1954 Convention. However, as Andrew Brouwer argues, statelessness has not been recognized to be sufficient in itself to ground a refugee claim under Canadian refugee law.525 Alternatively, stateless persons outside Canada could potentially come to Canada and receive permanent resident status upon entering, if they are recognized as members of the Convention Refugees Abroad Class and the Country of Asylum Class.526 However, for both of the refugee abroad classes, it is only stateless refugees who are eligible. Currently, there are a number of stateless persons who have come to Canada and made refugee claims believing that their statelessness would demonstrate their refugee claim. Unfortunately, in many cases their refugee claims were rejected because their statelessness alone was not considered to have met the threshold of persecution. Furthermore, although some adjudicators at the IRB have “recognized” refugee claimants as “stateless persons” this has no legal impact, since there is no legally recognized stateless person status under Canadian law. Following the rejection of their refugee claim, stateless persons live in legal limbo without any status in Canada and few viable options for permanent residence. They are unable to leave to any other country, but live under constant threat of deportation and detention. In such cases there are two options for stateless persons to attempt to acquire permanent residence. These include an application for humanitarian and compassionate considerations (“H&C”) or a Pre-Removal Risk Assessment (“PRRA”) application. Both of these mechanisms have also been criticized by Andrew Brouwer for their lack of consideration of statelessness and for not providing a realistic chance of success for stateless persons. Pre-Removal Risk Assessment (“PRRA”) The final opportunity to potentially obtain protected person status, and then apply for permanent residence, is the PRRA application. The PRRA is available to persons who are either subject to an enforceable removal order or are inadmissible to Canada.527 However, if a person has made a refugee claim or a PRRA application within the last 12 months (or within the last three years for persons from designated “safe countries of origin”) they are ineligible to apply for PRRA.528 The PRRA application is assessed on similar grounds to a refugee claim, but it is usually a written application and only considers “new evidence” since the applicant’s previous refugee claim or PRRA application was rejected.529 For de jure stateless persons, the PRRA has been argued to not be an effective path to permanent residence, as stateless persons subject to an unenforceable removal order will never have the opportunity to apply. This is because without having a country in which to return, valid travel documents, and/or a state agreeing to accept a stateless person, a PRRA application would not likely be provided to stateless persons.530 This Statelessness in the Canadian Context, supra note 4 at 48, citing Thabet v. Canada (Minister of Citizenship and Immigration), [1998] 4 FCR 21 (FCA), available at: http://canlii.ca/t/4mj3. 526 IRPR, supra note 21 at ss. 70(1) & 70(2)(c), 139, 144-147. 527 IRPA, supra note 20 at 112(1). 528 Ibid., at 112(2)(b.1)-(c). 529 Ibid., at 113. 530 Ibid., at 112(1); IRPR, supra note 21 at ss. 160, 165-166; Statelessness in the Canadian Context, supra note 4 525 109 109