First of all, I'd like to say that the three urban transit authorities we're dealing with, which are currently under provincial jurisdiction, are very safe companies, and they're definitely not operating in an unsafe manner.
However, it all goes through the railway operating certificate. So you can't see that as a permit that each railway will need to obtain in order to operate on federal track. Most of what may be required in the railway operating certificate these commuter railways already have in place.
The second thing that is really important to note is that in Bill C-33, under proposed section 12, concerning the railway operating certificate, there is a provision under proposed paragraph 17.9(1)(c) that allows the Governor in Council to exempt some persons from the railway operating certificate. So there was already provision at the time we were going to do the regulation to exempt some class of persons.
I honestly would be pretty uncomfortable right now to decide who should or should not require an ROC based on their current safety record. I don't think that should be perceived as a reward, that if you have a good safety record you don't need an ROC.
The legislation, the way it is now, already has some provisions that would allow them to be exempt at the time we do the regulation.