Indigenous and Northern Affairs Committee on Sept. 25th, 2017

[Corinne McKay]

I'm not clear on the question, but with our self-government, one of the issues that recurs frequently is that we're having to travel to Ottawa to remind our federal counterparts of provisions. We know that the treaty was an agreement between the federal and provincial governments, and we have to remind Canada and its different ministries of their obligations under our treaty. We have some provisions in our treaty that were not considered.

One example is environmental protection. We have a chapter in our treaty regarding the environment and have had to go on several trips to remind our federal counterparts of the provisions in our treaty. Such issues are not covered by our current funding, so we have chronic underfunding as a result of having implementation issues with our treaty.

[Cathy McLeod, Conservative, Kamloops—Thompson—Cariboo, BC]

Does it sound fair to say that it's a very long process to come to a treaty, but that we still have not got to the seamless implementation process yet?

[Margaret Rosling, General Counsel, Nisga'a Lisims Government]

We handed out some material before we sat down this morning. You're free to take it with you. It elaborates on some of the comments that President Clayton made in her opening remarks.

In the middle of the paper, you'll see the real thrust of what the Nisga'a Nation wants to make sure the committee hears today: the real challenges that modern treaty nations have found in the implementation of the modern treaties. Although there have been many successes, and the Nisga'a Nation has thrived in many ways under its modern treaty that's been in effect for the last 17 years, some of the implementation of the treaties has been a challenge. This led to the establishment of the Land Claims Agreements Coalition, which I'm sure you're familiar with, back in 2003. The coalition acts as a group to try to work with the federal government to be more successful and to implement the modern treaties. There is a need, we say, for a comprehensive policy within government for implementing modern treaties and for ensuring that there is an appropriate review body that reports directly to Parliament on the success that we're having in implementing our modern treaties.

[Cathy McLeod, Conservative, Kamloops—Thompson—Cariboo, BC]

Thank you.

Christopher. can you tell me a little bit about Westbank's path to self-government? You probably weren't there at the very start of the process, but how did your leadership decide to head down that path as opposed to some of the other options that might have been available? You don't have the grey hair that Chief Pasco has.

[Christopher Derickson]

Not yet. There is some coming in.

There's more information if you want to know the story of Westbank.

We had a federal judicial inquiry into the affairs and dealings of a previous council back in the 1980s. Out of that inquiry, one of the chief recommendations was that WFN needed to be a self-governing nation because the Indian Act structure of governance wasn't enough, or robust enough, for a first nation as entrepreneurial or as aggressive as Westbank was in pursuing business at the time. Because that was a recommendation coming from a federal inquiry, it forced Canada to the table, and we moved into self-government negotiations at that point.

That road to self-government went through several iterations of self-government agreements that we brought back to our community for votes. It took three different votes for self-government to finally be passed.

[The Chair, Liberal, MaryAnn Mihychuk]

That's seven minutes.

We're going to move the questioning on to MP Romeo Saganash.

[Romeo Saganash, NDP, Abitibi—Baie-James—Nunavik—Eeyou, QC]

Good afternoon, and thank you for being here.

I want to start by saying that, from experience, I've learned that once you negotiate an agreement or a treaty, the real challenge starts from there. I always give the example of the James Bay and Northern Quebec Agreement. In section 28, it says that, on an equal basis, Canada and Quebec will build a community centre in each Cree village. It's as clear as I just said it. However, for more than 25 years, that chapter was never implemented because both Canada and Quebec claimed that there was no definition of a community centre in the James Bay and Northern Quebec Agreement. We had to take both Canada and Quebec to court in order to implement that.

Eva, you said in your presentation that implementation remains a challenge for your nation. I'd like you to give us a couple of examples because even Corinne said that you have to travel to Ottawa to remind governments of the obligations under your treaty. I'd like you to elaborate a little bit on that and perhaps propose some recommendations as to how we can deal with those kinds of issues in the future.

[Corinne McKay]

The way we see moving forward from here on implementation is in the information that's been presented and in recommendation number four. There must be an independent implementation and review body separate from the Department of Indian Affairs and Northern Development and it could be the Auditor General's department or a similar office. Annual reports would be prepared by this office.

