Spot the Trend: Increasing Environmental Penalties in Canada

by Sean Parker and Kimberly Wasylenchuk[1]

On March 26, 2021, Teck Coal Limited (“Teck Coal”) entered a guilty plea on two counts of unlawfully depositing a deleterious substance into water frequented by fish, contrary to s. 36(3) of the Fisheries Act. Teck Coal was ordered to pay a total of $60 million in fines and monetary court orders arising from the infractions under the Fisheries Act. In addition to the monetary penalty, Teck Coal was ordered to comply with direction given under the Fisheries Act requiring pollution reduction measures.[2] The charges resulted from an investigation by Environment and Climate Change Canada (“ECCC”), which concluded that Teck Coal’s operations were depositing deleterious coal mine waste rock leachate (consisting of selenium and calcite) into the upper Fording River in southeastern British Columbia.[3]

This article examines the trend of increasing penalties in Canada resulting from prosecution of environmental offenses.

Shift in Policy?

The penalty to Teck Coal is the highest ever imposed by a Canadian court for violation of the Fisheries Act and the majority of the fine, $58 million, will go to the Government of Canada’s Environmental Damage Fund. By imposing this large fine, the Government of Canada appears to be taking an aggressive stance in relation to environmentally damaging conduct. Does this indicate a shift in policy on a broader scale?

Trend of Increasing Environmental Penalties in Canada

There appears to be a trend of increasing penalties for environmental offences in Canada as environmental issues continue to be at the forefront of public and political discussion. Governments at both the Federal and Provincial levels continue to seek stiff penalties for individuals and corporations that break the law.

The Canadian Environmental Protection Act 1999 (“CEPA, 1999”) came into force in March 2000 with the aim to prevent pollution and protect the environment and human health. Building on the legislative framework introduced under CEPA, 1999, the Environmental Enforcement Act (“EEA”) was introduced in stages:

  • Stage 1 in December 2010 wherein the bulk of the EEA came into force;
  • Stage 2 in June 2012 wherein amendments related to the fine regime and sentencing provision of CEPA, 1999 came into force with an accompanying regulation to allow enforcement with increased penalty provisions;
  • Stage 3A in June 2017 wherein the Environmental Violations Administrative Monetary Penalties Regulations (“EVAMP”) came into force, enabling the use of administrative monetary penalties for certain violations of legislation administered by the ECCC;
  • Stage 3B in July 2017 wherein all remaining amendments to the Canada Wildlife Act, Migratory Birds Convention Act, 1994 and Wild Animal and Plant Protection and Regulation of International and Interprovincial Trade Act came into force; and
  • Stage 4 in December 2020 commenced the beginning of the mandatory review of fine and sentencing provisions of the Acts enforced by ECCC.

The EEA established a stiffer penalty regime to give the Federal Government a stronger tool to use when pursuing environmental offenders and sanctioning harmful conduct. The EEA strengthened and harmonized enforcement regimes under nine of Canada’s Federal environmental statues. ECCC is responsible for the administration and enforcement of the pollution prevention provisions of the Fisheries Act and the enforcement provisions in other legislation under the EEA.

In many cases, the Federal officers (as members of ECCC and certain other agencies) will coordinate their investigations and efforts with the respective Provincial environmental authorities or ministry. In Alberta, the Environmental Protection Enhancement Act (“EPEA”) operates to promote the protection and wise used of the environment. Fines and penalties can be issued when an individual or corporation contravenes the provisions of the Act.

Recent Trend of Environmental Fines in Canada

Our review indicates that since 2014 there has been an increasing number of fines over $1 million issued in Canada. There are examples of large fines prior to this time, however, amendments to the Fisheries Act in 2012 and other factors appear to have resulted in precedents for larger penalties in recent years. In our view, one of these other factors is the “ratcheting-up” effect of increasing fines. Essentially, as fines increase, the baseline for assessing a penalty also increases. The effect is that the baseline continues to rise and accordingly so will the penalties ultimately issued. Inflation also contributes to the “ratcheting-up” effect as there is often a perception that penalties should increase commensurate with the purchasing power of the dollar. As an illustrative example, when looking at precedents in consideration of an appropriate sentence, a penalty of $200,000 issued for an offence 10 years ago would be viewed in the context of how much that amount was worth at the time, and a penalty of $250,000 may be viewed as comparable for a similar offence today.

