It's difficult. As you know, the Impact Assessment Act was passed with the goal of one review, one assessment. Failures of implementation have led us to a multiplicity of reviews and a multiplicity of assessments.
The problem with the process within proposed schedule 5 is that the proponent is not obliged to provide the agency with all the information. There's an exemption in section 20-something, I believe, where the proponent could issue a notice to the agency saying, “We will not provide all the information required to receive all these federal authorizations”, and that would be permitted to proceed. There's a concern that permitting could go ahead without fully understanding what the impacts would be on particular areas of federal jurisdiction—fish and fish habitat, migratory birds, species at risk and those things.
The other difficulty is that these things are done sequentially for a reason. We need to understand the impacts of a project on the environment before we can decide whether or not these impacts on a fish-bearing stream can be justified or mitigated. Any part of the mitigation hierarchy can be applied. It's concerning.