One of the challenges we've had in dealing with implementation that falls under the auspices or within the Department of Indigenous and Northern Affairs is that there's always a challenge with the corporate memory, people change and move on to different positions and we have to start the whole process over again. If we have a department that's independent, that's objective, then we can deal directly with the one department. In all of our dealings we have to go to different ministries to deal with the obligations in our treaties because it's not just with implementation. We have met with the Minister of Fisheries, the Minister of Transport, and we've met with virtually all of them.

We have to address the chronic underfunding under our fiscal financing agreement and this funding that we have needs to be in a new relationship in our fiscal financing agreement. We know that many of the provisions that we have to follow are inherited provisions from Indian and Northern Affairs. We just have to pick up what's working and leave behind what isn't and create a new relationship.

We know what we are obligated to comply with within our treaty and we are well versed with the abilities we have and the rights we have in our treaties. We have always viewed that treaty as a book of opportunities and it defines the relationship between our Nisga'a Nation and the federal and provincial governments.

[Romeo Saganash, NDP, Abitibi—Baie-James—Nunavik—Eeyou, QC]

My time is almost up, but I want to talk reconciliation with you, Chris.

You mentioned that one of your first recommendations was on the rights recognition and reconciliation table that needs to strengthened. I want to read you a quote from the Supreme Court of Canada in the Haida Nation case. The Supreme Court said:

Reconciliation is not a final legal remedy in the usual sense. Rather, it is a process flowing from rights guaranteed by s. 35(1) of the Constitution Act, 1982. This process of reconciliation flows from the Crown’s duty of honourable dealing toward Aboriginal peoples, which arises in turn from the Crown’s assertion of sovereignty over an Aboriginal people and de facto control of land and resources that were formerly in the control of that people.

Is that the basis of your talks, what was set out by the Supreme Court in terms of reconciliation?

[Christopher Derickson]

At the Okanagan nation level, yes. It's a focus on recognition of our rights and title to our traditional territory.

[Romeo Saganash, NDP, Abitibi—Baie-James—Nunavik—Eeyou, QC]

One of the other criticisms I would have, and anybody can take this one, is don't you feel that there's an inconsistency with federal policy and the constitutional issues that we have with our treaties, agreements, and so on and so forth? Because I'm not too sure how those two jibe, having a policy on lands claims, for instance, and the constitutionality of the documents, treaties, and agreements that we have? Is it something that needs to be considered as well in our work?

[The Chair, Liberal, MaryAnn Mihychuk]

A very short answer, please.

[Margaret Rosling]

If I may, I think that the concise response is that implementation of modern treaties is really suffering from the fact that there is not a policy for implementation of modern treaties and a review body that is mandated to ensure that those treaties are implemented. Until such a time as that is done, the implementation of the treaties and the success of modern treaties are really going to be at risk.

[The Chair, Liberal, MaryAnn Mihychuk]

Thank you.

The questioning now moves to MP T.J. Harvey.

[TJ Harvey, Liberal, Tobique—Mactaquac, NB]

Thank you, Madam Chair.

I want to start by answering Ms. Abbott's question as well as I can. I am from New Brunswick and I grew up in large-scale agriculture, but very much a family farm. The connection that I feel to the land in New Brunswick, given my personal life circumstances growing up, is really strong. I've spent the last 15 years advocating for the rights of agricultural producers across the country, specifically young farmers, because that is the demographic of people that I fit into.

Since getting elected and having not had very much relationship with first nations or indigenous communities in my riding, I've cherished the working relationship that I've garnered with the two indigenous communities there. It has become one of the most important relationships to me, and I would consider the chiefs in both of those communities to be among my best friends. Having had the opportunity to sit on the natural resources committee for the last two years, I think it's important that we recognize that these should not be silos. The environment, natural resources, health, and indigenous issues should all work collaboratively together. I don't like the four-quadrant approach. I like more of a model that's based on something like the rings around a star, where the centre is the centre of the conversation and each of the issues spin around the centre simultaneously. I think that better reflects where we should be trying to go as a nation.

That's my best shot at answering your question.

The second statement I would like to make is to Chief Pasco. In New Brunswick we have a saying, and given your speech earlier.... I don't have any questions for you, but I think you're good people and I appreciate your comments.

Mr. Derickson, my questions have to do with the comments you made about self-governance, especially taking into account the overarching success you've had on some levels as a first nation community since you became self-governing. You talked about the economic challenges that come from managing growth under a rigid process. Could you elaborate on how you think the process could be re-evaluated or changed to better reflect the growth in GDP or economic activity, and numbers of people who live there, to keep pace with your growing community? How could that model be used for other communities that wish to do the same thing, or that wish to govern using a different model?

