Citizenship and Immigration Committee on April 14th, 2016

[The Chair, Liberal, Borys Wrzesnewskyj]

Good morning. I'd like to call the meeting to order.

Pursuant to the order of reference received by the committee on March 21, 2016, the committee will now proceed to the consideration of Bill C-6, An Act to amend the Citizenship Act and to make consequential amendments to another Act.

I'd like to welcome our first panel of witnesses on the subject of Bill C-6: Andrew Brouwer, senior counsel in refugee law, Legal Aid Ontario; Audrey Macklin, professor and chair in human rights at the faculty of law, University of Toronto; and Tamra Thomson, director of legislation and law reform, and Christopher Veeman, executive member of the immigration law section, both from the Canadian Bar Association.

Welcome. Each of you will have seven minutes or less to make opening statements, and we will proceed alphabetically.

Mr. Brouwer, you're up first.

[Andrew Brouwer, Senior Counsel, Refugee Law, Legal Aid Ontario]

Thank you, Mr. Chair and members of the committee. It's a pleasure to be back before the committee.

I work for Legal Aid Ontario, or LAO. Legal Aid is the country's largest legal aid plan. Our mandate is to ensure access to justice for the most vulnerable and marginalized Ontarians. We do that through staff legal services, community and specialty legal clinics, and of course, funding private bar lawyers on certificates to represent our clients. Legal Aid Ontario helps almost 4,000 low-income Ontarians each day, accessing justice in the areas of criminal, family, immigration and refugee, and poverty law matters.

Legal Aid Ontario also has a law reform mandate directed to the core goal of access to justice for the most vulnerable. We have a number of key priority areas in the area of refugee and immigration law. Those are, first of all, equal access to and effective protection of charter rights; protection of mentally ill non-citizens; protection and promotion of the rights of the child; domestic implementation of international human rights law; and access to and protection of citizenship, particularly for naturalized Canadians.

We applaud the government today for introducing Bill C-6 so very early in its mandate, and we support much of what's in the bill. We're particularly pleased about the provisions scrapping the intention to reside requirement and removing the power to strip citizenship for national security grounds. We also support the changes to the language and the residency requirements for naturalization.

That said, in our view the bill's not perfect. There are some significant problems and gaps that we hope this committee can address. Of particular concern to us are five areas. I've handed out a summary in English and French of the specific recommendations we have, and I hope those are before you. I'll just go through very briefly what we're suggesting.

The first issue I know has been a topic of a great deal of debate. I'll rely on Professor Macklin on the issue of the revocation process. Legal Aid Ontario shares Professor Macklin's position on the best remedy for that, and I know that Minister McCallum has also expressed interest in looking at how to reform that provision.

The second is with respect to remedies for refused citizenship applications. Bill C-24 stripped refused citizenship applicants of their right to appeal refusals to the Federal Court, and introduced instead a remedy of judicial review by way of leave. That change imposes unjust and costly barriers to access to justice, particularly in an area that really goes to the core of what it means to be a member of society. Leave requirements in Federal Court can double the time it takes to get a remedy and double the cost of seeking that remedy; and leave refusals, as I'm sure you know, are made without reasons by the Federal Court judge, which does an injustice to the individual applicants who naturally will perceive the leave requirement as being arbitrary. They don't know why they get refused. We therefore urge the committee to amend Bill C-6 to reverse the amendments that were introduced in section 20 of Bill C-24 and return to the Federal Court appeal provisions that existed before.

Our third area of concern is with respect to the first generation born abroad limitation. We were very pleased to hear Minister McCallum affirm before this committee that there should be one class of citizen. There's no place in Canadian law, in our view, for provisions that treat citizens born on our territory differently from those who are naturalized. My grandchild will be a Canadian citizen no matter where she's born. Mr. Virani's grandchild—he is my MP—will not be, unless she's born on Canadian territory. That's an unjust distinction. We ask, therefore, that the committee amend Bill C-6 to include a provision that strikes down the first generation born aboard provision in section 3(3) of the Citizenship Act.

The fourth area of concern is with respect to the residency calculation. We supported the change to the residency requirements that were set out in Bill C-6. We ask that they be expanded so that credit can also be given for Canadian residency to those who have made a refugee claim that's been found eligible but are waiting to have their hearing. As you know, there is a massive backlog right now. People are waiting for three or four years to have their claim heard. They should get credit for that time.

