A Building Canada Act listing speeds up the federal review and locks it in. Provincial and local approvals still change with each government.
Roberts Bank Terminal 2 completed its federal impact assessment in 2023. Three years later, on August 29, 2026, the federal government published a Canada Gazette notice that it may list the same terminal under the Building Canada Act, alongside the Mackenzie Valley Highway. Public comment on both closed on October 1, 2026, the day Pacific Link became the first project listed.
If an impact assessment decision were the end of the federal process, a terminal three years past one would have no reason to seek designation. It is not the end, and that is the clearest way to see what the Act is for.
WHAT CHANGES?
• One conditions document replaces the federal permit stack. Once a project is listed in Schedule 1, the authorizations it needs under the statutes in Schedule 2 are deemed granted, subject to a single conditions document issued by the responsible minister. Those statutes include the Impact Assessment Act, Fisheries Act, Species at Risk Act, Canadian Energy Regulator Act, Canada Transportation Act, Canadian Environmental Protection Act, 1999 and Migratory Birds Convention Act, 1994. For Pacific Link, the government says the conditions document will serve as the CER certificate and include Fisheries Act authorizations and Species at Risk Act permits.
• The question moves from whether to how. In the government’s own description, listing shifts review from whether a project proceeds to the conditions under which it does.
• One door. The Major Projects Office acts as a single window into the federal process. The Act aims for federal decisions in two years rather than five or more. Pacific Link’s target is 11 months: Dominic LeBlanc, Minister of One Canadian Economy, is to complete its conditions document by September 1, 2027, allowing construction to begin. The Major Projects Office and the Canada Energy Regulator will consult on environmental protections, oversight, Indigenous ownership and local hiring along the way.
What does not change, and what can change with a government
• Provincial consent and permits. The Act covers federal authorizations only, and requires consultation with provinces and, for projects within exclusive provincial jurisdiction, their written consent. A highway, port or transmission line still needs every provincial and local approval it needed before. Provincial fast-track tools, such as Ontario’s Special Economic Zones Act, 2025 and the “one project, one review” assessment agreements with B.C. (2019), New Brunswick (December 2024) and Ontario (December 2025), were each made by a particular government, and a successor can revisit them.
• Consultation. Listing requires consultation with affected Indigenous peoples. Amendments made in committee require consultation reports to be published and an Indigenous Advisory Council to be established within the Major Projects Office, which has committed $40 million over two years to Indigenous engagement capacity.
• The evidence burden. Conditions under the Fisheries Act and Species at Risk Act are written against baseline data on fish habitat, species presence and watercourse crossings. A compressed review means that data has to exist sooner. It does not mean less of it is needed.
• The listing step. A project is not listed by announcement. A Gazette notice and comment period come first, and in the government’s words, a notice “does not mean a listing decision has been made.”
• Local policy. Councils change faster than any other level of government. Calgary’s citywide rezoning, approved in May 2024, was repealed in April 2026 by a council led by a mayor elected in October 2025 on that promise. Applications already in process kept the old rules, which is the clearest lesson for any owner: a filed application is the most durable protection a project has against a change in local policy.
Who gets designated
The government weighs five factors: whether a project strengthens Canada’s autonomy, resilience and security; provides economic or other benefits; has a high likelihood of successful execution; advances the interests of Indigenous peoples; and contributes to clean growth and climate objectives. As of October 1, 2026, the Major Projects Office lists 18 projects and eight broader strategies. Transportation and Infrastructure projects span the country: the Contrecoeur container terminal in Quebec (referred in September 2025), BC Hydro’s North Coast Transmission Line (referred in November 2025), the Mackenzie Valley Highway in the Northwest Territories and Roberts Bank Terminal 2 in B.C., both at the notice stage, and the Grays Bay Road and Port in Nunavut, with a decision targeted by the end of 2026.
If your project will never be listed
Most owners will never hold a Schedule 1 project, and it is fair to ask whether any of this applies to them. It does, in two ways. First, designated projects will compete for the same contractors, engineers and field crews as everything else in their region, on a federal timeline. A municipal interchange tendering in the Lower Mainland in 2028 will bid into a market shaped by a pipeline terminal and a container terminal planned for the same part of Delta, and a territorial road project in the Northwest Territories or Nunavut will share its short construction season and contractor pool with two national-interest corridors. Second, the conditions-document model is Ottawa’s working answer to permit fragmentation, and owners can borrow it without a listing.
Six things to do on a project in development now, with an election season under way:
• Build one permit register split by jurisdiction: federal, provincial and municipal. For each federal item, note whether it falls under a Schedule 2 statute and what evidence it requires.
• Start baseline surveys in the first field season available. Fish timing windows and species survey seasons set the earliest date the data can exist, and no review process moves them.
• Treat consultation as a schedule activity with its own owner, budget and duration, sequenced against design milestones.
• Track Canada Gazette notices and the Major Projects Office project list. They are the earliest public signal of which corridors and labour markets will be busy, and when.
• File what can be filed before a change of government. Calgary’s in-process applications kept their rules; an application still being drafted had no such protection.
• Keep a decision record that outlasts staff and ministers. A short file of every commitment, condition and consultation outcome lets a new minister, council or regulatory team pick up a project without restarting it and gives an incoming government a reason to continue rather than review.
For an owner who wants the speed the Act offers, two tests of readiness matter more than eligibility: does the data a regulator would need to write your conditions exist today, and would your project’s next step still be under way if the government changed tomorrow?
Questions about permitting sequence on a project in development? Talk to the PRI Team.
Contact Our Team.
We would love to hear more about you and the project that you have in mind.
“In a changing climate and economy, resilient infrastructure is about fit for purpose engineering solutions tailored for now and tomorrow.”
Jesse Unke, P.ENG., PE, PMP, RMP, CMC
Vice President, Transportation & Infrastructure
jesse.unke@priengineering.com