[Christopher Derickson]

I think the short answer is that we simply need to be provided with access to the revenues that are being generated on our lands. You need to be mindful that we don't have the designation of a municipality, so that excludes us from accessing all the grants that a municipality has, the infrastructure dollars, the gas tax. Until there's a recognition from the province that results in a change, or for instance when Canada is drafting those grant applications and they remember that there are first nations like Westbank out there that need to access those dollars and because those funds are designated for municipalities, we don't have access to them.

A new fiscal relationship, a new tax-sharing arrangement with Canada, would be advantageous. We don't want to only be self-governing; we want to be self-sufficient. By all accounts, we've raised the revenues necessary to become completely self-sufficient, not needing any dollars coming from Canada other than what we're already raising on our lands. I think a relationship like that for first nations in situations similar to ours would be ideal.

[TJ Harvey, Liberal, Tobique—Mactaquac, NB]

Ms. McKay, each of the panels we heard this morning addressed common themes, such as the specific changes process or adequate funding, direct communications with indigenous peoples, joint oversight, creating fundamental systematic change of the policies that are being worked on collaboratively.

My question is open to any of you within the panel. What are the changes that you feel would be the most reflective of what you would like to see in terms of changing the game on this issue?

[Corinne McKay]

I'd like to start and then call on our general counsel, Margie, to complete the response.

We are currently participating in developing a new fiscal policy. We are working with our modern treaty colleagues through the Land Claims Agreements Coalition. There is some good work being done at that table. It's not easy work and quite demanding. With the work of the development of a new fiscal policy, we would hope that any policy honours the Nisga'a treaty, because the options are a challenge to the federal government. There is a lack of compliance with the treaty. We are optimistic of that process.

The one issue I want to raise before I pass the mike over, simply because you spoke to the issue in our first nations community, is the determinants of health. We have heard the World Health Organization say that for every dollar you invest in children, you save $7 in social costs. Through the work we are all doing as first nations, and we're doing this not only for our people in our communities but for the generations coming behind, we want that investment to benefit us all as Canadians.

I'll turn the mike over to Margie.

[The Chair, Liberal, MaryAnn Mihychuk]

I'm sorry, we've run out of time.

I want to thank you, on behalf of all the MPs, for coming and presenting your stories, your recommendations, and your in-depth questions about why the government is still asking...when that wisdom was provided many, many decades ago.

We hope we've provided some responses to you that makes sense. We look for a better and a stronger Canada, and a better working relationship.

One of the areas that we as members identified was the land claims issues, and that's why we're here. We're hoping to advance these issues and make things better.

Meegwetch. I thank you for coming.

We're going to take a break for lunch.

[The Chair, Liberal, MaryAnn Mihychuk]

Welcome.

This is the continuation of hearings by the Standing Committee on Indigenous and Northern Affairs. We are here on a study pursuant to Standing Order 108(2) of specific claims and comprehensive land claim agreements.

I want to recognize that we are here on Tsawwassen traditional territory, and we're starting our process across Canada here in British Columbia.

You will have 10 minutes to present, then we'll go into rounds of questions, and you'll have an opportunity to answer.

We will be working on the report for the next couple of months, if you wish to submit something more robust. As long as it comes in by the middle of October, it should be able to supplement our study, help us produce a report that we're all proud of, and make some positive changes for Canada and, of course, for the nations that are involved in this trying process.

I want to welcome you here.

We have Havlik Metcs Limited, Morgan Chapman. We also have First Nations of the Maa-Nulth Treaty Society. Sioux Valley Dakota Nation from my home province is not here.

I will begin with you, Morgan.

[Morgan Chapman, Research Associate, Havlik Metcs Ltd.]

Thank you, Madam Chair.

My name is Morgan Chapman. I'm here presenting on behalf of Havlik Metcs Limited. We're based in Vancouver, Calgary, and Victoria and we're here representing over 15 first nations in Alberta and British Columbia, namely the Lesser Slave Lake Indian Regional Council's treaty and aboriginal rights research program, and the Treaty 8 Tribal Association's TARR program. We also service several independent first nations that are not members of consolidated claims research units in British Columbia.

