Indigenous and Northern Affairs Committee on May 1st, 2007

[The Chair, Conservative, Colin Mayes]

I call to order the Standing Committee on Aboriginal Affairs and Northern Development meeting of Tuesday, May 1, 2007.

Committee members, you have the orders of the day before you. We are continuing our study of Bill C-44, an act to amend the Canadian Human Rights Act.

The witnesses today are from the Assembly of First Nations of Quebec and Labrador, Ghislain Picard, regional chief; and from the Chiefs of Ontario, we have Angus Toulouse, Ontario regional chief. Welcome to the committee.

We're going to allow ten-minute submissions from each of you and then we'll move to questions from the committee members. Who'd like to start?

Mr. Picard, you can begin if you wish.

[Vice-Chief Ghislain Picard, Regional Chief, Assembly of First Nations of Quebec and Labrador]

Thank you very much.

[Greetings in Innu]

Firstly, I would like to mark the death of Ms. Bertha Wilson who, as a member of the Royal Commission on Aboriginal Peoples, was a champion of issues that are dear to our heart. We were obviously deeply saddened to learn of her death, which was announced this morning.

I am going to begin with a quotation:

No longer will we in Ottawa develop policies first and discuss them with you later. The principle of collaboration will be the cornerstone of our new partnership.

Cooperation will be a cornerstone for partnership between Canada and First Nations. This requires honourable processes of negotiations and respect for requirements for consultation, accommodation, justification and First Nations' consent as may be appropriate to the circumstances. Upholding the honour of the Crown is always at stake in the Crown's dealings with First Nations peoples.

The aboriginal peoples have the right to directly participate in... decision-making processes that are likely to affect them or their rights. When the status, rights or territories of aboriginal peoples are directly affected, any change to the political... framework of Canada requires the free and informed consent of the First Nations concerned.

Thank you for the opportunity to present to you on this important bill.

My comments today will be brief.

The quotes I read a moment ago are attributable to, in the order that I read them, the former Prime Minister, speaking on behalf of the federal government in 2004; the First Nations - Federal Crown Political Accord on the Recognition and Implementation of First Nation Governments, May 31, 2005, and the Assembly of First Nations of Quebec and Labrador principle No. 16 from a set of 26 principles adopted by Chiefs in 1998.

I started with those quotes because Bill C-44 was not developed jointly with first nations, at least not so with the members of the AFNQL. Despite its virtuous intent, it is another example of imposition on first nations without our consent, despite the fine promises of the Crown to the contrary. The AFNQL is not aware of any facts that would support the minister's claims and those of his officials that this provision has been debated on many occasions over the years.

I will read another one in the set of the AFNQL's 26 principles. Significantly, it is the first principle on the list.

The aboriginal peoples of Quebec have the right to the full enjoyment, as a collective or as individuals, of all human rights and fundamental freedoms, with no obstruction of discrimination, as recognized under international and internal law.

There is no doubt, therefore, that the AFNQL supports the full range of fundamental human rights of our peoples. Indeed, our very raison d'être is to advance our human rights as first nations peoples.

Ideally, Bill C-44 or a revised version should pass only being fully discussed with and receive the consent of first nations. The protection of individual human rights of first nations people should be a subject of discussion, negotiation and agreement between the first nations and Canada. The interrelationship of individual and collective rights requires a comprehensive approach. Bill C-44 is just one more piecemeal good intention that has as much chance to go bad for first nations as it has to be good for us.

The commissioner of the Canadian Human Rights Commission presented before you a couple of weeks ago a suggestion that a statement of principles to act as a set of guidelines could be produced through its discussions with the first nations after the bill comes into force. Presumably, the principles and guidelines will ensure the CHRC's good intentions to respect aboriginal and treaty rights while they pursue the protection of individual rights.

Excuse my cynicism, but first nations are still trying to heal from decades of paternalistic good intentions. Negotiating principles and guidelines of dubious legal force or legitimacy after the horse has left the barn does not seem like the best approach.

I know that all the parliamentary caucuses have already declared their intent to support the passage of Bill C-44, albeit with the possibility of amendment. I would have liked to confirm to you today the FNQL's full support of an approach that was jointly developed, or to say that our first nations members had been consulted or accommodated. Alas, I cannot say that because the federal government shirked its constitutional obligation and political commitment in that regard.

