This was a submission we made at the time that Bill C-24 was coming into effect. We're still proposing, in what we call the “hard cases”, that there be a provision to allow the department to grant citizenship.
The test that existed prior to Bill C-24 I described as a bit of a vacuum. Nobody really knew, but there were multiple different tests that were applied. As a compromise position, we proposed what IRCC had in citizenship policy manual 5, which were some allowable exceptions to physical presence in Canada. They're set out there on pages 6 and 7.
It's a bit more of a nuanced assessment of the persons's connection to Canada, and potentially could allow someone like your constituent to qualify for citizenship. On the other side of the coin, the physical presence test makes things very black and white for officers who are processing cases. I think that may have contributed to the speed with which they can process them. There's a bit of a trade-off in terms of having discretion on the one hand, to allow those cases to be processed, and the fast processing that everybody wants. CBA's position is that there are those cases where deserving potential citizens should be heard.