What I'm going to lead with today is something that you might not find in the material I provided a bit earlier, but is a theme that's come up in the prior presentations this morning. That's about the implementation of treaties. Our Treaty 8 first nations that we serve in Alberta and British Columbia signed their historical treaty in 1899. There are still numerous components of that treaty that have yet to be implemented. Those are the types of claims that we bring forward to Canada through the specific claims process.

As a firm, we've endorsed the 2012 National Claims Research Directors' joint submission, Justice at Last, with the main title “In Bad Faith”. Once Justice at Last came into effect under the specific claims process, we lost a number of categories of claims that were specifically rooted in those of an ongoing and variable nature or were breaches of treaty promise. We can no longer bring those categories of claims forward.

That is a unilateral policy change that was implemented by the government without consultation with the members of first nations communities who were taking advantage of the previous process and continue to take part in the process going forward. Claims today that we can bring forward are based on lands or assets promised under the treaty or issues of fraud on behalf of government agents. Those are three really big categories that we can still deal with. The Specific Claims Tribunal Act in that capacity has been used to strangle the specific claims process and the claims brought forward by first nations communities.

Changes to the act are needed in order to prevent that continued strangling of claims brought forward by first nations. As was also mentioned by Chief Judy Wilson this morning, the government itself wrote the rules to suit itself. It's always the judge, banker, jury, and executioner on the claims that are brought forward against itself. Court is seldom a desirable option because of the high cost, and the crown resorts to technical defences such as statutes of limitations.

On the funding side for specific claims, between 2010 and 2015, our personal clients received up to a 57% cut to the funding used to research and submit those claims to the government. Our colleagues on the other side of the table at Indigenous and Northern Affairs did not receive a cut. We were asked during that same time period to address workloads and changes implemented via unilateral policy implementation, namely the minimum standard, and we identified that as creating a 35% increase in our workload as a firm. That impact has cost us literally thousands of researcher hours just within our own firm. It has stalled the submission of claims, and it has been done by using make-work projects such as transcriptions for documents that are relatively clear, requiring clearer copies for documents that were photocopied askew or had highlighter marks on them but were still legible, and these are often things that do not impact the validity of the claim brought forward by the nation.

Other issues that we've experienced were cuts to other institutions such as Library and Archives Canada, and the inability of those institutions to provide us with records also strangled our progress on any claim research or submission.

One of the other big changes coming into Justice at Last was this idea of black-box processing of claims. Our firm used to have quite a high level of engagement with our analyst compatriots on the department side, and under the first few years of Justice at Last, namely the last 10, we lost that ability to collaborate with the analysts and have any sort of discussion. Counter-research reports used to be issued and submitted to the first nation that identified Canada's acceptance of a claim, on what grounds, or a denial of a claim. Evidence given to the first nation to explain those types of things are no longer received.

Members of the committee have not yet had an opportunity to read and review the 2016 Office of the Auditor General report. I would strongly suggest that document form part of your research into the issues around specific claims. Many, many, of the issues brought forward by first nations communities and by my colleagues in other claims research units from British Columbia—and I'm sure you'll hear from across Canada—have been bringing these claims forward for a number of years.

The Auditor General's report that was released last year solidified those claims as having evidence. So any issue that we've brought forward, the Auditor General found evidence of that issue being brought forward. There was proof, and it's undeniable. I would strongly recommend that you take that report into consideration.

We have seen some positive changes since the release of the report. We have been able to reach out to analysts. We have had some of those collaborative opportunity approaches come forward, and we've also seen a return to at least some information-sharing from the department when it comes to a reasoning for a claim being accepted. We haven't yet quite got to the point of a claim being accepted as valid after this period of change. But we are seeing some positive hints. Our biggest thing is we'd like to see those changes entrenched in the legislation because right now, it's at the whim of the director of the department or the head of INAC or the now-split department. Until those types of changes are solidified in legislation, there's no guarantee that this type of behaviour and that level of engagement with the first nations communities and the CRUs doing this work is going to be continued.

When we talk about the resolution of claims and the negotiation process, one of the biggest entitlements that you've heard today is this full and final release. The problem when it comes to the specific claim side is the government was willing to acknowledge partial acceptances, so they would find one of a number of allegations made in a file's specific claim to be valid but not find an outstanding legal obligation for the other allegations made by the first nation.

When it came time to negotiate those claims, if the claim was found to be a value large enough to determine that negotiations were possible, to agree to negotiate the first nation would have to agree to give up any right to pursue the other aspects of the claim where Canada didn't find an outstanding legal obligation. The way one of my directors has put it is Canada agrees to negotiate as long as the first nation agrees not to.

