Indigenous and Northern Affairs Committee on March 1st, 2018

[Bob Bratina, Liberal, Hamilton East—Stoney Creek, ON]

Is there anything that captures oral tradition? In some of the cases where issues have fallen down, in Russia, for instance, which has numerous indigenous groups they say, “You can't fish there because you have no proof that that's really your territory”, and they would obviously have an oral tradition that would say that it was. Is there anything that's captured in UNDRIP, or should be, that relates to the validity of oral tradition?

[The Clerk]

I'm not sure if there's a specific article in the declaration that speaks to it. I'm sure there are others in the room that probably know that off the top of their head, but I'd have to look through to see that.

Certainly in the approach that we're taking, both in terms of the negotiation processes, but also in how we're trying to do some transformations around how we deal with specific claims and the claims issues, we are very much in that world of trying to make more space in order to be able to take into account oral tradition and how that has a way of shaping how we need to view both concepts of territory as well as traditional rights that were being exercised and how they were being exercised.

I think you do have space that has been created by the courts. Certainly, the specific claims tribunal has created space for receiving oral history as evidence and giving it weight and credence. Within our processes, we are trying to build in more and more of that. Again, that is all part and parcel of trying to have an approach that is based more on recognition, where you're trying to move away from traditional forms of evidence as being a basis on which to make a decision, and instead, trying to talk about it more from a relationship perspective to get a better understanding from an indigenous group about how they perceive it, how they see it, and what their basing it on. I think you see more and more of that happening in all kinds of different facets of government, even in the ways we are talking about how traditional knowledge gets taken into account in scientific-based processes, like management of the fishery.

More and more, we have these spaces that are being created that are trying to recognize that there is a very valuable contribution to our understanding of the country that comes out of those oral traditions. We need to make the space for them and to be able to incorporate them.

[Bob Bratina, Liberal, Hamilton East—Stoney Creek, ON]

Just quickly, on dispute resolution—

[The Clerk]

Article 31.

[Bob Bratina, Liberal, Hamilton East—Stoney Creek, ON]

How does dispute resolution work? There could be disputes between the Canadian government and a first nation, or there could be a dispute between two first nations, or among all three, and so on. Can you say anything in a few seconds about how that works?

[The Clerk]

I think we are trying to find alternative ways of addressing disputes. A lot of work is going on around the specific claims process in particular, in trying to figure out different ways to address disputes when they arise.

We have similar issues about the so-called overlap of territorial claim issues, particularly in British Columbia. We've been trying to open the door to our indigenous partners, saying we want to hear more about how they resolve these things traditionally. We want to hear more about how they see resolving some of these issues, particularly when they are indigenous nation to indigenous nation. Many have protocols and other systems of governance to address these kinds of things. There's no reason we can't look at them as potentially being a basis on which we could then see what we can incorporate into our own processes.

[Bob Bratina, Liberal, Hamilton East—Stoney Creek, ON]

Thank you.

[The Chair, Liberal, MaryAnn Mihychuk]

Thank you. That concludes our time allocated for the first panel. We'll suspend for a couple of minutes and let the other crew come up for the next half.

[The Chair, Liberal, MaryAnn Mihychuk]

We're going to get started. I know the members are anxious to ask questions. Therefore, we need to get your presentations on the record.

I am going to suggest that the two organizations dealing with the environment are together. How you split it is up to you. I will probably be quite ruthless on timing, so try to keep it short so we don't have to get there. I will give you signals. You probably saw what I did in the last round, and I'll do that for this one.

Without further ado, I'm turning it over to the Department of the Environment and the Canadian Environmental Assessment Agency. Each group on the panel has up to 10 minutes. Please proceed.

[Dominique Blanchard, Assistant Deputy Minister, Public and Indigenous Affairs and Ministerial Services Branch, Department of the Environment]

Thank you.

I'd like to acknowledge that we are here today on the unceded territory of the Algonquin people.

My name is Dominique Blanchard. I am the assistant deputy minister of the public and indigenous affairs and ministerial services branch at Environment and Climate Change Canada. I am joined today by my colleague Brent Parker, who is from the Canadian Environment Assessment Agency.

Thank you to the committee for inviting my department to contribute to this session on the subject of Bill C-262. In my remarks today, I will discuss the actions of Environment and Climate Change Canada in advancing reconciliation with indigenous peoples and in working toward fulfilling the government's commitment to adopt and implement the UN Declaration on the Rights of Indigenous Peoples. I will address the work already under way as well as the opportunities we see to further enhance relationships between my department and indigenous peoples and governments.

