In our opinion, the greatest threat is that Canada will fail to comply with its non-refoulement obligations. Under the Geneva convention on the status of refugees, we have the basic obligation of non-refoulement. That requires us to never send someone back to a country where he may be persecuted. It is also part of the convention on torture and other cruel, inhuman or degrading punishment or treatment.
This is about hearings that will take place after 30 days, by which point people will not have had the opportunity to prepare their cases. This is also about doing away with almost all recourse, as I mentioned, including the Refugee Appeal Division, possibly for most unsuccessful claimants, as well as humanitarian claims and pre-removal risk assessments.
We believe that there is a very high risk of human error when there is no subsequent review. As a result, the risk of failing to comply with the non-refoulement obligations is very high as well.