One option that the FNQL member nations might have considered, had the time been taken to consult us, would be to amend the bill to recognize the power of first nation governments, the band councils, to allow the CHRA to apply or not. There could have been a sort of notwithstanding clause, similar to the one in Canada's Constitution, that allows legislatures to suspend application of their charter of rights for five years on specific legislation.

I could have been further backed up by the ultimate power of the people to decide by referendum within six months if they want the CHRA to apply. The referendum provision could have been mandatory on band councils that would opt to enact the notwithstanding clause. It might have been an interim step in the journey toward proper recognition and implementation of the first nations' inherent right to self-government.

It seems to me that this committee has at least a couple of options to do the right thing, to do what the federal government failed to do. Indeed, if you believe like I and many others do that Parliament shares with the federal government the discharge of the Crown's legal obligations to first nations, you will adopt either one.

First, you can either suspend further progress on the bill until the federal government and the first nations report back that full consultations have been conducted, the consent of the first nations has been obtained, and consequently specific amendments, a new bill, or a new approach are required. Alternatively, this committee can recommend to Parliament that it conduct such full consultations and seek the conditions for first nations' consent.

By adopting either approach, you will be assuring first nations that nothing is being shoved down their throats, even if you think it might be good for us. You will be signaling to first nations that Parliament is taking a non-partisan and thoughtful approach that respects the highest law in the land, the Constitution. It will give adequate time for first nations to analyze and debate amongst ourselves if our collective rights are threatened by the application of the CHRA and if so, how that might be mitigated.

There is no compelling reason or urgent situation demanding that this bill be passed at this time. Let us jointly take the time to do it properly.

I must make two final important points. First, the AFNQL has not been, is not and will very likely never show favour to any federal political party. We're non-partisan. The first nations government to government, nation to nation relationship to Canada is primarily realized through its government, not by political parties. The danger of being sidelined for years if we were to favour one party over another is too great. My earlier references to the former Prime Minister's commitment to first nations in 2004 and to the accord his Minister of Indian Affairs signed on behalf of Canada with the Assembly of First Nations in 2005 have nothing to do with their political party allegiances. Rather, they are recent high water marks in our relations that must be honoured as solemn commitments of the Crown to the first nations.

I conclude by noting the need for adequate resources to first nations to manage any impacts of the bill. History again shows us that no federal bill directed broadly to first nations has ever been adequately resourced, which is another plank in the federal long-term assimilation strategy. The study of possible impacts and the guarantee of adequate resources must be determined jointly with first nations prior to the bill becoming law.

I would be pleased to answer questions. Thank you very much.

[Brief closing in Innu]

[The Chair, Conservative, Colin Mayes]

Thank you, Mr. Picard.

Mr. Toulouse, please.

[Chief Angus Toulouse, Ontario Regional Chief, Chiefs of Ontario]

Good morning.

I'd like to thank the committee for this opportunity, albeit brief, to make a presentation on the important matter of Bill C-44. My comments today are based on a more comprehensive written brief, which I would urge the committee members to review. It should be in the clerk's hands within the next day or so; it's in translation, so hopefully it will get here in the next day or two.

As the Ontario regional chief, I work closely with the Chiefs of Ontario Secretariat, which is a coordinating body for the 134 first nation communities located within the boundaries of the province of Ontario. Ontario has the largest status Indian population of any province or territory in Canada. Therefore the position taken by the Chiefs of Ontario in relation to Bill C-44 should be given significant weight by the committee and the federal government.

The position taken by the Chiefs of Ontario with regard to the bill is a general one: the inherent right to self-government and other constitutional rights attached to individual first nations and not to the Chiefs of Ontario organization. Therefore, individual first nations may come before the committee and take different positions based on their particular right and history.

Before dealing with the specific issue of Bill C-44, I'd like to take this opportunity to share with the committee the priority concerns of Ontario first nations. These concerns have been identified through an ongoing strategic exercise. In summary form only, the priority concerns are as follows: 1. Rebuild our nations; 2. Negotiate respect and recognition of first nations jurisdiction; 3. New jointly developed federal land claims policies; 4. Respect first nations treaties, lands, and resources. Each priority is described in the written brief.

With these Ontario first nation priorities in mind, I'd now like to turn to the specific issue of Bill C-44. Subject to the following six conditions, Chiefs of Ontario, in principle, can endorse repeal of section 67 of the Canadian Human Rights Act.

