Public Safety Committee on April 14th, 2016

[The Chair (Mr. Robert Oliphant), Liberal, Rob Oliphant]

I'm calling the 10th meeting of the Standing Committee on Public Safety and National Security to order.

As you know, we are continuing our study, on reference from the House of Commons by order of reference on Thursday, March 24, to study Bill C-7 a bill that all Canadians are concerned about, of course, but there are certain groups more implicated in it than others. We are delighted to have with us representatives from the Mounted Police Professional Association of Canada, the National Police Federation, and the Mounted Police Association of Ontario.

We're going to begin today with a 10-minute presentation from the Mounted Police Professional Association of Canada. It will be followed by a joint presentation from the National Police Federation and the Mounted Police Professional Association of Ontario for 10 minutes as well.

[Rae Banwarie, President, Mounted Police Professional Association of Canada]

Good morning, honourable members of the parliamentary committee, Chair.

My name is Rae Banwarie. I am the President of the Mounted Police Professional Association of Canada. Thank you for the opportunity to address the committee regarding Bill C-7.

I have been involved in the pursuit of collective bargaining and unionization of the RCMP since 2007. MPPAC is a national, non-profit police association comprising regular members and civilian members of the RCMP in every region of the country. We're seeking to become the certified bargaining agent for all non-commissioned members of the RCMP.

I will begin by speaking to some of the amendments we would like to see in Bill C-7 that are found in our brief, which everybody has. We are compared to civil servants in this piece of legislation. The restrictions found in Bill C-7 are from the PSLRA. Why, is the first question? We are not civil servants, yet we're being compared to civil servants. We are a national police agency and should be compared to large police agencies like the OPP, Sûreté du Québec, Toronto metro, Vancouver PD, or Winnipeg Police.

I'll talk about some of the points on page 2 of our brief. As everyone knows, and has been made painfully aware, we continue to lose members of the RCMP. We've had incidents like Mayerthorpe, Moncton, and St. Albert. The list goes on and on. In all of these incidents the components of inadequate resourcing, inadequate training, and inadequate equipment have caused death and injury to our members. The recent four charges still pending in Moncton support this fact.

Why would we have a collective agreement that will continue to place our members' safety and that of the communities we police at risk? When we undermine the member resourcing, the equipment, and the training by not having proper measures in place to safeguard these critical parts of our policing, we're placing our membership at risk and everybody in every community that we police at risk.

We're seeking to have minimum staffing levels. For example, article 22 of the collective agreement of one of the biggest police agencies, the Toronto Police Service, talks about minimum resourcing. That's contained in the brief. We're looking for the ability to have that covered in the collective agreement.

We are also seeking to remove the reference to equipment and their restrictions on the scope of bargaining found in this bill and to add new provisions to address this in a collective agreement. We have amendments that we suggested on page 3 of our brief.

We conducted a national survey for our membership. We did a snapshot of approximately 1,000 members: our members and civilian members who are not part of MPPAC. We have the results, and 94% of the membership we surveyed say they want this as part of their collective agreement: just this one point. That's significant.

I'll move on now to harassment. Canadians sadly have become aware of the issues of harassment, which continue to plague the RCMP. There is a class action in the certification process in British Columbia with over 400 past and current female members of the force. There is another class action led by Linda Davidson, which is seeking $500 million in damages.

There have been multiple cases over the past decades of harassment. Why would a significant issue such as this—which has caused harm to our members and led in many cases to PTSD, sickness, depression, occupational stress injuries, and in some cases, suicides—not be brought under a collective agreement, so that it can be dealt with in an open and transparent manner? Binding arbitration has a potential component for redressing these situations, just like our core values in the RCMP of transparency and openness.

Without harassment being included in the collective agreement, we are essentially assisting in furthering this issue and allowing it to reproduce and flourish in the RCMP. This issue goes directly to the culture of the RCMP, and we have to address it. If we don't address it, we're setting up our organization to continue to fail.

We must delete the reference to “including harassment” in proposed paragraph 238.19(c) of this legislation that we're studying today. I believe it can be brought and should be brought under a collective agreement so we can start to mitigate it and deal with it.

Our recommendations are found on page 3 of our brief.

That is my portion. I will turn the rest of the presentation over to Lee Keane, my director.