Indigenous peoples are leaders in conservation. They have long been stewards of the environment and have well established rights related to the use of the land, waters, ice and wildlife. They have knowledge of the environment that spans generations.

The mandate of Environment and Climate Change Canada is to protect the environment and to conserve the country's national heritage. We undertake weather forecasting; wildlife conservation; air and water quality monitoring and protection; water quantity monitoring for informed water management decisions; and, oversee and contribute to measures that mitigate against and adapt to climate change.

Accordingly, it is critically important for Environment and Climate Change Canada to maintain and build strong and positive relationships and partnerships with indigenous peoples, and to collaborate in defining our environmental future. This is a responsibility that extends to each and every part of our department.

We have a history of establishing and supporting partnerships that enable us to reflect the perspectives of indigenous peoples in the delivery of our mandate. We are proud of recent efforts we have made to expand and deepen those relationships at local, regional, national, and international levels. For example, we have established joint distinctions-based senior bilateral tables to support nation-to-nation, Inuit-to-crown, and government-to-government relationships to assist with the implementation of the pan-Canadian framework on clean growth and climate change. We work with indigenous peoples on projects to support the stewardship of natural resources, including through, for example, the co-management of conservation areas, wildlife management boards, and indigenous-led projects supported by the aboriginal fund for species at risk.

At the international level, Canada has been recognized for its leadership in advancing the local communities and indigenous peoples platform under the United Nations Framework Convention on Climate Change. Indigenous peoples have joined us in representing Canada on the delegations for this and other international fora, such as the Convention on Biological Diversity or the Intergovernmental Panel on Climate Change.

We're also establishing countless partnerships at the local and regional levels. For instance, the Canadian ice service is partnering with Inuit communities to understand sea ice information needs in light of changing ice patterns in the north. We are collaborating with first nations on a project to develop training curricula related to environmental monitoring. We are also supporting indigenous-led efforts to address environmental challenges affecting the Great Lakes.

Finally, we and the Canadian Environmental Assessment Agency, along with other federal partners here at the table, worked closely with indigenous partners in developing the recently tabled Bill C-69, which proposes important requirements concerning the engagement of indigenous peoples in the environmental review process and the use of traditional knowledge to inform decision-making.

Sustaining and enhancing partnerships of this nature, and supporting the broader work being done across government to advance reconciliation, has required Environment and Climate Change Canada to look internally, as well.

In May of last year, our department created a new branch, which I lead. Part of our mandate involves bringing cohesion and organization to the department's indigenous affairs and reconciliation activities, and bringing to ground broader government efforts in these areas within our department.

In this vein, we're developing governance structures to ensure effective cross-departmental collaboration, developing tools to support broader engagement and consultation with indigenous partners, and implementing training and awareness opportunities to develop the intercultural competencies of our employees.

We are also working closely with many of the colleagues you have and will be hearing from today in implementing the Truth and Reconciliation Commission's calls to action, the principles respecting the Government of Canada's relationship with indigenous people and, relevant to our discussion today, the United Nations declaration.

In our view, working towards aligning our work with the provisions of the UN declaration presents an opportunity for us to build trust with our indigenous partners; enhance the integrity of our policy-making, research, and analysis; and achieve better environmental outcomes for all Canadians. Several articles in the UN declaration are tied closely to our mandate in that they reflect indigenous people's rights concerning the stewardship of the environment. For example, article 24 speaks to rights related to conservation of medicines, plants, animals, and minerals. Article 31 relates to the maintenance and manifestation of traditional knowledge, including in relation to flora and fauna. Importantly, article 32 confirms the rights of indigenous peoples to determine and develop priorities and strategies for the development and use of their lands and resources.

In regard to these articles, Environment and Climate Change Canada is well situated to build upon existing practices and relationships. Through our engagement in the negotiation of treaties and other arrangements, ECCC works with indigenous partners to collaboratively conserve and protect wildlife and other environmental resources. Also, as a science-based department, we are working to ensure that traditional knowledge informs our work, and we are reviewing and refining our approach that freely shared traditional knowledge can better complement contemporary scientific research to inform decision-making. Lastly, we're working to build transparent and comprehensive engagement processes that respect the rights of indigenous peoples in determining how lands and resources are used.