As well, those who have been accepted on humanitarian and compassionate grounds at stage one should also get credit for the time. It's a two-stage process, and people sometimes wait for years to get the final approval. That period of delay is not the fault of the applicant; it's a problem at Immigration, which is just taking too long to process them. We ask that they also get half-time credit for that period.

Finally, I'd like to ask the committee to consider seriously the issue of statelessness and how this act can be amended to deal with the stateless within Canada.

We are certainly hopeful that the new government's renewed recognition of the importance of international law and global engagement will result in our signing the 1954 Convention Relating to the Status of Stateless Persons, but there is something that we can do right now with this act to make sure that we are better protecting stateless persons and coming into better compliance with international law and norms.

We have three recommendations.

The first, which is critical, is to include a definition of “statelessness” within paragraph (a) of subsection 2(2) of the act. We ask that this include both de jure or legal statelessness as well as de facto statelessness. Practically speaking, the whole point of dealing with statelessness and assisting stateless persons to get protection is to make sure that every member of society has a connection to a state.

Concerns have been expressed by various people, including in a case in the U.K. called Pham, which shows the problems when we have an overly legalistic and narrow definition of statelessness. We are proposing the following definition, which is also included in the materials handed out. It's that “stateless” means that the person is not considered as a national by any state under the operation of its law and includes both de jure and de facto statelessness.

I've handed out a little printout from the website of CIC, which includes this government's understanding and definition of those two terms, de jure and de facto.

The second provision with respect to statelessness is that we're asking for an amendment to subsection 5(4) of the act, the provision that allows discretionary grants of citizenship in special cases. We propose that statelessness be identified specifically within the act as a factor that would justify a grant of citizenship under subsection 5(4).

Finally, we are proposing an amendment to section 10 of the Citizenship Act, the revocation process. We propose adding a restriction on revocation when it might result in a person's becoming stateless, whether de jure or de facto. We believe this would provide a very significant protection against an unexpected result of a revocation decision, and we ask that you seriously consider it.

Those are my submissions.

[The Chair, Liberal, Borys Wrzesnewskyj]

I'd like to remind the witnesses—I was a little lenient there on the timing—to attempt to stay within the seven minutes allocated for each witness's testimony.

Professor Macklin.

[Prof. Audrey Macklin, Professor, Faculty of Law, University of Toronto, As an Individual]

Thank you for this opportunity to make a presentation.

I will give my presentation in English but will do my best to answer any questions you might have for me in French.

I would like to echo Mr. Brouwer's congratulations to the government for the many salutary features of Bill C-6. For reasons of time, I'm going to accentuate those factors that I think perhaps still require further attention.

My presentation will be exclusively on the question of the procedure for the revocation of citizenship based on fraud or misrepresentation.

The process as it currently exists, through the amendments to the Citizenship Act made by the previous government, is such that where the government considers revoking citizenship, the minister or a delegate sends a notice to the individual concerned. The individual, the citizen, then has the opportunity to respond in writing to the allegations leading to the intention to revoke citizenship. That's done exclusively in writing, except that the minister has discretion to convene an oral hearing.

Based on whatever submissions the minister receives in response, and other evidence before the minister, the minister then makes a decision to revoke citizenship. At that point, the individual may seek judicial review before the Federal Court, but can only do so with leave of the Federal Court.

Rather than walk through a jurisprudential analysis of why I think this process probably fails to pass constitutional muster, let me just explain it through some examples.

Generally speaking, the more secure one's status, whatever it is, the greater the procedural protections one is afforded prior to a decision to remove that status. Similarly, the more important the consequences of the decision, the greater the emphasis is on procedural fairness in the course of making the decision that will have that consequence.

Bear those two features in mind while I recount that the process under the current law for revoking citizenship provides fewer procedural protections than one would have as a permanent resident before the immigration appeal division, or indeed, as an individual fighting a speeding ticket in court. I hope that illustrates to you that there might be something problematic about revoking somebody's citizenship with a thinner, less protective process than is required to lose permanent resident status or, indeed, to fight a speeding ticket in court.

I should add that in the United States, for example, citizenship revocation on grounds of fraud or misrepresentation is done through a civil court process. That is, it is done before an ordinary court using ordinary civil court procedures.