Each matter is unique and will turn on the specific facts, however, in our view there is little doubt that environmental penalties are increasing in Canada. The following discussion looks at a number of the more significant penalties in recent years.

2014:

Bloom Lake:

After pleading guilty to 45 charges under the Fisheries Act, Bloom Lake General Partner Limited (“Bloom Lake”) was ordered to pay $7.5 million in relation to several incidents including the breach of a tailings pond dam in Quebec. Infractions at the Bloom Lake mining site included releases of non-compliant effluent and ferric sulfate into fish bearing water. A likely aggravating factor taken into account for the stiffness of the penalty was Bloom Lakes’ failure to follow direction given by the Inspector.[4]

For a time, the Bloom Lake penalty was the largest fine ever imposed in Canada for environmental infractions. Over 200,000 cubic meters of deleterious substances was released following the breach of the Triangle Tailings Pond dam and the value of the fine likely reflected the severity level of the release.

2016:

Gwaii Wood Products:

In January 2016, three companies were fined a total of $2.2 million and other penalties for offences committed in October 2010. The provisions of the Fisheries Act in force in 2010 applied in this case as the new legislation came into force after the offences were committed but before the case made its way to court.

The three corporate defendants were involved in logging operations in British Columbia. Each conviction arose from harmful alteration, destruction, or disruption of fish vegetation near tributaries which fed into the Kumdis Bay Estuary, Mallard Creek and Mallard Creek itself, all in violation of Section 35(1) of the Fisheries Act.[5]

Teck Metals:

In March 2016, Teck Metals Ltd., (“Teck Metals”) pleaded guilty to three offences under the Fisheries Act and was ordered to pay a $3 million penalty for numerous deleterious effluent discharges into the Columbia River in British Columbia.

Teck Metals discharged substances including effluent which contained copper, cadmium, chlorine or pH and ammonia that were all present in high enough concentrations to be harmful to fish. Over 125 million liters of effluent was released between November 2013 and February 2015.[6]

2017:

Canadian National Railway:

Canadian National Railway Company (“CN”) pleaded guilty and was fined $2.5 million in relation environmental infractions that occurred in April 2015. The investigation determined that the oil-water separator and fuel storage system at Bissell Yard in Alberta was not compliant with the applicable Regulations, which caused about 90 liters of diesel to be released to the storm sewer. CN attracted the largest of its fines for deposit of a deleterious substance to fish-bearing water, in violation of the Fisheries Act, resulting in a $2 million penalty.

In addition to the Federal penalties, CN was fined $125,000.00 under Alberta’s EPEA for release of a substance that may cause a significant adverse effect and failure reasonably remediate after a release to the environment.[7]

Prairie Mines:

In June 2017, Prairie Mines & Royalty ULC (“Prairie Mines”) pleaded guilty to two offences contrary to the Fisheries Act and was sentenced to pay a monetary penalty of $3.5 million. In addition to the fines under the Federal legislation, Prairie Mines pleaded guilty to one count under Alberta’s EPEA and was given further penalties.

These charges arose from a spill at the Obed Mountain Mine. A dike that was holding back waste water at the mine failed, resulting in over 670 million liters of contaminated water and sediment spilling into the Apetowun Creek and Plante Creek which impacted the Athabasca River.[8]

Sherritt:

On October 3, 2017, Sherritt International Corporation (“Sherritt”) pleaded guilty to three counts under the Fisheries Act in relation to the Coal Valley Mine spill which occurred near Edson, Alberta. In August 2012, ECCC officers visited the mine and determined that effluent deposited from a wet water pond was deleterious to fish. A direction was issued under the Fisheries Act compelling Sherritt to stop the deposit. However, following a subsequent investigation, it was revealed there were two previous effluent releases from the same waste water ponds into the Erith River (part of the Athabasca River watershed) in July 2011. Sherritt was fined $1.05 million for the violations.[9]

Teck Resources:

In October 2017, Teck Resources Ltd., (“Teck Resources”) was fined $1.425 million for three violations of the Fisheries Act. The charges stemmed from an investigation in 2014 which concluded that Teck Resources was releasing harmful effluent into Line Creek, a British Columbia waterway with a high fisheries value. Several dead fish were spotted in ponds near Teck Resources’ Line Creek coal operation near Sparwood in southeastern British Columbia.[10]

2018:

Irving Pulp:

On November 5, 2018, Irving Pulp & Paper Limited (“Irving Pulp”) was ordered to pay a $3.5 million penalty following pleading guilty to three offences under the Fisheries Act. In addition to the fine, Irving was given direction pursuant to the Fisheries Act to implement appropriate planning to work toward building a new effluent treatment system.[11]

The charges arose from several infractions that occurred between June 2014 and August 2016 wherein improperly treated and deleterious effluent was released into the St. John’s River in New Brunswick.

