FPSLREB Decisions

Reasons for Decision

Introduction

1 Jasmine Stroz-Breton, the complainant, filed a complaint of abuse of authority concerning the appointment of Kimberley Batten, the appointee, to act in the position of ED-EDS-03 Chief, English Language Curriculum (the EDS-03 position) with the Department of National Defence (DND) in St-Jean-sur-Richelieu, Quebec.

2 It is the complainant’s view that the Deputy Minister of National Defence (the respondent) abused its authority in the choice of a non-advertised appointment process for this appointment and in the application of merit as the appointee was not qualified. The complainant also alleges that the respondent appointed Ms. Batten on the basis of personal favoritism.

3 The respondent denies that an abuse of authority occurred. A non-advertised appointment process was chosen to find a replacement for the incumbent of this position who was going to take maternity leave. The respondent states that the appointee, Ms. Batten, was fully assessed and found to meet the qualifications for the position.

4 The Public Service Commission (PSC) did not appear at the hearing, but presented a written submission in which it discussed relevant PSC policies and guidelines. It took no position on the merits of the complaint.

5 For the reasons that follow, the complaint is dismissed. It has not been established that the respondent abused its authority in this appointment process.

Background

6 The complainant and the appointee occupied positions with DND at the Canadian Forces Language School (the CFLS) in St-Jean-sur-Richelieu, Quebec.

7 The EDS-03 position became vacant when the incumbent, Jacqueline Asselin, commenced a one-year maternity leave in November 2011. The respondent learned of Ms. Asselin’s maternity leave approximately four and a half months prior to the commencement date. The respondent chose to use a non-advertised appointment process to appoint a replacement during Ms. Asselin’s leave.

8 Management decided to look at the five EDS-02 members of the English Curriculum development team. The complainant was not considered for the acting appointment because she is not a member of the English Curriculum development team. She is a teacher at the CFLS in an LAT-01 position and works in the Military Training Cooperation Program division.

9 On October 18, 2011, the Information Regarding Acting Appointment of Ms. Batten was posted on Publiservice.

10 On November 2, 2011, the complainant filed her complaint of abuse of authority with the Public Service Staffing Tribunal (the Tribunal) under s. 77 of the Public Service Employment Act, S.C. 2003, c. 22,ss. 12,13 (PSEA).

Preliminary Matter - Request for an adjournment 

11 Near the completion of the second day of the hearing, the complainant requested an adjournment of the hearing because she suspected that she had not received all the documentation she was entitled to receive from the respondent before the hearing. In its May 24, 2012, letter decision the Tribunal had granted, in part, the complainant’s request for an order for provision of information. The respondent was ordered to provide the complainant with the following information:

All information, documentation and notes that were used by the assessment board for the purposes of determining that the appointee meets the E-1, E-2 and E-4 requirements for the ED-EDS-03 position (11-DND-ACIN-MNTRL-359072), including any specific documentation of the ED-EDS-02 position on which the assessment board based its decision for the ED-EDS-03 position.

12 The complainant submitted on several occasions during the hearing that she should have been provided with the entire EDS-02 file of the manager, Ms. Asselin. The respondent explained that, in accordance with the Tribunal’s order, it had provided the complainant with all the documentation from the EDS-02 file that the assessment board used to determine that the appointee met the requirements of the EDS-03 position.

13 In considering the request for an adjournment, the Tribunal found that the complainant had been provided with the documentation the assessment board had relied on to satisfy itself that the appointee met the essential criteria. Ms. Asselin explained that the assessment board looked at the EDS-02 file to verify whether Ms. Batten met the essential requirement for experience in project management. In order to satisfy itself that she did, the board looked at Ms. Batten’s résumé and Ms. Batten’s reference checks. These documents were exchanged before the hearing.

14 Accordingly, the Tribunal is satisfied that, prior to the hearing, the complainant was provided with all the documentation from the EDS-02 file that was used for the purposes of determining that the appointee met the requirements for the EDS-03 position. Therefore, the complainant’s request for an adjournment was denied.

Issues

15 The Tribunal must determine the following issues:

1. Did the respondent abuse its authority by choosing a non-advertised appointment process?
2. Did the respondent abuse its authority by appointing a person who was not qualified?
3. Did the respondent abuse its authority by demonstrating personal favoritism towards the appointee?