What I will do is offer a suggestion or proposal for how one might consider amending the existing citizenship revocation process in a manner that would bring it into compliance with section 7 of the Charter of Rights and Freedoms. Section 7 of the charter guarantees to everybody the right to life, liberty and security of the person and the right not to be deprived thereof except in accordance with fundamental justice.

What I am proposing here is a mechanism for dealing with citizenship revocation on grounds of fraud or misrepresentation that complies, I think, with principles of fundamental justice. Let me preface it by saying that I anticipate that the majority of cases that would come up for revocation would concern potential fraud or misrepresentation regarding the physical residence requirements for citizenship, although there are certainly many other bases upon which citizenship could be revoked.

What I propose is that the first level decision remain with a delegate of the Department of Immigration, Refugees and Citizenship. From there, I would suggest that, should an adverse decision be made, the individual has the right to appeal to an independent quasi-judicial tribunal. An example of that one could consider is the immigration appeal division of the Immigration and Refugee Board. One might choose that or one might develop some other tribunal for that purpose.

One would have to consider the composition of that tribunal. Should they be legally trained? Do you want one member, perhaps two members or three members? These are all issues to be considered.

With respect to important questions of procedure and evidence before that appeal body, I think it would be important that the burden of proof—that is, proving that the facts and the law in favour of revocation are met—be on the minister; that it be proven on a balance of probabilities; that there be full disclosure of the record, so that the citizen has access to all the available evidence; and in addition, that the parties be able to adduce further evidence on appeal.

What would the jurisdiction or the mandate of such a tribunal be? It would be able to consider an appeal on the basis of law, fact, discretion, as well as what are called “equitable” considerations, or humanitarian and compassionate discretion. Broadly speaking, this conforms to the existing mandate of the immigration appeal division with respect to loss of permanent resident status. The tribunal would have various remedial options, which again could be further explored in questions.

What happens from there? It goes from the initial decision maker to an independent appeal body that has the ability to uphold or set aside the decision made by the first-level decision maker. In the event of an adverse decision, either side could then go to the Federal Court. One might ask whether it should be an appeal or a judicial review. I would favour an appeal. I think this is a matter, certainly, for further discussion.

It is important, and here I would concur with what Andrew said with respect to denials of grant of citizenship, that it be “as of right”; that is, that there be no leave requirement.

With that, I will end my presentation here. I look forward to questions.

[The Chair, Liberal, Borys Wrzesnewskyj]

Thank you, Professor Macklin.

I would now like to ask Ms. Thomson for her presentation.

You have seven minutes, please.

[Tamra Thomson, Director, Legislation and Law Reform, Canadian Bar Association]

Thank you, Mr. Chair, and honourable members.

Mr. Veeman and I will be sharing the seven minutes.

I'd like to start by thanking you for the opportunity to appear on these amendments to the Citizenship Act today.

The Canadian Bar Association is a national association. We are more than 36,000 lawyers across Canada, more than 1,000 of whom are members of the immigration law section, whose primary objectives include improvement of the law and the administration of justice. That is the optic by which we have reviewed the bill and make our comments to you today.

The submission you have before you was prepared and approved as a public statement by members of the immigration law section, and reviewed by the legislation and law reform committee. I would like to pass to Mr. Veeman to make the remainder of our remarks.

[Christopher Veeman, Executive Member, National Immigration Law Section, Canadian Bar Association]

Thank you to the committee for the invitation to appear.

I'm assuming that everybody has the submission. I'm proposing to highlight some of the points that we make in the submission, but it's there for you to review at your leisure.

Over the time I've been practising in this area, it's possible to discern two phases in Canadian citizenship law. The law was largely unchanged after the major rewrite in 1977—with the exception of the lost Canadian issue in 2009—until Bill C-24 came into effect. Leading up to Bill C-24, the perspective of practitioners in this area was that the system was in its “Byzantine” phase, if you can use that word. I say this because nobody knew what the legal test was for residency and how you qualified to become a citizen. There was a problem with the jurisprudence. The courts couldn't solve that problem, the processing times were backlogged, and Canada's interests were not being served by the old system.

The CBA supported the efforts in Bill C-24 to improve that situation. To its credit, Bill C-24 did fix a lot of those problems. The definition of residency was clarified, so we now have the physical presence definition. The decision-making process was streamlined, and also the government committed resources to processing. All those things led to the decline in processing times that we've seen.

