I understand the concern, but I think it's important to realize that Bill S-2 does not expand on the use of this regulatory authority that is incorporation by reference, which is already, as we've said, broadly used.
As for internally produced documents—that's by the regulators—it would be limited to documents that elaborate upon the main rules of conduct. This is to avoid concerns like the ones you mentioned.
For the external incorporation by reference, Bill S-2 codifies, if you will, the current practice. This is in cases where the documents already exist for an independent purpose that has nothing to do with the regulatory process. They just use the expertise that exists elsewhere to replicate the expertise in the regulations themselves, without having to reprise the content and instead of building the expertise in-house
I think it's important to realize that this bill, as I was saying in my speech, does not expand on enabling authorities. It's an aspect of the regulatory power, but it's an aspect like any other aspect of the regulatory power. It still needs to be exercised within the four corners of the enabling authority. It needs to be brought back into that perspective.