Quite frankly, our biggest issue is that of clarity. We don't think there's a lot of value in attempting to regulate minor activities, or to monitor streams that have no prospect of being used for navigation. I think Transport Canada has said as much; hence their wish to protect navigation, not navigability.
In the short term, if you could just remove the ambiguity, such that we could eliminate that step, it would provide us with some immediate relief, even if you wished to be very conservative in your definition at this time.