Back in 2014 the CBA opposed many of the other parts of Bill C-24. While Bill C-24 brought citizenship law out of its Byzantine phase, in the view of some practitioners it moved it in a sort of Kafkaesque direction where, as we've heard, a person can have their citizenship revoked by a government official without any hearing. In a point that wasn't touched on yet, section 13.1 was introduced into the law, which allows the department to suspend processing of an application essentially indefinitely. These are features that in our view do not support the rule of law. Another thing we heard under the changes that came in with Bill C-24 was that the system of appeals for citizenship matters was changed to judicial review instead. From the point of view of practitioners, that's an inferior system. As we've heard, you need to get leave, and in all cases where you don't get leave, you don't get reasons. People can get an application refused, and they don't have the opportunity to get an appeal with reasons.

Our section supports many of the aspects of Bill C-6 that reverse some of those changes, in particular the national interest revocation. We were strongly opposed to that. Rather than listing all the points that we do agree with, which are in our brief, I want to point out some of the things where we think the bill can be improved.

The first one has already been touched on today by Professor Macklin, and also by the minister in his remarks last Tuesday, which is the question of ensuring there is a fair and independent process for persons subject to revocation of citizenship for misrepresentation or fraud. Professor Macklin outlined that, so I'm going to skip over parts of this. Our solution for this problem is slightly different from what Professor Macklin has proposed. The overall goal is the same, to ensure that everyone has the opportunity to at some point have their case considered on humanitarian and compassionate grounds prior to the revocation of their citizenship. In our view, it may be appropriate to consider granting the department official that discretion when they're reviewing the case and have that decision directly reviewed by the Federal Court on a reasonableness standard.

In some situations under the current law, people can have their citizenship revoked for misrepresentation, and they go directly back to foreign national status. This is the case where the misrepresentation occurred in their permanent residency application, and then they subsequently obtained citizenship.

We say that all persons who have their citizenship revoked should revert to permanent resident status, and then have an appeal before the Immigration Appeal Division to retain that status and try to remain in Canada.

In our brief we have advocated, in terms of the grant of citizenship process, for some residual discretion to grant citizenship in deserving cases where people cannot meet the physical presence test, despite strong connections to the country and a desire to become Canadian citizens. In 2014 we proposed certain definitions that might be used.

I'll just give you a couple of examples of cases that might be problematic. A pilot who lives in Canada but is flying overseas for work may have trouble meeting the three in five standard. Just as an aside, the three in five standard is an improvement from the four in six. It's slightly more flexible, but still, there may be these hard cases that will arise.

[The Chair, Liberal, Borys Wrzesnewskyj]

Thank you, Mr. Veeman. Perhaps we can get into some of the other recommendations during the questioning. Your time is up.

Ms. Zahid, you have seven minutes for questions to our witnesses.

[Salma Zahid, Liberal, Scarborough Centre, ON]

First of all, I would like to take this opportunity to thank all our witnesses for coming and providing their input to this important legislation we are going through.

First, my question is either for Christopher or Tamra from the Canadian Bar Association. I read your submission. In your brief, you called for more flexibility in determining an applicant's ties to Canada rather than strictly relying on strict measures of physical delays. I certainly support flexibility and don't believe in unnecessarily onerous and lengthy residency requirements, but would giving citizenship judges more subjectivity here not open the door to potential uneven applications of the Canadianization demonstration, with standards varying from judge to judge?

[Christopher Veeman]

Yes, it's certainly possible that there could be differences, if you have to have a decision-maker assessing those questions. This type of analysis is undertaken in the context of the Immigration and Refugee Protection Act, section 25, where people can make an application to remain in Canada as a permanent resident on humanitarian and compassionate grounds.

That type of decision-making exists in our law in this general area. I guess from our perspective, we're the ones who are dealing with the people who have these hard cases, and we're looking for a way to advocate for them. We think some of them may have strong cases to become citizens.

[Salma Zahid, Liberal, Scarborough Centre, ON]

My question is for Andrew Brouwer. You have written and spoken extensively on the issues of statelessness and Canada's need to adhere to its international obligations with regard to not rendering any individual stateless through its immigration policies. Several bills have sought to address shortcomings in the Citizenship Act in this regard. Could you outline what changes you feel are still necessary to address this issue? Should these changes be made as an amendment to Bill C-6, or would they be better addressed on their own with stand-alone legislation that would allow for a more focused debate on that matter?

