The Environmental Law Centre's Laura Bowman writes that the Climate Change Accountability Act suffers from some of the same "problematic legal issues" that led to the failure of the earlier Kyoto Protocol Implementation Act. In the case of Friends of the Earth v. Canada, (2008 FC 1183, (T.D.) appeal dismissed 2009 FCA 297) a Federal Court found that the earlier act, unenforceable and, in Bowman's words, "too general in nature to have the true force of law". Bowman argues that:
Parliamentarians and activists need to be bolder in addressing climate change, by putting forward specific measures instead of emission targets without any means of achieving them.
Bill C-311, riding on a wave of political apathy, represents a failure to take risks on real measures. Targets are the ends, but legislators need to be prepared to provide the means, and soon.