Thank you, Ed.
The next recommendations I'm going to speak to are going to echo what my PDAC colleague Lisa McDonald said so eloquently. Thank you.
Turning to our third recommendation, the act contains timelines for various phases of the assessment process. The minister would be able to effectively stop the clock should the proponent not provide the necessary information within the timeline required by regulation or other prescribed activities not be completed. This is reasonable, but we suggest that the impact assessment act provide the minister with more guidance about the circumstances that would justify this suspension of statutory time limits.
The minister may also give notice of a deadline extension of up to 90 days, and the Governor in Council may extend the original extension an unlimited number of times. Unforeseen circumstances might indeed arise when an extension would be justified, however we believe and recommend that similar to the requirements for the minister when extending the deadline, the Governor in Council should provide reasons for the extension to ensure it is applied in a rigorous and transparent manner.
Our fourth recommendation is as follows. The act provides up to 45 days for the minister to decide to refer a project for a panel review, however no time limit is provided for the next step where the minister establishes a panel with its terms of reference to undertake the review. We recommend the act establish such a timeline.
Here is our fifth and final recommendation. The act allows for 180 days with possible extensions for the planning phase. Many parties must be involved: other federal regulators, departments and agencies, provincial governments, indigenous governments and entities, stakeholders, and the general public. The proponent must be forthcoming with information to meet the 180-day deadline, however failure by other parties to participate in a timely manner has the potential to result in a decision by the minister to extend the timeline.
CHA supports the minister's ability to suspend timelines, should that be required, to facilitate input from diverse groups or for other appropriate reasons, however we suggest that should a party take an unreasonable time to respond, or even refuse to participate, the minister of the agency be given explicit authority to issue a notice of commencement. This would provide a balanced mechanism to ensure that all parties are engaging in good faith.
In conclusion, I would like to reaffirm the hydro power industry's support for the government's objectives in the impact assessment act. We support the assessment regime being rigorous, transparent, respecting the rights of indigenous peoples, and being based on thorough, evidence-based analysis to ensure sustainable development in Canada.
A rigorous process that has public confidence is essential to earning our social licence to operate.
Once again, we would like to thank you for the opportunity to address you this afternoon.