I don't know if I wrote everything you asked, but between Luc and me, we'll try to cover most of the ground.
If I can start with the railway safety inspectors and their titles, we haven't decided yet if we're going to change their titles. What they do and what they will do in the future is changing, so they will do more audits and fewer inspections, as you mentioned. But I'll let Luc cover all the details on that one.
There's a big difference--and we've had conversations with the panel on that subject--between what's being done under the Railway Safety Act with inspectors and under the other acts. I'll cover the monetary penalties at the same time, outlining some of the differences
. If I take the Aeronautics Act, for instance, there's no power defined for inspectors per se in the act. Everywhere in the act, we talk about “the minister”--“the minister shall do”, “the minister can do”, “the minister can enter premises”, “the minister can ground an aircraft”--but we don't talk about the inspector. We have a regulatory instrument, a delegation instrument, whereby the minister delegates his authorities through the chain of command. He delegates most of his authorities to me, and I further delegate that to the DG of civil aviation, and down the line, all the way to the inspector. We have an instrument of delegation for everybody in the department concerned with the Aeronautics Act.
Here it's different. The act itself delegates power to inspectors, so in theory you could have an inspector who will do something somewhere in the country on his own without consulting. Some of the recommendations here, when we're going to come up with an important monetary penalty scheme, or we're going to come out with a railway operating certificate, you could have theoretically an inspector who would decide to pull out a certificate without consulting anybody. This is not advisable, but in theory, under the act as it is written now, you could have this situation.
On the aviation side, we keep reminding our inspectors that the minister is a person--he exists; he has delegated his authority, but in some big cases it's highly advisable to consult him. For example, if somebody wanted to pull the certificate of Air Canada tomorrow, I think we should meet the minister and see if he really wants that inspector to take that action. What has been taken into account? What are the repercussions on the public interest? What are the repercussions on the economy of the country?
All those questions also apply to the railway industry, which is why we're interested in clarifying this aspect. The panel has not made a specific recommendation with regard to that, except the title.