Another thing you see lots of is the elimination of the claim backlog. Again, this is a large part of the idea of partial acceptances, of getting a part of your claim recognized. That ends up pulling the claim back out of that process. It lands back in our CRU's lap. We end up splitting and resubmitting these claims, which doubles or triples workload for an issue that had it ended up at a negotiation table, Canada might have found a legal obligation or might have been willing to discuss those issues and resolve the concerns of the community.

As we've all identified, 10 minutes today is not a lot of time to go through all these issues, so as many others have said, a more fulsome report will be coming from our firm, we hope.

A couple of quick things, I didn't quite catch the time, but I'll keep going.

[The Chair, Liberal, MaryAnn Mihychuk]

You have two minutes.

[Morgan Chapman]

Change in federal negotiators; you've heard about that today. I can give you a few more concrete examples. We have one community that's now on its ninth federal negotiator. If you do that over the term of the negotiation, nine federal negotiator changes and a year uptake on each of those negotiators to come to the table, and again you've heard this morning, many of them come without a mandate. They come without the ability to offer anything more than an update on Canada's decision-making and are not able to make a decision.

I'm going to flip quickly into my recommendations and hope that I can get through most of them in my remaining time today. Obviously, there are many more but the Specific Claims Tribunal's power and authority need to be expanded and enhanced, particularly with respect to mediation and negotiations case management. We asked at one point for mediation with Canada and we were denied because to participate in mediation, both parties have to agree, and Canada refused to agree to mediate.

First nations must have the right to invoke the Specific Claims Tribunal's intervention without Canada's consent at any point in the process and not just after three years of collapse within the negotiations framework.

An independent specific claims funding allocation body should be established to fund all aspects of resolving outstanding claims. The Specific Claims Tribunal Act should be amended to eliminate restrictions on the types of claims. Any breach should be valid.

The Specific Claims Tribunal Act should be able to award non-pecuniary damages for breaches of solemn and sacred treaty promises where the honour of the crown is at stake.

The Specific Claims Tribunal Act should have the authority to hear claims before three years have elapsed if Canada has been stalling or impeding negotiations.

The Specific Claims Tribunal should have the authority to reduce or eliminate outstanding negotiation loans incurred as a result of the federal foot-dragging, policy flip-flops, or bad-faith negotiations.

And finally, we need to eliminate the early review submission process by the specific claims branch so the claim should start with a finding of validity by the Specific Claims Tribunal.

Our hope is that this process will encourage Canada to honour the four pillars outlined in Justice At Last.

In summary, all of Canada's practices in an effort to save funding and reduce costs at the specific claims branch have ended up frustrating first nations to the point where they are driven out of the process entirely and wind up in court or at the tribunal, which are both a more costly endeavour than if Canada were to have honourably negotiated fair settlements for these claims from the start.

[The Chair, Liberal, MaryAnn Mihychuk]

Perfect. Thank you for your presentation.

We now have our second delegation.

[Chief Charlie Cootes, President, First Nations of the Maa-nulth Treaty Society]

First of all, I want to thank the Tsawwassen people for allowing us to take care of this important business on their traditional lands.

The Maa-nulth first nations treaty society represents the five first nations signatories to the Maa-nulth treaty. Specifically, we are the Huu-ay-aht First Nations, the Ka:’yu:’k’t’h’/Che:k’tles7et’h’ First Nations, the Toquaht Nation, the Uchucklesaht Tribe and Ucluelet First Nation.

The Maa-nulth Treaty came into effect in April of 2011 and is currently the only modern treaty concluded with multiple nations. The fact that it took our five communities a decade and a half to negotiate and ratify this instrument speaks to the complexity and the difficulty of treaty-making and the process for reconciliation within Canada.

Treaty-making is complex, expensive, and politically difficult. As a result, any submission and short presentation intended to provide an analysis of Canada’s policy on modern day treaty-making can only scratch the surface. Because of time and resource constraints, we will limit this submission to a few observations and recommendations.

However, speaking as parties who have completed a modern treaty, we have paid the price for making a treaty and have learned a great many lessons. We have a deep understanding of what is required to negotiate a treaty, how a first nation transitions out of the Indian Act into treaty structures and self-government, and how to function as governments and economic entities in a post-treaty world.

