When European governments were paying record premiums for liquefied natural gas in 2022 and 2023, scrambling to replace Russian supply, Canada had nothing to sell them. The gas existed. British Columbia and Alberta hold substantial reserves and always did. What did not exist was a single operating export terminal on either coast. A NATO member with the resource sat out the most consequential energy security crisis its allies had faced in fifty years, holding a hand it could not play.

That specific failure has now partly ended. LNG Canada at Kitimat began exporting in 2025, the first major LNG export facility in the country's history. It took roughly a decade from approval to first cargo. Australia, competing for the same Asian buyers, built and commissioned multiple trains in a comparable window and became one of the world's largest exporters while Canada built one.

The interesting question is no longer whether Canada has a permitting problem. Everyone including the government now concedes it. The interesting question is whether the thing Parliament passed to fix it will actually work, and that question has a definite answer coming within about two years.

What Parliament actually did

The Building Canada Act, contained in Bill C-5, passed on 28 June 2025. It creates a category of National Interest Project, and for anything designated as one, the regulatory posture shifts from asking whether a project should proceed to determining how its effects should be managed. The Major Projects Office launched in August 2025 to administer it, with a stated mandate of achieving federal decisions within two years and implementing one project, one review through cooperation agreements with willing provinces. The government's own framing is that it is compressing timelines of five years or more down to two.

On 11 September 2025 the first five referrals were announced: LNG Canada Phase 2 at Kitimat, the Darlington small modular reactor, the Contrecœur container terminal expansion at the Port of Montréal, the McIlvenna Bay copper project in Saskatchewan and the Red Chris mine expansion in British Columbia. The government put the combined economic contribution above $60 billion. A second tranche followed in November, adding Ksi Lisims LNG with its associated 800 kilometre Prince Rupert Gas Transmission pipeline and a transmission line, the Canada Nickel Crawford project at Timmins, and Nouveau Monde Graphite's Matawinie mine in Quebec.

This is a serious legislative response. It is more than the previous decade produced, and anyone who spent that decade complaining about Canadian permitting owes it an honest assessment rather than a reflexive one.

Three reasons to withhold judgment

The first is selection. Look at what was referred. LNG Canada Phase 2 is an expansion of a facility that already exists, on a site already permitted, with an operator already there. Red Chris is an expansion of a producing mine. Contrecœur has been in planning for years. Referring projects that are already substantially de-risked produces good completion statistics and tests the framework very little. The real proof is a greenfield project on contested ground, and the list does not yet contain many of those.

The second is litigation. The Quebec Environmental Law Centre has applied to the Superior Court of Québec challenging the validity of the Act itself, arguing it confers excessive federal power. Separately, the legislation was amended during passage to remove a cabinet power to sidestep the Indian Act, and First Nations leadership has said the changes made do not go far enough. A statute that compresses timelines on paper but generates constitutional litigation and duty-to-consult challenges in practice has not compressed anything. It has relocated the delay from the regulator to the courts.

The third is that speed was never the only constraint. Trans Mountain was not slow merely because of process. It required the federal government to buy the asset outright and came in at close to four times its original estimate. Northern Gateway was cancelled after years of review. Energy East was abandoned by its proponent. Each had a different mix of regulatory, legal, political and commercial causes, and a statute addressing the regulatory component leaves the other three untouched.

The critical minerals gap is the harder one

Two LNG facilities being fast-tracked is a reasonable answer to the 2022 problem. Critical minerals are the more difficult case and the more urgent one.

Canada ranks among the leading countries by reserves of several materials that underpin batteries, transmission, semiconductors and defence systems: nickel, copper, graphite, cobalt, rare earths. Its share of global production of those materials sits well below its share of reserves. The gap is partly permitting and partly something the Building Canada Act does not touch at all, which is processing. Extracting ore and shipping it for refinement elsewhere captures the least valuable part of the chain. The Crawford and Matawinie referrals are notable precisely because both are explicitly tied to domestic processing, the Matawinie graphite to the planned Bécancour battery materials plant. Whether that integration survives contact with commodity prices is a separate question from whether the permits arrive.

Mine timelines also run longer than LNG timelines. A discovery moving to production in fifteen years means decisions taken now determine production in the 2040s. Allies signing offtake agreements this decade are not waiting.

What to watch, specifically

This publication has argued for years that Canada cannot build. That argument now has to become falsifiable, or it is just a mood.

Three tests. Does any referred project receive its federal decision inside the stated two-year window, measured from referral rather than from some earlier milestone? Do the cooperation agreements with provinces materialise, so that one project, one review becomes real rather than aspirational? And does a genuinely contested greenfield project, rather than an expansion of something already built, get designated and cleared?

If the answer to all three is yes by 2028, the complaint is answered and Canada's resource position becomes a usable instrument of foreign policy rather than a permanent grievance. If the answer is no, the country will have learned something more uncomfortable than that its permitting was slow. It will have learned that the slowness was never really about the permits.