As much as I agree it would be very useful for some of the new substance assessment processes to be much more in the character of an environmental assessment and to take a broader perspective on things, the challenge, of course, becomes what the basis is for that on the part of the federal government.
At the moment, the new substance assessment process within CEPA is grounded very much in the finding of toxicity. That's the basis on which the federal government can do something, and that's what defines the boundaries of the assessment.
If we were to take a broader perspective—and I don't disagree with the notion it would be very useful—we would then need some other constitutional basis on which there would need to be another federal hook, be it under the Fisheries Act in the case of AquaBounty, or somewhere else, in order to provide a foundation for that type of assessment and then to be able to operationalize the outcomes. That's the dilemma with that approach.
Within CEPA we're tied to a toxicity assessment for a complex series of legal reasons, and we have to broaden the basis of the assessment out from a federal perspective, or at least the grounding of the assessment from a federal perspective, in order to be able to incorporate some of these wider questions. I agree very strongly, particularly around things like products of biotechnology, but also other new substances, that we would very much want on the table these questions of what is the rationale, what are the downstream effects, what are the alternatives? They are very desirable questions to have new substance assessments, but trying to do it within the existing structure of CEPA would be challenging.