Environment and Climate Change Canada recognizes that there is more to be done. This will involve the continued examination of our contribution to the government's reconciliation agenda, including the implementation of the United Nations Declaration. This will mean further strengthening our engagement with indigenous partners, and assessing new opportunities to align departmental programs, policies, laws and regulations with indigenous rights and interests. And we will need to do more work internally to build greater awareness amongst our employees of indigenous rights and interests, and of our related responsibilities.

In closing, I would like to thank you for the opportunity to highlight some of the efforts under way at Environment and Climate Change Canada to move forward on our commitment to support reconciliation with indigenous peoples, including through the implementation of the UN declaration. As a department, we are steadfastly committed to this important work.

[The Chair, Liberal, MaryAnn Mihychuk]

Thank you.

Mr. Parker, are you speaking now?

[Brent Parker, Director, Legislative and Regulatory Affairs Division, Canadian Environmental Assessment Agency]

No.

[The Chair, Liberal, MaryAnn Mihychuk]

All right.

We're going to move on to the Department of Fisheries and Oceans.

[Robert Lamirande, Director General, Indigenous Affairs and Reconciliation, Department of Fisheries and Oceans]

I would also like to acknowledge our presence on the unceded territory of the Algonquin peoples.

I would like to thank the chair, vice-chairs, and committee members for the invitation to speak to you today to support your study of Bill C-262 and for the opportunity to elaborate on the suite of programs, policies, and legislative initiatives under the purview of the Minister of Fisheries, Oceans and the Canadian Coast Guard that have made and will continue to make advances toward reconciliation with the indigenous peoples of Canada.

I am Robert Lamirande, the director of indigenous affairs and reconciliation directorate at Fisheries and Oceans Canada. I would like to introduce my colleague, Marc Sanderson, acting director general, national strategies of the Canadian Coast Guard.

My directorate is responsible for providing policy advice on indigenous fishing and other matters toward advancing reconciliation with indigenous peoples; negotiating and implementing program, treaty, and other constructive agreements on Fisheries and Oceans management; promoting fisheries related economic opportunities through programming to support indigenous capacity to fish safely and effectively; and building relationships and partnerships with indigenous communities through effective engagements, which we do hand in hand with the national strategies directorate of the Canadian Coast Guard.

We do this work because the sustainable use of the fishery resource, the protection of fish and fish habitat, the conservation and management of our oceans, and the safety of those on the water are a priority for the department—a priority held in common with indigenous communities.

And because Fisheries and Oceans Canada and the Canadian Coast Guard have presence in many coastal and rural communities across Canada, we have worked hard with indigenous communities and groups to collaborate and partner on all aspects of our operations. These relationships are comprehensive, complex and dynamic. They are adaptive to the capacity of each indigenous community or group to participate in economic opportunities and in co-management.

We are now on a clearer path to a renewed, nation-to-nation, crown-Inuit, and government-to-government relationship, one that builds on the relationships and partnerships developed over the past decades. These relationships with indigenous communities are the touchpoints through which we will collaborate to articulate what reconciliation means in the context of Minister LeBlanc's portfolio.

This includes those changes to programs, policies, and laws necessary to demonstrate that we are moving to reconciliation with indigenous peoples. This commitment to reconciliation is guided by the principles respecting the Government of Canada's relationship with indigenous peoples. These principles, as you know, are themselves guided by the United Nations Declaration on the Rights of Indigenous peoples.

I want to highlight for you how Fisheries and Oceans Canada has worked in collaboration and in partnership with many indigenous communities. Through the innovative and successful Atlantic and Pacific integrated commercial fisheries initiatives, Fisheries and Oceans Canada provides commercial fisheries access, business management capacity, and training needed to build self-sustaining, indigenous-owned and operated commercial fishing enterprises.

Through the aboriginal fisheries strategy and the aboriginal aquatic resource and oceans management programs, Fisheries and Oceans Canada helps indigenous groups acquire the scientific and technical capacity, means, and training to meaningfully participate in fisheries, oceans, and habitat collaborative management, including employing aboriginal fisheries guardians.

Budget 2017, a year ago, has taken these programs a major step forward, investing over $250 million over five years and $62 million ongoing annually. This includes ongoing funding for the Atlantic and Pacific integrated fisheries initiatives and northern expansion through a new northern integrated commercial fisheries initiative.

