For purposes of this topic, it appears the problem is rooted in the fact that
a PR card does NOT constitute a form of identification.
Overall, I agree with this:
with some clarification.
A copy of the bio page of ALL passports (valid or otherwise usable at any time within the preceding five years) must be submitted, which is a requirement separate from the requirement to submit personal identification.
Prior application process also required, in addition to passport copies, one government issued ID-with-photo and a second form of identification with or without photograph.
Current application requires only one additional
photo ID so long as the applicant has submitted a copy of the bio-page of a recently valid passport (with photo); if the applicant has no such passport, the applicant needs to submit two government issued photo IDs.
Admittedly, the application checklist and instructions are not as clear as they could or should be, including as to the requirement to submit identification with the application.
It is curious, and perhaps a source of confusion, that in the instructions about what documents to submit with the application, references to what to submit if one has or does not have a passport are bulleted separately, at the same level as the instructions to submit the presence calculation, all travel documents, photos, and so on, including "Photocopy of personal identification," rather than, say, having the identification requires depending on passport/no-passport sub-bulleted under the the latter, the item "Photocopy of personal identification," particularly since there is only one corresponding item in the checklist itself (which, again, is the "Photocopy of personal identification" item).
PR cards are not a form of identification. Apparently.
While IRCC variably labels the PR card in different contexts, in the citizenship application instructions the PRC is referred to as an "immigration document." In other contexts, and in IRPA and related regulations, it is referred to as a "status document," and in IRCC's glossary it is referred to as a "Permanent residence document." By the way, PRCs are not actually "travel documents" either, even though they must be presented by PRs in conjunction with a valid travel document, usually a passport, to obtain permission to board a flight to Canada, and in the regulations governing who commercial carriers may allow to board transportation to Canada, may be referenced under provisions specifying required travel documents.
Perhaps one source of confusion is that other entities, even government bodies, will accept the PRC as a form of identification, ranging from banks to provincial authorities managing health care or drivers' licensing. And the PRC is government issued, bears the PR's name, DoB, and photograph, and has security features, and thus on its face factually (whether or not by law) fully documents the individual's identity.
And that confusion is exacerbated by the lack of any clear instruction that the PR card is not accepted as one of the required forms of identification. (While it is otherwise NOT listed among items which are accepted as identification, that is only in an appendix to the guide, which contains instructions for persons requesting a change of sex designation.)
In contrast, however, so far as I see there is nothing in the information or instructions provided by IRCC, regarding citizenship applications, which suggests let alone states that a PR card is a form of identification.
Note, for example, it is not listed among "some" of the "documents that can be used to establish identity" for purposes of citizenship. See
http://www.cic.gc.ca/english/resources/tools/cit/admin/id/accept-documents.asp (But it is also not listed as a document which is not accepted.)
The PR card is similarly NOT listed as a form of identification in the PDI covering identity documents which may be presented to establish identity at a citizenship interview, hearing, or test. See
http://www.cic.gc.ca/english/resources/tools/cit/admin/id/test-documents.asp
Overall, it is apparent that a PR card is not accepted as a form of identification for a citizenship application.
Proof of PR status:
Some of the confusion may derive from the fact that an applicant no longer needs to submit a copy of the CoPR or a copy of the applicant's PR card. Both of these were required pursuant to older application processes. However, they were required to establish the applicant's PR status.
For proof of PR status, the current application process only requires the applicant to submit (this is item 4 in the application):
-- the applicant's Client ID# (UCI) as shown exactly on the applicant's "most recent immigration document"
-- the applicant's name as shown exactly on the applicant's most recent immigration document
-- the applicant's date of birth as shown exactly on the applicant's most recent immigration document
-- the date the applicant became a PR of Canada
For the overwhelming vast majority of applicants, this means precisely this same information in the applicant's most recently issued PR card, noting that "immigration document" is defined to be the applicant's PR card, CoPR, or Record of Landing.
In any event, it appears for sure that NO copy of the PR card needs to be submitted with the application itself.
In this regard, it warrants observing there were also changes made to the regulations which took effect October 11. The current regulation prescribes that the application must include "any document created by the Canadian immigration authorities, or other evidence, that establishes the date on which the applicant became a permanent resident" (for Citizenship Regulations, No. 2 Regulation 2(1)(b) see
http://laws-lois.justice.gc.ca/eng/regulations/SOR-2015-124/page-1.html#h-2
The "or other evidence" element, which was added to the version of this regulation taking effect on October 11, is undoubtedly intended to be satisfied by the inclusion of the information outlined above (UCI, name, DoB, date of landing), to be listed in item 4 in the application.
Thus, even though terms like "document" and "evidence" typically refer to something other than information attested to by the applicant, the concurrence of this change in the Regulations with dropping the CoPR and PR card from the checklist makes it apparent this was deliberate and indeed no copy of the PR card needs to be submitted.
Caution: The PDIs for citizenship still indicate that the applicant needs to bring a copy of his or her CoPR AND PR card to the test or interview. See
http://www.cic.gc.ca/english/resources/tools/cit/admin/id/test-documents.asp