Analysis

16 Section 77(1) of the PSEA provides that a person in the area of recourse may make a complaint to the Tribunal that he or she was not appointed or proposed for appointment because the PSC or the deputy head abused its authority in the appointment process. Although the term “abuse of authority” is not defined in the PSEA, s. 2(4) states that “[f]or greater certainty, a reference in this Act to abuse of authority shall be construed as including bad faith and personal favouritism”.

17 The complainant bears the burden of proof in a complaint of abuse of authority. See Tibbs v. Deputy Minister of National Defence, 2006 PSST 0008, at paras. 48-55.

Issue I: Did the respondent abuse its authority by choosing a non-advertised appointment process?

18 Section 33 of the PSEA provides that “the Commission may use an advertised or non-advertised appointment process”. The PSEA uses permissive language and does not indicate a preference in the choice of process. InJarvo v. Deputy Minister of National Defence, 2011 PSST 0006, at para. 7, the Tribunal considered abuse of authority in the context of choice of process and held that:

Section 33 of the PSEA explicitly permits the use of non-advertised appointment processes. Nevertheless, s. 77(1)(b) of the PSEA provides for a direct challenge of the discretionary choice between an advertised and non-advertised process, on the ground of abuse of authority. The Tribunal has established that merely choosing to conduct a non-advertised process is not an abuse of authority in itself. For a complaint under s. 77(1)(b) of the PSEA to be successful, the complainant must establish, on a balance of probabilities, that the choice to use a non-advertised process was an abuse of authority.

19 Ms. Asselin has occupied the EDS-03 position of Chief, English Language Curriculum since December 2008. In early June 2011, she announced to her supervisor, Eric Reneault, and to the Human Resources (HR) division that she would be taking maternity leave at the end of October. The respondent had approximately four and a half months to find a replacement before her leave started.

20 Information regarding this appointment process was communicated to the five English Curriculum team members in August 2012 during a staff meeting. Ms. Asselin explained that two options were being considered at the time. Either the Chief of French Curriculum would assume responsibility as the English Curriculum team’s supervisor as well, or an English Curriculum team member would be appointed as the team’s supervisor.

21 Ms. Asselin testified that a decision had initially been made to ask the Chief of French Curriculum to take on the additional supervisory and administrative duties of the Chief of English Curriculum position. This option was not chosen for several reasons, including the fact that the project her team was working on required a full-time supervisor to oversee meetings, actual production, coordination with layout and multi-media, quality control and personnel management. Ms. Asselin also testified that the Chief of French Curriculum advised that he was not interested in the expanded duties.

22 Management therefore looked at the five EDS-02 members of the English Curriculum development team to select a person for the EDS-03 position. Of the five team members, it considered that only one member, Ms. Batten, might be qualified. She was assessed against the essential merit criteria listed on the Statement of Merit Criteria (SMC) used for the selection of Ms. Asselin for the EDS-03 position in 2008 and she was found to meet all of the essential merit criteria.

23 Ms. Asselin then sent the following e-mail dated September 12, 2011 to Lieutenant-Colonel Amirault:

As a result […], I would like to see Ms. Kimberley Batten nominated as acting EDS-03. Although this decision will undoubtedly lead to a few questions (as nominations always do), Ms. Batten is the only team member to meet all of the essential merit criteria that we used in the 2008 EDS-03 Chief of English, Curriculum staffing process. This is easily demonstrated and has already been documented…

24 Ms. Asselin testified that, at about the same time she sent her email to Lieutenant-Colonel Amirault, she prepared a written rationale (the rationale) to show how the non-advertised appointment process was the best staffing method to meet the needs of DND and she addressed each of the Public Service appointment values of fairness, access and transparency. She also prepared a written narrative assessment of the proposed appointee.

25 Lieutenant-Colonel Amirault approved the acting appointment two days later, on September 14, 2011.

26 The narrative assessment and rationale were provided to Mr. Reneault for his review. On September 21, 2011, he received the final version of the narrative assessment and he signed it on September 30, 2011. The date on which he received the final version of the rationale was not specified, but he signed it on September 23, 2011.

27 Ms. Asselin indicated in the rationale and during her testimony that there were several reasons why a non-advertised appointment process was chosen. Firstly, an advertised appointment process would have been lengthy, with little chance of filling the position before her departure. In addition, Ms. Asselin had been informed that she may have to commence her leave earlier than anticipated.

