Decision No. 106-AT-R-2010

March 30, 2010

March 30, 2010

IN THE MATTER OF Decision No. 405-AT-R-2008 – Council of Canadians with Disabilities vs. VIA Rail Canada Inc.

File No. U3570/00-81


Background

[1] In response to issues raised by the Council of Canadians with Disabilities (CCD) with respect to the accessibility of VIA Rail Canada Inc.'s (VIA) Renaissance passenger rail cars, the Canadian Transportation Agency (Agency) issued two decisions in 2003. Following a preliminary decision in March, the Agency issued a final ruling, Decision No. 620-AT-R-2003, in October (October Decision), in which it found undue obstacles to the mobility of persons with disabilities and required modifications to the Renaissance cars. The corrective measures were based on the design plans for the rail cars and related proposals by VIA that existed at that time. Specifically, the corrective measures in the October Decision required VIA to submit and obtain the Agency's approval of:

  1. its plan for the timing of the implementation of the modifications required by the Agency, including a proposed schedule for the commencement and completion of the modifications; and,
  2. the general arrangement plans, with dimensions, for the modifications required to the economy coach cars, the "accessible suite" and the stairs.

[2] While the two decisions were set aside and the matter was referred back to the Agency by the Federal Court of Appeal for reconsideration, they were subsequently restored by the Supreme Court of Canada in March 2007.

[3] VIA filed final conceptual plans in June 2008 for the modification of the Renaissance cars, which reflected significant changes from the plans at the time of the October Decision.

[4] VIA sought the Agency's preliminary approval of the elements of the conceptual plans before proceeding with the next stage of the modifications to the rail cars. VIA also filed a plan for the timing of the implementation of the required modifications, including a proposed schedule for the commencement and completion of those modifications.

[5] In light of the significant changes since the October Decision, the Agency decided in Decision No. 405-AT-R-2008 (Decision) to review the corrective measures it had ordered. The Agency found, on a preliminary basis, that VIA's design proposal at that time (Current Design Proposal) provided an appropriate level of accommodation for persons with disabilities who use Personal Wheelchairs and persons with disabilities who travel with service animals. Therefore, based on VIA's modified design proposal, the Agency varied the corrective measures contained in the October Decision by replacing them with the corrective measures that are repeated below in the Analysis and Findings section.

[6] VIA was required to submit, by September 22, 2009, the revised design plans intended to comply with the modified corrective measures, including a final implementation schedule, to obtain the Agency's final approval prior to VIA's implementation of the proposed modifications to the Renaissance cars.

[7] This Decision addresses VIA's final design proposal (Final Design Proposal) to determine whether it meets the requirements of the imposed corrective measures or otherwise provide an appropriate level of accommodation. The Agency's consideration of VIA's final implementation schedule will be addressed under separate cover.

Process

[8] VIA filed revised design plans on September 22, 2009. VIA's design proposal differed from the Current Design Proposal accepted by the Agency on a preliminary basis one year earlier. To assist in its assessment of the proposed modifications, the Agency accepted VIA's invitation to participate in a site inspection in New Brunswick on October 15, 2009, where VIA presented a mock-up of the accessible areas of the cars to Agency staff and CCD representatives.

[9] Comments on the viewing of the mock-up were submitted by CCD's representatives on November 4, 2009. VIA filed a modified Final Design Proposal on December 11, 2009.

Issue

[10] Does VIA's Final Design Proposal either meet the requirements of the modified corrective measures in the Decision or otherwise provide an appropriate level of accommodation?

Analysis and findings

[11] The Agency will consider VIA's Final Design Proposal below in the context of the corrective measures imposed by the Decision, including the commitments made by VIA at that time.

Sleeper car

Corrective measure 1: In at least one sleeper car in every Renaissance night train consist where a sleeper car service is offered, provide at least one accessible sleeping area by implementing the current design proposal, including VIA's commitments as confirmed by VIA in its submission dated July 11, 2008, and reflected in the Decision, and by ensuring that:

(a) aisles and door openings both in the route to access and within the accessible sleeping area, excluding the separate entrance to the sleeping area from the sleeper car aisle into the bedroom, are at least 810 mm wide.

