I think I echo the comments of several presenters who have suggested that the serious harm to fish requirement—the death of fish or permanent harm to habitat—just sets too high a bar to be useful for the protection of fish habitat for several species. Salmon is an obvious example. We think that just needs to be changed, full stop.
You could add a definition, or when you replace that definition—which, again, I think, must happen—you could expand and explain what cumulative harm means. You could include reference to cumulative harm in whatever your new habitat definition is. Even defining what cumulative harm means in the act, in the interpretation section, section 2, would be quite useful because it's a term that's tossed around quite a bit. Those are all opportunities.
I think it's really important that we align our definition about what is not allowed—the definition of what the prohibition is about—with something that is useful for fish, for protecting the kinds of fish species and the vulnerabilities that we all already know about, and that we clarify those terms where there is ambiguity. “Cumulative effects” is one of them. Throw a definition of cumulative harm—of what you're trying to avoid, of what you're asking people to look at—into the act so that it's something that we can all understand when we read it.