2019:

Syncrude:

Syncrude Canada Ltd., (“Syncrude”) was ordered to pay a fine of $1.775 million in relation to one count of violating the Migratory Birds Convention Act, 1994. Syncrude was charged with depositing or permitting the deposit of a substance that is harmful to migratory birds as 31 great blue herons were found deceased in an abandoned sump near Fort McMurray, Alberta. Additionally, Syncrude pleaded guilty to one count under Alberta’s EPEA and was ordered to pay an additional fine of $975,000.[12]

Kirby:

Kirby Offshore Marine Operating LLC (“Kirby”) plead guilty to three charges of violating Federal legislation in relation to a spill from the ‘Nathan E. Stewart’ vessel into the Seaforth Channel near Bella Bella, British Columbia on October 13, 2016. The tugboat ran aground, resulting in the release of approximately 107,552 liters of diesel fuel and 2,240 liters of lubricants into the water. Both substances are deleterious to fish and migratory birds. Kirby Offshore Marine Operating LLC owned the Nathan E. Stewart.[13]

Kirby was given the following fines:

  • $2.7 million for the offence of depositing a deleterious substance into water frequented by fish, in violation of the Fisheries Act;
  • $200,000 for the offence of depositing a substance harmful to migratory birds, in violation of the Migratory Birds Convention Act, 1994; and
  • $5,000 for the offence of failing to comply with the pilotage requirements under the Pilotage Act.[14]

Husky Oil:

In June 2019, Husky Oil Operations Limited (“Husky Oil”) was ordered to pay $2.7 million in fines for one count of violating the Fisheries Act and one count of violating the Migratory Birds Convention Act, 1994. The charges arose from an incident in July 2016 where 225,000 liters of heavy crude oil leaked from a Husky Oil pipeline, near Lloydminster, on the Saskatchewan side of the border. Of the total leakage, 90,000 liters entered the North Saskatchewan River.[15]

Husky Oil also pleaded guilty to one violation under the Saskatchewan Provincial environmental legislation for this incident.

2020:

Volkswagen Aktiengesellschaft

In January 2020, Volkswagen Aktiengesellschaft (“Volkswagen”) was ordered by the Ontario Court of Justice to pay a $196.5 million fine after pleading guilty to 60 charges for offences under CEPA, 1999; 58 counts for unlawfully importing vehicles into Canada that did not conform to prescribed vehicle emissions standards, and 2 counts for providing misleading information. The fine was directed to the Government of Canada’s Environmental Damages Fund. This was by far the largest environmental fine in Canadian history; however, it is somewhat on an outlier given the highly unique facts. This matter was part of Volkswagen’s global emissions cheating scandal where they faced hefty penalties in several countries.[16]

Drever:

On February 18, 2020, Drever Agencies Inc., (“Drever”) pleaded guilty to an offence under the Fisheries Act in relation to a charge for depositing a deleterious substance into water frequented by fish and was fined $1.25 million.

The ECCC responded to a solvent spill located on commercial property in Wetaskiwin, Alberta. The investigation determined that approximately 1800 liters of Petrosol solvent leaked from a storage tank owned by Drever and entered a nearby creek. Through laboratory analysis, it was confirmed that the solvent was deleterious and harmful to fish.[17]

2021:

Gibson:

In March 2021, Gibson Energy ULC and GEP ULC (collectively “Gibson”) was fined $1.5 million for two counts of violating the Fisheries Act. The charges arose from an incident that occurred in March 2014 when employees located a leak in the fire suppression system. From the leak site, chlorinated water escaped the system and entered an unnamed creek and the North Saskatchewan River. The chlorinated water was of a sufficient level to be harmful to fish in the river.[18]

What to Expect in the Future

Based on the trend in the recent years, there is little doubt that governments will seek, and courts will impose significant fines for contraventions of various Federal and Provincial environmental legislation. Powerful sentencing provisions, particularly in Federal legislation, give governments a strong tool to make offenders pay. The prevalence of stiff penalties and “ratcheting-up” effect often leads to fines that sting, which can no longer be viewed as a cost of doing business.

