I think we'll split the time because we have different recommendations.
In respect of the basis of claim form, I think the 15 days are untenable and unworkable. The same 15 days are also untenable and unworkable for the RAD.
Right now in the Federal Court we have 15 days to file the notice and then a further 30 days to perfect our record. Now we're going to be asked to do basically the same thing, which is obtain the CD of the hearing, somehow transcribe it, identify the errors, meet with the clients, and then prepare a record identifying the errors for the Refugee Appeal Division. All of that we're going to have to do within 15 days—on top of getting legal aid, having legal aid do a merit screening, and finding counsel. It's simply untenable. It's unworkable. As it stands today, it's simply window dressing. I don't think it's going to help refugees in any substantive way.
Looking at recommendations, one of the basic recommendations would be to extend the time. The Federal Court gives us 45 days to perfect the record. I think that's a reasonable amount of time. In respect of the hearing dates themselves, 30 days and 60 days, that's simply not enough time.
Mr. Goldman alluded to it in his testimony today. There was a time when the board was able to hold hearings within four to six months on a routine basis. It was only after the backlog that it went up to an average of 21 months. Our office routinely got called to schedule hearing dates within that timeframe, so we know it's doable. We know it can be done, and we know a fair and reliable system is achievable. It is an achievable goal. I don't think Bill C-31 gets us any further.