We didn't say in our brief that many members of the IRB are incompetent. What we said was there is scope for human error, and the wide variation in acceptance rates seems to confirm that the IRB, just as any institution, is open to human error.
Improving the PRRA is one important way of addressing any human error that could be committed in the IRB; however, we have a series of other recommendations, including the implementation of the refugee appeal division.