28 Secondly, the non-advertised process allowed for an expeditious replacement, which minimized the risk that the English Curriculum development project would be compromised. This project was a complex one that had a 2012 deadline. There were concerns that any delay could impede the Canadian Defence Academy’s ability to provide CF members with equal access to second language education and training learning materials.

29 Thirdly, management wished to provide an opportunity for an English Curriculum team member to have access to a professional development opportunity. In the present case, a member of the English Curriculum Development team, Ms. Batten, met the requirements of the position.

30 Finally, this appointment was for a one-year period only. Thus, management did not find it necessary to proceed with an advertised process. However, it was management’s intention to proceed with an advertised process to fill the position if the incumbent of the position did not return after her maternity leave.

31 Ms. Asselin testified that the option of rotating appointments of individual team members for periods of four months or less was considered. However, it was rejected because it posed a high level of risk to project stability. She also indicated that one of the team members required consistent supervision in terms of performance and was the subject of an action plan. It was deemed best if only one acting EDS-03 supervisor was privy to this protected information.

32 Furthermore, management was aware that a communal pool of qualified individuals who had experience ‘teaching adults’ existed, but it was not used because the SMC used for this pool did not align with the SMC used for the EDS-03 position. The SMC used for the EDS-03 position required experience in project management, supervision and language teaching while those qualifications were not used in assessing the persons in the pool.

33 The rationale for choosing a non-advertised appointment process, as reflected in the testimony of Ms. Asselin, provides a proper justification for the choice of process. The Tribunal is satisfied that a non-advertised process offered better chances of filling Ms. Asselin’s position before her departure. There were also legitimate concerns that the English Curriculum development project would be further delayed if a lengthy advertised appointment process was conducted.

34 Ms. Asselin testified that as Chief of English Curriculum she had extensive knowledge of each of the five team members’ work experience. In her view, Ms. Batten was the only qualified person among the EDS-02 Curriculum Developers in the English Curriculum team. Ms. Batten had been hired as an EDS-02 in the English Curriculum team in 2010. As Ms. Batten was found to meet all of the essential criteria, including supervisor of a team of education or training professionals, HR and management believed it would be inappropriate to formally assess all of the employees in the work unit as they knew from the outset that only one employee in the English Curriculum development team qualified.

35 Mr. Reneault stated that, based on his discussions with Ms. Asselin and his review of the working copies of the rationale and narrative assessment for the acting appointment, he was satisfied that Ms. Batten was qualified and that a non-advertised appointment process was more appropriate in these particular circumstances. He explained in his testimony that the choice of Ms. Batten was not made until it was shown that she met the essential qualifications for the position. He further clarified, during cross-examination, that draft documentation of the rationale and narrative assessment had been circulated to management before the appointment was approved by Lieutenant-Colonel Amirault on September 14, 2011.

36 After September 14, 2011, team members were notified in person that Ms. Batten would be appointed to act in the EDS-03 on the basis that she met the essential criteria for the position.

37  Helen Pohl, who has been a Curriculum Developer at the CFLS since January 2000, testified that she was told on September 19, 2011, that Ms. Batten would be replacing Ms. Asselin. Ms. Asselin explained to Ms. Pohl that the five Curriculum Developers were considered, but that only Ms. Batten met all of the essential criteria. Ms. Pohl disapproved of the choice made, but did not tell Ms. Asselin that she would have been interested in the acting appointment.

38 Approximately two weeks later, on September 30, 2011, Ms. Pohl sent an email to Ms. Asselin indicating that she would like to go on record as expressing her interest in an acting appointment to the EDS-03 during Ms. Asselin’s maternity leave.

39 On October 4, 2011, Ms. Asselin replied by email to Ms. Pohl. Part of the email reads as follows:

During a meeting with you on September 19^th 2011, I explained that Ms. Kimberley Batten would be appointed acting EDS-03 for the duration of my maternity leave. I further explained that all 5 EDS-02 English Curriculum developers, yourself included, had been considered for the appointment. That said, only one developer, Ms. Batten, met all of the essential criteria associated to the Chief of English Curriculum position, which requires significant and recent supervisory experience as well as recent ESL teaching experience.

