I completely share it.
When you look at Tervita itself and the outcome in that case, where there was a merger with a proven price increase, there was a predictable price increase with negligible efficiencies, yet somehow it succeeded on the efficiencies defence as a result of this requirement. The bureau didn't quantify quantifiable evidence.
I'm not sure what “quantifiable” means, for one thing. Everything is quantifiable, in theory. That's a problem. It puts this unnecessary enforcement burden on the bureau. I completely agree with them about that. If they have shown there's a substantial lessening of competition, I think the onus should shift to the parties to prove that they realize efficiencies that would offset those anticompetitive effects. I agree with those expressing concerns about Tervita.