[12] Consistent with the Current Design Proposal, VIA's Final Design Proposal will require a person using a Personal Wheelchair to enter the train through one of two 810 mm-wide exterior doors on the service car marshalled adjacent to the accessible end of the sleeper car. The person will travel through a 1,300 mm-wide vestibule at this end of the service car, which provides a turning radius of 1,500 mm with some overlap with the door opening to the diaphragm between the two cars, and make a 90-degree turn to enter the diaphragm. The Final Design Proposal reflects a width of 810 mm at floor level in the diaphragm, which widens to 1,000 mm above 185 mm from the floor.

[13] The doors at either end of the diaphragm between the cars are 1,000 mm wide. A person using a Personal Wheelchair will enter into the washroom of the accessible suite through an 820 mm-wide power-operated sliding door.

[14] The Agency finds that VIA's Final Design Proposal meets the requirement of corrective measure 1(a).

(b) the sleeping area is comprised of an accessible bedroom and washroom with sufficient clear floor space to accommodate persons using Personal Wheelchairs, and to accommodate their attendants and/or service animals.
in addition, VIA had committed to install a form of curtain or similar soft divider between the washroom and the bedroom, subject to unforeseen issues that may arise.

[15] The overall dimension of the accessible suite in the Final Design Proposal has not been modified; however, the space distribution between the bedroom and the washroom has changed. Another change in design is the replacement of the wall between the bedroom and the washroom with a soft curtain. VIA advises that the soft curtain will meet the requirements of CAN/CSA-B651-04 Accessible design for the built environment (CSA B651): "The curtains will be operable with one hand and with minimal force and will not require fine finger control, tight grasping, pinching or twisting of wrist."

[16] The modified space distribution between the washroom and the bedroom results in a larger washroom which is 1,767 mm wide x 1,641 mm long, compared to the previous respective dimensions of 1,550 mm x 1,677 mm. These dimensions exclude the vanity containing the sink, which is positioned along the interior wall that separates the washroom from the sleeper car aisle.

[17] The sleeper bedroom is 1,203 mm wide x 1,922 mm long (excluding the sofa), compared to the previous respective dimensions of 1,310 mm x 2,000 mm. Notwithstanding these smaller dimensions, this space still provides a 1,500 mm turning radius, albeit with a slight protrusion into the washroom. In addition, a part of the turning radius is under the sofa, which provides a toe clearance height of 255 mm. The Agency notes that this toe clearance space exceeds the 230 mm minimum toe clearance space for sink access recommended in CSA B651.

[18] The Final Design Proposal provides a clear floor space to accommodate persons using Personal Wheelchairs and their attendants and/or service animals, thereby providing an adequate level of accessibility. The Agency therefore finds that VIA meets the requirement of corrective measure 1(b). In addition, the Agency finds that VIA meets the requirement of corrective measure 1(b) as they relate to VIA's commitment to replace the wall between the washroom and the bedroom with a curtain.

(c) the location and design of all features such as power-operated door controls, grab bars, toilet paper and paper towel holders, soap dispensers, emergency call buttons, flush controls, faucets, and mirrors will be installed in compliance with CSA B651.

Toilet location and grab bars

[19] The location of the toilet in the Final Design Proposal has changed from a wall mount on the exterior wall near the bedroom to a corner mount immediately to the right upon entering the accessible suite. While the Current Design Proposal provided for a space of 900 mm wide x 1,677 mm long to allow for a right-side transfer from a wheelchair to the toilet, the Final Design Proposal reflects a transfer space of 900 mm x 1,500 mm on both sides of the toilet. The Agency notes that these dimensions are consistent with the CSA B651 recommendation for an individual washroom. While folding grab bars will slightly protrude in this transfer space, they can flip up and extend/retract, which will offer a proper level of accommodation. Similarly, the slight protrusion of the sink countertop in the transfer space does not appear to limit the functionality of the space for transfers to and from the toilet, in particular in light of the fact that the sink is 680 mm from the floor, thereby providing space under it and the counter for manoeuvring, should this be necessary.

[20] The corner-mounted toilet and the functionality of the grab bars were assessed by Agency staff and CCD representatives in the mock-up viewing. The testing of the transferability features resulted in positive comments from both CCD representatives.

[21] Based on the above, the Agency is of the opinion that the new location of the toilet and the addition of folding grab bars to facilitate unassisted transfers to and from the toilet provide an appropriate level of accessibility.