Each of the Maa-nulth first nations can now point to their governments that are founded on community-approved constitutions, comprehensive self-made legislation, and a respect for the rule of law. Each of our communities can now point to significant economic success stories, and each of our communities can now identify instances of cultural rejuvenation and reconciliation with our neighbours. These general successes cannot and should not be seen as a completed undertaking. They are merely the first step in a long and complicated journey to reconciliation.

What we will suggest in this submission are simply a few observations and recommendations on how to make that journey easier for everyone. We've limited our presentation to identifying three areas.

First, on modern treaties and reconciliation, from our experience, modern treaties should be seen, not as an end in themselves but as a constructive tool in successfully terminating the historic colonial relationship that has characterized our experience with non-aboriginal governments and societies. A modern treaty is a tool that enables us to define our own institutions of government and to empower those governments to better meet the needs of our citizens. While these are tools that make immediate changes in the structure of our relationship, the success in the use of this tool can only be measured over time. True reconciliation can only happen over time.

Neither reconciliation nor treaties should be viewed as a single event at fixed point in time. Reconciliation should be viewed as an ongoing process, and treaties as a living expression of a relationship. Moreover, the ability to confidently conclude that success has occurred, and that reconciliation is taking place, requires an ability to be informed by facts and data. In turn, future steps to enhance reconciliation must be shaped by the factual and statistical data accumulated over time in the post-treaty experiences of first nations. Laws and policies in the future will be better served by a sound statistical base.

Second, on modern treaties and statistical data, based on our experience in negotiations over many years, it is our view that the treaty process as currently administered is seriously deficient in its ability to contemplate a post-treaty relationship between our governments.

During our negotiations, the Maa-nulth chiefs introduced the proposition that treaties were living documents and, as such, had to be revised on a regular basis in order to determine the health of the relationship.

While we were successful in persuading Canada and British Columbia to incorporate the concept of a periodic review of the treaty every 15 years, we were not able to find wording to give precise guidance on how this review would take place. It is our understanding that the governments at that time were afraid we were simply looking for an opportunity to renegotiate the treaty at a later date. In fact, this was very much not the case. While we had no desire to renegotiate our treaty, we felt it was imperative we build a degree of flexibility to allow future generations to make economic, legal, and policy decisions that ensured that the objectives of the treaty were met. We felt, and still feel, it is critical to know which aspects of our treaty are working and which are not.

While the provisions in our treaty are not specific in this regard, it is our view that the periodic review process should be informed to the greatest degree possible by a statistical baseline of information. We therefore strongly urge Canada and British Columbia to adopt policies to foster data collection in post-treaty first nations; as well, to use various generally accepted criteria of social, economic, and policy indicators in this process; to work directly with first nations in this data collection and to invest the necessary resources in this data collection. It is our view that this information will allow for better governance and will benefit both the Maa-nulth and the federal and provincial governments. More importantly, we believe this information can be of immense assistance in bringing about true reconciliation.

On modern treaties and loan funding, in addition to acknowledging that modern treaties are living documents by which reconciliation is achieved over time, the Maa-nulth treaty nations strongly believe that the process itself must be fair and equitable. To the extent the current federal policy requires first nations to borrow money in order to participate in treaty negotiations, we believe that the process is inherently inequitable. First nations should not be required to pay to solve a problem they did not create, a problem that has had profound adverse effects upon our communities for generations. We agreed to this policy approach and to borrow a great deal of money because we felt we had no alternative if we were going to bring about an end to the historic colonial relationship.

However, the existence of these loans has proved to be both a political and an economic hardship. If Canada truly wants reconciliation with first nations, we urge you to, first, eliminate the required borrowing provisions in the comprehensive claims policy; second, forgive the loans that are currently outstanding for communities that have been engaged in treaty negotiations; and third, to the extent that any community has repaid any portion of their loans, those communities should be reimbursed for those funds.

With that, we thank you for the opportunity to express our views on these matters. It should be noted, however, that there are a great many more aspects to the claims policy about which we have views and recommendations.

Given the magnitude of the task you have taken on and the limited time we had to prepare and present our perspective, we would like to recommend that the standing committee allow Maa-nulth communities further time to prepare a more comprehensive analysis of your policy. If this were to be the case, we would be most willing to appear before you a second time and to speak to your recommendations.

Once again, thank you for this opportunity.