Thank you.
I think this group of witnesses has done a good job of identifying the concerns.
What I have gathered from your respective testimony, Ms. Proud, Mr. Walter and Mr. McCuaig, is that everyone agrees on Bill S-2, An Act to amend the Statutory Instruments Act and to make consequential amendments to the Statutory Instruments Regulations.
We understand the idea of modernization and how quickly regulations, agreements and similar documents are prevailing in Canada. Of course, this process is not easy. I listened with interest to the questions of my colleague, Mr. Albas, as both of us were sitting on the Standing Joint Committee for the Scrutiny of Regulations at the same time. Other individuals around this table have perhaps also been members of that committee.
To outside observers, that committee may appear to be the most useless of all, but that is because those individuals don't understand what happens in the committee. Once on the inside, however, we understand that this committee is probably the most important one, after the Standing Committee on Justice and Human Rights. That's at least how I see things. That is where the necessary parliamentary scrutiny and control take place.
One of the issues the joint committee has always raised concerning ambulatory incorporation by reference
—that's “ambulatory”, in English—
was accessibility. We are talking about accessibility and using the term “otherwise accessible”. However, the term “accessible” is not very clear, and I'm not sure that “otherwise accessible” is any clearer. It's a matter of determining how it would be possible to apply the power granted under the Statutory Instruments Act.
How can we ensure that this verification will be done in a parliamentary context?
Correct me if I'm wrong, but I think regulations incorporated by reference can still be reviewed and analyzed. However, that is a bit elusive. That's one of the problems.
Isn't this a way to bypass the role and work of our joint standing committee, here in the House of Commons.
You also talked about the need to have
what you call Treasury Board guidelines on what it is. We need definition of accessibility, knowing about the changes.
This is an approval of Bill S-2, but with a big caveat that we still need this. Will it work without those guidelines or is it going to be a free-for-all in a very short time?