I think you're right in terms of the impact it would have on representations to the Immigration and Refugee Board, but the starting point for our pre-removal risk assessment is the decision by Canada Border Services Agency that the person is ready for removal. There is a removal order. They have all the documentation. They have flights in progress. The last step is to offer the individual the opportunity to apply for a pre-removal risk assessment.
That part won't change. The person will get the application form from the Canada Border Services Agency officer. Instead of submitting the application to the Department of Citizenship and Immigration, the person will submit their application to the Immigration and Refugee Board.