Dear Prime Minister, 

The Southern Alberta Group for the Environment (SAGE) encourages the Government of Canada to legislate based on the values of distributive justice, social equity and intergenerational equity, which is largely premised on a sustainable relationship with the land – our natural environment.

The Government of Canada has a legislative responsibility for the quality (and quantity) of water in our rivers and lakes (Canada Water Act, Department of the Environment Act, Fisheries Act, & Navigable Waters Protection Act); biodiversity (Species at Risk Act); air quality (proposed Clean Air Act as part of the Canadian Environmental Protection Act); the promotion of renewable energy technologies (Energy Efficiency Act); and the reduction of greenhouse gas emissions (Canada Net-Zero Emissions Accountability Act & proposed amendments to Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds). These Acts and Regulations represent important oversight to provincial legislation and actions, and provide comprehensive direction to sustaining the health, resilience and productivity of the environment as valued by Canadians.

This is why SAGE has concerns about the fast-tracking of ‘national interest’ projects as articulated in the new Building Canada Act (Bill C-5). It is important that all projects be evaluated through public consultation and robust environmental assessment.

Irrigation Expansion and the Canadian Infrastructure Bank:

An example of our concern might be instructive. During the Covid pandemic, the Government of Canada directed the Canadian Infrastructure Bank (CIB) to finance projects as “a catalyst for private investment … that support economic growth for the benefit of Canadians.” The CIB website states: “We are working on projects, from coast to coast to coast, that reflect our core sectors for investment – green infrastructure, clean power, public transit, trade and transportation and enhanced broadband infrastructure.” The CIB entered an agreement with the Government of Alberta and Irrigating Alberta Inc. for improvements of irrigation infrastructure as well as increased water storage. This funding was provided without adequate consultation or assessment of cumulative effects related to substantial additions of water storage. There is no apparent oversight by the CIB to ensure that mandated environmental expectations are achieved, leaving this evaluation (or not) to the proponent of the funding. In other words, the project was being fast-tracked solely in the interest of encouraging economic activity at the detriment of the environment.

The result, with respect to the environment, is a number of reservoirs in the planning and regulatory review processes that are based on water modelling that ignores water availability concerns, impacts to the water quality and the health of riparian areas, and the future impacts of climate change. This additional storage is meant to expand irrigation (so as to pay back the CIB loans) leading to the conversion of 208,000 acres of land in a basin closed to new water licenses. Already there are proposals to convert native grasslands to irrigated land in anticipation of water that may (or may not?) be made available by the CIB-funded project.

In the response to our requests for designation of each of three proposed reservoir projects for federal impact assessment it is stated (see IAAC Registry for Chin Reservoir Expansion, Snake Lake Reservoir Expansion, and Deadhorse Coulee Expansion) the federal ECCC Minister says:

“The Canada Infrastructure Bank is expected to provide financial assistance, in the form of a loan to be repaid by the Proponent, for the purpose of enabling the Project to be carried out. The Canada Infrastructure Bank is responsible for meeting all of its legal obligations, including responding to the Duty to Consult to Indigenous groups and ensuring that the Project has met environmental assessment and other regulatory requirements.”

To be clear, it would have been much better for sustaining environmental health (rivers, water quality, species-at-risk) had the CIB engaged in public consultation and properly evaluated environmental risks prior to entering this agreement. We are all poorer for the excessive haste.

SAGE remains concerned about the similar inclinations to haste articulated in the Building Canada Act (Bill C-5).

Mining for Metallurgical Coal in the Crowsnest Pass, Alberta:

Our region has great concerns about the proposed Grassy Mountain coal mining project for metallurgical coal (currently Northback). This project was evaluated in 2021 by a Joint Review Panel and deemed ‘not in the public interest’. We are encouraged by the intention of Environment and Climate Change Canada to develop regulations to manage threats to the aquatic environment from coal mining effluent.

The report identified impacts to species-at-risk, risks of contamination of surface- and ground water, risks of air pollution, and that the project did not properly consider economic risks in its evaluation (which may be significant for the agri-food sector in our region), while overstating royalty payments. There was no cost evaluation for the long-term treatment of water (long after the coal mine would be closed) and dubious commitments for restoration after mine closure. Overall, this project is not good for people, it is not good for the environment, and it is not good for the citizen-taxpayer.

Since the publication of the Joint Review Panel’s report, and with new ownership, this project has been resurrected under a dubious classification change to an ‘advanced’ project and in the absence of a clear provincial coal policy. We would hope the federal government will continue to monitor the decisions of the Government of Alberta and intervene, if required, to uphold the recommendations of the Joint Review Panel.

