Mr. Chair, I want to clarify that we don't do the risk assessment; the risk assessment is done by the department.
But going back to your question, I see three parts to it. First of all, we're very engaged with the UN in terms of comparing with other countries. When I came in, I went to England, and we compared England. We looked at France. And that information is updated every year. When I go to Geneva every year, we have round tables of similar countries that have similar.... That allows us to see new ways of doing business, whether it's technology or whether it's how they interpret the convention, and the UN helps us with that very much.
The second thing is that there is no methodology known to measure and compare countries in terms of acceptance rate. We are not measuring necessarily the same thing. If I were to give an example, I'll use the United States. The United States has the first level rendering a decision within 60 days, and it is a public service. Then there's an appeal, and then there's another level of appeal over and above. So by the time they do their three levels of appeal and by the time you look at the acceptance rate, we're not very far behind.
In terms of the processing time that I've talked about, six months, I don't think I'm in a good position to compare, but I will say that if we ever get to six months, we're doing very well. If you could do it in four months, then there would be a limit as to how.... You can't sacrifice quality, you can't sacrifice equity, but you have to make sure that justice is not denied by having cases not heard. So that's our big....
I hope I've answered your question. The acceptance rate is difficult sometimes to measure. I would say we rank very well with the United States, contrary to the myth, the myth being that we would be porous or more.... My sense is when we look carefully we're not, and I think we're doing very well that way. But I'm not happy with the fact that we haven't reached the six months. I am not happy and will never be. I think when you look at the provinces and the responsibilities they assume on refugee determination, it's very important.
My other concern, of course, is with appeals. We never had a backlog on appeals; we were always rendering decisions on appeals in six months. Now we're going to 10 months. The numbers are too high. I have redeployed some decision-makers to the appeals side to make sure we're not falling too far behind. But on that side of the issue, the resource issue is very important also for the department, because in appeals it's an adversary system, where the department comes and represents the minister versus the appeal that is going to be heard. So if they don't have their resources...even if I had 60 decision-makers, it would not necessarily help me.
Some comparisons are possible. Best practices are compared—I'm going back to the refugee file—and on the acceptance rate I know that we are not, as we are portrayed, more generous than any other system in place. But it's hard to compare.