and education opportunities. Additionally, some stateless persons have temporary resident status (i.e., work and study permits) and have to renew their permits periodically, and there are additional costs for each of these applications. Finally, processing times are long (currently between 22 and 36 months). H&C applicants do not, as a general rule, have permission to remain in Canada, or have access to work permits or health care, until they receive approval in principle (first stage approval). Some applicants face removal proceedings while their H&C applications are pending and must make applications to the Court to stop deportation. Depending on the facts of the individual case, some persons (including some stateless persons) are able to receive health care and work permits while their application is in process. b. PRRA Applications Stateless people can also make a pre-removal risk assessment (PRRA) application if their refugee claim has been denied or if they are deemed ineligible to have their refugee claim considered by the IRB.50 This assessment is to ensure that the applicant would not be returned to a country where they would risk persecution or be in danger of torture or a risk to life, or of cruel and unusual treatment or punishment. However, only evidence that was not previously available at the time that a refugee claim was heard by the IRB is considered. If approved, PRRA applicants become “protected persons” who are eligible to apply for permanent residency. PRRA applicants may have a portion of their medical care costs covered by the Interim Federal Health program.51 To work, PRRA applicants may continue working on the visa that they may have obtained while awaiting a decision on their refugee claim. If they had not applied for a work visa while still an asylum-seeker, PRRA applicants may apply for a work visa while awaiting a decision. The PRRA application does not have fees associated with it. However, this application only becomes available once a person becomes “removal ready”, meaning that it is not always available to stateless person who may be in limbo, i.e., refused protection and permanent resident status. It must also be noted that the PRRA rejection rate is high for those who previously had a refugee claim rejected by the IRB. Overall, the PRRA is not an efficient or appropriate mechanism for identifying stateless people and granting them permanent resident status in Canada based on the particular vulnerabilities that they face because of their statelessness. c. Citizenship Applications Under section 5(4) of the Citizenship Act, stateless people can apply for a discretionary grant of citizenship based on their statelessness status.52 In June 2017, the Citizenship Act was amended to explicitly list statelessness as a basis for a discretionary grant of citizenship. Between June 2015 and 2017, IRCC received three applications for a discretionary grant of citizenship based on statelessness. As of 2017, none of these applications had been granted; two had been refused, and one application was pending a decision. In response to our request for statistics, the 50 https://www.canada.ca/en/immigration-refugees-citizenship/corporate/publications-manuals/operational-bulletins- manuals/refugee-protection/removal-risk-assessment/applications-intake.html. 51 https://www.canada.ca/en/immigration-refugees-citizenship/services/application/application-forms-guides/guide-5523applying-removal-risk-assessment.html#5523E5. 52 Citizenship Act, R.S.C., 1985, c. C-29, s. 5.(4). 13