You might have to go to court and pay a lawyer, but you're representing big industries that can afford that.
In addition, you may be underestimating environmental NGOs. I don't think they have any interest in bringing frivolous lawsuits and having to pay costs. They do not have a lot of money at their disposal. So they tend to pick and choose cases that can be won and that are significant in case law.
I think there's a problem under the civil action clause. Clause 21 is not referred to under the civil action clause. So I'm going to bring in an amendment to add something like clause 21 under the civil action clause. That would add some protection for you. I imagine that would make you feel more comfortable.