We're recommending that lines 15 to 27 on page 18 be deleted, and I'll explain why.
The extension of the time limit in subsection 19(2), at “the proponent's request, the Agency may extend the time limit”, is very reasonable from the standpoint that many impact assessments require field work. It's not all just done on the computer. There may be an ungulate survey required and the snow conditions aren't right for the aerial counts, so the proponent simply cannot meet the time limit due to weather or other limitations.
The agency can extend the time limit to gather the necessary information. However, in subsection 19(3), if the agency extends the time limit, all of a sudden the proponent may be required to provide additional information. It seems to me that the agency should be competent enough to scope out the project at the very beginning in terms of what information the proponent would be required to provide. But, again, as I pointed out, many of these studies are field studies and there are weather limitations and other limitations that can preclude reaching a time limit.
In subsection 19(4), if the agency is satisfied, it must post a notice. But, again, in subsection 20(1), it says, “If the proponent does not provide the Agency with the information or studies within the time limit...or within any extension of that time limit, the impact assessment is terminated.” It just stops. I think this is quite unfair for the proponent. Subsection 19(2) is quite good, given how difficult it is to collect information from time to time. Perhaps the community consultation has gone on longer than the original time limit that was specified.
Again, for all those reasons, I think our amendment deleting lines 15 to 27 is reasonable, because it doesn't preclude the provision of information, but it makes sure it's fair to the proponent.