SAGE encourages the Government of Canada to provide clear regulation managing the threats to the aquatic environment from coal mining effluent, and reduce greenhouse gas emissions from the burning of coal (thermal or metallurgical) as well as methane emissions from mining.

Meeting Greenhouse Gas Emission Targets:

We are encouraged by Canada’s submission of the 2035 nationally determined contribution (NDC) to the United Nations Framework Convention on Climate Change under the Paris Agreement and Canada’s targets to cut emissions up to half below 2005 levels by 2035. We are optimistic that Canada will continue to make the necessary decisions to achieve net-zero emissions by 2050. “The core political technology we need is to value our future, to care about the generations that come after. That’s because climate change is the tragedy of the horizon” (Carney, Value(s), 2021, p.308).

There are important sectors that need more attention in efforts to achieve net-zero emissions. The reduction of transportation emissions remain elusive with the disconnect between infrastructure, manufacturing of low-emission alternatives, and tariff barriers. There is also significant inertia in building standards for renovation and new construction. Provinces like Alberta are entrenched at the lowest tier of the National Building Code of Canada having removed the flexibility of municipalities to experiment with green building standards. Buildings last a long time, so constructing them to low standards today locks-in high emissions well into the future.

Continuing to subsidize fossil fuel exploration, production and transportation is problematic for reducing greenhouse gas emissions despite the wicked problems that surface with rising energy costs. Furthermore, there needs to be greater measurement and monitoring of fugitive emissions. Independent research on methane emissions from oil and gas operations indicate significant and continuous releases to the atmosphere. This is also true of bitumen and coal mining operations. Methane is an exceptionally potent greenhouse gas, with a global warming potential more than 80 times greater than carbon dioxide over a 20-year timescale. This makes methane emissions a critical factor in the accelerating climate crisis, which directly threatens the health and safety of our communities. It is in our collective interest to prevent methane venting and fugitive emissions from oil & gas operations and coal mining.

“After all, climate change is an issue that i) involves the entire world, from which no one will be able to self-isolate, ii) is predicted by science to be the central risk tomorrow, and iii) we can address only if we act in advance and in solidarity” (Carney, Value(s), 2021, p.7).

We are also concerned about encouraging greater oil and gas production by promising another pipeline to the west coast. SAGE understands that there are expectations of lowering the carbon intensity of oil and gas production, however, these emission reductions should be proven before expanding pipeline capacity. By ‘proven’, we mean measured, monitored and evaluated including carbon capture schemes that reinject carbon dioxide to enhance oil production. Minister Hodgson was quoted saying: “When you are injecting carbon permanently into the ground and permanently sequestering it, that is a good thing” – but when the carbon that is injected leaves the reservoir with the natural gas, it is not permanent. This is a shell game that will not help us lower carbon emissions in the long term.

SAGE welcomes ongoing commitments to meet our greenhouse gas emissions targets, and renewed commitments to clean transportation, clean energy regulations, methane emission reduction, and higher national building standards.

Why We Are Encouraged and Concerned:

SAGE is encouraged that Canada has leadership that understands the relationship between social needs, environmental health and the sort of economic activity that supports them.

We are concerned because of the political pressure to address short-term (and ever-recurring) economic and social crises. “Research in behavioural psychology has established that humans have a host of cognitive biases that mean we undervalue resiliency. We display a present bias and discount problems and benefits that will occur in the future, preferring immediate [political] rewards even if they are lesser in overall value” (Carney, Value(s), 2021, p.224).

We are concerned because Building Canada Act (Bill C-5) seems to devalue Indigenous consultation and important regulations and environmental processes by allowing projects to proceed without public participation and adequate evaluation through the environmental assessment process.

SAGE is encouraged because of the significant interest shown by the current Government of Canada to reduce greenhouse gas emissions and protect our air, water, wildlife and natural habitat as articulated by the Canadian Environmental Sustainability Indicators (CESI).

Response:

On behalf of the Right Honourable Mark Carney, Prime Minister of Canada, I acknowledge receipt of your correspondence dated November 25, 2025, regarding the environment and Bill C-5, One Canadian Economy Act. I regret the delay in replying.

Thank you for taking the time to write to Prime Minister Carney. Please be assured that the remarks you offer on behalf of the Southern Alberta Group for the Environment have been carefully read.

I note that copies of your communication have also been sent to the Minister of the Environment, Climate Change and Nature, the Honourable Julie Dabrusin, as well as to the Minister of Fisheries, the Honourable Joanne Thompson. With this reply, I am forwarding an additional copy to the President of the King’s Privy Council for Canada and Minister responsible for Canada-U.S. Trade, Intergovernmental Affairs, Internal Trade and One Canadian Economy, the Honourable Dominic LeBlanc, for information and consideration.

Once again, thank you for writing.