[Leland Keane, Board Member, Mounted Police Professional Association of Canada]

Mr. Chairman, honourable members of the committee, thank you for inviting me here to speak.

My name is Leland Keane. I'm a director of the Mounted Police Professional Association of Canada, also known as MPPAC.

I've been involved in the pursuit of collective bargaining for members of the RCMP since 1995. I would like to draw your attention to page 4 regarding discipline in part of our brief.

We have concerns with Bill C-7 about the adequacy and independence of the current process regarding discipline. The commissioner has the authority for appointing conduct authorities and conduct boards, but the appeals from these bodies are decided by the commissioner. The procedure lacks any independence from the RCMP commissioner.

In comparison, Ontario, for instance, has the Ontario Civilian Police Commission, which is much more independent. The first level of decision there on most misconduct issues is decided by the chief of police. Under section 87 of the Ontario Police Services Act, police officers or complainants can appeal that decision with the Ontario Civilian Police Commission, which is appointed by that lieutenant-governor. Further appeals would go through divisional court under section 88.

MPPAC calls upon the government to amend the current RCMP procedures for code of conduct and discipline matters to ensure a greater level of independence from the RCMP commissioner. We would like to see some civilian oversight.

On this fair dispute resolution process, RCMP members are precluded from striking. It's also in MPPAC's constitution. We don't want or seek the right to strike. Binding arbitration is vital to replace that process to make it fair and independent, which replaces our constitutional right to strike.

We have serious concerns about fairness and constitutionality of this dispute resolution in place. We understand the necessity for attracting and retaining personnel and Canada's fiscal circumstances, and the government's position is skewed in favour of that position.

In regard to arbitration, we want an arbitrator to independently consider all relevant factors and weigh those. Factors such as classification of employees would be something that we would be interested in having in the collective agreement. RCMP members are not civil servants, and it's not relevant to compare us to other civil servants.

MPPAC would propose such phrases “as between occupations in the public service” be deleted from the arbitrational factors in the PSLRA. We would like to see, on page 5, a paragraph (b):

the necessity of offering compensation and other terms and conditions of employment in the public service that are comparable to those of other employees in similar occupations in the private and public sectors, including any geographic, industrial or other variations that the arbitration board considers relevant;

[The Chair, Liberal, Rob Oliphant]

Mr. Keane, I don't want to interrupt. I just want you to know you only have one minute left, and you're about halfway through your submission. It may be appropriate for you just to highlight the key points and then refer the committee to your whole submission just so you have covered the whole thing.

[Leland Keane]

Thank you very much, Mr. Chairman. Absolutely.

I'll draw your attention to clause 40 of Bill C-7, the Government Employees Compensation Act. We would like that section struck. We have a situation that's dealt with internally by the RCMP management. Our members overwhelmingly do not want to be subject to provincial workers' compensation boards. Witness our recent survey, which we can provide to you.

We also have concerns regarding the clarity of the terms regarding affiliation under the PSLRA. It's too vague. There are some charter issues there with the association under the charter. “Affiliation” is not defined and can be used once we have certified, even against us in that.

What we seek in Bill C-7 is that the term “affiliated” be more specifically defined in order to give better guidance to the employee association, which would be allowed to certify.

I think that pretty much covers what we have. I draw your attention to our brief, and we certainly do welcome questions regarding any of those issues in our brief.

[The Chair, Liberal, Rob Oliphant]

Thank you.

I commend the whole of the brief to the committee members. We'll consider this part of your submission.

Mr. Merrifield, from the Mounted Police Association of Ontario.

[Peter Merrifield, Director, Mounted Police Association of Ontario]

As a past president of the Mounted Police Association of Ontario, and a current director, I was one of the original people involved in the application before the courts that began in 2004 and 2005, in the preparatory stages, to be filed in 2006. That application by the Mounted Police Association of Ontario, supported by the British Columbia Mounted Police Professional Association, has led this committee to this room. For 13 years, I have been committed to a piece of legislation whose spirit and intent was to be driven by officer safety and working conditions. This was never an application about pay, benefits, and issues like that.

I would like to tell you briefly about myself so you can understand what, who, and how is addressing you here today.