Emergency and flush buttons

[22] CSA B651 Section 4.3.6.3 calls for flush controls that shall: (a) be automatically activated; or (b) be hand-operated by a lever that (i) complies with Clause 3.2.3; and (ii) is located at the transfer side of the toilet.

[23] VIA explains that the toilet flush action in the rail cars requires that an electric signal be sent to the toilet controller to flush the toilet. This is currently accomplished by means of a push button. VIA states that the lever is not practical and it has determined that an automatic flush activation sensor is not reliable for railway applications.

[24] VIA indicates that it therefore intends to replace the existing push button with one that would meet articles (a), (b) and (c) of CSA B651 Section 4.1.3.9.3 for controls which: (a) comply with Clause 3.2; (b) have dimensions of at least 25 mm x 75 mm; and (c) are operable by touching any part of the surface with a fist or an arm.

[25] The Agency accepts VIA's justification for not installing a toilet flush control as prescribed by Section 4.3.6.3 of CSA B651 and finds that, in this context, the application of Section 4.1.3.9.3 of CSA B651 with respect to a power-assisted door is appropriate.

[26] VIA states that emergency and flush buttons will be located close to the toilet to facilitate an easier access.

[27] The Agency is of the opinion that emergency and flush buttons in the washroom in the sleeper unit provide an appropriate level of accessibility.

Sink

[28] Consistent with the Current Design Proposal, the sink is positioned along the interior wall that separates the washroom from the sleeper car aisle. The Final Design Proposal also reflects a clear floor area of 750 mm x 1,200 mm, of which no more than 480 mm is under the sink and countertop, which is consistent with CSA B651. The floor space under the sink countertop is 443 mm long, which is consistent with CSA B651 recommended combined length under a sink of 200 mm for knee clearance and 230 mm for toe clearance. The Final Design Proposal is also consistent with CAS B651 as it provides the recommended height of 680 mm for knee clearance and exceeds the 230 mm height for toe clearance.

Installation of other features

[29] VIA's Final Design Proposal sets out that the following features will be installed in accordance with CSA B651: door controls, emergency call buttons, electrical outlets, toilet flush buttons, light switches, temperature control, garbage receptacle, vanity, faucet and sink, mirrors, towel and soap dispenser and grab bars. In addition, VIA will locate the sink as close as possible to the edge of the countertop and will install a toilet seat with an open design to facilitate ease of use.

[30] The Agency is of the opinion that the foregoing features, in as much as they will be installed in accordance with CSA B651, and the positioning of the sink and the design of the toilet, including the grab bars, will facilitate their use by persons using a Personal Wheelchair, therefore providing an appropriate level of accessibility.

Conclusion

[31] Based on the above, the Agency finds that the location and design of the features are consistent with CSA B651, or otherwise provide an appropriate level of accommodation. The Agency therefore finds that VIA meets the requirement of corrective measure 1(c).

(d) the accessible sleeper car is marshalled in such a way that the accessible sleeping area is adjacent to the vestibule end of a service car to ensure a route that is accessible to a person using a Personal Wheelchair to the accessible sleeping area.

[32] Consistent with the Current Design Proposal, the Final Design Proposal reflects, as set out above, that the accessible sleeper car is marshalled in such a way that the accessible sleeping area is adjacent to the vestibule end of a service car, which will ensure an accessible route to a person using a Personal Wheelchair.

[33] The Agency therefore finds that VIA's Final Design Proposal meets the requirement of corrective measure 1(d).

(e) the diaphragm doors between the service car and the accessible sleeper car will be kept locked in the open position when the accessible suite is occupied by a person with a disability.

[34] The doors at either end of the diaphragm are operated by a push-plate switch and are currently equipped with an obstacle detection system that will open the doors if a person or object is detected. VIA confirms that it will establish new operating procedures, such that when the accessible suite is occupied, the onboard crew will lock these two diaphragm doors in the open position. The doors will also remain in an open position in the event of a power failure.

[35] The Agency therefore finds that VIA's Final Design Proposal meets the requirement of corrective measure 1(e).

Further VIA commitments related to the sleeper car

[36] Consistent with the Current Design Proposal, there will be two beds: one converted from the sofa seat and the second which will unfold from the wall above the seat. As reflected in the Current Design Proposal and based on the mock-up, the sofa seat, which will be situated along the wall facing a person upon entering the sleeper unit, will be partially converted to a flip-up construction to allow for more wheelchair space parallel to the window.