For more information on these issues and how they may affect you or your business, please contact Sean Parker in Edmonton, Michael Barbero in Calgary or another member of our Energy, Environment and Regulatory Practice Group.

[1] With thanks to Dolores Noga.

[5] R. v. Gwaii Wood Products Ltd., et al, 2017 BCPC 6

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Cost Awards and Funding for Environmental Hearings in Alberta

By Sean Parker and Anna Fitz

On March 18, 2021, Partner Sean Parker and Associate Anna Fitz presented a webinar on obtaining costs awards at environmental tribunals, how tribunals award costs, and what sort of factors they consider. This article discusses the key points raised during the webinar (which can also be viewed here[1]) as well as recent developments that have since taken place.

The basis for awarding costs by an environmental tribunal is often different from costs awarded by a court. Courts generally follow the “loser pays” principle, which means that the party who is unsuccessful in court generally must pay a portion of the successful party’s legal costs.

On the other hand, environmental tribunals often take a different approach, considering the public interest component of tribunals’ mandates. Environmental proceedings often involve the weighing of various competing interests and policy considerations. These proceedings often do not produce judicial “winners” and “losers”, per se.

Furthermore, tribunals’ discretion to award costs is dependent upon the statute that gives them their power. For example, if a statute is silent on costs, the tribunal may have no authority to award costs at all. This underscores the importance of considering specific tribunals’ legislation and practices on awarding costs. The following discussion looks at the practices of the main tribunals that conduct hearings on environmental matters in Alberta.

Alberta Energy Regulator (“AER”)

•       Responsible Energy Development Act, SA 2012, c R-17.3

–      s. 3 establishes the AER

•       Alberta Energy Regulator Rules of Practice, Alta Reg 99/2013

–      s. 58.1 lists considerations for awarding costs

The AER is responsible for the development of energy projects such as oil, oil sands, natural gas, and coal. This includes allocating and conserving water resources, managing public lands, and protecting the environment in relation to those projects. It shares responsibility with Alberta Environment and Parks (“AEP”) over the environment and specified environmental legislation. The AER’s Rules of Practice provide a detailed list of factors it considers regarding costs.

The purpose of a cost award from the AER is about encouraging participation as much as it is about indemnification. The overarching consideration is whether the costs are reasonable and necessarily related to the hearing in question. As noted in a 2018 article analyzing past AER decisions, the AER is most likely to refuse costs for a scientist or engineer’s contributions on the grounds that these professionals failed to provide a meaningful contribution[2]. The most common reason for reducing a lawyer’s fee, on the other hand, is that the lawyer spent too long preparing.

Public Lands Appeal Board (“PLAB”)

•       Public Lands Act, RSA 2000, c P-40

•       Public Lands Administration Regulation, Alta Reg 187/2011

–      s. 232(1) addresses costs and factors the panel considers when awarding costs (or declining to do so)

The PLAB’s function is to hear appeals regarding decisions by AEP directors on the use of public lands; for example, the issuance or denial of surface dispositions on Crown land. The PLAB has discretion and can award all, none, or partial costs.

The PLAB applies the starting point that each party is responsible for its own costs. It will consider awarding costs when the amounts claimed are directly and primarily related to the preparation and presentation of the party’s submission for the hearing.

The Public Lands Act prevents parties from recovering costs against the Crown. While this has drawbacks, parties can also use this provision to their advantage in the context of stay applications (a stay generally freezes an order pending the outcome of the appeal, when the PLAB will vary, confirm, or reverse the director’s decision). For example, in the King decision,[3] the Director of Regional Compliance issued the company an administrative penalty for allegedly subleasing two Miscellaneous Leases on public land without authorization. The company appealed this decision and requested a stay of the administrative penalty. The Board noted that if the Company was ultimately successful its appeal, it could still not recover costs against the director. On this basis, the Board concluded the company would suffer irreparable harm if it did not receive a stay. Relying on this line of authority could be useful to parties seeking to postpone paying a fine until the appeal has been decided.  

