As I think the committee is aware, there was a lot of concern from refugee expert organizations and refugee lawyers about the changes in Bill C-12. That legislation has now passed, but we have some important opportunities to address the ways in which we could reduce the inefficiencies and the backlogs that will be created by Bill C-12.
For example, we are concerned about the fairness of hearings under the PRRA system. That could result in backlogs of reviews at the Federal Court later. We are also concerned about families because of the nature of the complex ineligibilities in the bill. These will be split, with parents being sent to the PRRA process and children being sent to the IRB, or a number of individuals will be stuck in limbo for extended periods without status, unable to move on with their lives and in a much worse situation for moving on to contribute to Canada.
The regulations provide an opportunity for the government, and the government has committed to looking at certain kinds of key exemptions that could be introduced for certain kinds of refugee claimants who would not be banned from accessing the IRB. CCR believes strongly that in addition to the exemption for unaccompanied minors, the minister should be looking at exemptions in a few key areas.
They include, for example, the need to have an exemption from the new ineligibilities in the context of a rapid change in a country's condition. That has nothing to do with how long a person has been in the country, but it would enable a more effective process for a person to act as a claimant at the IRB and result in fewer reviews at the Federal Court later.
We think it would be really important to have exemptions for people who are from moratorium countries, meaning countries where Canada cannot return people, which means they would not have access to the PRRA.
We also think it would be important to look at the principle of family reunification and the best interests of the child, so that when a family member already has access to the IRB, they would not be separated from their family, who would be shunted to a separate process in the PRRA.
Those three scenarios could result in revisions of the case, because they could be found to be cases where basically principles of justice were not found.
I think a number of exemptions under Bill C-12 would make for a more effective and expeditious process for Bill C-12 and would be an important part of the national system.