Thank you for your question.
Perhaps I can preface my answer by saying that this was a test for the act. This was the first GM food animal in the world. There are many more under development. In my opinion, it failed, so we really need to learn from this. I would look to you and others who are scholars in CEPA to find ways to fix it. I identified, from a layperson's point of view, two of the big failures.
One, I think, was just a complete disregard for the science. When it came to the science, it was like a bait and switch. They assessed a very narrow thing, and then Environment Canada went ahead. DFO did the assessment of a very narrow request, and Environment Canada went ahead and approved something much larger and, I think, destined to result in the genetic contamination of wild salmon, which is an irreversible impact. We're going to see more of this, so we need to figure this out.
Two, I'm familiar with the Fisheries Act and the Canadian Environmental Assessment Act, and I was, to use a technical term, gobsmacked to discover that there was no opportunity for public engagement, interaction, or any kind of discussion about the pros and cons. You'll notice that the smack, or the approval, came out subsequent to the decision. It could have come out earlier in the Canada Gazette. That could trigger at least some public engagement.
The company got a waiver so that they didn't have to do an invasiveness test. They got it because the product was said to be contained. Environment Canada, for whatever reason, didn't publish that waiver until our court case was under way, at which time they also published hundreds of other waivers dating back almost 10 years, which they had forgotten to publish.
It's a difficult act to understand. It's not very transparent. People such as Dr. Meinhard Doelle at Dalhousie, yourselves, Dr. David Boyd, and others could probably identify ways in which public engagement could be better designed and brought into the act. We've actually asked for a strategic environmental assessment because we think this is going to be a big area for all of us. It may not be now, but it will become so.