Environmental Appeals Board (“EAB”)

•       Environmental Protection and Enhancement Act, RSA 2000, c E-12

–      s. 96 jurisdiction to award costs

•       Environmental Appeal Board Regulation, Alta Reg 114/1993

–      ss. 18 and 20 factors to consider

•       Rules of Practice

–      R. 33 describes the Board’s approach to costs

The Environmental Appeals Board is an independent board that allows Albertans to appeal various decisions made by AEP, such as issuing industrial approvals, water licences, reclamation certificates, administrative penalties, enforcement orders, and environmental protection orders. The EAB’s starting point is that parties must bear their own costs. Costs must be directly and primarily related to preparation for and presentation at the hearing, and a key factor is a party’s contribution to the hearing.

The EAB has had some interesting new developments recently. For example, in Cherokee Canada Inc. et al v. Director, Regional Compliance, the EAB considered a cost application following the successful appeal of an AEP compliance director’s decision to issue a series of enforcement orders against a brownfield developer and a prior owner of the former industrial site[4]. In its cost decision, the EAB found that the Director’s behaviour in the course of the appeal was improper and sufficiently egregious that it awarded the first costs award against the Director in the EAB’s history. The cost award was also precedent-setting as the total amount, in excess of $1,500,000, was by far the largest ever issued by the EAB.

More recently, on March 31, 2021, the Court of Queen’s Bench released its decision in Brookman v Environment and Parks (Director), 2021 ABQB 249, a judicial review that challenged the EAB’s general approach to costs, and in particular the starting point that parties bear their own costs, among other things. The Court upheld the EAB’s general approach, or “foundational principle”, to costs and found as follows at paragraph 30:

While the advantages of consistency cannot overtake the requirement of reasonableness in either the decision-making process or the decision, in identifying and applying a starting point to its review of costs, the Board did not improperly fetter its discretion. The Reconsideration Panel considered other factors relevant to an award of costs including the level of involvement of counsel in the hearing process, the contributions of the Applicants, and whether the Applicants’ contributions detracted from the focus of the appeal. The Reconsideration Panel’s approach to the exercise of its discretion was framed by the governing legislation and fairly accounted for the policy considerations that bear on an award of costs. It acknowledged the need to create a cost environment that encourages participation, that neither rewards nor punishes participation, that deters vexatious participation, and that recognizes the value of relevant contribution. I see no basis in the reasoning to conclude that the foundational principle articulated by the Board, in theory or as applied, unduly constrained the decision-making process, or that the Reconsideration Panel did not remain live to the possibility of awarding costs if the circumstances merited.

Another interesting EAB matter is the recent Court of Appeal Normtek decision, which has the potential to expand the parties who can seek standing to bring an appeal before the EAB. The potential for increased parties also brings the potential for increased costs. For further information on the Normtek decision, please view our previous blog post here.

Surface Rights Board

•       Surface Rights Act, RSA 2000, c S-24

–      s. 39 addresses costs

The Surface Rights Board helps landowners, occupants and operators resolve surface access and compensation disputes. While companies have a right to access their resources for development, landowners must also be compensated. Board panels have a degree of discretion “so long as costs are incurred in or incidental to proceedings and necessary criteria are met.” Costs must be reasonable, and directly and necessarily related to the proceedings[5]. While the Surface Rights Board does sometimes award interim costs, in one decision it commented that it lacks the statutory discretion to award advance costs.

The Surface Rights Board’s practice is different than many other tribunals in that it will almost always award costs to a landowner, even if not successful in the proceedings. The policy consideration underlying this approach is that the landowners are forced into the process; they have no option to deny the company access to the resources underlying their lands. In addition, there is often a disparity in the means available to an individual landowner as compared to a large resource development (often oil and gas) company. Accordingly, parties can assume that at least some costs will be awarded to a landowner in proceedings before the Surface Rights Board.

Natural Resources Conservation Board (“NRCB”)

•       Natural Resources Conservation Board Act, RSA 2000, c N-3

•       Rules of Practice of the Natural Resources Conservation Board Regulation, Alta Reg 77/2005

–      ss. 25, 28

The NRCB is responsible for reviews of proposed major natural resource projects under the Natural Resources Conservation Board Act, and for the regulation of confined feeding operations in Alberta under the Agricultural Operation Practices Act. The legislation states the Board “may” award costs or intervenor funding, providing it with broad discretion when awarding costs.

