The short answer is no, there is no stage in any process where there would be no trigger. But a decision-maker needs to ask, at each stage in the process, what is the likelihood that my decision will have an actual impact on an aboriginal interest?
At many stages, particularly the planning stages, it's hard to imagine where the impact will be. As you're getting closer and closer to the final decision, such as emitting permits or making decisions that will authorize interference with physical things--land, water, resources--then yes, you're going to be more concerned about it.