In the case of adding criteria to something in a bill, when you have a list of criteria, you can always play around within the scope of what's required. In this case, we're going beyond just requirements and giving the board additional responsibility, creating an additional administrative burden. In arriving at our analysis of the bill, we looked at the summary of the bill and we looked to the way the bill is drafted.
The summary of the bill reads as follows:
This enactment amends the Criminal Records Act to, among other things, allow persons who have been convicted under the Controlled Drugs and Substances Act, the Narcotic Control Act and the National Defence Act only of simple possession of cannabis offences committed before October 17, 2018 to apply for a record suspension without being subject to the period required by the Criminal Records Act for other offences or to the fee that is otherwise payable in applying for a suspension.
Basically, the bill does two fairly narrow things. It allows people to apply for a record suspension without being subject to the period required by the Criminal Records Act for other offences, and it waives the fee that's otherwise payable in applying for that suspension. That is what guides us in our analysis, as well as the way the bill is drafted. You'll note there are clauses that specify that the onus is on the applicant to prove various things.
That's how we understand the scope of the bill.