Consultation on General Purpose Debt

As part of its mandate to support the efficiency of Canada's national transportation system, the Canadian Transportation Agency (CTA) calculates regulated cost of capital rates. The CTA uses these in various rail related determinations – including regulated interswitching and the Maximum Revenue Entitlement (MRE).

The CTA recently held a public consultation on two components of regulated cost of capital rates, namely net rail investment and capital structure (2020 Consultation on Cost of Capital Rates). The CTA is now seeking input on whether the category of debt that it has identified as “general purpose debt” should be included in the calculation of cost of capital rates.

At the conclusion of this consultation, if it is determined by the CTA that general purpose debt should be included on the regulatory balance sheet, then the CTA will also make a determination on how it should be apportioned based on the submissions filed in the 2020 Consultation on Cost of Capital Rates.

The CTA's Discussion Paper: Whether General Purpose Debt Should Be Included in the Calculation of Cost of Capital Rates covers the key issues in detail and also asks questions that you can answer about each of them.

Consultation Process

You are invited to submit your input to the questions posed in the discussion paper by August 20, 2021 . Your responses to the questions should include a supporting rationale and evidence to allow the CTA to properly assess its validity.

Your initial public submissions will be posted here on August 20, 2021 in the official language in which they were submitted, along with your name or that of the organization represented.

Stakeholders can provide responses to initial submissions by September 9, 2021.

Public versions of the responses will be posted here by September 10, 2021.

Input can be sent to

If you wish to submit a video due to accessibility issues, please send an email to with the subject line "Video". We will contact you to coordinate your submission.

Confidential Information

If any document you send us contains information you believe should be treated as confidential, you must give us two copies of it, as follows:

  1. One copy (the public version) from which the confidential information has been blacked out.
  2. One copy (the confidential version) in which:
    • each page is marked “contains confidential information” at the top; and
    • you highlight or otherwise identify on each page the confidential information that was blacked out in the first copy.

We will post the public version on our website, and keep the confidential one for our own use only. However, all input we receive is subject to the Access to Information Act and Privacy Act. We will protect the confidentiality of your information in accordance with these Acts, but those Acts can require us to release information if someone requests it and it doesn't fall within the legislated exceptions.

Written submissions


Third-party information liability disclaimer

Some of the information on this web page has been provided by external sources. The Agency is not responsible for the accuracy, reliability or currency of the information supplied by external sources. Content provided by external sources is not subject to official languages, privacy and accessibility requirements.

Privacy notice; submission language and accessibility

During the CTA's Public Consultation period, individuals and organizations were invited to submit comments. In the interest of transparency, all of the submissions that the CTA received have been posted with its original content. For accessibility purposes, the CTA has converted all documents to PDF.

Initial public submissions

CP submission
August 20, 2021
(PDF ; 1 mb)
The Brattle Group (Prepared for Canadian Pacific Railway Company)
August 20, 2021
(PDF ; 1.7 mb)
Statement of Dr. Michael W. Tretheway (Prepared for Canadian Pacific Railway Company)
August 20, 2021
(PDF ; 306 kb)
August 20, 2021
(PDF ; 854 kb)
CN submission
August 20, 2021
(PDF ; 973 kb)

Responses to initial submissions

CN response
September 9, 2021
(PDF ; 824 kb)
CP response
September 9, 2021
(PDF ; 734 kb)
McMillan response
September 9, 2021
(PDF ; 514 kb)


Friday, April 8, 2022
See Determination No. R-2022-39
Date modified: