Biodiversity Boreal Climate change Conservation planning Natural resource development Peatlands

The Mitigation Hierarchy in Federal Policy in Canada: A Call for Coherence and Consistency

Poulton, D. & Ray, J.

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As Canada moves to accelerate federal approvals for major resource and infrastructure projects, this report calls for a unified federal framework to apply the mitigation hierarchy - a structured approach to avoiding, minimizing, remediating, and offsetting environmental impacts.

Key points

Despite its widespread international use, the hierarchy is applied inconsistently across federal departments and agencies, creating confusion, inefficiencies, and risks to biodiversity, climate objectives, and public confidence. A coherent, centralised policy would align the federal major projects agenda with Canada’s commitments to halt and reverse biodiversity loss, providing clarity and predictability for both regulators and industry.

1. Sequence of actions is critical: The mitigation hierarchy prioritizes avoiding impacts first, followed by minimizing, remediating, and only then offsetting - each step carrying greater ecological risk and uncertainty.
2. Policy fragmentation: Canada currently has multiple, uncoordinated federal applications of the hierarchy, creating confusion and inefficiencies across departments.
3. Federal opportunity: A unified framework could align policy language, expectations, and accountability across agencies without requiring new legislation.
4. Benefits for major projects: Applying the hierarchy early in project planning reduces costly redesigns, litigation, and conflict while improving outcomes for biodiversity and climate.
5. Offsetting as a last resort: The report cautions that offsetting should not substitute for earlier steps in the hierarchy. It must be applied only after avoidance, minimization, and remediation have been fully pursued, and never as a shortcut to approval.

Recommended citation

Poulton, D. & Ray, J. (2025). The Mitigation Hierarchy in Federal Policy in Canada: A Call for Coherence and Consistency. Wildlife Conservation Society Canada [WCS Canada]. https://doi.org/10.19121/2025.Report.52275