Condition one is consultation and accommodation. Bill C-44 should not proceed without a thorough consultation process, open to all interested first nations. The federal government has admitted that there was no specific consultation leading up to Bill C-44. Careful consultation and accommodation are a legal and a moral requirement. There is no urgency to Bill C-44, as the section 67 of the Canadian Human Rights Act issue has been pending for 30 years and first nation actions not directly connected to the Indian Act are already exposed to the Canadian Human Rights Act.

In the context of the consultation, the federal government should be required to provide a detailed legislative policy and fiscal impact assessment of Bill C-44. This is a matter of basic due diligence, which the federal government has refused to do to date.

The second condition is the interpretive provision. The bill must include an interpretive provision to balance the tension between individual and collective rights. There is a serious risk that the individual rights of the Canadian Human Rights Act will have a serious negative impact on the collective rights and traditions of first nation governments. The interpretive provision must also protect the Indian Act from the real risk of wholesale gutting because of exposure to the Canadian Human Rights Act. All serious legislative and policy proposals on the repeal of section 67 since 2000 have included an interpretive provision. That is the bright line in this policy area.

I'm referring in particular to the following: first, the Canadian Human Rights review panel, “Promoting Equality: A New Vision”--2000; second, joint ministerial advisory committee report on governance legislation--JMAC 2002; third, BillC-7 , First Nations Governance Act, FNGA, 2003; fourth, the Canadian Human Rights Commission, “A Matter of Rights” - 2005.

Without an interpretive provision, repeal of section 67 is like throwing a grenade into collective rights, and also into the Indian Act.

Condition three is the realistic transition period. The transition period for implementation of the bill should be changed from the proposed six months to three years. Again, the bright line from all serious proposals since 2000 is that a transition period of approximately 18 to 36 months is required. First nations are entitled to a reasonable opportunity to adjust programs, practices, and legislation.

The predictable result of Bill C-44 will be administrative chaos. I acknowledge the standing offer of the Human Rights Commission to assist first nations with the transition process. However, the reality is that the commission will be preoccupied with its own transition and will not have the capacity to assist the 600-and-so first nations in just six months.

I note that the six-month transition process of Bill C-44 is doubly flawed. Section 3 refers to transition in connection with undefined aboriginal authorities. It is unknown if such authorities include first nations governments and related entities.

The fourth condition is regarding adequate financial resources. The federal government must provide first nations governments with adequate new financial resources to deal with all aspects of Bill C-44 implementation. The new open-ended liabilities that flow from Bill C-44 include the following: training and capacity; legal costs defending complaints; and the costs of settlements and awards. These liabilities may be staggering in the long term. First nations governments are not in a position to assume new, unfunded liabilities. The growth of the first nations funding envelope has been capped by the federal government at approximately 2% since 1996. As a result, many first nations, especially in the north, are near or past the point of bankruptcy.

The fifth condition is the non-derogation clause. There should be a non-derogation clause protecting aboriginal and treaty rights.

And the sixth condition is first nations human rights jurisdiction. There must be a binding recognition by the federal government that first nations governments have the independent jurisdiction to develop their own human rights regimes, including regional and national human rights institutions. Long before Canada existed, first nations governments enjoyed a rich heritage of protecting collective and individual rights. The regime under the Canadian Human Rights Act may be treated as a fallback for first nations that choose not to exercise their jurisdiction in relation to human rights.

These six conditions are all critical. Most of them reflect the bright line of serious policy development since 2000. In its current form, Bill C-44 is a radical and unexplained departure from that bright line.

In landmark decisions such as Guerin, Sparrow, Delgamuukw, and Taku and Haida, the Supreme Court of Canada has made it crystal clear that the federal government is subject to a constitutional fiduciary obligation to consult and accommodate first nations when a federal proposal is likely to have a negative impact on asserted or established first nations rights.

The extent of the duty depends on the significance of the underlying right and the significance of the likely negative impact. Bill C-44 is very likely to have a very significant impact on significant first nations collective rights. The likelihood of significant impact is magnified many times by the absence of an interpretive provision. It is likely that unmitigated application of the Canadian Human Rights Act will directly interfere with the action of first nations governments on first nations territory. It is also likely the Canadian Human Rights Act will lead to the disabling of significant portions of the Indian Act. One scenario is that the protective land provisions of the Indian Act will be eliminated, opening the way for fee-simple mortgaging and the loss of reserve land.

