Background
On March
1, 2001 Newfoundland Power signed an agreement with Aliant to purchase all of
the support structures (“poles”) owned by Aliant on the island of Newfoundland,
including those outside its service territory, on the terms outlined in the
Support Structures Purchase Agreement
(“Purchase Agreement”) filed with the application. Subsequent to the execution of this
agreement Newfoundland Power permanently assigned its rights to purchase poles
outside its service territory to 11003 Newfoundland Inc., essentially modifying
the Purchase Agreement to include only those poles within Newfoundland Power’s
service territory. The total number of
poles being purchased by Newfoundland Power is 101,875, consisting of 69,848 joint use poles and 32,027 non-joint
use poles.
In
addition to the Purchase Agreement Newfoundland Power and Aliant have entered
into a Facilities Partnership Agreement (“Facilities Agreement”) whereby Aliant
will continue to have access to the poles.
Newfoundland Power, as owner of all poles, will provide Aliant with
services related to its pole requirements, including the maintenance and
replacement of the poles acquired from Aliant and the design, construction and
maintenance of additional poles to meet Aliant’s ongoing requirements. Aliant will compensate Newfoundland Power
for these services as outlined in the Facilities Agreement, paying, in 2001, an
annual rental fee of $32 per pole for all joint use and non-joint use poles and
also making a capital contribution for new non-joint use pole
construction.
Newfoundland
Power will also receive revenue from cable television service providers (“CATV
Operators”) in respect of their attachments on the poles to be purchased. Under the Facilities Agreement CATV
Operators will pay Newfoundland Power $12.84 annually per attachment which
represents a blend of the rate that CATV Operators currently pay Aliant and
Newfoundland Power.
The Facilities Agreement
provides for an initial term of 10 years and for renewal terms as mutually
agreed. Upon termination or non-renewal
of the Facilities Agreement, Aliant is obligated to purchase all of the
non-joint use poles on which it has attachments and 40% of the joint use poles
at a price representing the net book value (original investment less
accumulated depreciation) of those assets.
The
aggregate purchase price to be paid by Newfoundland Power to Aliant for the
support structures in its service territory is $45,858,000, to be paid over a
period of five years as provided for in the Purchase Agreement. This purchase price represents the net book
value of the poles as of December 31, 2000.
On May 8, 2001 the Board
received an application from Newfoundland Power for approval to acquire all of the
utility poles and related assets of Aliant located in Newfoundland Power’s
service territory. In its application
Newfoundland Power requested an Order of the Board
approving:
(i) the Purchase
Agreement with Aliant comprising of a total aggregate purchase price of
$45,858,000, with payment of
$22,929,000 in 2001 and the remainder to be paid in annual instalments
to January 1, 2005;
(ii) the Facilities Agreement, effective as
of January 1, 2001, governing Aliant’s use of all support structures in Newfoundland
Power’s service territory, including the payment of remuneration by Aliant to
Newfoundland Power in connection with Aliant’s use of support structures and
payment of contributions with respect to the construction of certain support
structures;
(iii) the supplementary capital expenditures
for 2001 in the amount of $26,245,000, consisting of $22,929,000 to be paid to
Aliant in 2001 and $3,316,000 for distribution plant additions in 2001; and
(iv) other such matters as may appear just and
reasonable upon the hearing of this application.
The Hearing
The dates of June 7th
and 8th were set aside to hear the matter and notice of the public
hearing was published throughout the province.
Intervenors submissions were received from Glovertown Cable on May 23,
2001 and from Newfoundland and Labrador Hydro (“Hydro”) on May 25, 2001.
As part of their
intervenor’s submission Hydro requested a delay in the hearing dates. On May 29, 2001 Newfoundland Power filed a
reply to Hydro’s intervenor’s submission and requested that the Board order
that the matters raised by Hydro in their intervenor’s submission not be
considered at the public hearing or alternatively that the Board limit Hydro’s
submission to matters raised in the application and that Hydro be asked to
re-file their intervenor’s submission to comply with the regulations of the
Board.
A preliminary hearing was
held on May 30, 2001 to deal with both requests at which time the Board ordered,
after hearing representations from both parties, that the hearing would proceed
on June 7th and 8th as planned. As well the Board did not grant Newfoundland Power’s request that
Hydro’s intervention not be considered at the public hearing or that it be
limited in scope. At the Board’s
request Hydro re-filed a more concise scope of its intention for cross
examination before the commencement of the hearing.
