Thank you, sir. An excellent question.
When we looked at this, for our review of CAPP, certainly one of the concerns we had was that it had a charter-like appearance and the preamble certainly indicated that it could rise to that status. That gave us pause to ask, is this an attempt to bolster up this legislation to a charter-level authority? This is fine, and if Parliament decides that's important, it should do that and proceed through the amending process accordingly.
But where we see this as a problem is that Canada has built up detailed regulatory processes to conduct environmental assessments that look at very detailed technical data, and they arrive at conclusions that look at disadvantaged groups and the job opportunities provided, development of infrastructure in the north--for example in Mackenzie--all building to a decision that rests on whether there's a likely significant effect.
The problem with this bill, from our legal perspective, is that the definitions in this act do not line up with the tests in the Canadian Environmental Assessment Act, so there's a different standard.