[37] VIA confirmed its commitment to install a table located near the window that can fold up and down to allow for increased manoeuvring space in the bedroom. The Final Design Proposal sets out that the height of the table is adjustable and the table folds up against the outer wall.

[38] VIA further confirmed its commitment to install call buttons in the sleeper section. The Final Design Proposal reflects the installation of a call button on the exterior wall next to the folding table. A telephone is also situated on the interior wall, at the end of the sofa. As set out above, those features will be installed in accordance with CSA B651.

[39] VIA's proposed design does not include a tie-down in the accessible suite as there is no requirement for a tie-down mechanism in the sleeper section, based on VIA's consultation with Transport Canada.

[40] Based on the above, the Agency finds that VIA meets the requirements of the corrective measures regarding the sleeper car, as they relate to the above-noted commitments.

Economy coach car

Corrective measure 2: In at least one economy coach car in every Renaissance train consist, provide at least one accessible seating area by implementing the current design proposal, including VIA's commitments as confirmed by VIA in its submissions dated July 11 and 15, 2008, and reflected in the Decision, and by ensuring that:

(a) aisles and door openings both in the route to access and within the accessible seating area are at least 810 mm wide.

[41] Consistent with the Current Design Proposal, the Final Design Proposal reflects that the tie-down and adjacent accessible washroom allow for autonomous accessibility by providing direct access to the economy coach car through an 810 mm-wide exterior door into an expanded vestibule area. The vestibule area will provide a 1,500 mm turning radius and a 900 mm-wide aisle to reach the accessible seating area.

[42] VIA's Final Design Proposal indicates that the route to the tie-down area is at least 810 mm in width and the tie-down is situated in such a way as to allow direct wheel-in access. While the Final Design Proposal indicates that the area between the tie-down, when it is occupied, and a new guard rail along the exterior of the washroom wall is less than 810 mm, should a person require more room to manoeuvre past the tie-down (e.g. a person using crutches), the person occupying the tie-down may have to move their wheelchair. The Agency is of the opinion that such a situation would rarely occur.

[43] Based on the above, the Agency finds that VIA's Final Design Proposal meets the requirement of corrective measure 2(a).

(b) there is a washroom that can accommodate a person using a Personal Wheelchair including an attendant and/or a service animal, in close proximity to the wheelchair tie-down.

[44] Consistent with VIA's Current Design Proposal, a person using a Personal Wheelchair will enter the accessible washroom through a 1,000 mm-wide power-operated door, the controls of which will be situated in accordance with CSA B651. The toilet will be located in the left-hand corner upon entering the washroom. There will be space to the right and to the left of the toilet to permit a wheelchair to be positioned at a 45-degree angle to the toilet for transfer purposes.

[45] VIA enlarged the washroom in the Final Design Proposal: 2,371 mm at the widest point along the exterior wall x 1,500 mm long (vs. 2,000 mm x 1,650 mm in the Current Design Proposal). The Current Design Proposal indicates spaces to the right and to the left of the toilet of 900 mm x 1,650 mm and 1,050 mm x 1,500 mm. VIA's Final Design Proposal now provides for a space on both sides of the toilet which measures 900 mm x 1,500 mm, which the Agency notes are dimensions consistent with the CSA B651 recommendation for an individual washroom.

[46] Consistent with the Current Design Proposal, a turning radius of 1,500 mm is reflected in the Final Design Proposal, with an overlap of 25 mm by the sink countertop. Notwithstanding, the Agency is of the opinion that the height of the countertop and the sink allows for a functioning 1,500 mm turning radius. The Agency notes that CSA B651 calls for a minimum sink toe clearance of 230 mm. As the height of the lower portion of the space underneath the sink vanity is 598 mm from the floor, the Agency finds that, notwithstanding the 25 mm overlap by the sink countertop, this will provide an appropriate level of accommodation in terms of an adequate turning radius.

[47] Also consistent with the Current Design Proposal, the Final Design Proposal reflects a sink that will be positioned in the right-hand corner upon entering the washroom, allowing for front and side access. The Final Design Proposal reflects a clear floor area of 750 mm x 1,200 mm, of which no more than 480 mm is under the sink and countertop, which is consistent with CSA B651. The heater grille under the sink does not interfere with this space. The floor space under the sink countertop is 455 mm long, which is consistent with the CSA B651 recommended combined length under a sink of 200 mm for knee clearance and 230 mm for toe clearance. The Final Design Proposal is also consistent with CSA B651, as it provides the recommended height of 680 mm for knee clearance, and exceeds the 230 mm height for toe clearance.