[Andrew Brouwer]

Certainly there's a great deal that Canada could and should do with respect to statelessness. We're here talking about Bill C-6. I do think that, if you take a look at my handout, you'll see there are some changes that can be made in this context that would make a big difference right now with respect to access to citizenship; and particularly, introducing a definition in law, in the Citizenship Act, would make a big difference.

Beyond that, though, I agree. There are some larger issues that need to be dealt with, with respect to the protection of stateless persons. I know that the UNHCR, Amnesty International, and other organizations have been asking the new government to consider, once again, signing on to the 1954 convention. I think that would be a very important step, and having done that, establishing a process for status determination for stateless persons likewise would be an important step.

If we were able to recognize—through a procedure like they have in the U.K. and in other countries—a procedure for determining whether someone is truly de facto or de jure stateless, and then grant them access to Canadian status, I think that would be a critical change. That is a stand-alone measure that needs to happen, and that needs to have some debate and some legislative crafting, for sure.

Beyond that, another measure that I understand the department was looking at was to make amendments to the H and C, the humanitarian and compassionate, permanent residence guidelines to make sure that statelessness is an identified factor for the exercise of discretion under section 25 for grants of permanent residence. That would be similar to what I'm recommending now that the Citizenship Act have under subsection 5(4), which is again a recognition that statelessness is an important factor that should justify an exercise of discretion to grant citizenship.

[Salma Zahid, Liberal, Scarborough Centre, ON]

My question is for Ms. Macklin.

I would like to touch on the revocation of citizenship for acts that demonstrate the [Inaudible--Editor] “Canadian values” that was introduced to the Citizenship Act by Bill C-24 and that Bill C-6 proposes to remove. In an op-ed in the Toronto Star on April 25, 2013, you likened this provision to the “medieval practice of banishment”.

Could you discuss how allowing a politician to revoke citizenship for a vaguely defined [Inaudible--Editor] of values opens the door to a slippery slope of grounds for revocation and opens the provision to a likely challenge under the Charter of Rights and Freedoms if it is not removed from the act?

[Prof. Audrey Macklin]

The revocation of citizenship engages several charter rights, most notably I think section 7, which I described earlier. It may also constitute cruel and unusual treatment or punishment, as the Federal Court has recently defined it in the refugee health care case.

The way in which the previous government formulated citizenship revocation was to predicate it on commission of listed offences. They were, broadly speaking, national security offences. If you were convicted for one of those offences, the minister could further revoke citizenship.

That tells us two things. One is that citizenship revocation is in effect being used as punishment. It is a punishment that is being imposed by a minister outside of a normal minister's legal powers. The power to find somebody guilty of a crime and to punish them belongs to a court and only to a court. A minister doesn't have that authority. That's one problem. Another, of course, is the principle of double punishment, that whoever does it, you can't punish somebody twice for the same offence. These are in addition to constituting it as what I've called cruel and unusual treatment or punishment.

Finally, in earlier jurisprudence from the Supreme Court of Canada about denying prisoners the right to vote, the court there said that revoking something as fundamental as a right of citizenship in furtherance of the achievement of symbolic value constituted a breach of the right to vote. If you take that principle and extrapolate it, then surely it applies to citizenship as well.

[The Chair, Liberal, Borys Wrzesnewskyj]

Thank you, Ms. Macklin.

Mr. Tilson, for seven minutes.

[David Tilson, Conservative, Dufferin—Caledon, ON]

Some of you have been here before for Bill C-24. Welcome back. All of your presentations are legal, but I can understand why: you're all lawyers.

I want to ask a question on the issue of revocation, which deals with terrorism. It's happening more and more, particularly in Europe, but it has happened here.

Canadians want to feel safe. I just want to outline—you probably already know this, but I'll outline it anyway—three other jurisdictions that have similar legislation to Bill C-24, and if we have time, perhaps you could comment on them.

In the United Kingdom, under the provisions of the British Nationality Act 1981, a natural-born British citizen could have their citizenship revoked if the Home Secretary is satisfied that it would be conducive to the public good to do so and the person would not be rendered stateless. Naturalized citizens of the United Kingdom could have their citizenship revoked if the Home Secretary is satisfied that it would be conducive to the public good to revoke citizenship because the person engaged in conduct seriously prejudicial to the U.K.'s vital interests and the Home Secretary had reasonable grounds to believe that the person could acquire another nationality.