I am currently a sergeant in the RCMP. For the last three years I have been a member of the internal staff relations program. I have been a member of the Mounted Police Association in good standing for 13 years. I've sat on the board of directors of the Canadian Police Association, and I've been president of the MPAO. I am one of the co-founders and executive chairs of the new National Police Federation, which is another group seeking national certification to represent members of the RCMP. I am also a military veteran, and I proudly served in the Canadian Armed Forces in rotary-wing operations, Mr. O'Toole, just so we are clear. I've stood for Parliament and was the first serving member of the RCMP to run in a general federal election, in 2004. Because I am not on that side of the table, I think you know the outcome.

As a co-chair of the national officer safety committee within the RCMP, as well as a member of the national policy health and safety committee, I have been responsible for representing members of the RCMP on health and safety issues in accordance with the Canada Labour Code and in conjunction with RCMP management. Having had a seat at the table, I have a very good view of what's going on inside.

Because the spirit and the intent of this legislation, when we brought it forward as a legal challenge, were to improve the working conditions of the members of the RCMP, I am very concerned over the exclusions and the very limited scope of collective bargaining that have been included in Bill C-7. Originally, we would have liked to see a Royal Canadian Mounted Police labour relations act. That didn't seem to come to fruition. There seem to be remnants, from our management and whoever was involved in drafting the legislation, that seem to mirror the former Bill C-43. We have to work with what we are given, and as an appellant before the courts I appreciate the very strict timeline that this committee has been given to try to generate this.

As a result of that, and my having been one of the people who compiled this, there really was an overwhelming desire to improve officer safety and working conditions. Our application sought rights and the ability to influence and determine our working conditions. Once it was submitted, we fought for nine years before the courts, at every level: Ontario Superior Court, Court of Appeal, Supreme Court of Canada. We sought to right a wrong, which is often what police officers do. Our seeking to right that wrong was to seek the fundamental rights that every other Canadian had, that every other police officer in the country had, and that was to have a say in our working conditions, to be entitled to legally supported collective bargaining.

More than a year after the decision by the Supreme Court, it would appear that the legislation presented by way of Bill C-7 does not embrace the spirit and intent of the MPAO/BCMPPA application, nor of the SCC decision itself. The intention of the SCC included a key word, which I often do not hear repeated, and that is the word “meaningful”. It was to include choice and independence, to guarantee that we were able to participate in meaningful collective bargaining.

I am somewhat concerned that the input provided to the committee has relied heavily on the management perspective of the RCMP, because this bill, this legislation, is about empowering the members of the RCMP. Because of the information you've been given by management, I feel that—if I can use a euphemism here—somehow the foxes have installed a security system in the henhouse, if you will. I'd like you to consider what matters. When our officers are safe, the public is safe, and that is your responsibility as elected officials.

Now, I had very short notice to appear at the committee. Part of that was my fault. I have a written submission that I will be providing to the clerk through the weekend. It is important you realize that some things that were brought up at the meeting the other day.... I have put my position in the RCMP at risk speaking to you today, and I have brought the signed order of the commissioner of the RCMP with me, if you wish to see it.

That would be my timer, so I would stop at this point and answer any questions you like.

Mr. Sauvé.

[Brian Sauvé, Co-Chair, National Police Federation]

Good morning, Mr. Chair and members of the committee. Thank you for allowing us to speak today on behalf of the general membership of the RCMP.

I'll tell you a little bit about me. I am also a sergeant in the RCMP, presently stationed in Vancouver, British Columbia, but also on leave without pay from the RCMP to work in the National Police Federation as a co-founding chair.

Previous to my role in the National Police Federation, I was a staff relations representative. That particular body elected me to run as the chair of the staff relations representative program's health committee. We advocated on behalf of better health benefits and working conditions under the Canada Labour Code, as well as such supplemental benefits as dental care and massage therapies.

During my period in that role, between May 2012 and February 2016 just past, I was involved in a number of large initiatives. I'll just hit on a couple of them. One was the transition of the RCMP to provincial-territorial health care. Others were the discussions around changes to supplemental benefits, such as dental care and massage; the drafting and release of the RCMP's mental health strategy; the implementation of the Road to Mental Readiness training for members of the RCMP to increase their mental resilience; the outreach of Veterans Affairs benefits to members of the RCMP; and I was directly involved with the study of, the drafting of, and the implementation of the RCMP's internal determination process with respect to occupational injuries. I brought to that the perspective of a member on the ground.

