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Smarter, more efficient approvals can build infrastructure faster

Canada’s economic and infrastructure ambitions depend on faster, more proportionate approvals. Expanding on existing assets and building within existing corridors—where land, baseline conditions, industrial operations, labour, mitigations, and affected communities are already better understood—is a strong example of where to begin.

This article is part of our Smarter regulation series, in consultation with Canadian Association of Petroleum Producers (CAPP).

Key takeaways

  • Canada can build essential infrastructure faster by focusing regulatory scrutiny on new and incremental impacts, not just on corridors that have already been established, reviewed, and mitigated.
  • The federal government’s reform direction is sound, but the devil is in the details of implementation. Payoff depends on design choices that are still open, and now is the time to shape them.
  • Real speed requires more than coordination. It requires a more efficient and effective regulatory decision-making process: lead regulators need delegated authority, consolidated consultation, binding timelines, and risk-calibrated information requirements.
  • Modelling suggests the stakes are substantial: accelerating major projects—such as energy infrastructure—towards the government’s two-year approval target, and retaining investment that might otherwise be lost, could unlock more than $540 billion in real GDP and over 50,000 jobs per year on average.  

Not all infrastructure projects are created equal, but Canada’s current approval processes often treat them as though they are. When widening an existing highway from four lanes to six, the relevant question is the incremental impact of the additional lanes, not whether the corridor should exist in the first place. Yet Canada’s federal approval framework for energy and linear infrastructure does not consistently make this distinction.

The distinction matters. Projects proposed within existing transportation, energy, and utility corridors often benefit from decades of established land use, environmental data, and community engagement. The risks are typically narrower and more predictable than those associated with new developments. But approval processes do not always reflect that reality.

Delivering infrastructure efficiently is rarely the responsibility of one order of government alone. Major projects typically require federal, provincial, and often municipal approvals, each with its own process and timeline. This paper focuses on the federal framework, where much of the reform agenda currently sits, but the larger opportunity lies in federal, provincial, and municipal alignment behind a shared process and ambition.

This paper is about the economic opportunity of more proportionate review, not the Crown's duty to consult—a constitutional obligation that must be upheld in full. Where we point to reducing duplication, the aim is a single, better coordinated consultation process that strengthens, rather than diminishes, Indigenous rights.

A more proportionate approach could help unlock faster project delivery without compromising oversight. While in-corridor development is not the whole opportunity, it is a clear place to start.

The case for regulatory reform is well established, and the federal government has set an ambitious agenda to pursue it. The opportunity now is not to re-argue the need for change, but to translate that ambition into implementable design with reform that delivers speed without sacrificing rigour.

Why this matters to Canada’s economy and society

Canada’s ambitions—building the strongest economy in the G7, becoming an energy superpower, diversifying exports beyond the United States1—depend on expanding pipelines, transmission lines, rail networks, and export-enabling assets.2 Economic growth, energy development, a better-connected and modernized electric system, and export diversification will largely be delivered through infrastructure built within or leveraging existing corridors.

For these in-corridor projects, the land, baseline conditions, surrounding communities, and existing mitigations are already better understood. Additional reviews can become redundant: delays disguised as diligence. The better approach starts with a key question: does incremental activity create incremental impact? If so, does that impact require anything additional beyond the mitigations previously proven effective for the corridor? More activity does not necessarily mean new risk, and new risk does not necessarily require new measures.

This points to a core regulatory principle: proportionality. Review effort should reflect incremental impact, and scrutiny should concentrate where incremental disturbance, and therefore risk, is greatest. Smarter, more efficient regulation can enable a faster path to the growth, productivity, competitiveness, energy security, and export diversification unlocked by new infrastructure.  

Current regulatory and policy challenges

The federal government’s recent discussion paper, “Getting Major Projects Built in Canada,” proposes a clear and ambitious direction: a single project authority, one-year review target, consolidated consultation, and the identification of preapproved economic zones.3 Its subsequent report, “What We Heard,” confirms both the appetite for reform and the care it demands.4 This signals real momentum. The opportunity is to build on it: translating these proposals into design choices that deliver in practice.

