keesio said:
Because that is how they normally operate. All the major changes I can think of have been announced prior to going into effect. Condition 51, Changing the sponsorable dependent age to 18, the changing of Citizenship by decent rule, etc...
On the contrary, it seems clear that this government oft times offers little or perhaps even no advance notice of when significant changes are coming and will take effect. Other than the
notice inherent in the grant of Royal Assent in mid-June, the provisions implemented on August 1st, for example, which included some very substantial changes, were implemented with
NO advance notice to the public, none. Even the formal changes to the
Citizenship Regulations adopted attendant the changes effected August 1st were not published in the Gazette until
after the fact. Similarly, last February when fees were increased, there was not a single day's notice to the public. Back in 2012, when CIC implemented OB 407 radically changing how it processed citizenship applications, even the vast majority of personnel at CIC had very little notice it was coming, let alone much information about what it was and how it would change things (predictably with near disasterous results).
Some changes have been implemented with
some but not a lot of notice, like the changes in language requirements (which necessitated changes to the regulations of a type for which the law requires formal notice to be published in the Gazette), but the amount of notice was minimal and there was very little notice of the date the changes would be put into effect.
What elevates the level of frustration is that there are individuals in this government who almost certainly have a specifically planned date in mind (by now anyway), one that will most likely be the actual date. This government could give the public advance notice, but it deliberately chooses not to do so. And whether that date is May 1st or September 1st will make a significant difference to many thousands of PRs on the cusp.
While planning is of course in order, for those anticipating making an application in the coming year, and worrying in contrast has little ultility, I fully understand the frustration of those who are on the cusp, those who will reach the point they are qualified under the current residency requirement sometime between spring and fall 2015. It is rather difficult to
plan for an unknown, and the date the new presence requirements will take effect is indeed an unknown. Best guess is sometime between May 1, 2015 and September 1, 2015, probably by October 1st at the latest, quite certainly some time between January 1, 2015 and October 30, 2015. But that is all a guess. Definitely some time in 2015, but again beyond that it is all a guess. (As I said before, I am highly skeptical of reports coming from CIC personnel as to a prospective date, since this government keeps department personnel in the dark nearly as much as they do the public -- albeit as the actual date does get closer, then there are likely to be some credible reports from CIC personnel.)
Prospective applicants should be able to expect at least some notice, sufficient notice to at least cover a reasonable mailing period, so that unlike with the fee change in February (which affected hundreds or more applications already in the mail, given the total lack of notice), applicants can know as of the day they go to mail their application.
But with this government, there is no guarantee there will even be that much notice. We do not know how much formal notice there will be, if any.
In the meantime, though, the irony is that there are a significant number of PRs who may benefit from the change, who will become qualified sooner when the new law takes effect.
Note: relative to the August 1st changes, the order by the Governor in Council which set August 1st as the date those provisions were to come into force was made July 31st, but not published until well after the fact. The first public notice of the changes which, for example, eliminated the role of CJs in the granting of citizenship for non-residency cases, was issued later in the day August 1st.