As we embark on the renewal of these programs, we are also undertaking a review to see where and how these programs can be strengthened in collaboration with the National Indigenous Fisheries Institute, a technical organization established in May 2017 whose board is made up of experts from national and regional indigenous organizations. The institute is enabling the co-development, co-design, and co-delivery of our indigenous programs.

However, working collaboratively and in partnership with indigenous communities is not focused solely on fisheries.

The Oceans Protection Plan, for example, is enabling indigenous communities and groups to meaningfully participate and partner in Canada's marine safety system, from waterways management to emergency preparedness and response.

We are working with indigenous communities and partners to create a new indigenous chapter of the Coast Guard Auxiliary in British Columbia. And discussions with other indigenous communities are exploring opportunities to establish additional auxiliary units in the Arctic and in British Columbia to bolster responses to emergencies and pollution incidents.

A national strategy on abandoned and wrecked vessels will build an inventory of the problem vessels, and a risk assessment methodology. Indigenous communities will be invited to participate in these assessments and to help prioritize interventions.

Through engagement with indigenous communities in British Columbia, the Canadian Coast Guard has launched an environmental response officer recruitment program. We are also nearing completion of a process to recruit Inuit students for a new rescue boat station in Rankin Inlet, Nunavut.

Ongoing training programs across the country will provide participants with the knowledge, skills, and hands-on experience to enable them to play a greater role in marine safety in their communities in a safe and effective manner.

As you know, reconciliation also means self-determination of indigenous communities often but not exclusively through negotiation and implementation of treaties. Fisheries and Oceans Canada is participating in over 40 active rights reconciliation self-government negotiations with indigenous communities on fisheries and oceans matters.

Fisheries and Oceans Canada is also making systemic changes to better enable collaborative partnerships with indigenous peoples, and we have done so through important proposed legislative changes: Bill C-55, An act to amend the Oceans Act ; Bill C-64, An act respecting wrecks, abandoned, dilapidated or hazardous vessels; and Bill C-68, An act to amend the Fisheries Act. Proposed amendments to the Oceans Act will strengthen, among other things, the ability to designate marine protected areas on an interim basis and, as with all marine protected area designations, partnering with indigenous communities is the foundation for the successful protection of these unique aquatic ecosystems.

The proposed Wrecked, abandoned or hazardous vessels act, under the Minister of Transport, with the Minister of Fisheries and Oceans and the Canadian Coast Guard, would enable, among other things, agreements with a government, council, or other entity authorized to act on behalf of an indigenous group to exercise the powers and perform certain duties or functions of the minister.

The proposed amendments to the Fisheries Act and the programs enabled by these changes include certain amendments specifically aimed at advancing reconciliation, including new tools to enhance opportunities for partnering with indigenous peoples in the conservation and protection of fish, fish habitats, and shorelines; and amended provisions to enable agreements with indigenous governing bodies and any body, including a co-management body, established under a land claims agreement, to further the purpose of the act. Such agreements could enable the declaration of the law of an indigenous governing body, including a bylaw, to be equivalent in effect to a regulation under the Fisheries Act.

Fisheries and Oceans Canada and the Canadian Coast Guard have advanced and will continue to advance reconciliation through concrete changes to programs, operational practices, and legislative frameworks that give voice to the United Nations Declaration on the Rights of Indigenous Peoples. As we move forward we will seize on the relationships and partnerships we have with indigenous communities to articulate renewed nation-to-nation relationships with indigenous peoples within the mandates of Fisheries and Oceans Canada and the Canadian Coast Guard.

Thank you.

[The Chair, Liberal, MaryAnn Mihychuk]

Very good.

Our final presentation is from the Department of Natural Resources.

[Genevieve Carr, Acting Director General, Indigenous Policy and Coordination, Department of Natural Resources]

Good afternoon, and thank you for your attention.

I, like my colleagues, wish to acknowledge that we are meeting today on unceded Algonquin territory.

Thank you for the invitation to speak today to support your study of Bill C-262.

My name is Genevieve Carr. I am the acting director general of indigenous policy and coordination, a new unit in the Department of Natural Resources, which reports directly to the deputy minister and which was formed to support efforts to foster reconciliation with Canada's indigenous peoples.

I wish to acknowledge my colleague, who has joined me today, Mr. Terry Hubbard, who is the director general of the petroleum resources branch in the energy sector of Natural Resources Canada.

