I make them because, under international law, to assess whether someone is a refugee or not, states are required to give them a right to be heard.
If, for example, you're going to refuse someone, you should give them an opportunity to respond to your concerns. That is also in conformity with Canadian jurisprudence under the Singh decision, so that's under the mandatory hearing requirement. A full appeal right through the refugee appeal division of the IRB is also a right that has been enshrined in international law and norms.
On the moratorium countries, the reason we make that suggestion is that we saw, when Canada brought in amendments in 2019 that did a similar thing and gave PRRA applications to certain ineligible persons as a first-instance refugee status determination, that persons from those countries weren't getting assessed. They don't have an opportunity to get refugee protection. They don't have an opportunity to integrate, and they don't have an opportunity to bring their family over. Arguably, persons from those countries who are under a suspension of removal have strong claims. They're coming from places like Afghanistan, Syria and Iraq, so they should have an opportunity to have their cases heard.