The Impact Assessment Act requires substitution agreements with other provinces. What we propose is that the act be changed such that it is as of right: that it is legally embedded that if a project is happening in a province, it is the provincial government or regulator that approves it; it does not have to go through a substitution agreement.
The substitution agreements require the federal government to be comfortable with the provincial government's regulatory approval process. It should be deemed that for a province, given its powers under the Constitution to oversee its resource development, it is acceptable as of right. We would like to see that it does not have to go through the path of individual substitution agreements by province, and that the act be amended such that a project is as of right the province's responsibility if it is happening in that province.