[48] Consistent with the Current Design Proposal, the Final Design Proposal reflects that washroom accessories such as toilet paper and paper towel holders, soap dispensers, emergency call button, faucets, and mirrors, will be installed in compliance with CSA B651. In addition, the Final Design Proposal reflects folding grab bars on both sides of the toilet to allow for unassisted transfers. This feature and the functionality of the grab bars were assessed by Agency staff and CCD representatives in the mock-up viewing.

[49] The Agency's findings on the sleeper car toilet flush controls as well as the information provided on the toilet seat set out above in respect of corrective measure 1(c) are also applicable for the economy coach car.

[50] Based on the above, the Agency finds that VIA's Final Design Proposal meets the requirement of corrective measure 2(b).

(c) there is sufficient clear floor space in the wheelchair tie-down area to accommodate a person using a Personal Wheelchair and a service animal; and the tie-down area, in conjunction with the area that is adjacent to it, provides adequate manoeuvring and turning space to allow a person using a Personal Wheelchair to manoeuver into and out of the tie-down area and access the accessible washroom. - in addition, VIA had committed to install a flip-up table at the tie-down area on tracks to move up or down and forwards or backwards, depending on where the person is positioned in the tie-down and the height of the wheelchair. In addition, space for a service animal will be provided in front of the person if the wheelchair is secured at the back of the tie-down area or to the left of the person.

[51] Consistent with VIA's Current Design Proposal, the Final Design Proposal reflects the location of the tie-down on the double-seat side of the economy coach car to provide more space and drive-in access. According to VIA's Current Design Proposal, a floor space of approximately 1,280 mm wide x 1,500 mm long was to be available in the tie-down space along the car wall, and a space of 1,280 mm wide x 1,120 mm long on the aisle side.

[52] While the total length and width of the tie-down are different in the Final Design Proposal, the Personal Wheelchair footprint (750 mm x 1,200 mm in CSA B651) is provided in the tie-down area to allow for the positioning of a person using a Personal Wheelchair.

[53] VIA states that "[...] the proposed table does not flip up. It will move fore and aft and will be height adjustable." The height of the adjustable table is from 735 to 890 mm from the floor which is consistent with the CSA B651 recommended height of between 730 and 860 mm. Notwithstanding the fact that the table does not flip up, the Agency finds that the fact that the table can be moved back and forth and up and down will contribute to the usability of the space for a person to turn and manoeuvre their wheelchair and, therefore, offers an appropriate level of accessibility for a person using a Personal Wheelchair.

[54] Consistent with the Current Design Proposal, there will be a turning radius of 1,500 mm in the tie-down area, which is consistent with CSA B651, to allow manoeuvring in and out of the position. While a small portion of the turning radius protrudes into the aisle space, the Agency finds that this will not interfere with other passenger traffic as it will only be used temporarily.

[55] The Agency's Implementation Guide Regarding Space for Service Dogs Onboard Large Aircraft (Guide) sets out the approximate amount of floor space to accommodate persons with disabilities and their service dogs. The Guide sets out that the floor space to be provided for medium service dogs should be between 3,871 and 4,903 cm2; for large service dogs, it should be between 4,916 and 5,787 cm2.

[56] The Final Design Proposal reflects the positioning of a service dog in between the person occupying the tie-down and the window seat that forms part of the row of double seats facing the tie-down. The Final Design Proposal assumes that an attendant will be occupying the aisle seat facing the person occupying the tie-down. This floor space measures at least 4,845 cm2 when a person's Personal Wheelchair is secured in the aft location, i.e. the furthest position away from the table in the tie-down area (there is a fore and aft position in the tie-down for the person who uses a Personal Wheelchair). The Agency therefore finds that the space is adequate for a medium service dog.

[57] With respect to the large service dogs, the space is 71 cm2 less than the minimum space of 4,916 cm2 for large service dogs, as set out in the Guide. The Agency is of the opinion that in situations where more space is needed for a large service dog and the person with a disability is also travelling with an attendant, while not ideal, it might be necessary for the attendant to sit across the aisle to allow for sufficient space for the service dog. However, it is expected that this would be rare, given that it is relatively uncommon for a person with a disability to travel with both a service dog and an attendant.