In addition to the direct
evidence and exhibits pre-filed by Newfoundland Power, a number of information
requests were issued to Newfoundland Power by the Board and Hydro, and to Hydro
by the Board.
The hearing opened on June 7th
with the following parties appearing:
On behalf of Newfoundland Power:
Mr. Ian Kelly, Q.C.
Mr. Peter Alteen, LLB
On behalf of Hydro:
Mr. Wayne Chamberlain, LLB
Mr. Geoff Young, LLB
On behalf of Glovertown Cable:
Mr. Terry Burry
The Board was assisted in
the proceedings by its legal counsel, Mr. Randy Pelletier, LLB.
Evidence for Newfoundland Power
was given by Mr. Philip Hughes, President and Chief Executive Officer, Mr.
Barry Perry, Vice President Finance and Chief Financial Officer, and Mr. Earl
Ludlow, Vice President, Operations and Engineering. Mr. John T. Browne, of
JTBrowne Consulting, appeared as an expert witness for Newfoundland
Power.
Mr. Terry Burry of
Glovertown Cable also made an oral presentation to the Board and participated
by way of cross-examination of Newfoundland Power’s witnesses. Hydro participated by way of cross-examination
of Newfoundland Power’s witnesses and final argument.
At the request of the Board,
the Board’s financial consultants, Grant Thornton, also reviewed the
application and supporting documentation.
A copy of their report was filed by the Board as part of the proceeding.
Summary of Evidence and
Submissions
Newfoundland Power presented the proposed
arrangement as one that will result in more efficient and cost effective
operations that will be administratively simpler than the present
arrangement. It argued that the
evidence presented demonstrates that the arrangement is beneficial from a
financial perspective for the utility and will result in positive benefits for
customers. The cash flow analysis shows
a net present value of the after-tax cash flows associated with the purchase of
Aliant’s poles and the provision of support structure services to Aliant over
the 10-year analysis period of $1,623,503 (Exhibit 10).
On the issue of the non-joint use poles it
was Newfoundland Power’s position that these poles should be included in the
rate base since it is more beneficial for the customers. Even though the value of the poles is
relatively small in terms of the percentage of rate base, the value of the
efficiencies to be gained from including them in the rate base is
significant. Excluding the non-joint
use poles from the rate base would mean tracking the poles and the associated
costs separately, reducing the efficiency of the arrangement and the benefits
to the customers. In addition, the
costs of the non-joint use poles will be recovered from Aliant through rental
charges and the capital contributions it will pay. As well, revenue from the non-joint use poles is greater than
the cost, which reduces costs to the customers.
Hydro did
not present any evidence in the hearing but did file information requests and
participate in cross-examination and final argument during the hearing. In its written intervention and at the
opening of the hearing Hydro expressed concerns about the Board being asked to
approve the Purchase Agreement as presented since it deals with poles in
Hydro’s service territory. Counsel for
Newfoundland Power confirmed that the poles located in Hydro’s service
territory did not form part of this application and that Newfoundland Power
does not require approval of the agreement but only approval of the $45.9
million expenditure over the five-year period as set out in the agreement. Hydro accepted this position.
Hydro’s
primary concern at the hearing was Newfoundland Power’s position that the
non-joint use poles which are not used for electrical service be included in
the rate base. They argued that there
was no compelling reason for the Board to allow non-electrical assets into the
rate base. It was Hydro’s position that
the legislation requires that the Board apply tests consistent with generally
accepted sound public utility practice and that the non-joint use poles do not
meet the traditional test of being used and useful.
In his
oral presentation Mr. Terry Burry of Glovertown Cable described the impact, in
his view, that approval of the application would have on his company. His position was that approval of this
application would mean that he would have to deal with a single monopoly and
that there would be no benefit to his company or his customers. He stated that he also fears that pole
attachment rates will rise. He also
expressed concern about the current regulatory regime that he has to operate
under with respect to pole attachments.
The
report of the Board’s financial consultants, Grant Thornton, was also entered
into evidence. This report confirmed
the reasonableness and appropriateness of the assumptions used in the financial
and economic analysis and verified that the assumptions were appropriately
incorporated into the schedules and calculations. Overall it was Grant Thornton’s conclusion that the analyses
submitted in support of the application appeared reasonable and appropriate.
