OCASI Comments on Immigration Levels Plan

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August 15, 2019 - OCASI made the following submission to Immigration, Refugees and Citizenship Canada in response to call for feedback on the three-year immigration levels plan released by the government in November 2017.

Click here for the submission in PDF format.

Submission to Immigration, Refugees and Citizenship Canada on Immigration Levels Plan

Immigration Levels Plan

Context: The current plan is to achieve 340,000 immigration arrivals by 2020, approximated at 1% of the Canadian population. Statistics Canada population growth projections are slightly higher, at a little over 38,000,000 by the end of 2020.

Recommendation: Immigration arrivals can be higher

  • OCASI is in favour of the proposal to set annual immigration arrivals at 1% of the population, however this should be considered the minimum threshold. OCASI member agencies believe that Canada can take in many more people, as much as 450,000 per year.
  • The higher number has been proposed by the Conference Board of Canada, which has projected a resulting growth in GDP.
  • A range of stakeholders across Canada from many different sectors support the call for higher arrival numbers, including several that have a direct role in immigrant settlement and integration such as community service providers and employers.

Context: The present breakdown is approximately 58% for economic class, 27% family class, 14% refugees and a little over 1% for the humanitarian class.

Recommendation: Allocate higher numbers for family class, upto at least 50%

  • Economic class allocations within overall immigration numbers have increased gradually for more than three decades, while family class allocations have decreased.
  • Median earnings across all immigration classes are lower than the median for Canadian-born residents, but tend to improve over time across the board. Statistics Canada has reported that principal applicants in the Canadian Experience Class have reported the highest earnings compared to all other immigration categories, most likely because they have prior work experience in Canada and are nominated by an employer.
  • The earnings gap between immigrants and Canadian-born residents persists despite more stringent immigration requirements over time for educational attainment, prior Canadian work experience and official language ability.
  • Race, ethnicity, gender and country of origin are reported in a range of research reports as significant factors in earnings difference for immigrants, despite higher levels of educational compared to the Canadian-born population. Clearly, immigration selection alone cannot reduce or eliminate the earnings gap. It must be addressed instead through other measures to identify and address systemic barriers to labour market access, and wage discrimination.
  • Immigrants who arrive as accompanying family members or sponsored relatives have the added advantage of starting off with the social and community support of family and friends, which can contribute to better social cohesion and build stronger communities.
  • A higher family class allocation will let Canada come closer to fulfilling the promise of family reunification by reducing years of family separation, particularly in the case of parents and grandparents sponsorship and family reunification for groups such as migrant workers in the Caregiver program.

Context: There is an annual cap of 17,000 on the number of parents and grandparents sponsorship applications that will be processed. Applications are selected by lottery. Interest in sponsorship far exceeds the cap, and the limit is typically met within weeks.

Recommendation: Process all applications for family class sponsorship while eliminating the applications cap and selection lottery, and eliminate IRPA regulation 117(9)(d)

  • The present system is insufficient to meet the need for family reunification, and compels Canadian residents to apply year after year to make it into the selection pool. Those who wish to reunite with family members should have to apply only once. The present cap falls far short of the demand and must be revisited particularly in light of higher immigration intake targets announced in the multi-year levels plan.  
  • The minimum income requirement (of 30% above Low-Income Cut-off for the previous three years) privileges applicants with more financial resources and makes family sponsorship an entitlement of the wealthy. Low-Income Canadians are barred from reuniting with parents simply because they are poor.
  • The Supervisa has significant financial restrictions (such as the high cost of health insurance) that put it out of reach for everyone except those with financial privilege.
  • The excluded family members’ regulation 117(9)(d) of the Immigration and Refugee Protection Act (IRPA) is a significant barrier to family reunification. It has a disproportionate negative impact on refugees and vulnerable migrants who fail to disclose a family member, especially children.

Recommendation: Eliminate the cap for caregiver permanent resident applications

  • Until 2014 the Caregiver program was one of the few migrant worker programs in Canada that provided a pathway to permanent residence. Since 2014 a cap was imposed on the number of applications, and entry requirements were made more stringent.
  • Caregivers must work in Canada for at least two years (as well as meet other requirements) before they can apply for permanent residence. If they are good enough to work, they are good enough to stay.

Settlement and Integration

Context: Employment or self-employment are among the main concerns for immigrants immediately after arrival in Canada, as found in OCASI Making Ontario Home and other studies. As stated earlier, race, ethnicity, gender and country of origin is reported in various studies as a significant factor in earnings difference for immigrants, despite higher levels of education compared to the Canadian-born population.

Recommendation: Remove systemic barriers to settlement and integration, and invest in appropriate programs

  • Challenges to labour market entry must be require targeted measures to identify and address systemic barriers to labour market access and wage discrimination, such as Employment Equity legislation and the Federal Contractors Program. Such legislation must be extended to all employers in Canada, including private and non-profit sectors and must be strengthened with programs that support their targeted implementation so that all under-represented groups will benefit.
  • While initiatives to support better international credentials recognition and accreditation are on the rise, they are not universal and are not necessarily linked to employment. Additional supports such as Bridging and targeted employment programs would help to connect internationally-trained immigrants with a job that is consistent with their training and experience.

Recommendation: Settlement services, including language training, should be provided to all who need them.

  • Remove eligibility restrictions for federally-funded settlement services so that service can be accessed on the basis of need and not immigration status, including migrant workers, international students, refugee claimants, Canadian citizens and those with precarious immigration status.
  • OCASI as well immigrant and refugee-serving sector members of the National Settlement Council (sector umbrella organization) have called for a removal of the eligibility criteria.