Montréal, September 22, 2026 – The Centre québécois du droit de l’environnement (CQDE) expresses serious concerns following the federal government’s introduction yesterday of the omnibus bill C-39 (Building Canada Strong Act). Behind its 240 pages and promises of efficiency, this massive bill marks a serious setback for environmental law, a deeply troubling expansion of the executive branch’s discretionary power, and a weakening of public participation and respect for the rights of Indigenous peoples.
A dismantling of the environmental legal framework
Under the guise of streamlining procedures, the bill proposes to amend several major laws, including the Impact Assessment Act, the Canadian Energy Regulator Act, the Canadian Environmental Protection Act, the Fisheries Act, the Canadian Navigable Waters Act, and the Species at Risk Act.
The bill proposes to impose a fixed one-year deadline between the submission of studies by the project proponent and the final decision. According to the CQDE, such a rigid timeline would be incompatible with the assessment of complex, large-scale projects – which often involve significant risks – and which require studies spanning multiple seasons, an analysis of cumulative impacts, meaningful public participation, and genuine consultation with Indigenous peoples.
The bill also proposes to amend the Building Canada Act (which stemmed from Bill C-5) to designate “regions of national interest,” a vague and undefined concept, so that they too may be exempt from compliance with various laws, including environmental ones. The proposal aims to expedite project authorization in these zones through a pre-authorization regime, shifting from a project-by-project review to a regional assessment.
“What the government presents as an efficiency gain is, in fact, bypassing a legal framework built up over decades” says Geneviève Paul, Executive Director of the CQDE.
Another setback for democracy
The CQDE condemns the use of yet another omnibus bill, a method that is problematic from a democratic standpoint and prevents parliamentarians from conducting a comprehensive and rigorous review of a bill with diverse and significant ramifications.
“The government had already granted itself the power to circumvent the application of its own laws with C-5: it is continuing this bulldozer-style approach with a bill that tramples on the rule of law, nature, and legislation meant to protect the public,” emphasizes Geneviève Paul.
“By seeking to speed up processes at all costs in the name of short-term economic imperatives, while seemingly ignoring the worsening environmental crises, the government’s proposed approach will expose the public to even more serious and costly consequences.”
A contradiction with stated objectives
The government justifies this reform by citing the need to remain competitive and attract investment while upholding a strong rule of law. Canada presents itself to Europe as a reliable partner, grounded in the rule of law. The bill does the opposite, granting even more discretionary power to the executive branch in the name of speed.
“It is not by expanding the government’s discretionary powers that we will build a strong Canada or achieve the goal of simplification; on the contrary, this undermines the rule of law that Canada claims to offer its international partners,” adds Geneviève Paul. “The government claims it wants to respect Indigenous rights and protect the environment. The approach proposed in C-39 is completely at odds with these objectives: this bill should be withdrawn. ”
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