Additional Response from The Honourable Julie Dabrusin (March 30, 2026):

Thank you for your letter of November 25, 2025, concerning the Building Canada Act (BCA) and the impact assessment process. I appreciate the Southern Alberta Group for the Environment’s engagement in the federal impact assessment process and your emphasis on the importance of cumulative effects, environmental stewardship, and long‐term sustainability.

The Government of Canada shares your view that intergenerational equity and long‐term environmental health must remain central to federal decision‐making. Canada’s climate objectives, including achieving net‐zero emissions by 2050, continue to guide how projects of national interest are identified and assessed.

Before a project can be designated under the BCA, consultations must take place with Indigenous Peoples, provinces and territories, and federal ministers. The project must also meet the criteria set out in the BCA: strengthens resilience; provides economic benefits; is executable; advances interests of Indigenous Peoples; and contributes to clean growth and climate change objectives.
Projects identified under the BCA are not exempt from federal oversight or regulatory requirements, including those under legislation for which I am responsible, such as the Impact Assessment Act (IAA). All projects, including major infrastructure and fossil fuel‐related projects, continue to be assessed under existing laws and policies. Designation of a project under the BCA does not remove federal environmental protections related to water, biodiversity, air quality, or greenhouse gas emissions.

When a project is designated under the BCA, it effectively provides a single upfront decision about whether the project can proceed, including a decision under the IAA. Proponents are still required to provide the necessary information to federal agencies and departments, including the Impact Assessment Agency of Canada (IAAC), as they would in the ordinary course of assessment and permitting. In other words, if the BCA lists a project that is a subject to the IAA, an impact assessment must still be undertaken. Our government remains committed to ensuring that any project identified under the BCA will continue to be subject to environmental protections while supporting one Canadian economy.

To ensure all major projects meet regulatory requirements in a timely manner, our government is re-engineering the impact assessment process to improve timeliness and predictability while maintaining the Government of Canada’s commitments to strong environmental protection and meaningful Indigenous and public participation.

A core feature of the re-engineered process is a focus on key issues within federal jurisdiction related to the project-specific assessment, including impacts to fish and fish habitat, species at risk, federal lands, Indigenous rights, and transboundary effects. Where applicable, greenhouse gas emissions are assessed in a manner consistent with the IAA and Canada’s broader climate commitments, including a rigorous examination of methane emissions through strong measurement, monitoring, and regulatory oversight for credible emissions reductions. These processes remain grounded in scientific analysis and are informed by Indigenous consultation and public input.

Proponents will be expected to identify and address the key issues earlier and throughout the impact assessment process. IAAC will seek to proactively engage Indigenous groups and the public, as appropriate, before an impact assessment begins to build capacity and support participation. Indigenous groups and the public will continue to play a central role in shaping impact assessments and informing the identification of key issues to be assessed.

Recent legislative changes, including through the BCA, do not diminish Canada’s constitutional duty to consult and, where appropriate, accommodate Indigenous Peoples. The Government of Canada’s duty to consult Indigenous Peoples remains a fundamental obligation. Federal decision‐making is supported by early and ongoing engagement with Indigenous communities and by the consideration of Indigenous knowledge, consistent with our commitments to reconciliation.

Our government recognizes that although the world is on a low-carbon trajectory, fossil fuel demand is expected to continue in the years ahead. With the right investments, Canada can continue to meet global demand for oil and gas throughout the global net-zero transition by reliably supplying global markets with products produced with the lowest possible emissions and the highest possible environmental protections. This is why in Budget 2025, the Government of Canada released a Climate Competitiveness Strategy that aims to boost Canada’s economy and position it as a leader in clean growth and decarbonization.

Canada also signed a Memorandum of Understanding (MoU) with Alberta on November 27, 2025, which notes Canada and Alberta’s commitment to achieving net zero greenhouse gas emissions by 2050 and will help ensure that Alberta’s oil barrels are among the lowest energy intensive in the world. This MoU also signaled the intention to negotiate an equivalency agreement on the Clear Electricity Regulations, where the province will have to show that they have a pathway for their electricity system that results in equivalent emissions outcomes and that meets the shared commitment of net zero electricity by 2050. This agreement could also support the deployment of nuclear technologies, carbon capture and storage, energy storage, and increased interties with neighbouring provinces, creating significant economic opportunities while supporting the increased supply of clean, reliable, and affordable power.

As federal, provincial, territorial and Indigenous governments work collaboratively to advance projects of national interest, the Government of Canada remains committed to environmental stewardship. Federal environmental protection requirements will continue to apply to ensure transparent, rigorous reviews that uphold environmental, social, and economic considerations for long‐term sustainability.

Thank you again for your continued promotion of environmental stewardship and for providing your views on these important matters.