It is not a fair assessment at all.
First of all, when it comes to the issue of refunds, there are no gaps. The APPR is indeed poorly drafted, but it is not a complete code. For example, the APPR does not say that passengers are entitled to a seat in the cabin, but the APPR's silence does not mean the airline can transport passengers in the cargo bay. The situation is similar with respect to refunds.
With respect to this specific issue, it is simply not well drafted. The fundamental right of passengers to a refund should have been incorporated in the APPR for simple clarity purposes, which would have spared the public this issue. We cautioned the agency about it in our 52-page report. We cautioned the agency about it during our consultation. Unfortunately, the agency did not listen. The government did not listen.