Determination No. A-2022-10

February 1, 2022

APPLICATION by Airlines for America (A4A) and the National Airlines Council of Canada (NACC) [applicants], on behalf of their members, for an exemption from the special declaration requirement of section 62 of the Accessible Transportation for Persons with Disabilities Regulations, SOR/2019-244 (ATPDR), pursuant to subsection 170(4) of the Canada Transportation Act, SC 1996, c 10 (CTA).

Case number: 
20-07165

SUMMARY

[1] The Canadian Transportation Agency (Agency) received a joint application from the applicants on behalf of their member air carriers (member carriers). They seek conditional exemptions from section 62 of the ATPDR, pursuant to subsection 170(4) of the CTA.

[2] Subsection 170(4) of the CTA allows the Agency to exempt a person or class of persons from the application of certain regulations on any terms that it considers necessary. The Agency can grant an exemption, after consulting with the Minister of Transport, if it is satisfied that the person has taken or will take measures that are at least equivalent to those that must be taken under the regulations.

[3] Following a review of information filed by the applicants about their member carriers’ tariffs and the submissions from disability rights organizations, the Agency grants an exemption to Air Canada and Jazz Aviation LP (Jazz Aviation) from section 62 of the ATPDR, pursuant to subsection 170(4) of the CTA, provided that they meet certain conditions set by the Agency. Additionally, for the reasons set out below, the Agency dismisses the application for exemptions for the other carriers.

BACKGROUND

[4] The applicants filed a joint application on July 30, 2020, for exemptions from section 62 of the ATPDR on behalf of certain of their member carriers. The NACC member carriers are:

    • Air Canada;
    • Jazz Aviation;
    • Air Transat A.T. Inc. (Air Transat); and
    • WestJet Airlines Ltd. (WestJet).

[5] The A4A member carriers seeking exemptions are:

    • Alaska Airlines, Inc. (Alaska Airlines);
    • American Airlines Group, Inc. (American Airlines);
    • Delta Air Lines, Inc. (Delta Air Lines); and
    • United Airlines Holdings, Inc. (United Airlines).

[6] For purposes of international travel, both the Warsaw Convention and Montreal Convention (collectively, the Conventions) treat mobility aids as baggage and subject them to limits of liability provided for in the provisions of their respective Conventions. For example, the Montreal Convention’s current liability limit is 1,288 special drawing rights—the International Monetary Fund’s unit of accounting—or approximately CAD 2,300. Frequently, however, the value of a mobility aid is greater than the monetary limits established in the Conventions.

[7] In order to address this problem, section 62 of the ATPDR requires an air carrier to advise a person travelling with a mobility aid during international travel of the option to make a special declaration of interest, under Article 22(2) of the Montreal Convention or under Article 22(2) of the Warsaw Convention. This special declaration may be made at any time before the mobility aid is removed by the carrier for storage in the aircraft’s baggage compartment. Where a special declaration of interest is made, the carrier is unable to rely on the limits of liability in the Conventions for lost, delayed or damaged baggage if the passenger’s mobility aid is lost, delayed or damaged, and the carrier’s maximum liability will be the value of the mobility aid set out in the declaration.

[8] The applicants assert that the member carriers should not be required to advise passengers of their right to make a special declaration because they generally waive, by either policy or practice, the limits of liability contained in the Conventions for mobility aids.

[9] On October 27, 2020, the applicants filed supplemental information in support of their application. After reviewing this supplemental information, the Agency found that the information provided in the application and supplemental information filed was insufficient to assess the request for exemptions. In particular, although the supplemental information included some examples of carrier policies, the submission failed to identify the particular carriers to which these policies applied. The Agency informed the applicants, in an email dated December 21, 2020, that it would consider the application upon receipt of clearly worded tariff provisions for each of the member carriers seeking an exemption. Such tariff provisions would be required to demonstrate that each carrier waives the limits of liability set out in the Conventions for claims related to lost, damaged or destroyed mobility aids.

[10] On February 12, 2021, the applicants filed, in support of their request, a second supplement, which set out the member carriers’ relevant tariff provisions or provided information about them.

