I would echo those comments. I would say that the principles that underlie the objectives of CEAA 2012, and certainly the changes to the Navigable Waters Protection Act, of certainty, clarity, and reducing duplication in the process are still valid today. While nothing is perfect, I think that proceeding with the way things were thought of in 2012 is the corporate way to go.
On October 20th, 2016. See this statement in context.