Thank you. That's quite helpful.
I've looked up some information in a report called, Fallen Behind: Canada's Access to Information Act in the World Context, by Stanley Tromp in 2008. He did in fact find that of all the Commonwealth countries, the 50-odd countries, there are only two that do not provide for independent review of the citing of cabinet confidence: South Africa and Canada.
So just as his report is called, we've certainly fallen way behind. But even more interesting, what we find among Commonwealth and OSCE countries is that the average request response time is two weeks, and in many countries it's just 10 days.
How is it that virtually all western democracies are able to do this in 10 days to two weeks, yet in Canada, with this new mechanism of using the PCO, so that it's in PCO consultations, it's now taking as long as a year?