That is absolutely right. It's one of many provisions in the bill--which I did not have enough time to address in my comments--that is drafted in a very broad and ambiguous way.
In most statutes there's some kind of requirement that someone who files a complaint somehow be affected in some way by the activity that is being complained about. This bill gives standing to people who have no direct interest in any of these matters. They can be any resident of Canada or any member of the developing country where activities are taking place, and even if they're not close to the project or are not affected in any kind of direct way by the project, for whatever reason they can file a complaint and that complaint must be reviewed and assessed and investigated by the minister.
The threshold for deciding whether an investigation must occur is set very low under this bill. As a result, any cleverly crafted complaint that simply meets a bare prima facie test--as it's called in legal language--can trigger a ministerial investigation, and that investigation is public. That becomes known in the host government and will immediately raise issues about the permits that the company has and their ability to obtain necessary permits. It will raise issues in Canadian capital markets. It will dry up financing long before the actual decision by the minister is rendered.