I'd be happy to respond.
We believe that the ultimate goal of the intention of “one project, one review”, should be multi-jurisdictional collaboration, not substitution, and that where any kind of collaboration or substitution is allowed, that should be to the highest standards, so we were fairly disappointed in those provisions in the act.
We think if the government wants to move forward with retaining substitution as an option, it needs, first of all, to require any substituted processes to implement them or to fulfill the conditions that are set out in proposed section 63, rather than just be based on the minister's opinion that they will live up to some general standard.
Add a requirement to obtain indigenous consent on substitution decisions and then require participant funding on substituted processes. Right now the act exempts the federal participant funding program from substituted processes, but a lot of provincial jurisdictions, including mine, don't provide participant funding. That should be maintained.