Alberta Utilities Commission (“AUC”)

        • Alberta Utilities Commission Act, SA 2007, c A-37.2

–      s. 21, costs of proceedings

–      s. 22, local intervenor costs

The AUC regulates Alberta’s investor-owned electric, gas, water utilities, and certain municipally-owned electric utilities to ensure that customers receive safe and reliable service at just and reasonable rates. The Commission is empowered to award costs, but it is not required to do so. The Commission has its own scale of costs which it applies when awarding costs, though parties can request additional costs for particularly complex matters.

Unlike some other tribunals discussed above, the AUC also has an intervenor funding model that it regularly applies. Intervenor funding is different than a cost award. Intervenor funding is a mechanism where interested parties may apply to the tribunal for funding to participate in the proceedings. Intervenor funding is often (but not always) made available from public funds. Cost awards on the other hand are typically sought at the end of a hearing (however, sometimes they can be sought on an interim basis during the proceedings) and generally to be paid by one party to another.

The AUC’s practice of granting intervenor funding is different than the approach used by some other tribunals, such as the EAB and PLAB, at least in part due to the nature of their respective mandates. The AUC is a regulator and makes decisions to grant various approvals and regulatory authorizations in the first instance. On the other hand, tribunals like the EAB and PLAB are appeal tribunals that do not grant approvals in the first instance, but rather hear appeals of decisions made by governmental officials, where it may be presumed that the initial decision-maker already considered the public interest. Accordingly, the policy considerations are different, which is reflected in the legislative framework and practices of the tribunals.

Impact Assessment Agency (“Agency”)

(formerly the Canada Environmental Assessment Agency)

•       Impact Assessment Act, SC 2019, c 28, s 1

The Agency is a federal body accountable to the Minister of Environment and Climate Change. It leads federal reviews of major resources projects, looking at the environmental, economic, social, and health impacts of these potential projects.

The Agency’s Funding Program is meant to help individuals participate, and to ensure their concerns are taken into account. Funding is not determined per project or activity; rather, it is determined by the level and complexity of activities undertaken with the applicant, either Indigenous groups or the public. The Agency pre-establishes maximum funding levels for many activities so that the same amount is available to each applicant across the country.

Canada Energy Regulator (“CER”)

(formerly the National Energy Board)

•       Canadian Energy Regulator Act, SC 2019, c 28, s 10

–      s. 206

The CER reviews extra-provincial energy development projects. It also enforces safety and environmental standards.

The CER administers a Participant Funding Program (PFP) to facilitate the participation of the public – and, in particular, the Indigenous peoples of Canada and Indigenous organizations – in public hearings under section 52 or subsection 241(3) of the Canadian Energy Regulator Act and any steps leading to those hearings. The program is not intended to cover the full cost of expenses. PFP is administered independently of the public hearing.

Takeaways:

  • Costs before an environmental tribunal do not work the same way as costs before a court;
  • Tribunals often do not follow the ‘loser pays’ principle;
  •  Tribunals are constrained by their legislation, and all have different practices;
  • Contribution to the process is an important consideration; and
  • Costs are highly discretionary and will depend on the particular circumstances of a given matter.

For further information on costs awards work before environmental tribunals, and how this might affect your litigation strategy, please contact Sean Parker, Anna Fitz, or any member of our Energy, Environmental and Regulatory practice group.


[1] The hyperlink to the recorded webinar will be available for 30 days after the publication of this article. 

[2] Shaun Fluker and Erik Dalke, “An Analysis of Costs Awarded by the Alberta Energy Regulator,” 2018 55-3 Alberta Law Review 805

[3] King and Kingdom Properties Ltd. v. Director, Regional Compliance, Lower Athabasca Region, Alberta Environment and Parks, 2020 ABPLAB 3.

[4]  Cherokee  Canada  Inc.  et  al.  v. Director,  Regional  Compliance, Red     Deer-North     Saskatchewan     Region,     Operations     Division,     Alberta Environment and Parks, 2020 ABEAB 10; Appeal Nos. 16-055-056, 17-073-084, and 18-005-010-CD (A.E.A.B.),2020ABEAB 10.

 [5] Canadian Natural Resources Limited v Robb Farms Ltd., 2021 ABSRB 257

Canadian Natural Resources Limited v Flanagan, 2020 ABSRB 908

Montana Alberta Tie Ltd. (Re), 2012 ABSRB 73

 

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