[58] The Agency therefore finds that an appropriate level of accommodation will be provided in terms of clear floor space in the wheelchair tie-down area to accommodate a person using a Personal Wheelchair and a service animal; an adequate turning radius; and an adequate manoeuvring space.

[59] Based on the above, the Agency finds that VIA's Final Design Proposal meets the requirements of corrective measure 2(c). In addition, the Agency finds that VIA meets the requirements of corrective measure 2(c) as they relate to VIA's commitment regarding the table and the location of a service dog in the tie-down area.

(d) there is seating for an attendant, which faces the wheelchair tie-down.

[60] Consistent with the Current Design Proposal, a lowered row of double seats will face the tie-down to provide space for travel companions or attendants, and VIA confirmed during the viewing of the mock-up that the window height in the tie-down area is low enough to allow an adult to look out the window from the floor-level tie-down.

[61] The Agency finds that VIA's Final Design Proposal meets the requirement of corrective measure 2(d).

Space for service animals

Corrective measure 3: In every Renaissance economy coach car, to ensure sufficient space is provided for persons who travel with service animals, implement the current design proposal and the following policy, subject to availability and VIA's 48-hour advance notice provisions:

(a) one of the existing quad seating spaces per economy coach car will be allocated, upon request, to allow two persons and two service animals to sit together; this space will be reserved exclusively for two individuals travelling with two service animals.

[62] Consistent with the Current Design Proposal, the Final Design Proposal includes a quad seating space (two rows of double seats that face each other) in each economy coach car, which will be allocated, upon request, to allow two persons and two service animals to sit together. The floor space measures 1,230 mm long x 635 mm wide between seat cushions. The height of the table is 670 mm in the Final Design Proposal, which is 6 mm lower than the height of 676 mm in the Current Design Proposal. However, the Agency is of the opinion that it still provides sufficient space for the height of a large service dog which is, on average, between 530 and 660 mm, as set out in the Agency's Guide.

[63] The Agency therefore finds that VIA meets the requirement of corrective measure 3(a).

(b) in the event that a larger space is required for the service animal, VIA will make available the quad area or the tie-down space for the exclusive use of the individual and the animal.

[64] VIA has confirmed that such arrangements will be made, if required. The Agency therefore finds that VIA meets the requirement of corrective measure 3(b).

(c) the lowered row of double seats at the trailing end of each economy coach car will also be used to accommodate one person with one service animal; the second seat at this location will not be assigned.

[65] Consistent with the Current Design Proposal, the Final Design Proposal includes a lowered row of double seats at the trailing end of each economy coach car (1,230 mm wide and 370 mm from the front of the seat cushion to the next seat back). VIA has confirmed that these lowered row of double seats will also be used to accommodate one person travelling with one service animal and that the second seat at this location will not be assigned. The Agency therefore finds that VIA meets the requirement of corrective measure 3(c).

Corrective measures 4, 5 and 6:

4. In every Renaissance coach car, to ensure that there are at least two additional movable aisle armrests on the double-seat side, in addition to the existing four moveable aisle armrests.

5. With respect to the exterior stairs to the cars, to ensure that the stair risers on the Phase 1 Renaissance cars are closed.

6. Because these changes will necessitate changes to VIA's policies and procedures, VIA will modify its internal and external information sources to reflect these changes, including internal policy, procedures and training material relied on by its personnel, information contained on its Web site and published documents that are available to the public.

[66] VIA confirmed that it will install at least two additional movable aisle armrests on the double-seat side, in addition to the existing four moveable aisle armrests; close the required stair risers; and make the required modifications to the above-noted information sources in light of the necessary changes to its policies and procedures. The Agency therefore finds that VIA meets the requirements of corrective measures 4, 5 and 6.

Conclusion

[67] Based on the above, the Agency concludes that VIA's Final Design Proposal, in addition to VIA's confirmation that it will fulfill the various commitments it made at the time of the Decision, meet the related requirements of the corrective measures ordered in the Decision or otherwise provides an appropriate level of accommodation.

[68] This Decision takes effect on January 25, 2010, the date on which it was verbally communicated to the parties.


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