My remarks today will focus on some the areas where Natural Resources Canada is working to proactively ensure that our policies, programs and legislation align with the United Nations Declaration on the Rights of Indigenous Peoples.

My department is transforming its internal operations and culture, reviewing its policies and practices, and working across government to align with the principles, norms and standards of the United Nations Declaration.

We support Minister Carr—I should note there is no relation, despite our shared last name—in his role as a member of the Working Group of Ministers on the Review of Laws and Policies Related to Indigenous Peoples. We work closely with our colleagues across government to support horizontal engagement and policy initiatives, such as the permanent bilateral mechanisms established with national Inuit, first nations, and Métis organizations, federal responses to the Truth and Reconciliation Commission's calls to action, and the recently launched engagement of a recognition and implementation of rights framework.

We are also advancing corporate change within our organization to increase cultural competencies of all staff within the department, and we are helping to transform the department so that it can become an employer of choice for indigenous Canadians.

Natural Resources Canada is changing how we work and partner with indigenous peoples, placing emphasis on creating lasting relationships that respect and recognize the rights of indigenous peoples. Examples include the department's Generation Energy dialogue on the shift to a low-carbon future, which was heavily shaped by its engagement with and perspective of indigenous peoples from across Canada.

This engagement is ongoing as the vision that grew from Generation Energy moves to being implemented. NRCan is driving inclusion of indigenous leadership in federal, provincial, and territorial fora, such as the Energy and Mines Ministers' Conference, and the Canadian Council of Forest Ministers, as well as international trade delegations to facilitate with jurisdictions that control many of the levers for resource development. The geo-mapping for energy and minerals program is another example that has allocated close to $1 million to northern indigenous organizations to develop tools and capacity to integrate science knowledge into decision-making by northerners, for northerners.

Natural Resources Canada is also taking measures to support self-determination through full and fair opportunities to indigenous peoples to participate in the natural resources economy. Some examples include the establishment of an economic pathways partnership to make it easier for indigenous groups potentially impacted by major pipeline projects to access existing federal programs, and help support job training and business opportunities. The indigenous forestry initiative supports forest-based indigenous economic development across Canada. This year it will provide over $2.5 million to indigenous communities and organizations for capacity and business development. The IFI is exploring options to move toward a shared governance model with indigenous peoples.

The green jobs science and technology internship program is starting to take action to target career-stream jobs for indigenous youth, recognizing the importance of opportunities for indigenous youth employment in the natural resources sector.

The interim approach for major project reviews allowed my department to enhance public and indigenous participation in projects undergoing reviews by the National Energy Board. As part of the interim approach, Minister Carr appointed a three-person panel, one member of which was indigenous, specifically to create opportunities to share views not already heard by government on the Trans Mountain expansion pipeline project. Enhanced indigenous engagement through the review process led to an $86-million federal investment to establish and co-develop two indigenous advisory and monitoring committees for National Energy Board-regulated pipelines. These committees are now actively working with the National Energy Board as projects move to construction. They're an important example of how co-development can advance shared goals of safety and protection of environmental and indigenous interests for federally regulated projects.

Lastly, my department is changing laws and policies to entrench a new way of doing business, both for government and for the private sector that has an interest in developing Canada's resources. The active participation of first nations, Inuit, and Métis organizations and communities from across Canada was key to our efforts to modernize the National Energy Board, given concerns around the nature and process of indigenous peoples' participation in the regulation of pipelines under federal jurisdiction.

To note, two of the five members of the NEB modernization expert panel were indigenous. Appointed by Minister Carr, the Minister of Natural Resources, the panel was tasked with conducting a targeted review of the board's structure, role, and mandate. Natural Resources Canada provided a total of $4 million in participant funding to 157 indigenous groups over a two-year period, to provide capacity for those groups to participate in the NEB modernization review.

Our experiences through the interim period, and the lessons learned through the NEB modernization process, were critical to shaping the proposal for a new Canadian energy regulator that was tabled as part of Bill C-69 last month in Parliament. The Canadian energy regulator, CER, will help oversee a strong, safe, and sustainable Canadian energy sector as we transition to a low-carbon economy. The regulator will conduct reviews that are more open, accessible, inclusive, and transparent. This will give communities and indigenous peoples a greater voice in their future.