40 Ms. Pohl did not file a complaint with the Tribunal regarding this acting appointment. However, Ms. Pohl testified at the hearing that she had experience acting in the EDS-03 position from November 2003 to February 2004. She was not interested in a permanent career change, but was interested in developing her expertise in small projects.

41 The complainant submits that the appointment of Ms. Batten is flawed because Lieutenant-Colonel Amirault had not seen the final versions of the rationale and the narrative assessment when he approved the appointment on September 14, 2011.

42 The evidence shows that although these documents had not been finalized, they were being prepared at the time of the appointment. Drafts of the documents had been provided to management prior to the appointment and Lieutenant-Colonel Amirault was aware of the situation and much of the detail as a result of Ms. Asselin’s email of September 12, 2011. The documents were signed on September 23 and 30, 2011, that is, a few days after Lieutenant-Colonel Amirault signed the appointment on September 14, 2011.

43 The Tribunal finds that the substance of both the rationale and the assessment were formulated prior to the appointment. The complainant has failed to demonstrate how finalizing the documents after September 14, 2011, in and of itself, constitutes an abuse of authority in this case.

44 The complainant also submits that by choosing a non-advertised appointment process, the respondent did not respect the values of fairness and transparency, as set out in the Public Service Commission Appointment Policy. In addition to arguing that the written rationale failed to properly address fairness and transparency, the complainant testified that this process was unfair, essentially because she did not have the opportunity to apply for the position.

45 The Tribunal addressed this argument in Jarvo. The Tribunal held in Jarvo, at para. 35:

…Under the PSEA, non-advertised appointment processes are not unfair merely because they eliminate the opportunity for employees to apply; that is the essence of their nature. Given the very nature of a non-advertised appointment process, the lack of opportunity to apply cannot reasonably be the basis for determining an absence of fairness.

46 The Tribunal also found in Jarvo, at para. 28, that in the context of staffing in the public service, one cannot consider fairness through the narrow lens of one individual’s perspective:

…To make objective appointment decisions, delegated managers must consider several perspectives and seek to balance often competing interests when they consider the options available to them to staff a position. It could be said that a manager needs to consider fairness from several perspectives, knowing that the decision is unlikely to be perceived as fair by everyone.

47 Thus, even though the complainant did not have the opportunity to apply for the position, the Tribunal is satisfied that the non-advertised appointment process was fair. The Tribunal is satisfied that the choice of process was made objectively and with the idea of finding, without delay, a qualified person to replace Ms. Asselin while she was scheduled to be on leave.

48 Furthermore, the written rationale in this case deals directly with fairness and transparency. With respect to fairness, the rationale states that in order to select a candidate in the most objective manner, and in the hopes of offering a professional development opportunity to a current member of the English Curriculum Development team, management chose to consider all five members of the team.

49 As for transparency, the rationale states:

Information regarding this appointment process was communicated to all team members on an individual basis in the three months leading up to the appointment. The Chief of English Curriculum explained to each team member that two options were being considered with regard to staffing the EDS-03 position: either, option a) the informal selection of the Chief of French Curriculum as team administrator/coordinator or option b) the appointment of an English Curriculum team member.

50 The Tribunal is satisfied that, in addition to being fair, the non-advertised appointment process was also transparent. The respondent communicated the information about the process in an open and timely manner to the English Curriculum team members. It proceeded accordingly in order to appoint a person before Ms. Asselin’s departure. See Jarvo, at para. 27.

51 The Tribunal therefore finds that the rationale for choosing a non-advertised appointment process properly explains how the staffing values of fairness and transparencyhad been met in proceeding by way of a non-advertised process.

52 In conclusion, the Tribunal finds that the complainant has not demonstrated that the respondent abused its authority in choosing to use a non-advertised appointment process.

Issue II: Did the respondent abuse its authority by appointing a person who was not qualified?

53 Section 36 of the PSEA provides that a deputy head may use any assessment method that it considers appropriate to determine whether a person meets the qualifications. The respondent has broad discretion to determine the assessment methods to be used. In the present case, the complainant has not established that the tools used by Ms. Asselin were inadequate for a thorough assessment of Ms. Batten’s qualifications for the EDS-03 position.

54 Danielle Moffet, President of Local 10377 of the Agriculture Union of the Public Service Alliance of Canada, testified that in her capacity as Local President, she asked several questions regarding the staffing of the position and was not satisfied that Ms. Batten met three essential experience qualifications for the EDS-03 position. She stated that, in her opinion, the circumstances here were akin to those in the decision of the Tribunal in Ayotte v. Deputy Minister of National Defence, 2009 PSST 0021.

