To the Honourable Marc Miller, Minister of Immigration, Refugees, and Citizenship,
Dear Minister Miller,
On behalf of the Canadian Immigration Lawyers Association (CILA), a rapidly growing organization representing close to 500 members, we extend our warmest congratulations on your recent appointment as the new Minister of Immigration, Refugees, and Citizenship. We eagerly welcome your leadership and vision as we navigate the complexities and challenges of the immigration landscape in Canada.
CILA takes pride in its mission to promote excellence in immigration law and advocate for just and inclusive immigration policies. With our diverse membership of dedicated legal professionals across the country, we are committed to supporting the Government of Canada in creating a fair, efficient, and compassionate immigration system that serves the interests of all Canadians.
We commend your dedication to public service and your significant experience in advocating for the rights of Indigenous peoples, your work with the Standing Committee on Indigenous and Northern Affairs, as well as your contributions to fostering economic growth and cultural diversity in Canada. Your expertise and commitment are valued assets as we address the pressing issues facing our nation’s immigration landscape.
CILA members have a vested interest in ensuring that our immigration system remains responsive, equitable, and inclusive. As practitioners, we have witnessed firsthand the transformative impact that well-crafted immigration policies can have on individuals and communities, as well as on Canada’s social fabric and economic prosperity. Our association has actively participated in various immigration-related discussions, and we take pride in being a reliable source of expertise for policymakers and legislators.
Considering your experience as a fellow lawyer and your dedication to principles of equity, diversity, and inclusion, we are eager to collaborate with your esteemed office. We believe that by working together, we can continue to advance Canada’s immigration system, ensuring it remains at the forefront of global best practices.
As we embark on this journey together, we humbly request the opportunity to meet with you and members of your team to discuss the pressing concerns of our membership and to explore ways we can collectively enhance Canada’s immigration landscape.
As we prioritize key issues affecting immigration in Canada, we wish to highlight the following areas that are of utmost importance to CILA and our membership:
1. Improving Client Experience: While we appreciate the spirit of recent innovations, including the TR to PR Pathways, e-landings, the new Canadian Refugee Protection Portal, and online citizenship applications, we are concerned about the challenges faced by vulnerable applicants, such as refugees and ‘low’ skill workers, in navigating these systems. We would like to address issues related to old and new technology, slow processing times, and generic responses to status inquiries. CILA would welcome the opportunity to share our clients’ experiences and make recommendations for meaningful and immediate change.
2. Exclusion of Counsel: Access to competent counsel is crucial in ensuring access to justice for vulnerable individuals in our communities. We advocate for the protection of the right to counsel and seek to minimize the exclusion or marginalization of lawyers from immigration processes. CILA members are eager to provide valuable insights into counsel’s experience representing clients through IRCC’s platforms. We are concerned about certain programs, like electronic certificates for citizenship, which exclude counsel. We urge the Department to view immigration lawyers as a resource to shorten processing times and create efficiencies rather than design programs that exclude us.
3. Addressing Challenges with IRCC Portals: IRCC’s “Authorized Representative Portal” and “Employer Portal” have frequently experienced outages, causing applicants to miss deadlines and impacting Canadian employers during a period of labor shortages. We urge IRCC to promptly address these technical difficulties, provide meaningful technical support, and consult with stakeholders, including CILA, to optimize the portals.
4. Business Experience Class: We believe that promoting immigrant entrepreneurship and investment can support Canada’s economic recovery. A Canadian Business Experience Class could facilitate the transition of small and medium-sized businesses from retiring baby boomers to immigrant entrepreneurs and investors. This program could be particularly beneficial to smaller regions of the country, such as Atlantic Canada.
5. Strengthening the College and Transparency: We advocate for the strengthening of the College, particularly in terms of discipline and investigation, and call for transparency in disclosing all firms and companies where regulated consultants work as employees or contractors.
6. Undocumented Workers: We propose that undocumented workers in construction and health care, with an employer willing to file and successfully obtain a Labor Market Impact Assessment (LMIA), should be able to apply for an employer-specific work permit at an inland office on an expedited basis.
7. Temporary Foreign Workers: We believe that labour market pressures across Canada and in specific sectors require that IRCC work with ESDC to exempt many occupations from the mandatory recruitment process. The province of Quebec maintains a whole host of occupations that no longer require the employer to advertise vacancies before hiring foreign workers. The same exemptions should apply regionally across Canada where labour market information confirms acute occupation specific shortages.
8. Reimagining the Student Program: We believe in prioritizing quality over quantity in the student program to enhance the overall experience of international students.
9. Maintained Status and Travel: We suggest that individuals in maintained status be allowed to travel while their applications are pending, especially if processing times remain at 5 months.
We recognize the challenges that your office faces in addressing these matters, and we are enthusiastic about collaborating with you to find innovative and effective solutions. CILA and its members remain committed to working towards a robust and inclusive immigration system that reflects the values and aspirations of all Canadians.
Once again, congratulations on your appointment as Minister of Immigration, Refugees, and Citizenship. We look forward to the potential collaborations ahead and to contributing our expertise to the continued growth and development of Canada’s immigration policies.
Thank you for your attention to these important matters, and we look forward to the potential collaborations ahead.
Sincerely,
Ravi Jain
Co-president, Canadian Immigration Lawyers Association (CILA)
