Substituted impact assessments in Canada: What they are and how they work

A substituted assessment process allows another jurisdiction to conduct the assessment of certain major projects instead of the federal government if certain conditions are met. Learn how substitution works under the Impact Assessment Act (IAA), including its benefits, steps, and requirements.

On this page

• An introduction to substituted assessments
• Benefits of a substituted assessment
• Understanding how substituted assessments work
• Approving a substituted assessment request approval

An introduction to substituted assessments

A jurisdiction, such as a provincial government, can ask to replace the federal impact assessment process of a major project with its own process. This is known as substitution. It allows for a single assessment that meets federal and provincial requirements, supporting the goal of "one project, one review."

In other words, if a project requires assessments both federal and provincial governments, the province can ask to lead the process on behalf of both levels of government, using its assessment process and following its timelines. Substitution is appropriate in circumstances where a province is generally willing to and has the authorities and resources to incorporate key federal issues into its process.

Benefits of a substituted assessment

A substituted process improves the efficiency of project reviews by using a single assessment.

Substituted assessments:

• reduce duplication
• simplify the process
• ensure meaningful participation without repeating steps
• save time and resources for project proponents, Indigenous groups and anyone else involved in the assessment

Proponents

The person or entity that will carry out the proposed project.

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Understanding how substituted assessments work

Below are the steps for requesting, approving and undertaking a substituted assessment process.

1. A jurisdiction submits a substitution request to the Minister of Environment and Climate Change (the Minister) during the planning phase of an impact assessment.
2. The Impact Assessment Agency of Canada (IAAC) publishes the request, leads a public comment period and consults potentially affected Indigenous communities about this request.
3. The Minister considers comments received during the consultation period along with other information about the other jurisdiction’s process before deciding to approve the request to substitute the project assessment process.
4. If approved, the jurisdiction conducts the assessment with support from IAAC and other federal departments, as required. For example, substitution has been used regularly and successfully in British Columbia, and both levels of government continue to collaborate and support each other as needed throughout the process.
5. At the end of the process, the jurisdiction prepares an assessment report.
6. The federal government and the jurisdiction make their own final decisions, with the federal government focused on setting conditions to address significant adverse effects within federal jurisdiction.

This approach supports the principle of "one project, one review" by eliminating duplication while ensuring that both levels of government uphold their respective responsibilities.

Approving a substituted assessment request

To approve a substitution request, the Minister must be satisfied that the jurisdiction’s process meets certain conditions:

• considers the factors under subsection 22(1) of the IAA, such as Indigenous Knowledge, environmental effects, and contributing to sustainability
• involves relevant federal experts
• ensures consultation with affected Indigenous Peoples
• provides opportunities for meaningful public participation
• provides public access to records related to the assessment
• prepares a publicly available assessment report, which is to be submitted to the Minister. The report must:
  • set out the effects likely to be caused by the project
  • identify adverse effects that fall under federal responsibility
  • specify which of those effects are significant and their extent
  • set out how Indigenous Knowledge was used to understand the project’s effects

Federal

These are departments and agencies that have specialized information or knowledge. They must provide this information on request to IAAC (or another body that is conducting an impact assessment, such as a review panel). They must also engage with the proponent.

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