[11] Given the potential public impact that this regulatory exemption could have, on March 3, 2021, the Agency launched a consultation to hear from members of disability rights organizations and the public. The Agency received two individual submissions from disability rights organizations, namely Barrier Free Canada (BFC) and Spinal Cord Injury Canada (SCI), and a joint submission from:

    • Council of Canadians with Disabilities;
    • Canadian Council of the Blind;
    • Alliance for the Equality of Blind Canadians;
    • National Coalition of People who use Guide and Service Dogs;
    • Service Dog Users of Canada; and
    • Confédération des organismes de personnes handicapées du Québec.

THE LAW

[12] Part V of the CTA gives the Agency powers to protect and advance the fundamental right of persons with disabilities to an accessible federal transportation network. These powers include the authority, under subsection 170(1) of the CTA, to make regulations for the purpose of identifying or removing barriers or preventing new barriers—particularly barriers in the built environment, information and communication technologies and the delivery of programs and services—in the transportation network under the legislative authority of Parliament.

[13] Pursuant to subsection 170(1) of the CTA, on June 25, 2020, the Agency promulgated the ATPDR, which provide a set of clear, consistent, specific and legally binding accessibility requirements for many transportation service providers. The ATPDR apply to large carriers and terminals in modes of transport under federal jurisdiction.

[14] Section 61 of the ATPDR describes the obligations of a carrier if the mobility aid of a person with a disability is damaged, destroyed or lost during transport or is not made available to the person at the time of their arrival at their destination.

[15] Section 62 of the ATPDR, which relates to the special declaration of interest, states:

(1) If a person with a disability who uses a mobility aid makes a reservation with an air carrier for transportation on an international service, the air carrier must advise the person of the option to make a special declaration of interest, under Article 22(2) of the Montreal Convention or under Article 22(2) of the Warsaw Convention, that sets out the monetary value of the mobility aid and a description of its identifying features.

(2) The air carrier must permit a person with a disability to make the special declaration of interest at any time before the mobility aid is removed by the carrier for storage in the aircraft’s baggage compartment.

(3) An air carrier that operates an international service must publish, including by publishing on its website, a notice for persons with disabilities who use mobility aids that informs them of the option to make a special declaration of interest under Article 22(2) of the Montreal Convention or under Article 22(2) of the Warsaw Convention.

[16] Subsection 170(4) of the CTA states that:

On application and after consulting with the Minister, the Agency may, by order, on any terms that it considers necessary,

(a) exempt a person from the application of regulations made under subsection (1) if the Agency is satisfied that the person has taken or will take measures—at least equivalent to those that must be taken under the provisions of the regulations for which an exemption is to be granted—to remove barriers or to prevent new barriers….

The order ceases to have effect on the earlier of the end of the period of three years that begins on the day on which the order is made and the end of any shorter period specified in the order.

POSITIONS OF THE APPLICANTS AND CONSULTATION PARTICIPANTS

The applicants

[17] The applicants submit that their member carriers generally waive, whether by policy or practice, the limits of liability set forth in the Conventions for claims of loss, damage, or delay of mobility aids in international transportation. They further claim that section 62 of the ATPDR, which requires that air carriers advise passengers of the right to make special declarations of interest under the Conventions, is inconsistent with these waivers of limits of liability.

[18] They submit that advising the passenger of the right to make a special declaration of interest serves no purpose given that the carrier waives the limits of liability for mobility aids, is not in a passenger’s best interest, and may create barriers rather than remove them. They indicate that it may be confusing for the passenger to be advised of the right to make a special declaration of interest, despite an air carrier waiving the Conventions’ limits of liability. They also assert that a person may inadvertently make a special declaration of interest that is less than the replacement value of their mobility aid and only be able to make a claim up to the amount specified in the special declaration of interest.

[19] The applicants filed excerpts of, or information about, their member carriers’ tariffs:

    • The tariffs of Air Canada and Jazz Aviation state that the normal carrier limit of liability will be waived for substantiated claims involving loss of, damage to, or delay in delivery of mobility aids, such as wheelchairs, walkers, crutches, scooters and other mobility aids. They further indicate that the liability of the carrier for substantiated claims involving the loss of, damage to, or delay in delivery of mobility aids, when such items have been accepted as checked baggage or otherwise, would be based on the cost of the repair or the replacement value of the mobility aid.
    • Air Transat’s tariff states that normal limitations of carrier liability will be waived for substantiated claims involving loss of, damage to, or delay in delivery of mobility aids. It also states that if a mobility aid is damaged or lost, the carrier will immediately provide a suitable temporary replacement without charge. If a damaged mobility aid can be repaired, the carrier will arrange, at its expense, for the prompt and adequate repair of the mobility aid and return it to the passenger as soon as possible. If a damaged mobility aid cannot be repaired or is lost and cannot be located within 96 hours after the passenger’s arrival, the carrier will, at its discretion, replace it with an identical mobility aid satisfactory to the passenger, or reimburse the passenger for the replacement cost of the mobility aid.
    • WestJet’s tariff states that, if a damaged mobility aid can be repaired, the carrier will arrange, at its expense, for the prompt and adequate repair of the mobility aid and return it to the passenger as soon as possible. If it cannot be repaired or is lost and cannot be located, the carrier will, at its discretion, replace it with an identical mobility aid satisfactory to the passenger, or reimburse the passenger for the replacement cost of the aid. 
    • Alaska Airlines’ tariff states that the carrier sets the maximum liability for a lost, damaged or destroyed wheelchair or other assistive device at the original, documented purchased price of the device.
    • American Airlines’ tariff states that its “Excess value charge” and “Valuation limit of baggage” exclude assistive devices.
    • Delta Air Lines and United Airlines both indicate that they are in the process of amending their tariffs to include a waiver of limits of liability. They state that confirmation of the amended tariff language will be provided after filing their respective new tariff with the Agency.

Disability rights organizations

[20] Three submissions were received from disability rights organizations.

[21] While BFC supports the request, SCI and the organizations that made the joint submission are opposed to it.

[22] BFC states that having the person with a disability sign such a special declaration adds no value and may, in and of itself, become an additional barrier and generate unnecessary confusion.

[23] SCI states that it should be mandatory that carriers advise passengers of their right to make special declarations of interest. It raises the concern that air carriers are improperly putting the onus on passengers with disabilities to be aware of their right to make a declaration of interest. It further states that there is no requirement to post the information about the waiver of liability on the website and that there is no guarantee that the person will be able to find the information even if it was posted. Therefore, SCI submits that the onus should be on the carriers to fully and fairly disclose the passenger’s rights under the special declaration of interest.

[24] The joint submission indicates that not having the option to make a special declaration of interest may result in the person not being reimbursed in full for their lost, destroyed or damaged mobility aid when a claim is made, because of the potential for disagreements with the carrier about the value of the reimbursement.

[25] Another concern raised in the joint submission is that a carrier could change its tariff after being granted the exemption. Similar to the concern raised by SCI, the joint submission indicates that the exemption would put the onus on a person with a disability to know which carriers have an exemption and this would create additional barriers for a person travelling with a mobility aid.

[26] In addition, the joint submission states that reimbursements should include expenses in addition to the cost of replacement, such as required travel to a specialist to take necessary measurements.

[27] The joint submission proposes that, should the Agency decide to grant the exemption, the exemption order should contain certain conditions including:

    • granting it for a limited period of two years and reviewing the impact after that period;
    • requiring carriers to inform every passenger with a mobility aid, in plain and clear language, whether the carrier has waived its limits of liability;
    • ensuring that the reimbursement will not be less than what the passenger could have claimed through a declaration of special interest; and
    • having a process where people could contact the Agency for assistance in resolving disputes related to mobility aids.

ANALYSIS AND DETERMINATIONS

Overview of section 62 obligations

[28] The purpose of the ATPDR is to provide a set of clear, consistent, specific and legally binding accessibility requirements for many federal transportation service providers to enable persons with disabilities to travel with a predictable and consistent level of accessibility across a barrier-free modern national transportation network. Persons travelling with mobility aids face unique challenges, especially when their mobility aid is lost, damaged or delayed.

[29] As noted above, for purposes of international travel, the Conventions treat mobility aids as baggage, and the liability of carriers for lost or damaged mobility aids is subject to the limits of liability for baggage set out in the Conventions. Article 22(2) of the Conventions establishes a monetary limit to a carrier’s liability for lost or damaged baggage, unless a higher value has been declared by the passenger through a special declaration of interest.

