For major expansions of treatment plants, usually there is a federal trigger, which can be through different processes, such as if the project involves an impact on federal lands, if a project is receiving infrastructure funding from the federal government, and if there is the need for permits, either through the Fisheries Act or for the Navigable Waters Protection Act. It really depends on where the project is located in Canada and the type of potential impacts the project may have.
As my colleague said, when our members are looking at these projects, it's generally a long-term planning process. It takes 10 to 15 years to site a new waste water treatment plant, design it, build it, and operate it. When they engage consulting firms to do this sort of work, they're always looking as far in advance as possible at all the preferred alternatives. If there are triggers under the federal act, will they have to do a harmonized federal-provincial EA? Again, it depends on where the projects are located, the receiving waters impacted, etc.