RAC Statement on the Building Canada Strong Act (Bill C-39)

Ottawa, Ontario, September 24, 2026 – The Railway Association of Canada (RAC) welcomes elements of Bill C-39, but believes the legislation falls short of its ambitions in several key areas.

A central proposition of Bill C-39 is to breathe statutory life into the government’s ambition to accelerate, streamline, and better coordinate federal approvals for infrastructure projects. RAC applauds that objective. Central to achieving it, however, will be thoughtful and considered execution. RAC also supports the bill’s expansion of geographical exceptions for constructing new rail lines without the need for approval from the Canadian Transportation Agency. This will help accelerate the development of new rail capacity by removing unnecessary, slow, and in many cases duplicative, regulatory processes.

The legislation also includes some positive changes to the Canada Labour Code. The proposed special mediator, which will issue a public report, would improve much needed transparency and accountability. Allowing employer applications for geographic certification should help achieve more stability for bargaining at B.C. port terminals.

Unfortunately, the proposed reforms fall short of solving Canada’s labour instability challenges in our critical transportation supply chains. The legislation appears to accept that the government should only be able to react to a strike or lockout after it has started, rather than avoid the significant damage caused by frequent and recurring work stoppages in key transportation sectors, even when the parties are hopelessly deadlocked, there is no longer any meaningful bargaining taking place, and the national interest is clearly impaired. In these exceptional but impactful situations, the government needs effective legal tools to protect all Canadians; to avoid the significant harm to Canada’s national economy, supply chains, and international reputation; and to avoid increasing consumer costs and diverting cargo to less efficient, more costly routes. This balance can be achieved in a way that fully respects collective bargaining and Canada’s Constitution. It is critical to send a signal to the world that Canada is a reliable trading partner and stable place to invest and do business.

Bill C-39’s proposed resurrection of extended interswitching for yet another pilot will undermine the government’s trade diversification, investment, and economic growth objectives. The data from two previous trials of this policy clearly demonstrate that the key consequence is the diversion of Canadian traffic and trade to a U.S. railroad, along with the jobs and investment that go with it. Compounding the harmful effects of the policy, the bill’s proposed coming-into-force approach sets up ongoing regulatory and investment uncertainty, the opposite of conditions that would help attract investment into Canada’s supply chain infrastructure.

RAC is also concerned about the bill’s proposed creation of a National Trade Corridors Council, which appears aimed at adding layers of duplicative and unnecessary bureaucracy. This concept risks weakening network efficiency, throughput capacity, fluidity, and investment, undermining the overall health and performance of rail networks across North America. Canada benefits from a freight rail industry that is among the safest, and most efficient and cost-competitive in the world. Supporting and enhancing these industry characteristics is best achieved by harnessing the power of free markets, private sector operations, and a strong investment climate, not government-driven interventions in complex supply chain operations.

RAC looks forward to working constructively with all Members of Parliament and Senators as they study Bill C-39. RAC urges all Parliamentarians to support the strengths of Bill C-39, while at the same time taking action to address its weaknesses. This is the only way to ensure the legislation supports, rather than hinders, the government’s economic growth, investment, and trade diversification agenda.