55 The facts in the Ayotte decision differ significantly from the facts in this case. In the Ayotte decision, the appointee in a non-advertised process lacked one of the qualifications and the respondent tailored the SMC to favour the appointee.

56 In the present case, for the reasons that follow, it has not been established that the respondent abused its authority in the application of merit. The SMC was not tailored for the appointee. The evidence shows that it was the same one used in an EDS-03 appointment process in 2008.

57 The appointee’s qualifications were assessed by Ms. Asselin who testified that she had daily contact in the workplace with Ms. Batten. She supervised Ms. Batten’s work in the English Curriculum development section, and observed that she was doing an excellent job. She added that Ms. Batten demonstrated superior organizational and interpersonal skills and enthusiasm about the project on which she was working.

58 The information Ms. Asselin used to assess Ms. Batten included her own assessment of Ms. Batten in the workplace, Ms. Batten’s résumé, information from two reference checks obtained when Ms. Batten was hired as a Curriculum Developer in 2010, and clarifications provided to Ms. Asselin by Ms. Batten in an email dated September 9, 2011, regarding her experience in project management and teaching.

59 Using the same essential criteria listed on the SMC that served for her appointment as Chief of English Curriculum in 2008, Ms. Asselin assessed Ms. Batten and found that she met all of the qualifications for the EDS-03 position. Ms. Asselin recorded the results in the narrative assessment document, listing the merit criteria and how Ms. Batten met them. The narrative assessment was presented to Mr. Reneault with the rationale for choosing a non-advertised appointment process.

60 The complainant submits that Ms. Batten did not meet three essential experience qualifications for the EDS-03 position, specifically E-1: Significant work experience as supervisor of a team of education or training professionals, E-2: Significant experience in project management in the field of education or training, and E-4: Significant and recent experience in the field of teaching English as a second language and/or foreign language to adults.

61 The complainant extensively questioned Ms. Asselin about her assessment of Ms. Batten’s experience in these three fields. Ms. Asselin explained in detail the work performed by Ms. Batten that satisfied these requirements.

62 With respect to significant work experience as supervisor of a team of education or training professionals for the required minimum period of at least one year within the last three years, Ms. Asselin testified that her conclusion that Ms. Batten met this merit criterion was based on Ms. Batten’s résumé, which was corroborated by the reference checks.

63 With respect to significant experience in project management in the field of education or training which had to be in the last five years, Ms. Asselin testified that her conclusion that Ms. Batten met this merit criterion was based on Ms. Batten’s résumé and the clarifications obtained from Ms. Batten on September 9, 2011.

64 The complainant also questioned Ms. Asselin about her assessment of Ms. Batten’s experience in the field of teaching English for the required minimum period of two years within the last ten years. Linda Chroniak, who worked with Ms. Batten from 1997 to 2009 in a private language school before Ms. Batten joined the public service, testified that as a manager of the private language school, Ms. Batten did not teach full time. She testified that she taught for approximately 100 hours per year. The complainant submitted that this was evidence that Ms. Batten did not have experience in the field of teaching English for the required minimum period of two years within the last ten years.

65 Ms. Asselin testified that her conclusion that Ms. Batten met this merit criterion was based on her personal knowledge, information she had received from Ms. Batten’s two references who had confirmed the extent and the duration of her experience in teaching, and the clarifications Ms. Batten had provided in her email dated September 9, 2011. She explained that this information clearly demonstrated that Ms. Batten hadexperience in the field of teaching English as a second language for the required minimum period of two years within the last ten years. In particular, Ms. Batten had taught English as a second language teacher (LAT-01) at the CFLS for a full year in 2009-2010 and had been a part-time teacher for the balance of the 10 year period. In her view, this met the experience requirement.

66 The complainant referred the Tribunal to the collective agreement between Treasury Board and the Public Service Alliance of Canada for the Education and Library Science group. The rate of pay of the employees in the Education group depends on their years of service. The collective agreement provides, in calculating the rate of pay, that a full year of experience prior to appointment will be credited to the employee for teaching 400 hours of second language either at night school or on some other part-time basis. The complainant argues that since itwas not clearthat Ms.Battenhad accumulated 800 hours ofteaching, i.e., the equivalent of two full academic years of teaching, the respondent abused its authority and did not make an appointment based on merit.

