I think things could be added to early construction, for example. A requirement to issue reasons would be very important. That particular guiding context, in which early construction could or couldn't be permitted, would be very helpful. The ability to amend conditions issued under the Impact Assessment Act, even if it would increase adverse effects on areas of federal jurisdiction, is particularly concerning. Introducing a requirement that this cannot specifically be done in a way that would lead to a jeopardy finding under section 73 of the Species at Risk Act would be helpful.
There's an immense amount of discretion in the legislation. I think you are well placed in this committee to recommend guardrails on the use of that discretion to ensure that environmental standards can be maintained.
