The government's own 2016 review states that “One of the key findings from the previous evaluation was that the program”—the program they refer to is the pre-removal risk assessment program—“had evolved from its original intent of providing a 'safety net' for migrants requiring removal, to providing failed asylum seekers one more step in the asylum system, evolving into a de facto appeal mechanism.”
Isn't that what you're doing with this process, turning the pre-removal risk assessment process into basically a de facto appeal process?