Issues
for Decision
This
application has been presented to the Board as essentially an amendment to
Newfoundland Power’s approved capital budget for 2001. The Board has approved previous capital
budgets after public hearings and after hearing considerable evidence about the
proposed capital expenditures and their necessity for reasons of safety and of
reliability and quality of service.
While this application is being considered under section 41 of the
Public Utilities Act, it is obviously not a typical capital budget amendment
application and cannot be considered in the same manner. The proposed 2001 expenditure of $22,929,000
represents an increase of over 50% in the approved capital budget for 2001,
with the remaining $22,929,000 to be spent over the next four years as provided
for in the Purchase Agreement.
After
hearing the evidence and the representations from the intervenors, there are
several issues of concern for the Board.
The key questions for consideration and decision are:
1.
Should
the 32,027 non-joint use poles be included in the rate base?
2.
If
the 32,027 non-joint use poles are excluded from the rate base, what will be
the impact on the remainder of the transaction and can the Board approve the
expenditure for the joint use poles?
In dealing
with these questions, and other issues arising from the application, the Board
has decided to address the question of inclusion of the non-joint use poles in
the rate base first, since the decision on this issue may affect a
determination on the application itself.
The Board’s
findings and reasons for decision on these questions are outlined in the
sections following.
1. Should the 32,027 non-joint use poles be
included in the rate base?
In dealing
with the question of whether the 32,027 non-joint use poles should be included
in the rate base the Board has to look to its governing legislation. The Public Utilities Act provides direction
to the Board on how it should fix and determine the rate base of a
utility. Section 118 of the Public
Utilities Act directs the Board to give a liberal interpretation to the
Act. The Board is also guided by
section 4 of the Electrical Power Control Act (the “EPCA"), which requires
the Board to apply tests consistent with “generally accepted sound public
utility practice”.
Section
64 of the Public Utilities Act deals with valuation of assets and gives the
Board the authority to “inquire into and determine the extent, condition and
value of the whole or a portion of the property and assets of a public utility used
and useful in providing or supplying a particular service to or for the public”
(emphasis added). “Service” is
defined in the Public Utilities Act as “the use and accommodation given to
consumers or patrons, and a product or commodity provided by a public utility,
and also includes, unless the context otherwise requires, the plant, equipment,
apparatus, appliances, property and facilities employed by or in connection
with a public utility in performing a service or in providing a product or
commodity and devoted to the purpose in which the public utility is
engaged…”. The particular service
referred to in section 64 then is taken to mean the electrical power supplied
to consumers.
Section
78 of the Public Utilities Act provides for the Board to fix and determine the
rate base for each kind of service provided or supplied to the public by a
public utility and to revise the base.
In particular section 78(2)(c) states that the Board may, in addition to
the value of the property and assets determined under section 64, include costs
in whole or in part of land or other property and assets acquired or held in
reasonable anticipation of future requirements (emphasis added). This is taken to mean that, even if an
asset is not currently used, there must be some anticipation that the asset
will be used in the future for the provision of electrical service. In assessing the “used and useful” status of
an asset, the Board also accepts the principle that there must be some
imminence and certainty of that use before an asset may be included in the rate
base. This principle was described in
case law presented during the hearing.
Section 78(h) also provides for the Board to include “other fair and
reasonable expenses which the board thinks appropriate and basic to the
public utility’s operations” (emphasis added). Again, the Board takes this as direction that the rate base is to
include only those assets and expenses that are related to the provision of electrical
service.
The
question then to be answered first is whether the 32,027 non-joint use poles
are actually “used and useful”, which is the generally accepted test for
deciding whether an asset should be included in the rate base. In this case, under the used and useful
standard, customers of Newfoundland Power should only pay for the cost of those
assets that are used and required to be used to provide them with electrical
service.
It is
Newfoundland Power’s position that the non-joint use poles have been included
in the proposed arrangement for reasons of administrative and operational
efficiency. There was no evidence that
the poles are being purchased for reliability, safety or quality of service purposes. In response to PUB-13 Newfoundland Power
confirmed that 76%, or 24,000, of the non-joint use poles to be purchased from
Aliant are 30 ft. or less and are generally located such that they will
unlikely be used by Newfoundland Power in the provision of electricity. Of the remaining 8,000 poles it is not clear
from the evidence that these poles will ever be used for the provision of
electricity, even if they meet the technical requirements for such, because of
location, routing or safety reasons.