I'll discuss the determination process, because it came up on Tuesday in discussion, and I want to clear up a few issues there. The need for this process came about for two reasons. The first was the change to provincial health care. The second was our position that the RCMP for many years had not dealt with members who got sick on the job in a timely fashion, allowing them to languish, perhaps fall through the cracks, and not return to work in a timely and effective manner. Our position was simple. The RCMP needed to adopt a national determination process for occupational injuries to treat all members equally, regardless of posting, division, province, or territory.

I will say that the idea of moving to a provincial compensation or a workers' compensation board idea was brought to the table by RCMP management. It was unequivocally, categorically, and vehemently opposed by me, by my committee, and by the entire SRR program. The reasons for that I'll go into now.

We are Canada's national police force. Our members should be treated equally everywhere in Canada, no matter their province of posting. Most of those members do not choose their province of posting. This brings in the area of concern over adjudication of occupational injuries and how provinces differ.

Some examples, and these are just the highlights, would be presumptive legislation for PTSD regarding first responders. Ontario just passed that. Ontario has it. Alberta has it. Manitoba has it for all employees. Nova Scotia, New Brunswick, and B.C. have private members' bills out there that are seeking to get it, but we don't know if those will pass. Other provinces do not. Suffice it to say, then, that in today's RCMP, with the focus on the mental health and well-being of its members, I would suggest perhaps more study needs to be done in that area before pulling the pin.

Chronic stress claims resulting from workplace harassment vary significantly from province to province under workers' compensation. There is no clear benchmark. In my role as an SRR, I can attest that disciplinary proceedings have a significant impact on the involved member. The stress from protracted investigations and protracted discipline hearings can have a permanent impact on that member's life.

Appeal timelines in the workers' compensation world vary considerably between provinces. The lowest is a 30-day appeal for Nova Scotia. The longest is one year. Some provinces have different timelines according to what the decision was about.

Then there are the job search bonuses in case of a discharge—for example, if someone cannot return to active duty and they end up taking a medical discharge. The job search bonuses, whether you're actively seeking or not actively seeking, vary widely across the country, depending on the province you're in.

These are a few of the concerns, just the highlights, with respect to the inequality of care that exists today under WCB legislation across Canada. We have not even begun to discuss a scenario such as a member who gets hurt in Alberta, returns to work, and then gets transferred to New Brunswick. It's my understanding that the receiving WCB can ask to review the entire file of the approving WCB and alter, rescind, or modify treatment.

Not all avenues—

[The Chair, Liberal, Rob Oliphant]

Just to give you a warning, could you wrap up fairly quickly. Thank you.

[Brian Sauvé]

Not all avenues have been adequately explored, and I'd suggest that this change to GECA is premature at best. There are other possible options.

As members of the RCMP, we already are eligible for access to Veterans Affairs Canada through the Pension Act for permanent disabilities. Members who receive a permanent disability related to their service to Canada can apply for a disability pension through VAC. VAC is an independent adjudicator, separate from the RCMP, with internal avenues for appeal such as the Veterans Review and Appeal Board. Through the discussions on disability management, we made the suggestion that seeing as Veterans Affairs Canada is involved at the back end on permanent disability, why not have them involved at the front end making the initial adjudication, so that there is consistent service delivery across the country.

With Veterans Affairs, we've had those discussions with the deputy minister and they are on board. They are interested in doing that. What we would have to provide to them are the business rules that we want to follow. For example, do we want to follow WSIB's business rules? Veterans Affairs would then train and staff-up their staff and provide that service delivery across the country. However, RCMP management was not interested in entertaining that option.

[The Chair, Liberal, Rob Oliphant]

Thank you.

[Brian Sauvé]

I'm open for questions down the road.

This was a last-minute attendance by myself as well, so I'll provide a written submission to the clerk.

[The Chair, Liberal, Rob Oliphant]

Very good. Thank you very much.

To begin our questioning, we're going to start with Mr. Mendicino for seven minutes.

[Marco Mendicino, Liberal, Eglinton—Lawrence, ON]

Thank you very much, Mr. Chair.

I want to begin by thanking each and every one of you for coming before this body today to provide some evidence and important testimony on what is I think a bit of a watershed moment for the RCMP and its members.

Just to give you a little bit of personal background, I'm a former federal prosecutor, with over 10 years of service with the PPSC, which before was the Federal Prosecution Service. In that capacity I was the president of the Association of Justice Counsel, which was the first association to represent DOJ civil lawyers and federal prosecutors at the bargaining table. So I just want to tell you there is light at the end of the tunnel.

I was there when we were certified and we had to go and compete for it. I was there when we did our first two rounds of collective bargaining. I was there when we regrettably had to actually engage in some litigation with the government. Hopefully it doesn't come to that. I think that your appearance today will be part of a productive and ongoing dialogue as we make our way towards your end goals, your workplace goals.

I've got three areas I'd like to focus on, and most of them can fall under the broad category of exclusions. I take it from your written submissions that this is an area of primary importance. I'm talking specifically about what I think is proposed subsection 238.19, where the exclusions...what would not be bargainable, if I can put in just more general language.

Let's talk quickly about harassment, and I don't mean to do the subject any disservice, but I know that there is a lot of history there. It's well documented. There is active litigation. It's a delicate issue. Can I ask, are there other collective bargaining agreements, that you have come across where harassment has been on the bargaining table? It really is an open question. I don't have anybody in mind in answering this.

[Peter Merrifield]

When it comes to exclusions, I think the models to cite.... I listened to the testimony Tuesday, and comments from both Deputy Commissioner Dubeau, and I believe Minister Goodale talked about Bill C-7 being in alignment with all of the other police associations in the country, but we beg to differ. Two of the largest provinces, British Columbia and Ontario, don't list exclusions. So, yes, in their collective bargainings, within British Columbia the fire services and police act, have no exclusions, absolutely none. Within Ontario, it's listed within section 119(3) of the Police Services Act, where so long as it falls in compliance with section 126, which describes the duties of a police officer, components may be included in collective bargaining.

[Marco Mendicino, Liberal, Eglinton—Lawrence, ON]

So the short answer is yes. I think to be fair to the RCMP management witnesses who testified a couple of days ago, they did clarify in their testimony that they had some research that would illustrate that this wasn't unprecedented. I wouldn't want to leave any member of the public or the members of this committee with the impression that they were in any way trying to mislead. I think they would admit that there are other examples to be cited from.

I think one of my colleagues, Mr. Erskine-Smith, did ask them to come back to us with evidence, so we hope to receive that. I would encourage you to do the same.

Have you got any concrete language or proposals? Have you started to turn your mind around what a statement of principle around harassment looks like? Unless I'm mistaken, I don't see that in your submission.

[Rae Banwarie]

We're just in the introductory stages of that as part of an amendment to it, but it is a very big, dynamic, huge issue that we're going to have to bring forward in terms of what you're asking for, but that's something that our lawyers are looking at right now to go into more in depth for us as part of our proposal for a collective agreement.

[Marco Mendicino, Liberal, Eglinton—Lawrence, ON]

Let me leave this thought with you. There are substantive rights and there are procedural rights in the law, and you could have, assuming this is something you are thinking about and brainstorming... Again, I am in no way trying to sort of predetermine the outcome of this committee's deliberations on this subject. If you were talking about a substantive right like no discrimination or harassment in the workplace, and then leave it to another form or body to scope out procedurally how you uphold that right... I put that out there.

The second area that I want to talk to you about is just safety and uniforms. This is something that did come up in your submission, and you actually refer to a case that is from the Ontario Court of Appeal, which is at page 2, footnote 2, and the name of the case is Re Metropolitan Toronto Board of Commissioners of Police and Metro Toronto Police Association. That's very helpful for all of us.

I'm going to go back and try to read that case a little bit, but I do believe that since that case there have been amendments to the Police Services Act that would make the very subject matter that was approved by the Ontario Court of Appeal at that time not bargainable. What I'm referring to, again very generally, is operational requirements. When you go to the board and say, “We want to put this in the hopper to be negotiated”, when you start to move into a zone that really falls within operational requirements decisions, the general rule is that is a no-fly zone, putting it colloquially.

[Peter Merrifield]

What they've done with respect to that is the residual management right, which is recognized in labour law. With the residual management right within collective bargaining, there are certain things we could not encroach on, but what is supported within other case law decisions is the speaking to the direct officer safety working conditions so, while they did recede a bit on the 1975-76 decisions with the arbitrators and the court of appeals with regard to two-member cars, when it came to the significant components of officer safety, most of those elements have been upheld and allowed to continue to be in collective bargaining agreements. There is language to support that, which is missing in Bill C-7, even language about collaborative committees. There is not one word in Bill C-7 for a collaborative committee outside of the Canada Labour Code mandatory committee.

