There are four points that I would offer for this proposed amendment.
First, given that length of time is a significant factor in shaping the bill, it is something that would normally be put in the Citizenship Act and legislation, and not put in the regulations.
The second point is that it would be redundant to have it in two places. The proposed amendment would have it in the act, but you would also have it in the regulations.
The third point is that there is already regulation-making authority in the act to define the information and evidence that would be required for us to assess the substantial connection requirement. I would like to point out that the department already does this on a regular basis for various lines of businesses, from assessing permanent residency status to assessing the grant of citizenship, whereby they have to meet 1,095 days within the last five years.
We also do this through the interim measure, whereby for those born on and after December 19, 2003, they would have to demonstrate a substantial connection to Canada of 1,095 days. The department already has a lot of experience and is doing this already. We have processes in place.
The last point is that putting this into the regulations versus operational guidance would make it quite restrictive in terms of giving us the flexibility to assess the requirement.