Yes, that's exactly right. The concern the association has is with the rest of the procedural mechanisms. For example, if this arises in a mid-trial application, there's actually a requirement that the complainant have the opportunity to be represented and have standing on these applications as well.
That means the complainant, who up until now has had no reason to have a lawyer, has to go off, figure out if they have funding, secure the funding if they have it—hiring a lawyer is expensive—and go out and retain a lawyer. That lawyer needs time to prepare to address the issue that's arisen because now they have standing and are entitled to make submissions. Then you have to get that lawyer's availability because they are probably also dealing with a busy criminal practice. Then all three lawyers and the assigned trial judge have to get back into a courthouse where, as this committee knows from dealing with recent developments in the law of delay, often requires an eight- or 10-month wait, sometimes shorter if you're jumping up against the Jordan ceiling, but not necessarily.
It's not the notice requirement that is in itself problematic. It's the practical implications of the procedure as currently worded.