It is clear to the Board
that, applying generally accepted sound public utility practice as required,
the concept of “used and useful” as
provided for in the Public Utilities Act does not include the non-joint use
poles. They are not currently used for
the provision of electricity and there is no reasonable anticipation of the
non-joint use poles being used in the near future for the provision of
electrical service.
Newfoundland Power argued
that this transaction should be approved as presented since it would be in
accordance with the intent of section 3 of the EPCA, which stipulates the power
policy of the province. Section 3(b) of
the EPCA states, in part:
“all sources and facilities for the production,
transmission and distribution of power in the province should be managed and
operated in a manner
(i)
that
would result in the most efficient production, transmission and distribution of
power,
(ii)
that
would result in consumers in the province having equitable access to an
adequate supply of power,
(iii)
that
would result in power being delivered to consumers in the province at the
lowest possible cost consistent with reliable service,”
It is Newfoundland Power’s
position that the proposed transaction will result in power being delivered to
consumers in the most efficient manner and at the lowest possible cost
consistent with reliable service and that the most efficient joint use
arrangement is one that includes both the joint use poles and the non-joint use
poles in an integrated distribution network.
The Board interprets this section of the EPCA as dealing only with the
sources and facilities for the production, transmission and distribution of
power in the province. It is clear that
the joint use of poles for reasonable compensation as provided for in section
53 of the Public Utilities Act is in accordance with this section of the EPCA
in that it reduces overall costs to consumers.
The Board does not agree, however, that the non-joint use poles can be
included in “sources and facilities” for the distribution of power.
Newfoundland Power also
argued that, since the mix of joint and non-joint use poles support structures
is dynamic, the cost of tracking and maintaining the necessary information is
extremely high and that this should be a consideration for the Board when
deciding whether to include the non-joint use poles in the rate base. In response to NLH-13 Newfoundland Power
states:
“While at any point in time
some support structures will only be used by one of the parties, this situation
will be dynamic as each party’s requirements change. The detailed tracking required to determine if a particular pole
is jointly used at a particular point in time for rate base certification will
be as inefficient and expensive as past attempts to track CATV attachments
which are outlined more fully in response to information request PUB-1, pg. 3
to 4 and 6 to 9. Prospects to improve
tracking of attachments are limited by the fact that neither Newfoundland Power
nor Aliant Telecom actually distinguishes between joint-use and non-joint use
poles or in any other definitive way.
Even if such tracking could be economically undertaken, it would not
yield any perceptible consumer benefit.”
There was no evidence
brought forward in an attempt to actually quantify the cost of tracking so the Board
is unable to ascertain the actual impact of having to track the non-joint use
poles if they are not included in the rate base.
In his report filed with the
application, Newfoundland Power’s expert witness Mr. John T. Brown stated:
“Assets used to provide
telecommunications service are not directly used to provide electric power
service. However, where assets are part
of an arrangement that reduces the cost of providing regulated service, they
are used and required to be used and benefit the customers of regulated service
by reducing the rates they pay.”
Mr. Brown argued that, since
the non-joint use poles are integral to the arrangement, they should be
considered an investment used and useful for the purpose of rate base. Under cross examination by Board counsel and
Hydro he clarified that it was his evidence that the non-joint use poles were
integral to the proposed arrangement itself, which consists of the Purchase
Agreement and the Facilities Agreement.
Mr. Brown also stated that,
because the non-joint use poles are so integral to the arrangement, it would be
difficult to split out that part of the arrangement and determine what the
independent price would be for the non regulated, non-joint use poles. It was also his position that the additional
costs associated with keeping the non-joint use assets out of rate base are not
justified given the relatively small size of the asset and that these costs
would have to be passed on to customers eventually. This is not an acceptable argument or justification for the Board
in terms of having to consider the question of whether these poles should be
included in the rate base. As well, the
Board does not accept as a given that the additional costs of tracking the
non-joint use poles outside of rate base would have to be included in regulated
expenses and passed on to customers.
In clarification of previous
testimony, Mr. Ludlow stated that the non-joint use poles do carry some of the
communications and data lines for the company and are therefore integral to the
distribution network. The Board is not
convinced that this, in and of itself, is sufficient to meet the definition of
used and useful. Presumably
Newfoundland Power already uses the non-joint use poles for this purpose. It is not necessary, therefore, that
Newfoundland Power own the non-joint use poles for this aspect of their
operations to continue, or that the status quo would have a detrimental effect
on the provision of electrical service.
