The reference to a criminal record, I understand that to be a reference to one of the areas of exemption, which is determination of rehabilitation. Intuitively I would understand why that might be one for which it is more difficult to establish service standards, but another one that's being exempted, for instance, is an application for a temporary resident permit, so as a result of these changes, someone applying for a temporary resident permit would no longer have the benefit of having an established service standard. It doesn't seem like assessing an application for a temporary resident permit should be any more or less difficult compared to many other application categories in establishing what an appropriate service standard should be.
I can accept the inclusion of the one on determination of rehabilitation, but explain to me why it's somehow difficult to establish what a service standard should be for a temporary resident permit.