In view of the likely significant effect on important rights, the Supreme Court of Canada jurisprudence is clear. At a minimum, a very significant and careful consultation and accommodation exercise with first nations is constitutionally required.

As Bill C-44 represents a radical departure from the bright line of policy discussion since 2000, the federal government cannot rely on past discussions to justify the bill. Most past discussions contradict the approach of the bill.

While I'm respectful of the work of the commission and while I understand the pressure to endorse Bill C-44, I cannot agree with the last-minute revision contained in the presentation to the committee. A statement of general principles will not protect the rights of first nations. There is no guarantee that later unspecified guidelines would make any difference in the face of the black and white terms of the Canadian Human Rights Act.

What is required is a binding interpretive provision developed in consultation with first nations. Before the passage of the bill, anything less would be a foolish act of faith in a federal government that has already shown its true colours by reneging on the 2005 Kelowna accord and scuttling the draft declaration on the rights of indigenous people.

In conclusion, Bill C-44 is a punitive and ham-fisted approach to the sensitive and complex issue of the repeal of section 67 of the Canadian Human Rights Act. The federal government has ignored the bright line of serious policy work since 2000 and proposes to implement the Canadian Human Rights Act without reasonable protection for the collective rights of first nations and the fiscal crisis of first nations.

Bill C-44 is consistent with a negative agenda towards first nations that is aimed at levelling collective rights and destroying whole parts of the Indian Act. The federal government position that there will be no extensive consultation on Bill C-44 is untenable as a matter of Canadian constitutional law and reflects dishonour on the Crown and all Canadians.

As described in detail in our written brief, the repeal of section 67 can only be contemplated if six key conditions apply. I respectfully urge the committee to do the right and lawful thing, which is to reject the punitive Bill C-44 and to adopt amendments and a timetable consistent with the six conditions. In doing that, it will be an incremental step towards rebuilding the relationship with first nations.

The adoption of Bill C-44 as is will be another nail in the coffin. The results are predictable: embittered relations with first nations; possible litigation based on the failure to consult and other grounds; administrative chaos; and an ever-deepening financial crisis for first nations.

That's the presentation I have for you this morning.

Thank you.

[The Chair, Conservative, Colin Mayes]

Thank you, Mr. Toulouse.

We'll move on to the question portion of our meeting.

Before we begin, I want to say that because we bridge the lunch hour, we bring in food for lunch. Committee members and witnesses are welcome to help themselves to that lunch.

Mr. Valley, please.

[Roger Valley, Liberal, Kenora, ON]

Thank you, Mr. Chairman. I didn't know you were going to feed us, so that's good news to me.

Thank you for the opportunity to speak at this committee again.

My first question will be for Chief Picard. I'm going to quote something you started with at the very beginning. You said it's clear that the statements from 2004 regarding the former Prime Minister were the start of doing business differently. You said: “No longer will we in Ottawa develop policies first and discuss them with you later.”

I'm very conscious of the comments you made about being very careful to be non-partisan. But as I see it, we were starting to form a relationship that was going to change the way business was done and a new relationship was starting. Again, I respect your wish not to be partisan, but could you tell me, from seeing a new start in 2004, what do you see right now?

[Vice-Chief Ghislain Picard]

Again, from our perspective in Quebec, we have spent years trying to promote what we consider to be a lack of justice in terms of the issues that we defend and promote as first nations in Quebec--not only in Quebec, but in the rest of the country as well. It seems to me that we are only repeating the statements that previous leaders have made. When you look at the situation in the majority of aboriginal communities across the country, it seems to me that there comes a time when you say enough is enough. We've been caught up in the situation where we seem to be playing that game where we favour one party against another party or parties. To us—and this is quite true in terms of the thinking behind many chiefs in Quebec—what we have to challenge is the capacity of the institutions such as Parliament or the National Assembly in Quebec to face their obligations.

One example I could take is that the Quebec government always refers to a resolution that it passed in 1985 recognizing aboriginal nations in that province. That resolution was adopted unanimously by all parties in Quebec. Yet when it comes time to implement that resolution, that's where we seem to be caught up in this game between what the Liberals have promised and what the other parties don't do. To me, the issues that we defend certainly merit that kind of consideration, that this is beyond party politics and party allegiances.

[Roger Valley, Liberal, Kenora, ON]

Thank you. I agree with you.

