That's a tough one. We did have recommendations that we had put forward pre-bill with respect to section 22—sections 17 to 22—in case the bill did open up those sections. That's where my focus has been.
I think there may be opportunity through the implementation framework to look at some aspects of how we could build in some quasi-enforcement. There's a two-year time frame to develop an implementation framework with respect to the right to healthy environment. I think looking at ways to have some kind of complaint or enforcement mechanism through that may be something, but I really would encourage the government to look again at sections 17 to 22 of CEPA and go back to some of our early recommendations pre-bill on how to strengthen those sections.
Disconnecting the requirement for investigation before bringing in an environmental protection action was one of the recommendations. Removing some of the cost barriers to a citizen's bringing enforcement action under section 22 would be another one, as is removing the idea that the Environmental Protection Act can only be brought when there's a highly significant risk. That was the recommendation that the department made in their earlier discussion paper, to remove the word “significant” and just say when there's a risk. That was, for some reason, not followed through in the bill.
I didn't answer your question directly. I went back to section 22, but I still think that a future bill could maybe help address those issues with respect to sections 17 to 22.