects with economic, social, and environmental merit to proceed in a timely and responsible manner.

To help improve clarity for proponents and stakeholders alike, we believe the environmental assessment of projects needs:

  • a more rigid scoping process;
  • a clearly defined project list;
  • limited opportunities for suspension of timelines; and
  • timely appointment of a panel.

In particular, legislation that would compel the review panel to lead and commit to a single, consolidated scoping procedure early in the process and one that is agreed to by all jurisdictions and federal authorities would be a significant improvement to the current situation.


John Gamble:


Bill C-69 should be implemented in a way that ensures impact assessments are used to evaluate whether a project complies with public policy rather than be used as a platform to debate public policy. While the assessment process should consider and be aligned with the government’s broader policy objectives, such as climate change and Indigenous reconciliation, a project assessment should not become a forum where those policies are debated.

To this point, the nature and scope of public participation in the assessment process also needs to be clearly defined. Notwithstanding the efforts to be open and transparent, participation should be prioritized to parties directly impacted and those with specific and relevant expertise. This will help proponents that are fully compliant with the regulatory regime better understand the consultation process.

We do commend the government’s focus on First Nation participation in this process. When proponents respect First Nations’ culture and knowledge and make them true partners, everyone benefits. For instance, there are organizations such as the First Nations Major Projects Coalition could play a central role in consultation and planning on major projects.



While some of the concerns we raise today are expected to be addressed in regulation, we recommend instead they be directly addressed in the Act to create more clarity. Most projects that will be subject to Bill C-69 will require long-term investments and commitment of resources. Therefore, the more that is enshrined in legislation, the more certainty there is for making informed business decisions in regard to these projects.



ACEC wishes to reiterate that we share the government’s intention to modernize and improve our regulatory system to make way for a robust, efficient, effective and transparent process.

We want to see the right projects proceed and we want them to be done right. We want to see both the economic and societal benefits that arise from major projects done in an environmentally responsible way.

Nevertheless, we believe that in its current form and in the absence of the intended or envisioned regulations, Bill C-69 leaves more questions than answers and has the potential to cause the adverse effect, which could in turn impact investments, Canada’s economic growth and the timely completion of major projects.

Thank you for the opportunity to be here and we look forward to your questions.


*Photo caption: Bottom L-R: ACEC-NB Executive Director Christy Cunningham and ACEC-Canada President and CEO John Gamble pictured with Top L-R: Conseil économique du Nouveau-Brunswick CEO Thomas Raffy, Saint John Region Chamber of Commerce CEO David Duplisea, and CEO of Atlantic Chamber of Commerce Sheri Somerville, BBA, BPR, SCMP.