In support of the
Application, Newfoundland Power also provided information on Canadian joint use
practices obtained by a survey of 17 Canadian electric utilities. This information showed that the proposed
arrangement, where Newfoundland Power will own all poles in its service
territory, is consistent with that experienced by 7 of the 12 electric
utilities. The remaining 5 electric
utilities have joint use arrangements more consistent with Newfoundland Power’s
current arrangements. However, in
response to information request PUB 5.1, Newfoundland Power stated that none of
the respondent electric utilities own the poles used exclusively by the
telecommunications company.
The Board finds that the
32,027 non-joint use poles do not meet the used and useful criteria for the
purpose of being included in the rate base.
Therefore Newfoundland Power’s request for approval of capital
expenditures to buy these poles is denied.
Approval was also requested
for additional supplementary capital expenditures of $3,316,000 for
distribution additions for 2001. In
response to information request PUB-10 Newfoundland Power provided a breakdown
of these expenditures between the joint use and non-joint use poles. The joint use portion of these costs is
$1,881,750, and the non-joint use portion is $1,433,800. As provided for in the Facilities Agreement,
Aliant was to pay contributions to Newfoundland Power totaling $855,000 towards
the cost of the additions to the non-joint use property.
Since the Board has decided
that the non-joint use poles will not be allowed as part of the rate base, the
additional capital expenditures requested for the non-joint use property will
not be approved as part of the capital budget for 2001.
The Board was compelled to
examine the argument of Newfoundland Power with respect to the effect on
customers of not allowing the inclusion of the non-joint use poles in the rate
base. In addition to the operational
efficiencies identified, this transaction has been presented as one which will
have a net positive financial impact on the company’s revenue requirements and
hence customers. It was suggested that,
in not allowing the non-joint use poles in the rate base, the Board would
effectively be foregoing revenue which will not be available to customers.
While the Board is extremely
cognizant of its role in balancing the utility’s customer and shareholder
interests, it is difficult to see the direct benefit of this transaction for
customers. The Board is not
convinced, based on the information provided, that customers will actually realize
any of the benefits in the same way that shareholders will since the effect on
revenue requirement, and hence rates, won’t be tested until the next rate
hearing. The company indicated this
will not likely occur until 2002, when rates for 2003 will be set.
Indeed there may be any
number of good business deals and acquisitions that the company could seek out
which may generate incremental efficiencies and possibly better financial
results for both customers and shareholders.
Notwithstanding these benefits, the Board will still be compelled to
consider whether the addition of these assets to the rate base of the utility
would meet legislative requirements.
2. If the 32,027 non-joint
use poles are excluded from the rate base, can the Board approve the remainder
of the transaction?
Having ruled that the 32,027
non-joint use poles are to be excluded from rate base the Board must now turn
itself to the effect of this ruling. In
particular the Board must be sure from the evidence that the purchase of the
remaining 69,848 joint use poles will not negatively affect revenue
requirements into the future and hence ratepayers. The Board also has to assess whether it has sufficient
information to approve the remainder of the application.
In response to information
request PUB-1, Newfoundland Power provided information on the effect of various
scenarios on the revenue requirements and the return on rate base and on equity
for the company for the period 2001-2005.
This evidence shows that the incremental effect on revenue requirement
for the proposed transaction are as follows:
Proposed Transaction
Effects on Revenue
Requirements
($000s)
Year 2001 2002 2003 2004 2005
Surplus
(Deficiency) 914 498 408 580 698
This shows that, for the
first five years of the transaction, the revenue received by the company will
exceed the revenue requirements associated with the additional pole ownership
and related obligations in each year.
The rate impact analysis provided in Exhibit 10 of the pre-filed evidence
also presented this information for a 10-year period with essentially the same
magnitude of revenue surpluses indicated for 2006-2010 and showing an
annualized net present value of the annual revenue for the 10-year period as
$500,000. However Newfoundland Power
also states that, while this suggests that the new support structure
arrangement will have a positive impact on future customer rates, the amount of
the surplus is not large enough, in and of itself, to have a direct impact on
rates. This additional revenue will be
available, however, to offset expenses.
