If you look at the “Time limit for information or studies” proposed for section 19, you see that the information that is requested by the Impact Assessment Agency is requested earlier than that process. Then, on the “Notice of commencement”, that's the information requested of the proponent.
The proponent then has the time that the proponent needs to take. It's intentional, because not all proponents operate at the same speed, and not all projects operate at the same speed—