Thank you for that question.
If I could draw a spectrum across our western allies, with the U.S. at one end and France at the other, we and Australia are somewhere in the middle. The United States has maintained the commanding officer in such a way that they can convene courts martial and things like that. They very much remain an actor in terms of processing courts martial for more serious offences.
That being said, with the changes in 1999 that Bill C-25 brought forth, essentially taking the commanding officer out of the court martial system, we have maintained that type of independence. Through a series of European Court of Human Rights judgments in the 1990s, the UK has sought to further civilianize their system.
To answer your question, the summary hearing system in Bill C-77 would roughly mirror what they call non-judicial punishment in the United States, where the commanding officer can mete out very minor punishments for very minor offences. The U.K. has a similar system, as do the Australians.