Thank you very much. It's good to be back to speak with you about Bill C-24. As you know, the bill was introduced on February 26, 2014, and the Minister of Citizenship and Immigration at the time said that the bill is meant to reduce citizenship fraud, increase efficiency of the system, and reduce backlogs.
At OCASI we believe that the bill is likely to exclude more people from citizenship by making the process more difficult. We are especially concerned that the bill diminishes the value of Canadian citizenship by treating differently those who have dual citizenship and those who don't between Canadian-born citizens and naturalized citizens, and between immigrants who do not work in the Canadian armed forces and those who do.
The bill gives more power to the minister to revoke citizenship and reduces judicial oversight.
We are particularly concerned about the impact on racialized immigrants and refugees and on immigrant and refugee women and children.
I wanted to remind us that this year marks the 100th anniversary of the Komagata Maru and the 75th anniversary of the SS St Louis, reminders of Canada's history of shamefully racist immigration policies.
Changes to the Citizenship Act must work to undo the racist policies of the past by welcoming newcomers, bearing in mind that the majority of new immigrants and refugees today are people who 75 or 100 years ago would have been deliberately excluded from Canada.
We believe that, in discussing this bill and moving forward with our discussions, there are certain principles we must pay attention to. The act lays out citizenship rules and thus defines who is Canadian and who we are as a country. This important legislation must therefore incorporate the following principles:
a) Respect for the principle that all citizens are equal.
b) Respect for the principle that citizenship is a status from which rights derive, and is thus similar to our status as human beings. It is not something that can be lost through bad behaviour.
c) We must ensure that the legislation is consistent with the best interests of the child.
d) And we must recognize that some permanent residents face systemic barriers to full participation, including refugees who have suffered persecution and long years of deprivation.
I am going to touch on a number of clauses in the bill that we wanted to respond to.
The first involves longer periods of residence in Canada before applying. Bill C-24 would require applicants for citizenship to have lived four out of the last six years in Canada, compared to three out of the last four under the current law. It will no longer allow applicants to count time in Canada before becoming a permanent resident. The change will result in making people wait longer before they can qualify to apply for becoming a citizen, undermining Canada's stated commitment to integrate newcomers.
Becoming a citizen is particularly important for refugees who have no other country they can turn to. Until they are citizens, they have a sense of insecurity and face practical problems, such as difficulty travelling without a passport.
Certain permanent residents will be disproportionately affected, such as refugees and live-in caregivers. Racialized women are over-represented among live-in caregivers, and many typically endure years of exploitative working conditions. Not being allowed to count time spent working in Canada to qualify for permanent resident status will further disadvantage these individuals. Other permanent residents such as those who qualify for the Canadian experience class, including international students graduating from Canadian universities, will also be disproportionately impacted by this change.
And in Ontario, over and over I've been hearing from international students that part of the drawing card to come to Canada for school is because there is a pathway to permanent residency and then to citizenship.
We have two recommendations here: keep the period of residence to three out of the last four years and keep the rule allowing applicants to count at least one year in Canada before becoming permanent residents.
The intention to reside in Canada. I know the last panel spent some time on this, the fact that applicants for citizenship have to swear an intention to reside. The provision will apply only to naturalized citizens, thus creating a different and less inclusive category. Their mobility rights will be in jeopardy for fear that their citizenship might be revoked for misrepresentation or fraud, while those born in Canada will have the ability to travel freely and pursue education or work opportunities overseas.
OCASI has heard that a growing number of immigrants return to their country of origin or travel to another country for employment because systemic barriers in the Canadian labour market have made it difficult to find suitable employment here at times.
Many others have returned for a period of time to meet other obligations such as looking after aging parents, a practice that will likely increase as it becomes increasingly difficult to reunite with parents and grandparents in Canada.
There is a serious risk that these Canadians would be seen as engaging in misrepresentation simply because they have to go elsewhere to make a living or to fulfill family obligations. We have one clear recommendation here: delete this new provision.
Regarding language acknowledgement, the bill greatly expands the group of individuals who must meet language and knowledge requirements in order to become citizens of Canada. Under the current law, individuals between the ages of 18 and 54 are required to meet these requirements in order to become Canadian citizens. Bill C-24 will require applicants between the ages of 14 and 64 to pass the citizenship test.
There are a number of other issues. Older refugees may be able to learn enough English or French to function but may nonetheless have difficulty passing the legislated language test.
Older permanent residents must be encouraged and supported when learning one of the official languages and acquiring knowledge about Canada. However, given the greater difficulties in learning a new language at an older age and in passing tests, expanding the requirements to include those up to age 64 will result in excluding a significant number of individuals from citizenship. Older people are generally recognized as vulnerable members of our society. Creating more barriers to citizenship will make them more vulnerable.
The rationale for extending the test requirements to applicants aged 14 to 18 is not clear. Youth at this age will be in high school and must have been in Canadian schools for the past several years. If they do not speak French or English or know about Canada, the fault surely lies with our schools. Furthermore, with respect to language testing, it is not known what proof of language ability will be accepted. The proofs currently accepted will not work for youth—completion of high school or government-funded language classes—and there is no standardized documentation across school boards throughout Canada. The fear is that adolescents will face significant administrative hurdles to prove their language ability or face the cost of an approved language test, which can run up to $200, a cost that is often beyond the capacity of families. By adding new requirements for youth aged 14 to 18, we risk producing a new category of youth who have spent most of their formative years in Canada but are denied citizenship and thus the possibility of participating fully in society.
Our recommendation: keep language and knowledge test requirements to the existing age group of those who are 18 to 54 years of age. I want to add here that we've been successful in having Citizenship and Immigration Canada also recognize that passing a speaking and listening test does not work for deaf and hard-of-hearing immigrants, and so we were able to have an exception made under which an audiology report will be accepted as an exception. We want to applaud that move, but we also want to see this done.