67 The SMC used for this appointment process did not requirea specific number ofteaching hours. Itrequired experience in the field of teaching English as a second language for a minimum period of two years within the last ten years.Essentially, the criterion required a cumulative total of two years in the past ten years. The evidence demonstrates that Ms. Batten hadexperience in the field of teaching English as a second language for the required minimum period of two years within the last ten years because she taught English full-time in 2009-2010 and part-time for the balance of the 10 year period.

68 The Tribunal therefore finds that the complainant has not established any abuse of authority in the assessment of Ms. Batten’s experience.

69 The complainant also submits that the respondent did not properly assess the other Curriculum Developers for the position to be staffed. According to the complainant, other employees were equally, if not more, qualified than the appointee because they have many years of experience at the CFLS.

70 In accordance with s. 30(4) of the PSEA, there is no requirement to consider more than one person in making an appointment. Nevertheless, Ms. Asselin did turn her mind to each of the five members of the English Curriculum development team, but found that only Ms. Batten possessed the essential experience qualifications. Accordingly, the respondent chose to appoint Ms. Batten using a non-advertised appointment process. This decision falls within s. 30(4) of the PSEA and the Tribunal finds no abuse of authority in the respondent’s actions. Whether another employee might be as qualified or more qualified, a manager is not required to appoint the most qualified person. The PSEA gives managers considerable discretion in choosing the person who meets the essential qualifications and who is the right fit for the position. See Clout v. Deputy Minister of Public Safety and Emergency Preparedness, 2008 PSST 0022 at paras. 30-32.

71 Based on the evidence, the Tribunal concludes that the complainant has failed to prove on a balance of probabilities that the respondent abused its authority in its determination that Ms. Batten met the merit criteria for the EDS-03 position.

Issue III: Did the respondent abuse its authority by demonstrating personal favoritism towards the appointee?

72 The complainant submits that the respondent personally favoured Ms. Batten in this staffing process.

73 As noted by the Tribunal in Glasgow v. Deputy Minister of Public Works and Government Services Canada, 2008 PSST 0007, at para. 41:

…The selection should never be for reasons of personal favouritism. Undue personal interests, such as a personal relationship between the person selecting and the appointee should never be the reason for appointing a person. Similarly, the selection of a person as a personal favour, or to gain personal favour with someone else, would be another example of personal favouritism.

74 The complainant argues that Ms. Asselin demonstrated personal favouritism towards Ms. Batten because they worked closely together. The complainant observed, during her regular visits to the English Curriculum section, that Ms. Batten was often in Ms. Asselin’s office.

75 Ms. Pohl testified that Ms. Asselin worked closely with two of her team members, including Ms. Batten, and gave them more prominent roles. She also testified that she had seen Ms. Asselin and Ms. Batten having lunch together one day during an event that involved all of the Curriculum Developers.

76 Ms. Moffet, Ms. Pohl and the complainant all testified that they feel disadvantaged compared to others because they have roles with the union.

77 Ms. Asselin testified that she treated all her employees equally. She also described the lunch she had with Ms. Batten. She added that she had sent an invitation to all the English Curriculum team members, but that only Ms. Batten had accepted. She explained that while she and Ms. Batten got along well at work,they only had a professional relationshipandhad neverhad any contactoutsideof the office.

78 The Tribunal finds that the complainant has presented no evidence that personal favouritism was a factor in the appointment of Ms. Batten. There is no evidence of the existence of a personal relationship between the appointee and Ms. Asselin that could have affected the appointment process. The Tribunal therefore concludes that the complainant has failed to prove that the respondent abused its authority based on personal favouritism.

Decision

72        For these reasons, the complaint is dismissed.

Nathalie Daigle
Member

Parties of Record

Tribunal Files:

2011-1072

Style of Cause:

Jasmine Stroz-Breton and the Deputy Minister of National Defence

Hearing:

February 5, 6 and 13, 2013
Montreal, QC

Date of Reasons:

April 25, 2013

APPEARANCES:

For the complainant:

Elaine Massie
Danielle Moffet

For the respondent:

Vanessa Reshitnyk

For the Public
Service Commission:

Trish Heffernan
(written submission)