Realizing these gains will depend on how the reforms are designed and implemented. Specifically, reforms must include clarity with respect to how faster-tracked projects are defined, decision-making authority granted to the lead regulator (including any limitations or guardrails to that authority), and whether timelines are binding in practice.

Here are some of the key challenges present in the current approval landscape.  

The government’s agenda targets real and well-documented friction in the current system. Understanding precisely where that friction sits is the first step to designing it out.

Current thresholds often focus on total project size or length rather than the amount of new disturbance, causing review intensity to exceed a project’s incremental impact.

For example, public filings for TC Energy’s NGTL West Path Delivery 2023 Project describe approximately 40 kilometres of pipeline loops, most of them paralleling existing rights-of-way, with only about 6 kilometres of new right-of-way.5 Despite this largely in-corridor footprint, the project proceeded through the fuller Section 183 process,6 which typically runs 18–24 months longer than the more proportionate alternative.7 As a result, the process from application to certificate took more than 770 days. This case illustrates how thresholds based primarily on project size can trigger a level of review that may not align with the amount of new disturbance.  

Even where a lead regulator exists, independent approval authority often rests with separate federal departments, each with its own priorities, process, data and information submissions, consultations, and conditions.

The challenge becomes even greater across federal and provincial jurisdictions. A project that satisfies a provincial environmental assessment may still be subject to a separate federal review of substantially the same impacts, on its own timeline and against its own requirements. Additionally, where a corridor crosses provincial boundaries, proponents may be required to navigate multiple provincial processes alongside the federal ones. The federal government has acknowledged this and started to act, moving toward greater reliance on provincial reviews where jurisdiction overlaps through cooperation agreements and a "one project, one review" approach. These efforts are still early, but promising—the value comes from making the coordination consistent and dependable.  

Process duplication also affects communities, including Indigenous rightsholders, farmers, and residents residing within Renewable Energy Zones.8 These communities may be asked to participate repeatedly in projects within corridors where relationships, baseline information, and prior consultation processes already exist. This places a real burden on communities who may be engaged repeatedly.

Even a committed timeline offers little certainty if the requirements keep moving. Proponents frequently report an initial set of studies expanding as the review proceeds, leaving them to either decline the extra work—and risk the regulator lacking what it needs—or "stop the clock" to complete it. A one-year target means little if the definition of a complete application can shift midway. This is why reform must pair binding timelines with clear completeness criteria, disciplined information requirements, and firm limits on pauses and extensions—a need stakeholders raised directly in the government's engagement.

Application requirements frequently demand detailed studies across all aspects of a project regardless of where risk is concentrated.

As a result, regulatory effort is often spread broadly rather than focused on residual risks and genuinely novel incremental project impacts. Reviews become highly bespoke, and knowledge developed through previous assessments within the same corridor is repeatedly recreated rather than systematically leveraged. This can extend timelines and increase costs without necessarily improving decision quality.  

Five principles for smarter regulation

We are defining Smarter regulation as regulation and policies that strike the optimal balance of safeguarding Canadians while not stifling economic growth or investment.

In evaluating the design of both current and future regulations, we’ve defined five foundational principles:  

Five recommendations to strengthen outcomes

The path to smarter regulation does not require lower standards, but rather a stronger alignment between regulatory effort and risk. These recommendations build on the direction the government has already set, focusing on the design choices that will determine whether its ambition is realized in practice.

These recommendations are not limited to in-corridor projects. They describe how to make federal approvals proportionate and efficient for projects of every kind, with in-corridor development being a clear and immediately actionable case.

Recommendation 1. Segment projects smarter: by risk and new disturbances, not gross size
(Foundational principle(s): Risk-based and proportionate)

A tiered approval model should sort projects into review classes based on risk factors that focus on incremental impact, rather than relying primarily on project size, for example. Project length or footprint may remain relevant considerations, but so may the proximity to sensitive areas, the novelty of the activity, and the extent of genuinely incremental disturbance.

Projects that are well-understood and lower risk, including those built largely within existing corridors, should enter a more proportionate review stream, while genuinely novel or higher-risk projects would remain subject to more comprehensive review. The same risk-based logic could be applied to transmission and rail infrastructure.