[30] Section 62 of the ATPDR specifically provides protections for persons with disabilities who travel with mobility aids during international travel in light of the fact that customized mobility aids may cost more than the monetary limits for baggage established by the Conventions and that a person may not be aware of these limitations or the ability to make a special declaration to ensure that the limits do not apply. Therefore, section 62 requires carriers to advise a person travelling with a mobility aid of the option to make a special declaration of interest regarding the value of their mobility aid, to ensure that they are fully compensated for any loss or delay of or damage to the mobility aid beyond the limits of liability set by the Conventions. This special declaration would set out the monetary value of the mobility aid and a description of its identifying features. Section 62 imposes no limits on the number of aids for which a person can make a special declaration.

Threshold for an exemption from section 62

[31] A4A and NACC argue that their member carriers should be exempted, pursuant to subsection 170(4) of the CTA, from the requirement of section 62 of the ATPDR, given that they already waive all limits of liability for mobility aids set forth in the Conventions.

[32] The Agency’s power to grant exemptions under subsection 170(4) of the CTA is limited to situations where it is satisfied that the carrier has “taken or will take measures—at least equivalent to those that must be taken under the provisions of the regulations for which an exemption is to be granted—to remove barriers or to prevent new barriers”. Accordingly, the member carriers’ tariffs must clearly indicate that they waive the limits of liability such that there is no purpose to be served by offering a person the opportunity to make a special declaration of interest on account of the fact that each member carrier’s waiver is “at least equivalent” to what is required under section 62 of the ATPDR.

[33] A mere statement in a carrier’s policy or generalizations about its policy are not sufficient to establish that the carrier has in place measures that are at least equivalent to the requirement in section 62 of the ATPDR. Furthermore, a policy that reserves discretion for the carrier in its application is not enforceable and, thus, is not sufficient to be considered as an equivalent measure to the regulatory requirement in the ATPDR. In order to be considered equivalent, sufficient detail must be included in a binding term of contract between the passenger and the carrier.

Analysis applicable to all carriers

[34] Disability rights organizations expressed a number of general concerns about an exemption from section 62 of the ATPDR, including a concern that an exemption could hinder a passenger’s ability to receive a full reimbursement due to the potential for arguments with the carrier about the value of the mobility aid. The Agency notes that the presence of a special declaration does not necessarily mean that the passenger will recover the full amount stated. A special declaration will reflect the maximum liability that the carrier accepts to pay on any claim. However, the carrier may require proof of the loss, for example a statement that the mobility aid is irreparable and a quote for a replacement aid, or some other support for the amount claimed.

[35] The need to substantiate a claim does not change based on whether the maximum is the amount contained in the Conventions or the amount stated on the special declaration of interest. Nonetheless, when disputes do arise between carriers and passengers, the Agency’s complaints process is available to resolve these disputes.

Carrier-specific analysis

[36] In total, the applicants made three submissions to support their request for exemptions. The application and the supplemental information did not contain specific tariff provisions of the member carriers and included generalizations not specifically attributed to any carriers. On December 21, 2020, the Agency informed the applicants that member carriers must reflect relevant policies and practices in their tariffs so that they form part of the contract of carriage with passengers and that it would consider the application only upon receipt of clearly worded tariff provisions waiving the limits of liability set out in the Conventions for claims related to lost, damaged or destroyed mobility aids.

[37] In their second supplemental filing, the applicants provided excerpts of, or information about, the member carriers’ tariffs. However, for Delta Air Lines and United Airlines, no tariff excerpts were provided. Instead, these carriers indicated that they are in the process of amending their tariffs to include a waiver of the limits of liability. Although the carriers did not file amended tariffs as part of this exemption request process, they subsequently filed updates to their tariffs with the Agency’s Tariffs and Research Directorate. However, given that the updated tariffs do not include any changes to provisions relating to the carriers’ limits of liability for mobility aids, the Agency is not able to assess whether the measures proposed by Delta Air Lines and United Airlines are at least equivalent to those required by section 62 of the ATPDR and, thus, will not consider an exemption for these two carriers at this time.

[38] The Agency has carefully reviewed the relevant tariff provisions of each member carrier and assessed them below on an individual basis.

Air Canada and Jazz Aviation

[39] Rule 105 of the international tariff of both Air Canada and Jazz Aviation states:

(4)(a) Normal carrier limit of liability will be waived for substantiated claims involving loss, damage or delay in delivery to mobility aids such as wheelchairs, walkers, crutches, scooters and other mobility aid. When such items have been accepted into the care of the carrier as checked baggage or otherwise.