If the 32,027 non-joint use
poles and associated revenues are excluded from regulated rate base and revenue
respectively, the effect on revenue requirements of the proposed acquisition
was shown in PUB-1 as follows:
Proposed Transaction
Effects on Revenue
Requirements
($000s)
Year 2001 2002 2003 2004 2005
Surplus (Deficiency)
789 391 301 439 531
This evidence shows that the
impacts on revenue requirements with the 32,027 non-joint use poles excluded
from rate base are less positive, but still positive nonetheless. The Board also looked to the rate impact
analysis presented in Exhibit 10 for some indication as to whether alternative
scenarios were explored for their impact on rates. While the analysis presented only dealt with the proposed
transaction, it was stated: “If the analysis shows a revenue surplus it would
indicate that the proposed arrangement would tend to reduce rates. A revenue deficit on the other hand would
suggest that the proposed arrangement would tend to increase rates.” (Exhibit
10, page 3 of 8)
It was also stated by
Newfoundland Power that, if the non-joint use poles are excluded from rate base,
the difference between the improved rates of return would accrue to the
Company’s shareholders as opposed to consumers. This means that the incremental surplus in regulated revenue
that would result from the proposed arrangement would decrease if the revenue
from the non-joint use poles was excluded.
The net positive impact would then flow directly to shareholders, and
the benefit to ratepayers would be reduced by this same amount. From the response to PUB-1, this reduced
benefit to ratepayers would average $129,000 each year for the next five years.
On the basis of the evidence
before it, the Board is satisfied that the purchase of the 69,848 joint use
poles will result in a net positive financial impact on the company’s revenue
requirement. This assumes that this
part of the transaction proceeds as presented with no changes in the Purchase
Agreement or Facilities Agreement.
However, given its decision
on the non-joint use poles, the Board is uncertain as to whether Newfoundland
Power will proceed with the transaction as presented. Under cross examination by Board counsel, Mr. Hughes stated that
if the Board did make such a determination the utility would have to consider
whether or not Newfoundland Power would want to change some aspect of the arrangement. Mr. Brown, the utility’s expert witness,
also testified that the non-joint use poles are an integral part of the overall
arrangement and that, in his view, there would be a question of whether Aliant would
proceed with the deal as is if they were only selling the joint use poles.
Other than the information
presented in PUB-1 there was little other evidence as to what effect the
exclusion of the non-joint use poles from the rate base would have on the
transaction, and in particular, on the Purchase Agreement and/or the Facilities
Agreement. In addition, given the
evidence of the company, the Board is uncertain as to how Newfoundland Power
will separate and record the costs of operating, maintaining and monitoring the
non-joint use poles.
It is also not clear whether
Newfoundland Power will, or can, now proceed with the purchase of the 32,027
non-joint use poles. Although not
raised during this hearing, the Board brings attention to section 24(1) of the
EPCA, which states:
“Subject to this Act, a
retailer shall not engage or invest in or carry on any business or activity
other than the business of the production, transmission, distribution or
retailing of power and the business or activity that is generally related to
it”.
Given the Board’s
responsibilities under sections 16 and 17 of the Public Utilities Act, it will
have to be assured that the intent of this section of the EPCA is upheld by any
further action by the utility with respect to the non-joint use poles.
The Board considered whether
it should approve the capital expenditure for the 69,848 joint use poles in
light of its decision on the non-joint use poles. Given the uncertainty outlined above, the Board is not prepared
at this time to approve the application as submitted. It will however consider a subsequent application, which will
have to address the concerns noted above.
IT IS THEREFORE ORDERED:
1.
The
application by Newfoundland Power for approval of:
(i)
the
purchase by Newfoundland Power of certain additions to its property and assets;
and
(ii)
for
approval of an agreement concerning the terms and conditions upon which Aliant
shall jointly use certain facilities of Newfoundland Power
pursuant to Sections 41 and
53 of the Act, be and is hereby denied.
2. Newfoundland Power shall pay all costs
associated with the hearing of this application.
Dated at St. John’s, Newfoundland
this 6th day of July 2001.
Darlene
Whalen, P.Eng.,
Vice-Chairperson.
________________________
William
B. Crosbie, P.Eng.,
Commissioner.
Gerard
Martin, Q.C.,
Commissioner.
__________________________
G.
Cheryl Blundon,
Director
of Corporate Services and
Board
Secretary.
Orders / Home