I have provided a brief overview of some of the work my department is undertaking to align with the United Nations Declaration and have focused my remarks on: internal corporate changes and support to whole-of-government priorities; changes in how we partner externally to build meaningful relationships and create space for full and fair access to economic opportunities; the application of lessons and experiences from the last two years to propose new legislation for energy regulation in Canada.

This government set a new path for its relationship with its indigenous peoples in Canada, and our work is not done. We will continue to work closely with other departments on programs, policies, and initiatives that are aligned with the key principles of the declaration. We will also continue to support self-determination and engagement through programming that develops the capacity of indigenous peoples to participate in the natural resources sector and leverage that wealth creation to support their own priorities. We will continue to work closely with indigenous peoples to advance policies, programs, and regulations, including approaches to consider and protect indigenous knowledge in federally regulated energy project reviews; outline expectations for early engagement, planning, and roles for monitoring and oversight; enter into collaboration agreements on project reviews; and ensure we have appropriate indigenous representation on boards and panels.

Thank you for your attention. I look forward to answering any questions you may have.

[The Chair, Liberal, MaryAnn Mihychuk]

Thank you.

Questioning will start with MP Mike Bossio.

[Mike Bossio, Liberal, Hastings—Lennox and Addington, ON]

Thank you all so much for being here today. They were great presentations.

The panel members talked a lot about how UNDRIP would serve as an interpretation tool that the courts would use to interpret Canadian law and how the different departments were also using it as a tool to interpret how Canadian laws would be developed moving forward. In looking at that, and now looking at it through the lens of FPIC in the same fashion, it's such a complex issue. You can't interpret it, as has been indicated by the other side, in a black-and-white, simplistic, yes-or-no interpretation. As our colleague who formed this legislation, Bill C-262, had said, the rights of one group do not abrogate the rights of another, so we must take a different approach in looking at FPIC.

I would say that, based on your presentations, it seems like you are taking this type of an approach, and I would like to expand. When you're looking at the development of a project, do you approach it in this similar fashion? If there are disputes that arise, you use dispute resolution mechanisms or finally, ultimately, the courts. Would you care to comment further on that?

[Genevieve Carr]

It looks like you're looking right at me.

[Mike Bossio, Liberal, Hastings—Lennox and Addington, ON]

Sure, you and Dominique as well, if she'd like to comment on the approach that environment is taking. Please go ahead.

[Genevieve Carr]

I'll also lean on my colleague Terry Hubbard, but let me start in terms of the general approach in the context of natural resources projects where we do aim to secure free, prior, and informed consent through processes based on mutual respect and dialogue.

This means that we work in partnership with indigenous peoples from the start through early and inclusive engagement so we can get to better project decisions and outcomes. The interim principles, as I mentioned, allowed us to effectively try out new approaches and figure out better ways to engage early and more meaningfully. I think Terry could reflect that the approach that we've learned, both through our consultations on the modernization of the National Energy Board, but also through the approach on interim principles, allowed us to help design legislation that would entrench the principle of FPIC by embedding that partnership with indigenous peoples. The recognition of rights, co-operation, and respect will guide how we will protect our environment and grow our economy.

[Mike Bossio, Liberal, Hastings—Lennox and Addington, ON]

I think that's pretty good.

Dominique, I would like to maybe have you speak to this as well, but really, through the lens of Bill C-69 and the standpoint of that early engagement process that will happen with indigenous communities, and indigenous communities participating directly and controlling, in some instances, impact assessment.

[Dominique Blanchard]

Brent from the Canadian Environmental Assessment Agency is best positioned to answer the question.

[Mike Bossio, Liberal, Hastings—Lennox and Addington, ON]

Sure, please go ahead.

[Brent Parker]

Thanks for the question. You're right, they're in Bill C-69, when the impact assessment act is proposed. There is a new set of provisions, and they are certainly in line with, and in support of, the United Nations Declaration on the Rights of Indigenous Peoples.

The agency has been evolving over time in terms of moving away from just a de minimis standard of duty to consult, and looking at going above and beyond that in terms of engagement with indigenous peoples. What the impact assessment act will do is institutionalize some of those practices. The early planning process that you mentioned is one of those places where there's an obligation on the agency to offer to co-operate with indigenous jurisdictions. There's also a mandated obligation for the agency to consult with indigenous groups, and to collaboratively develop what's called an indigenous engagement plan. That's something that would be regulated. That plan would be co-developed with those groups that are implicated in the process, and would drive the impact assessment process that would take place after that.