Thank you.
This represents a fundamental change to the structure of the legislation, which in itself I leave it to you to decide if that's a good thing or a bad thing. The rest of the law hasn't been designed around this approach.
The way the tribunal has been designed, and the way it's been set up, is for receiving complaints by the commissioner. The commissioner serves as the triage for complaints to go to the tribunal. This would mean there would be absolutely no filters before someone goes to the tribunal, which is equivalent to a court. It's a highly judicialized process. They also would not have the support of the PSIC, because he wouldn't be there explaining how he found that there was a reprisal and why he's come to the tribunal. They would be left on their own.
Just consider that if this change is going to be made, there may be other changes that would be required in the legislation in order to make this work properly.