Chief Toulouse, you mentioned 134 communities that you serve. I think you know that I serve 41 in the Kenora riding, and half of those are remote sites and they face some challenges. The problem I'd like to ask you about is that there's no or very little consultation. I sometimes think what's worse with this government is that it's selective consultation. I've seen it in my riding. When they have a question to ask, they're very careful who they ask. I really worry about that selective consultation, because it will get them the message that they want delivered and it will not reflect the message of the people.

Why do you think they're reluctant to consult on a broad basis and with everyone who's involved?

[Chief Angus Toulouse]

I'm not certain why there's a reluctance to consult. I know there's a huge need or a huge requirement by the first nations to be engaged on this very matter. There are too many times, because of the Indian Act, that there have been codes or policies that have been developed at the first nation level that are going to impact negatively or create this chaos that I spoke of. There needs to be time for the harmonization to take place of the existing codes or the laws that are there now with the new approach of repealing section 67.

That's what we were talking about in Ontario. There's this need to sit down with the first nation communities throughout Ontario, and as you mentioned, Mr. Valley, the remote communities in northern Ontario are out of sight, out of mind. They're really going to need to be consulted because of the way they've done business or looked after their people since they've been there. They've demonstrated that there is a need, at times, for the collective will to be understood, as opposed to the individual rights that may be there. There is full support for the individual human rights of any first nations person to prevail.

[Roger Valley, Liberal, Kenora, ON]

Thank you. I want to follow up on that point.

I don't mean to refer to just one group, but you mentioned northern Ontario where there are fly-in communities that are out of sight, out of mind. All across Canada different communities have different levels of expertise or resources they can draw on.

It may be a bit of a tough question, but I want to know how it's going to impact on the local band offices in these remote sites that have very few resources and require outside resources for a lot of things, like professional and legal advice. I want to know what it means right in that local band office when something like this happens. I'm going to guess at it, which is always dangerous for us, but—

[The Chair, Conservative, Colin Mayes]

You only have 30 seconds.

[Roger Valley, Liberal, Kenora, ON]

I guess it's a lack of confidence in what the government's doing.

I don't think he'll cut you off, but he will cut me off.

What does it mean at the local street level and in the local band office? Again I'm guessing, but I think it's a lack of confidence.

[Chief Angus Toulouse]

You have to remember that as first nations people we've always had a collective approach to many of our issues. We have had a collective approach to the way we've lived on this land for thousands and thousands of years. There was this tremendous need for a collective understanding of why certain decisions were made for the benefit of all the people.

Right at the ground level, at the band office, there is no legal counsel. There are not enough policy analysts. There are no individuals who can assist the community in trying to deal with the issue of education, for example.

Each community struggles with providing an education program for each of the students. There is a need for a collective approach to the loss of the culture and language. Language is a foundation of who we are as a people, and I think it needs to be taught in the schools. The problem I see at times is that there may be occasions when they cannot afford to bring in a teacher to teach French, for example. That is a human right or basic right that an individual has.

That kind of concern is there right now, when first nations barely have enough resources within the current funding structure to meet their first language, which is their aboriginal language, be it Ojibway, Cree, or whatever. Then they're asked to provide additional kinds of services that may not be available to them, resource-wise.

I'm not sure if I answered the question.

[The Chair, Conservative, Colin Mayes]

Thank you.

Mr. Lemay, please.

[Marc Lemay, Bloc, Abitibi—Témiscamingue, QC]

I would like to thank you for being here this morning.

I listened carefully to the representatives of the Assembly of First Nations of Quebec and Labrador and I have been through his brief with a fine-tooth comb.

Rest assured, Mr. Toulouse, I will read your brief carefully once it has been translated and sent to us. You have my word.

I have a concern. In about 10 minutes, when members on the government side have the opportunity to ask questions, they will probably ask the same question, but from a different perspective.

We have been told that Bill C-44 is the fruit of 30 years of discussions. I was not here 30 years ago. I imagine that neither of you were either, but you have been chief and grand chief of your respective first nations for a number of years.

My question is very simple. We have been told that extensive consultations were undertaken, as a result of which, it was decided to review the act and repeal section 67, which is a symbol of discrimination against aboriginal peoples.