Note: The liability of carrier for substantiated claims involving the loss of, damage to, or delay in delivery of mobility aids, when such items have been accepted as checked baggage or otherwise, is to be based on the cost of the repair or replacement value of the mobility aid.

[40] The Agency finds that the tariffs of Air Canada and Jazz Aviation are consistent with their obligations under the ATPDR in that they contain binding contractual obligations that:

    • contain an express waiver of the normal carrier limits of liability for substantiated claims involving loss of, damage to, or delay in delivery of mobility aids, such as wheelchairs, walkers, crutches, scooters and other mobility aids; and
    • provide that the amount to be reimbursed will be based on the cost of repair or replacement value of the mobility aid.

[41] The Agency is satisfied that the clear and express waiver alleviates the need for passengers travelling with mobility aids to make a special declaration as it would serve no purpose.

[42] Additionally, subsection 62(2) of the ATPDR requires air carriers to permit a person with a disability to make the declaration at any time before the mobility aid is removed by the carrier for storage in the aircraft’s baggage compartment. If the declaration is not made within this period, the liability is limited to what is allowed by the Conventions. A waiver, on the other hand, is not subject to any time limit, such that a waiver of all limits of liability guarantees greater rights to person travelling with a mobility aid.

[43] Accordingly, the Agency accepts that the measures put in place by Air Canada and Jazz Aviation are at least equivalent to those required by section 62. After having consulted with the Minister, the Agency grants exemptions to Air Canada and Jazz Aviation, pursuant to section 170(4) of the CTA, on this basis.

Air Transat and WestJet

[44] The tariffs of Air Transat and WestJet both indicate that they waive the limits of liability but also include a statement that the carrier will, “at its discretion”, replace a damaged or lost mobility aid with an identical mobility aid satisfactory to the passenger, or reimburse the passenger for the replacement cost of the mobility aid. The Agency finds that leaving the reimbursement or replacement at the discretion of the air carrier creates uncertainty for passengers with disabilities who must travel with mobility aids and, more importantly, is inconsistent with the regulatory requirements contained in the ATPDR in relation to mobility devices.

[45] Accordingly, the Agency finds that neither Air Transat nor WestJet have measures at least equivalent to those required by section 62 of the ATPDR and, thus, that exemptions are not warranted. For this reason, the Agency does not grant exemptions to WestJet and Air Transat.

Alaska Airlines

[46] Alaska Airlines’ tariff sets the maximum liability for a lost, damaged or destroyed wheelchair or other assistive device at “the original, documented purchased price of the device”.

[47] The obligation under section 62 of the ATPDR states that the special declaration is to state the “monetary value” of the mobility aid. However, the requirement to compensate the passenger when their mobility aid is lost, damaged or destroyed is set out in section 61 of the ATPDR, which requires, among other things, that the carrier reimburse the passenger for the “full replacement cost”.

[48] Accordingly, Alaska Airlines’ tariff provision is inconsistent with section 61 in situations where the current cost of the replacement mobility aid is higher than the original purchase price as a result of, for example, inflation.

[49] The Agency finds that an exemption from the requirement to inform a passenger of their option to make a special declaration of interest should not be granted under such circumstances, as Alaska Airlines’ tariff could deprive the passenger of a higher amount of compensation to which they would be entitled under the ATPDR. Consequently, the Agency finds that Alaska Airlines’ measures are not at least equivalent to those required by section 62 of the ATPDR, and thus, does not grant Alaska Airlines the requested exemption.

American Airlines

[50] Rule 116 of American Airlines’ international tariff states:

(V) Excess value charge (excluding assistive devices)

(1) For purposes of transportation under the Montreal Convention, a passenger may, declare a value for baggage in excess of the maximum liability of 1,288 SDR’s per passenger for all checked baggage.

(2) When such a declaration is made, a charge of such excess value will be assessed at USD 5/CAD 6 per $1000 or fraction thereof. Note: A higher declared value may not be applied to money, jewelry, silverware, negotiable papers, securities, business documents, samples, paintings, antiques, artifacts, manuscripts, irreplaceable books or publications or other similar valuables.

(3) Excess valuation baggage may be checked for online travel only.

(W) Valuation limit of baggage (excluding assistive devices)

(1) The total declared value may not exceed USD 5,000/CAD 6,100.

