Regulatory Submissions

The Government of Canada created the “2030 Emissions Reduction Plan” to describe steps required to reduce emissions across the entire economy to reach our emissions reduction target of 30 percent below 2005 levels by 2030 and put us on a path to achieve net-zero emissions by 2050. This complements the Pan-Canadian Framework on Clean Growth and Climate Change, the Canadian Net-Zero Emissions Accountability Act, the Clean Fuel Standard and Canada’s international obligations under the Paris Agreement.

The government released a 2023 Progress Report on the 2030 Emissions Reduction Plan and invited Canadians to share their views on Canada's Climate Future through a virtual public engagement platform. The input gathered from this process will be one of several factors considered when setting the 2035 target. The implications of the 2035 target may manifest through taxation, capital markets, regulatory affairs, and access to talent, or other avenues.

PDAC encouraged their members to participate in the virtual engagement platform and submitted a commentary letter outlining the relationship between critical mineral demand through 2035 and emission projections over the same period.

In December 2022, the Ministry of Transportation introduced amendments to the Canadian Aviation Regulations (CARs) aimed at restricting commercial pilot flight time. While well intentioned, the amendments lack clarity and may significantly affect mineral exploration by reclassifying much of the industry’s aerial work as “air taxi” operations. This change has major financial and logistical consequences for explorers, as an operation may now need two pilots where one was previously sufficient. More importantly, they pose a notable safety risk, as the reduction in flight hours could limit pilot capacity to participate in evacuations or other emergencies. 

Canadian Aviation Regulations Advisory Council (CARAC) Notice of Amendment NPA-2023-006 indicates that the amendments pose safety risks in the face of an unprecedented wildfire season. As a result, the Ministry of Transportation issued further amendments to the aerial work regulations to clarify the impacts of the changes on forest firefighting operations and launched a one-month consultation period in May 2023.

As the risks to pilots and firefighters arising from the amendments are similar to those foreseen to arise in exploration operations, PDAC’s submission aims to elucidate this relationship and provide key recommendations.