My question is for both of you, it does not matter who answers first. In what way were the Quebec and Ontario Assemblies of First Nations consulted? Were you consulted? What shape did the consultations take? Aside from the Assembly of First Nations and the grand chiefs, were there any other consultations? Were the so-called—and I do not like the term—isolated communities in Northern Ontario consulted? Kashechewan, in Ontario, springs to mind. We could take the example of Winneway or Kitcisakik in Quebec.

Have there been, to your knowledge, any consultations on repealing the infamous section 67 since 1977? If yes, what shape did they take?

[Vice-Chief Ghislain Picard]

Allow me to try to answer.

You are right in saying that we have been talking about these issues for 30 years. Furthermore, there does seem to be a problem and that problem certainly needs to be addressed. However, the consultations only addressed broad questions. Today, we have before us a bill on which the communities have not really been consulted. As you all know, in some cases, it is the wording that really counts.

As we both mentioned, adequate funding is also a very important issue. I was delighted to address the question that was raised earlier. There are striking examples of the bind in which first nations governments and band councils often find themselves when they have to implement new legislation or amend existing acts. Take the example of the 1985 amendment to the Indian Act. It reinstated Indian status to women who had lost their status upon marrying a non-aboriginal.

I imagine that many of the chiefs who preceded me could provide you with examples of how a lack of resources effected the implementation of this amendment. Overnight, the band councils had to prioritize certain services. I draw your attention to this because when the amendment was introduced in 1985, the band councils were never really given any extra funding to address the legitimate needs and claims of the significant number of people who returned to the community. In my opinion, the same applies here.

[Marc Lemay, Bloc, Abitibi—Témiscamingue, QC]

Mr. Toulouse.

[Chief Angus Toulouse]

The reviews and studies that have taken place so far do not constitute adequate consultation. There was no previous formal direct consultation with first nations that would have allowed for some discussion on an interpretative provision to allow first nations to talk about the detail that needs to be talked about in harmonizing what it's going to mean at the first nation government level when it provides programs and services.

So as far as we're concerned, no consultation has adequately taken place. Those reports that are listed aren't on consultation, even though it's been suggested that it's been around for 30 years.

[Marc Lemay, Bloc, Abitibi—Témiscamingue, QC]

Can I have another minute?

[The Chair, Conservative, Colin Mayes]

One minute, please.

[Marc Lemay, Bloc, Abitibi—Témiscamingue, QC]

Grand Chief Picard suggests that the committee stop its work and consult your associations. I am inclined to think that you are essentially asking us to do the same, Grand Chief Toulouse.

There is something that is really bothering me. Everybody seems to agree that the section has to be repealed. But how much time is needed for genuine consultation? One month? Four months? Eight months? A year? Should we set aside our work on the issue and resume our work in September? Unfortunately, I do not have the experience that you do with your communities. I know it is difficult to put a figure on it, but I would like us to try. Either one of you can answer, or both of you, if you so wish.

[Chief Angus Toulouse]

The various reports that have considered this over the last number of years have suggested allowing a three-year process for first nations to be engaged and to describe in detail how it's going to work. So it would take another six months to three years to focus specifically on this.

[The Chair, Conservative, Colin Mayes]

We're going to move on to Mr. Albrecht on the government side.

[Harold Albrecht, Conservative, Kitchener—Conestoga, ON]

Thank you, Mr. Chair.

Thank you to both of our witnesses for appearing today.

I don't think there's any question that all of us around this table are eager to see the lives of all aboriginal people improved all across Canada. While there's been some interplay in terms of the political aspect of it, it's true that some of these statements made by the former Prime Minister sound great. Unfortunately, the previous government had a long time to implement some of their good ideas.

I think what we're struggling with right now is the fact that this government is intending to act. Once we come close to action, we're all getting a little bit nervous as to what the final result would be, but I think it's clear that we do need to move ahead on this.

Mr. Toulouse, you used the term “there is no urgency” to repealing section 67 of the Canadian Human Rights Act. Are you confident there are no issues now, in terms of human rights violations in first nations communities, that possibly could be averted simply by having this section applied to all first nations, and then if they're not averted, at least those who are subject to these discriminatory practices would have the right to come forward?

[Chief Angus Toulouse]

What I would say, though, is that proceeding with this is going to create more chaos. It's going to create more conflict. What I was pushing on is ensuring that there's an interpretive provision that talks about those good things that are there and completing this work in a timeframe in which it's concentrated on. We have to get going on it. I know what's being said, but let's get going on it. Let's do it within the next three years and get it done.