The act is good and bad.
One of the problems with the act is it's complicated. But I don't know how you get around that. I think it would be nice if we could have an act that is less complicated, but I think that's a wish that won't be fulfilled.
Another area in the act that I think is increasingly going to get in the way of its being a good act is its ability to support federal-provincial cooperation. I think the answers this committee was given by Environment Canada on Monday on the equivalency provisions.... I think that's an area you should delve into in your review, and see what the provinces think. Get some firm opinions from those who are trying to work out cooperative arrangements with the federal and provincial governments.
Our view is that the equivalency provisions in the act basically say, “If you do it our way—the federal way—then that's equivalency and that's okay”. We would like something broader, which recognizes there may be different ways of doing things. Provinces tend to often work through permit programs, which aren't specifically regulations. Is that recognizable as equivalency under the federal provision in section 10? I don't think so. Other provinces are increasingly experimenting, and the federal government also wants to experiment with challenge programs to industry.