Recommendation 2. Delegate authority to the lead regulator
(Foundational principle(s): Harmonized and coordinated)

The lead regulator should maintain delegated authority over relevant federal permits because coordination alone is not sufficient. Even where a lead regulator exists today, independent approval authority often rests with separate federal departments, each with its own process, data and information submissions, consultations, and conditions.

Where individual statutory decisions must remain with their respective authorities, they should nonetheless be integrated into a single coordinated process—one application, one consultation, one timeline, and one decision—led and sequenced by the lead regulator, so the proponent faces one accountable point of contact rather than several running in parallel.

A primary lead regulator with delegated authority provides the essence of harmonization: one regulator should oversee one process, one consultation, and one decision.

Recommendation 3. Coordinate consultation through one process
(Foundational principle(s): Harmonized and coordinated)

Major projects trigger multiple, overlapping consultation and engagement processes across federal departments, and with communities, stakeholders, and Indigenous rightsholders. These should be coordinated through a single, well-organized process led by the lead regulator, rather than run in parallel by separate departments. Crucially, the Crown's constitutional duty to consult Indigenous Peoples must be upheld in full within that process—coordination should make it more meaningful and better-resourced, not diminish it.

Recommendation 4. Name the timeline and make it binding
(Foundational principle(s): Transparent and predictable)

Timelines should be explicit and binding. Binding statutory timelines are not new to Canadian regulation; the CER Act already sets a 300-day limit for Section 214 applications. For projects within the in-corridor review class, this discipline should be tightened: a decision within six months of a completeness determination, with extensions reserved for genuinely exceptional circumstances and defined circumstances. The precedent exists; the task is to apply it where the proportionality case is strongest. Time certainty is a critical consideration for investors making decisions across jurisdictions. Without timeline certainty, Canada risks losing investment to jurisdictions that can provide faster and more predictable approval pathways.

Recommendation 5. Calibrate information requirements to actual risk
(Foundational principle(s): Risk-based and proportionate, Outcomes-focused)

Information requirements should be calibrated to residual risk, with standard mitigations codified for common and well-understood impacts. Where risks have been repeatedly assessed and are already known to regulators, proponents should not be required to recreate the same evidentiary record for every project. Regulatory effort should focus on genuinely incremental impacts and unresolved risks. Where previous assessments have already established baseline conditions and effective mitigations, that knowledge should be reused rather than recreated.

Together, these changes would advance broader smarter regulation principles:

  • risk-based and proportionate review
  • reduced duplication
  • stronger harmonization across agencies and governments
  • clearer accountability;
  • and a greater focus on outcomes rather than process.

Economic analysis and estimated impacts

Smarter, more efficient regulation can reduce delays, improve certainty, and support faster deployment of capital into critical infrastructure. The economic logic is straightforward: the same project, built sooner. The federal government has already set the ambition. The Major Projects Office, established under the Building Canada Act, has a core mandate to reduce approval and permitting timelines for nation-building projects to a maximum of two years.9 The target is clear; the task now is delivery.

The prize for getting there is substantial. We modelled10 approximately $25511 billion in major energy projects, spanning oil and gas and electricity assets, drawn from projects listed as “in review” and “announced or planning” in Natural Resources Canada’s Major Projects Inventory. As approval timelines shrink from up to a decade toward the government's two-year target, projects move from planning to operation much faster. A facility that would not have begun operations until 2041 under historical timelines could be operating as early as 2033, delivering economic benefits years sooner.

Applied across the projects we modelled, this acceleration would bring forward approximately $361 billion in real GDP between 2028 and 2045,12 and around 57,000 additional jobs per year on average over the same period, as employment is generated earlier and sustained across more years than under the status quo.

But the greater risk is not delay; it is projects that never get built at all. Without the certainty of a faster, more predictable process, capital moves to jurisdictions that decide sooner, and projects that would strengthen Canada’s economy are shelved or relocated. Under a scenario in which half of this investment fails to proceed, the additional foregone opportunity is approximately $185 billion in real GDP between 2036 and 2045 and roughly 48,000 jobs per year on average over the same period.13

Together, faster approvals and greater execution certainty represent an opportunity to unlock more than $540 billion in real GDP. Staying the course risks leaving that value on the table. Canada does not need to lower standards to build faster. By making approvals more proportionate to risk and reducing unnecessary duplication, governments can maintain strong oversight while enabling critical infrastructure investment, turning ambition into on-the-ground delivery.  