[Marco Mendicino, Liberal, Eglinton—Lawrence, ON]

I'm familiar with that kind of entity, but just in the interests of time, I want to come back to harassment because I know that this is a real preoccupation with all of the associations and I'm sure with the employer as well. There was a statement made by one of the witnesses that resonated with me, and that is, if we don't have harassment on the bargaining table, it would allow the current state of dysfunction to continue, if I understood it correctly.

I would say that, in a scenario where harassment is determined in our report referred back to the House not to be on the table, in other words, that the current proposal remain as is, it seems to me on a reading of the Public Service Labour Relations Act, under which you would fall, that you do have other recourse. Namely, you could file an unfair labour practice complaint, and so there is language that does deal specifically with harassment and with discrimination, and those statutory avenues would be presumptively available to you in a situation where you couldn't bargain it, so just to give you some—

[The Chair, Liberal, Rob Oliphant]

I'm afraid I need to interrupt you.

If you would like to respond specifically on that issue, we would welcome anything in writing.

Mr. O'Toole.

[The Honourable Erin O'Toole, Conservative, Erin O'Toole]

Thank you all for appearing and certainly for your service.

The Conservative Party has tried to approach Bill C-7in a way that respects the timelines involved and respects the unique nature of the RCMP, so, unlike Mr. Mendicino, who just talked about harassment, we're focused on clauses 40 and 42. You may have followed our questions on that, and that's where our concern lies.

I was struck though, Mr. Banwarie, that you suggested you are surprised that this is like the PSLRA, but that was what the court case was about. The charter right was that the staff relations program did not provide the charter right, which is kind of why we're here.

A couple of you mentioned that you were part of the staff relations program, the insufficiency of which led to the decision of the Supreme Court of Canada. What specifically with that structure was the inherent weakness, from your point of view, for those who were involved directly in those roles?

[Peter Merrifield]

Fundamentally, with the application from the MPAO side it was a lack of independence for management that was probably the key component. It's very difficult to utilize the system for resolution for workplace conflict, difficulty, harassment, safety concerns, when your program of representation ultimately reports to and is funded and controlled by management. It was that seeking of independence.

Make no mistake: they fought some great fights on behalf of members and they achieved certain things, but the court clearly recognized that because of the totalitarian nature of a paramilitary structure, in the Royal Canadian Mounted Police, there was a glass ceiling. This was to remove that glass ceiling.

That would be the most inherent difficulty, I suspect, and it forced a lot of creative manoeuvring to try to get around it.

This just opens the door and gives the same fair ability to deal directly with management from an independent, protected position that other police services enjoy through their associations.

[Rae Banwarie]

We have the same sort of scenario now, with the Enhancing Royal Canadian Mounted Police Accountability Act, in terms of discipline and everything. The employer controls all facets of that process, whether it's a conduct board, a medical board, or a discharge process. The only avenue available to our members is through litigation and the courts; that's it.

There's no procedural fairness in that set-up. That's why that whole component involving discipline and conduct must be removed and must go to an independent process.

[Erin O'Toole, Conservative, Durham, ON]

I'd like to follow up on that, because that is an area in which I feel the government has struck the right balance.

Mr. Merrifield, you talked about the RCMP and their important role as a paramilitary organization. I think there are certainly problems.... If discipline, operational matters, postings—all of the unique nature of our federal police service, which I'm very proud of—should not be part of collective bargaining, essentially you don't have a chain of command, and you can't be the unique force that you are.

Not that I'm trying to help these guys too much, but Bill C-7 tries to get the balance right. That's my point of view. I don't want to see a unionized military. I don't think you would have thought it would work well when you were in rotary-wing.

I'm going to devote what little time I have to what Mr. Sauvé focused on very well, which is the potential lack of a high standard with clauses 40 and 42.

While I was veterans affairs minister, as someone in the crowd knows here today, I made sure that the veterans association was part of my direct stakeholder advisory group, and I was inclined to the solution you discussed in terms of using the expertise at VAC.

A key concern is whether you have been able to identify provinces in which the standards for workers compensation are not at levels that you feel are sufficient for the RCMP.