Yes, absolutely.
When we're looking at making interim orders in the transportation sector, one of the things we looked at in preparing our submission was the Aeronautics Act. We note that under part 1, section 6.41 of the Aeronautics Act, it provides for a very robust system for interim orders.
We note that the proposed changes to the CSA discuss that the minister can act when immediate action is required, where there's indirect or direct risk to marine safety or marine environment. However, there are three things in the Aeronautics Act that we see and really like, which we don't see as part of this legislation.
One of the parts of the Aeronautics Act stipulates the following:
Before making an interim order, the Minister...must consult with any person or organization that the Minister or deputy considers appropriate in the circumstances.
I think that consultation with all those affected parties, by an interim order, is absolutely fundamental before an interim order is made. I don't think that interrupts how quickly you might need to act in that kind of situation.
Another part that we would really like to see is the duration of the interim order.
In the Aeronautics Act, it stipulates that an interim order shall last for no more than 14 days, unless there is an extension granted by the Governor in Council for up to one year. I think that up to one year is crucial, because that ensures, and puts in the safeguards, that the regular regulatory process isn't circumvented.
We note that in the proposed changes to the CSA, that extension can be extended for up to two years, effectively creating a three-year-long interim order as part of the CSA.