(2) No baggage of any one passenger, having a declared value in excess of USD 5,000/CAD 6,100 will be accepted unless special arra[nge]ments have been made in advance, by the passenger with AA.

[51] Under section 1 of the ATPDR, an “assistive device” is a category that includes mobility aids, as well as medical devices, communication aids and other aids designed to assist a person with a disability with a need related to their disability.

[52] Although these tariff provisions state what passengers must do in order to have the limits of liability set out in the Conventions waived for goods that are not assistive devices, they do not specify, with any clarity, what passengers must do in order for the limits of liability set out in the Conventions to be waived in respect of mobility aids. In fact, the tariff is silent on whether a special declaration is an option for passengers with mobility aids or if a special declaration is unnecessary because the carrier proactively waives the Conventions’ limits of liability for mobility aids. Absent a clear indication to the contrary, the limits set out in the Conventions arguably continue to apply to mobility devices. Accordingly, the Agency finds that American Airlines’ tariff does not include a measure that is at least equivalent to the requirements of section 62 of the ATPDR as it does not contain the requirement to advise a person of the option to make a special declaration of interest, much less contain a provision clearly waiving the limits of liability.

CONDITIONS

[53] Subsection 170(4) of the CTA allows the Agency to grant an exemption “on any terms that it considers necessary”.

[54] Disability rights organizations requested that if exemptions are granted, they be made subject to conditions, including that:

    • exemptions be for a period of two years, after which their impact should be reviewed;
    • carriers be required to advise a passenger whether they waive the limits of liability; and
    • reimbursements be not only for the cost of replacement, but also for related costs such as travel to a specialist to take measurements.

[55] Subsection 170(4) of the CTA contains a three-year limitation period on the duration of exemption orders issued under this authority. Accordingly, the duration of the exemptions will be limited by operation of the legislation and a review of their impact would occur in the context of any application for a subsequent exemption.

[56] The Agency agrees that the carriers benefiting from this exemption should advise passengers that they waive the limits of liability set out in the Conventions. To do so provides reassurance to passengers travelling with mobility aids and helps to avoid confusion among those who have been advised by other air carriers that a special declaration is necessary in order for a higher limit of liability to apply.

[57] With respect to the question of reimbursement, the Agency notes that paragraph 61(b) of the ATPDR requires the carrier to “reimburse the person for any expenses they have incurred because the mobility aid was damaged, destroyed or lost or because it was not made available to them at the time of their arrival at their destination”. Consequently, a condition to this effect is unnecessary.

[58] Finally, to the extent that any exemption is granted, it would be conditional on the continued existence of measures that are at least equivalent to those that must be taken under section 62 of the ATPDR.

CONCLUSION

[59] Upon examination of the tariffs and information provided by A4A and the NACC, the Agency finds that two of the eight air carriers, Air Canada and Jazz Aviation, meet the criteria for an exemption under subsection 170(4) of the CTA by fully and unconditionally waiving the limits of liability for mobility aids in international travel.

[60] The other member carriers, namely Air Transat, WestJet, Alaska Airlines, American Airlines, Delta Air Lines, and United Airlines have not demonstrated that they have measures in place that are at least equivalent to those that must be taken under section 62 of the ATPDR. As a result, the Agency dismisses the exemption requests of these carriers.

ORDER

[61] Pursuant to the authority in subsection 170(4) of the CTA, and after consulting with the Minister of Transport, the Agency exempts Air Canada and Jazz Aviation from section 62 of the ATPDR for a period of three years, with the following conditions:

    • each air carrier must include its reimbursement policy in its tariffs, including the steps the person must take, and information or proof the person must provide to the carrier, in order to make a claim for reimbursement, and it must publish this information on its website;
    • each air carrier must file its updated tariffs for the Agency’s approval by March 15, 2022. The updated tariffs must include the carrier’s reimbursement policy, including the steps the person must take, and information or proof the person must provide to the carrier, in order to make a claim for reimbursement;
    • each air carrier must advise passengers at the time of reservation, or as soon as it is made aware that the passenger is travelling with a mobility aid, that the carrier waives the limits of liability, and it must publish this information on its website;
    • each air carrier must not make changes to the tariff provisions related to the waiver during the period of the exemption; and
    • these exemptions expire on February 1, 2025.

Member(s)

Elizabeth C. Barker
J. Mark MacKeigan
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