The latter provision, which would leave a person stateless, came into effect two years ago. The term “conducive to the public good” includes involvement in terrorism, espionage, serious organized crime, war crimes, or unacceptable behaviours.

In France, where it's still being dealt with—their legislation has passed through the lower house and is now in the Senate—the French law allows naturalized citizens to have their citizenship revoked if doing so will not render them stateless.

All states seem to be concerned with the issues that you've raised on statelessness.

Article 25 of the Code Civile provides that citizenship may be revoked for persons convicted of certain crimes related to national security; however, citizenship can only be revoked if it was acquired less than ten years before the conviction, or 15, depending on the crime. In other words, I suppose there's the issue of fraud, which I don't recall any of you having commented on.

The current debate in France is over a new legislative proposal to allow for revocation of the citizenship of natural-born French citizens with another citizenship when they are convicted of a crime of a serious attack on the life of the nation. The law passed the French lower house of their parliament in February and is now before the Senate. It's quite controversial. It hasn't passed, that I know of.

Following the passage in both houses, the law would require a constitutional amendment, and this in return requires a two-fifths majority vote in their two legislative houses together. That may not happen.

In Australia, there were changes in December of last year. Dual-national Australians may lose their citizenship for national security reasons. The specific grounds for losing citizenship are engaging in specified terrorist-related conduct, fighting for a declared terrorist organization, and being convicted of a specified terrorism offence.

These laws seem to be similar to what was put forward in Bill C-24, although the French law may not happen. I'll ask particularly the representatives from the Canadian Bar Association—maybe we'll start off with Mr. Veeman—whether you have any reaction to this. I expect you're going to say, ah, but we have the Charter of Rights, although to my knowledge there's no jurisprudence on that subject as of yet.

[Christopher Veeman]

I think my reaction is more of a practical one, in the sense that I'm not sure how the revocation of someone's citizenship actually makes us safer. I think the problem of terrorism—

[David Tilson, Conservative, Dufferin—Caledon, ON]

Well, they'll be gone. That's what makes it safer.

[Christopher Veeman]

Yes, but people will find a way back into the country. It's better to keep them in a jail, which, if they're convicted of a terrorism crime, is probably where they're going to end up.

[David Tilson, Conservative, Dufferin—Caledon, ON]

Mr. Chairman, speaking through you, my understanding of these three jurisdictions and of Bill C-24 is that this would happen after a conviction—not before a conviction, but after a conviction.

[Christopher Veeman]

I haven't studied that legislation.

[David Tilson, Conservative, Dufferin—Caledon, ON]

Ms. Thomson?

[Tamra Thomson]

I'll defer.

[Prof. Audrey Macklin]

I can speak to this, if you'll permit me.

French President François Hollande has recently announced that they have abandoned their attempt to enact that legislation, so I don't think France is doing that.

It is true that Australia doesn't have any kind of entrenched bill of rights. In Britain, from what I understand, it is continually litigated and remains litigated, most recently in the Pham case. Rather than point out the anomalous cases of countries that have enacted this legislation, I think it's more interesting to note how many haven't, including the United States, which long ago, through the U.S. Supreme Court said, “citizenship is not a license that expires upon misbehaviour”.

As to the idea that we are made safer by stripping citizenship and removing people, my understanding is that governments have characterized terrorism as a global problem. That is to say, it is not one that is parochial in the sense that we resolve it by exporting it to somewhere else. In fact, people remain at risk, so exporting people who are alleged terrorists to some other country is in fact not a solution on its own terms, such as countries have characterized this problem.

Finally, allow me to highlight the absurdity of following the British model. Let's say that somebody is a Canada-U.K. citizen, and let's say that both countries decide that revocation of this person's citizenship is warranted, then I guess it's just a race to see who gets to revoke it first. The other country has to accept that person because that person will become a “mono-citizen”. If one thinks that the UK approach is a model that ought to be emulated by all other countries, one needs to think of consequences if everybody behaves in that way. I would suggest that the consequences are absurd.

[The Chair, Liberal, Borys Wrzesnewskyj]

Thank you, Professor Macklin.

Ms. Kwan, you have seven minutes.