You're saying that your main concern is that it's de novo.
The way I understand it is that in the Federal Court this happens quite a lot. There are certain instances with judicial review where there's a reasonableness standard, but there are also instances where de novo reviews happen. We had Newfoundland before us, and their commissioner has middle-ground power. The Privacy Commissioner actually recommended this middle-ground power. We ultimately didn't recommend that, but the Canadian Bar Association was before us and recommended it, and certainly said that as a first step it might make sense to adopt what Newfoundland has adopted, and then, if need be down the road, go further. There are some concerns that we haven't applied this to ministers' offices, which I understand and I accept, but the order-making power doesn't strike me as a great concern.
Do you think what the CBA and what Newfoundland recommended to us seems reasonable?