Care should be taken in giving the government carte blanche to delegate. The potential implications of Bill 40 are far-reaching. On the other hand, delegation involves a loss of public control and direct ministerial accountability that need to be fully considered as they cut to the core of our democratic institutions. Bill 40 appears to be well intended and that the Bill could yield positive consequences. However, in its current form there is also potential for the Bill having far reaching negative implications.
Amendments are necessary to guard against unintended impacts.
The lack of consultation regarding Bill 40 makes may cause unnecessary suspicions. We are disappointed by the lack of consultation in relation to such an important piece of legislation. We have not had an opportunity to thoroughly review the Act or consult with our clients. This lack of consultation engenders a spirit of distrust with environmental groups even in the context of well-intended changes. Government's introduction of Bill 40 without very limited consultation follows on the heals of the government's disdainful attitude to consultation regarding changes to the Forest Practices Code and regulations, the Mining Rights Amendment Act , and changes to Vancouver's planned light rapid transit system.