Okay.
Your critique of the board, which I very much appreciate, really advocates making the board a lot more like a court. You'd have independence of the decision-makers, an open process, and two levels, with the more experienced level acting as an appeal division.
You would know well, sir, by virtue of your experience in the judiciary, that administrative tribunals often don't have all the trappings of a formal court system, yet that seems to be what you're advocating. Is there room here, do you believe, for something less than, or a facsimile of, a trial court?