Unpacking Canada’s “What We Heard” Report on Major Projects

Earlier this year, the government proposed major changes to how it reviews and approves these projects. The goal is ambitious: get federal reviews and decisions completed within one year.

Before moving ahead, the government asked Canadians what they thought. (We built some resources for you to help with this consultation here!)

Last week, it released its “What We Heard” report, summarizing the results of that consultation. We read it closely, and there’s honestly a lot to digest, so we’ve put together a guide here to help you understand the report. 

First: Canadians aren’t necessarily opposed to building faster

One of the report’s clearest messages is that there is considerable common ground.

Industry, governments, environmental organizations, Indigenous Peoples, and members of the public may disagree about individual proposals, but they broadly recognize that Canada’s regulatory processes can be complicated, duplicative, and slow.

In total, the government received 403 detailed written submissions, including 135 from Indigenous groups, 112 from environmental organizations, 103 from industry, 21 from academics and others. It also received more than 26,000 emails from members of the public. 

Importantly, the report says those who opposed parts of the proposal generally did not oppose major-project development itself.

The disagreement was about how Canada gets there.

Participants consistently raised the need to maintain environmental protections, uphold Indigenous rights, protect scientific integrity and ensure that decisions remain transparent and evidence-based even as the system moves faster.

Environmental impacts were a major concern.

Under a strict one-year timeline, participants raised concerns about whether this was enough time to accommodate complex scientific work, including seasonal environmental studies and cumulative-effects assessments.

Some proposals would allow some early construction work to begin before the full assessment and decision-making process is finished. If work starts, money is spent, and a project gains momentum before all the evidence has been considered, does it become harder to reconsider the project later genuinely?

The report captures this concern: stakeholders warned that early work could create irreversible environmental impacts or effectively predetermine approval.

There were also major concerns about proposed changes to protections for species at risk.

Here, evidence shows public participation made a difference.

The government had originally proposed giving Cabinet limited power to bypass an important Species at Risk Act test for certain major projects. After the consultation, a senior government source confirmed that the government will no longer proceed with that proposal, following overwhelming concern about species-at-risk protections.

However, environmental groups say that there are still several other means to bypass the Species at Risk Act. 

But on other issues, the government is already moving ahead

This is where questions remain.

One of the three proposals that generated the most concern from members of the public was making the Canada Energy Regulator (CER) the sole assessor for certain pipeline projects.

Participants questioned whether a sector regulator focused on areas like engineering, safety, licensing and project operations could fully replace the broader multidisciplinary assessment traditionally provided through the federal impact-assessment process. Concerns included scrutiny of climate impacts, cumulative environmental effects, species at risk and Indigenous rights.

Yet on the same day the What We Heard report was released, the federal government announced regulatory changes that moved certain pipelines, power lines, and offshore renewable-energy projects out of the previous Impact Assessment Act process and into assessments managed by the CER.

The government says CER assessments remain rigorous and consider environmental, climate, socioeconomic, and Indigenous-rights impacts.

What evidence demonstrates that the new process will provide the same quality and independence of assessment while being faster?

The design of the “What We Heard” report raises questions of its own

The government received 403 written submissions from Indigenous Peoples and organizations categorized as stakeholders, including 103 from industry, 112 from environmental organizations, 21 from academia and 14 from think tanks. The government also proactively sent its discussion paper to 92 industry and environmental stakeholders and held meetings with Indigenous Peoples and stakeholder organizations.

Then there were the public responses: more than 26,000 emails from citizens.

The report treats those responses quite differently.

Throughout the main sections, we repeatedly see formulations such as “many stakeholders supported,” “most stakeholders agreed,” followed by shorter passages noting that “others raised concerns.” Some of the issues E4D has been particularly concerned about, such as environmental safeguards, independent assessment, political discretion and scientific integrity, do appear in the report. Still, it frequently presents them as a counterpoint to broader stakeholder support for streamlining.

Meanwhile, the report largely summarizes all 26,000-plus public emails in a two-paragraph section near the end of the main findings.

The government notes that most came through advocacy campaigns and civic-engagement platforms. But it also says something significant: respondents consistently raised the same three concerns about economic zones, changes to the Species at Risk Act, and making the CER the sole assessor of pipeline projects.

However, the report gives us very little information about how different forms of participation were weighed.

What makes someone a “stakeholder”? How does a formal submission from a corporation, industry association, environmental group or academic institution compare with thousands of individual citizens expressing the same concern? Does a campaign email count differently from an independently written email? If so, how?

The answer should not necessarily be “one person, one vote.”

But there should be an answer.

AI was also used to analyze the consultation.

This becomes even more important because the government disclosed that Cohere and Microsoft Copilot were used to supplement officials’ analysis and summarize responses to the engagement.

Indigenous submissions were specifically excluded from AI-assisted analysis and were analyzed by government officials. The government also says employees reviewed and validated the final report.

We appreciate that disclosure. And with tens of thousands of submissions, it is understandable that government would explore technology to help analyze large volumes of information.

But we still know very little about the methodology.

What exactly were the AI systems asked to do? Which submissions were processed using them? How were themes categorized? How were differences between a detailed technical submission and a form email handled? How were minority perspectives preserved? What validation process was used to ensure that the resulting summary accurately reflected the underlying submissions?

If AI helps determine what government believes it “heard” from Canadians, the public should understand how that analysis was done.

What we want to see next

The government says this consultation will inform policy design, legislative and regulatory drafting, implementation and future engagement. New legislation is expected in the coming sitting of Parliament.

As that legislation emerges, E4D will be looking for a few things.

We want environmental assessments to remain scientifically rigorous even when timelines are shortened. We want clear safeguards around early construction and political discretion. We want Indigenous consultation to remain meaningful, not become another box to check under a one-year deadline.

Meaningful consultation should tell Canadians more than what government heard. It should also show us what changed because of what it heard, and, when government chooses not to change course, why.

Stay tuned! We’ll be watching closely.