Thank you you for that question.
We have a range of concerns relating to the designation of countries of safety. It's our first position that it's never appropriate to designate a particular country as safe. Refugees may come from any country in the world, and the reality is that conditions change quickly in countries around the world, so a country that was safe may overnight become very unsafe. The result of the designation is that those people will be denied access to the kinds of protection that Canada should be providing.
In terms of some of the changes that have been proposed in Bill C-31, even as compared to Bill C-11 the last time around...at least the last time around there was to be an advisory committee that included outside advice on which countries were or weren't safe and should or shouldn't be designated. The minister has taken out any access for external advice and turned it into a completely insulated government decision, and we have huge concerns about that.
Beyond that, UNHCR has commented about the designation of countries. My understanding about their position is that they have said that in certain circumstances it may not be inappropriate to accelerate claims from some countries, but even the UNHCR has consistently said that an appeal has to be there even if you're going to designate a country. Bill C-31 takes that appeal away, and, as I mentioned earlier, not only does it take that appeal away, but there is also no real access to Federal Court for people from designated countries.
We're also concerned about the changes at the IRB, about the fact that decision-makers at the Refugee Protection Division now will be civil servants, not people who are put there for a fixed term with some degree of independence. They are now going to be the only people hearing claims from people from countries that their boss has designated as safe. We have concerns about how that is going to be impacting their ability to make impartial decisions on refugee claims before them.