It is a submission on behalf of a party, which is an employer. It's an employer-driven program.
Secondly, LMOs are an extremely complicated part of the law. It's not as plain or straightforward as people would believe it is. We see a significant number of refusals in British Columbia and Alberta. I have the statistics here; I can look them up and give them to you.
But given the fact that proposed section 91 indicates that all submissions under the act should require representation, and the complexity of regulation 203, I believe it's....