As to specific timelines, I don't know whether you said this, but we've talked about 28 days for the basis of claim, 120 days for access for the hearing, and 45 days, the same as we have currently in Federal Court, to perfect an appeal.
I think we both agree there needs to be, as there is now, a stay pending a leave application in the Federal Court. There should be no deportation of a failed refugee claimant until the Federal Court has looked at whether or not there's an arguable case. It's a difficult standard to meet, practically speaking, but they should at least have that shot. There should be no refugee denied access to the appeal division. If we're going to have an appeal, everyone should have access to the appeal, otherwise it's not an appeal.
It's our position that there has to be an opportunity to raise a new risk, or new evidence, or new circumstances prior to deportation. That means access to a PRRA prior to removal, after the RAD or the RPD has dismissed a claim. It may not be that there's a PRRA for everybody, but where someone can raise a prima facie risk, and he can show there is something that's changed, he should have that risk reviewed prior to deportation. Failure to do that, we believe, is contrary to the charter's section 7, and is contrary to both the convention against torture and the covenant on civil and political rights, not to mention the refugee convention.
We have many other things we could recommend about detention.