failed to properly apply the IAP model, on the one hand, and
review of factual findings for palpable and overriding error, on
the other. The power to review on grounds of compliance with
the IAP model is given to “a reviewing Adjudicator”, a term that
embraces both the first and second level of review. However, only
“a second Adjudicator” is specifically assigned the responsibility
to review an adjudicator decision for factual errors on the palpable and overriding standard. In my view, the term “second adjudicator” can only embrace the first level of review. I add that it
would constitute a breach of the IAP model should the “second
adjudicator” inappropriately fail or refuse to conduct a review
for palpable and overriding error, and it would be open to a
re-review adjudicator to so find. However, it would be wrong for
a re-review adjudicator to second-guess a review adjudicator’s
call on factual errors under the guise of upholding the IAP
model. There may also be cases where misapplication of the
IAP framework by the review or re-review adjudicator could
involve disturbing factual findings made by an adjudicator. For
example, if the adjudicator used extra-curial knowledge as an
independent basis for a decision contrary to the framework, correcting such a misapplication of the framework will necessarily
involve interference with the factual findings of the adjudicator.
 Finally, both the review adjudicator and the re-review adjudicator have the authority to review prior decisions to ensure that
the IAP model has been followed. I agree with the re-review adjudicator in the present case that the standard of review for that
must be correctness: see Fontaine v. Canada (Attorney General),
2016 BCSC 2218, supra, at para. 24. I also agree that the task of
the re-review adjudicator is to review the decision of the review
adjudicator. However, as the standard of review on the only available ground is correctness, the review adjudicator’s decision on
that issue does not attract deference at the re-review stage.
 Shortly before the oral argument of this appeal, M.F.
moved to amend his notice of cross-appeal. Canada did not consent to the amendment but did not strenuously resist. In my
view, the amendments sought were inconsequential and I would
accordingly dismiss the motion to amend.
 I agree with the administrative judge that Canada did not
breach its disclosure obligations. In any event, I fail to see what
purpose a declaration to that effect would serve at this point.
 The documents at issue were listed as supporting documents in the IRS school narrative and POI report and copies
were available upon request. There is no suggestion that Canada