"In a world that is increasingly being defined by energy insecurity, trade uncertainty, and geopolitical instability, countries need to focus on the things within their control. Smart, efficient, and risk-based regulations that provide certainty and enable industries to move with alacrity can be a major competitive advantage in the race to attract global capital. The analysis and recommendations done by Deloitte are a positive contribution to the much-needed efforts underway to modernize Canada's regulatory environment." 

– Lisa Baiton, President & CEO, Canadian Association of Petroleum Producers (CAPP) 

We modelled approximately $255 billion14 in major pipeline transportation, clean electricity and electricity projects.15 Assuming construction begins in 2036, capital expenditures associated with these projects, together with a high-level estimate of their future output, are estimated to generate approximately $391 billion in real GDP over the 2036–2045 period.16

More efficient and predictable approval processes could accelerate project development, allowing projects to come online sooner and generate economic benefits earlier. For example, a facility expected to begin operations in 2041 under current regulations could instead begin operations in 2033.

Under a scenario where the proposed regulations reduce approval timelines for major projects by eight years, we estimate that approximately $361 billion in real GDP could be brought forward from beyond 2045 into the 2028–2045 period. This would increase cumulative real GDP generated until 2045 from approximately $391 billion to $752 billion. Accelerating these projects would also bring forward the creation of approximately 57,000 jobs per year, on average between 2028 and 2045. The accelerated scenario generates employment earlier in the forecast period, resulting in additional years of job creation relative to the business-as-usual case.

Under a counterfactual scenario where 50% of project investment is assumed to be lost due to delays and uncertainty, reforms that retain it would deliver $185 billion between 2036–2045, and job creation increases by 48,000, on average between 2036 and 2045.

While actual outcomes will depend on project-specific circumstances and implementation, the modelling indicates that more efficient approval processes could generate meaningful economic gains.  

  1. Government of Canada, "Government of Canada launches calls for proposals for the $5 billion Trade Diversification Corridors Fund and the $1 billion Arctic Infrastructure Fund,” published March 4, 2026.
  2. Office of the Prime Minister, “Mandate Letter,” published May 21, 2025.
  3. Government of Canada, “Getting Major Projects Built in Canada - Discussion Paper on Proposed Legislative, Regulatory, and Policy Reforms,” published May 8, 2026.
  4. Government of Canada, “Government of Canada releases What We Heard reports on proposed reforms on major projects, trade and transportation, and labour relations,” published September 9, 2026.
  5. Government of Canada, “NGTL West Path Delivery 2023 Project,” accessed August 14, 2026.
  6. Canada Energy Regulator, “Commission Practices on Section 183 Applications (CER Act),” published June 15, 2026.
  7. Under the Canada Energy Regulator (CER) Act, pipeline projects follow one of two review pathways. Shorter projects can use a proportionate process under Section 214. Longer projects fall under the fuller Section 183 process.
  8. Government of Canada, “Getting Major Projects Built in Canada - Discussion Paper on Proposed Legislative, Regulatory, and Policy Reforms,” published May 8, 2026.
  9. Government of Canada, Major Projects Office, accessed August 31, 2026.
  10. Economic impacts were estimated using the Deloitte Access Economics Regional General Equilibrium Model (DAE-RGEM), a dynamic, multi-region computable general equilibrium (CGE) model built on the GTAP database, with Canada represented at the provincial level.
  11. Investment and real GDP figures are expressed in 2017 dollars ($255 billion in 2017 dollars is approximately $331 billion in current dollars).
  12. Real GDP impacts are expressed in 2017 prices.
  13. Real GDP impacts are expressed in 2017 prices.
  14. Investment is reported in 2017 dollars (approximately $331 billion in current dollars).
  15. Project information was sourced from Natural Resources Canada’s Major Projects Inventory (MPI). The analysis included projects classified as “in review” and “announced or planning” in the MPI within the next 10 years. Thresholds were set at $50 million in capital expenditures for pipeline transportation projects and $20 million for electricity projects.
  16. Real GDP impacts are expressed in 2017 prices.  

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