Licence Appeal Tribunal
Tribunal File Numbers: 18-006473/AABS, 18-006682/AABS
In the matter of an Application pursuant to subsection 280(2) of the Insurance Act, R.S.O. 1990, c. I.8, in relation to statutory accident benefits
Between:
M.C. and M.C.
Applicants
and
Pembridge Insurance Company
Respondent
DECISION
ADJUDICATOR:
Craig Mazerolle
APPEARANCES:
For the Applicants:
Joseph Obagi and John Lundrigan, Counsels
For the Respondent:
David Murray, Counsel
Hearing Held In-Person:
April 30 – May 2 and May 29, 2019
OVERVIEW
1The present case is a peculiar one, as I must consider the merit of two houses that will never exist. That is, in response to impairments brought on by an accident on May 18, 2015, the parties put forward competing plans for home modifications payable under the Statutory Accident Benefits Schedule (the “Schedule”).1 The costs of both plans were found to outpace the cost of building a new residence, so neither renovation materialized. Instead, a new home has been constructed for the applicants, and so the Tribunal is now being asked to determine how much the respondent must pay to help cover these costs.
2The applicants also alleged that the respondent unreasonably withheld payments, such that they are entitled to an award under s. 10 of Regulation 664.
3I have concluded that the applicants’ proposed housing modifications are reasonable and necessary. I have also concluded that the applicants are entitled to an award amounting to 25% of the value of the disputed back-up generator (inclusive of HST and interest in accordance with s. 10 of Regulation 664).
HOME MODIFICATIONS AND S. 16 OF THE SCHEDULE
4Entitlement to rehabilitation benefits is determined under s. 16 of the Schedule. An applicant has the onus of demonstrating—on a balance of probabilities—that the rehabilitation expenses listed in a treatment plan are reasonable and necessary for the purpose of “reducing or eliminating the effects of any disability resulting from the [accident-related] impairment or to facilitate the person’s reintegration into his or her family, the rest of society and the labour market.”
5Section 16(3)(i) defines home modifications as follows:
home modifications and home devices, including communications aids, to accommodate the needs of the insured person, or the purchase of a new home if it is more reasonable to purchase a new home to accommodate the needs of the insured person than to renovate his or her existing home
6Section 16(4)(c) then limits an insurer’s obligation to pay for this type of benefit:
[An insurer] is not liable to pay…for the purchase of a new home in excess of the value of the renovations to the insured person’s existing home that would be required to accommodate the needs of the insured person…
7Put another way, an insurer’s payment toward the construction of a new house shall be no greater than the cost of the renovations that would have been needed to accommodate an applicant’s impairments in her or his pre-accident household. As such, this present dispute is based on the disparity between the values of the parties’ proposed home modification plans.
PARTIES’ COMPETING PROPOSALS
8On May 18, 2015, the applicants—a married couple in their late 50s and early 60s—were involved in a motorcycle accident that required the amputation of significant portions of their right legs. The couple continues to struggle with the lasting effects of this accident, but—as evidenced at the hearing—they have made commendable advances in adapting to these new circumstances, including their usage of prosthetic legs and wheelchairs.
9To help meet these new mobility needs, the applicants decided that they required modifications to their pre-accident home—a one-storey, bungalow-style house in rural Ontario. Therefore, the couple worked with their occupational therapist, Elaine Marchand Shepherd, to hire an accessible construction expert, Scott Puddicombe, to develop a new house design (the “Puddicombe Plan”).
Applicants’ Proposal – The Puddicombe Plan
10As detailed in his initial report (dated April 4, 2016), the Puddicombe Plan envisioned that hallways, rooms, and entrances/exits would all be enlarged to accommodate the couple’s wheelchairs. Or, as Mr. Puddicombe wrote: “The existing floor plate of the home does not have sufficient space to accommodate the use of 2 wheelchairs simultaneously without significantly compromising many of the existing areas of the home.” This lack of space would, therefore, be remedied by building out the existing ground floor—a set of modifications that would maintain the bungalow-style layout of their pre-accident home. In fact, as Mr. Puddicombe mentioned in his testimony to the Tribunal: “My goal is allow a person to get as close to their pre-accident lifestyle as possible within what’s possible with the structure.”
11The Puddicombe Plan also included the construction of a covered, one-car garage, as well an extended, uncovered driveway that would accommodate the second family vehicle. A lift would connect the main floor to the new garage and the pre-existing basement.
12To ensure at least one means of egress would be non-mechanical, Mr. Puddicombe proposed that the front door would be equipped with a ramp. The back entrance would have a mechanical lift.
13There would also be several smaller modifications (including perimeter and path lighting and a laundry unit attached to the master bedroom) as further means of increasing mobility and ease of access for the applicants.
14Finally, this Puddicombe Plan called for the purchase of a back-up generator at a cost of $10,000.00 (plus HST), an expense he justified in his rebuttal report (dated October 24, 2017). He reasoned that, due to the high likelihood of power outages in rural locales, a back-up generator would ensure that the couple always had reliable use of the house’s lifts and prosthetic charging devices.
15Due to the dislocation caused by these renovations, Mr. Puddicombe then budgeted $12,000.00, so that the couple could rent alternative accommodations for six months at $2,000.00 per month. According to his testimony, this monthly amount was an estimate based on his professional experience.
16The total cost of the Puddicombe Plan came to $557,090.00.
17The applicants asked the respondent to fund these modifications in two identical treatment plans, dated June 14, 2016.
18On April 21, 2017, the respondent informed the applicants that it would partially approve these treatment plans. That is, in accordance with a plan produced by accessibility consultant Randy Sora (the “Sora Plan”), the respondent agreed to pay the applicants $483,960.00.
Respondent’s Proposal – The Two Sora Plans
19As became apparent during the hearing, the Sora Plan can be best described by the way it differs from the Puddicombe Plan. That is, while both Plans expand the interior space of the home to allow for wheelchair access, the Sora Plan differs from the Puddicombe Plan in several major respects.
20First, by relying on the findings of the respondent’s occupational therapist, Tracie Shaw, the Sora Plan is premised on the idea that a two-car garage is essential for the well-being of the applicants. Briefly, she testified that the couple complained about being homebound following the accident, so she wanted to ensure that they could both safely and easily leave the house to engage in community activities (e.g., the wife’s volunteer work). In light of this accident-related need, the house required safe and covered access for both family vehicles.
21Second, in contrast to the Puddicombe Plan, the Sora Plan does away with the bungalow-style design of the family’s original house, as the size of the property meant that a two-car garage and larger, wheelchair-accessible rooms could not be contained in a single storey. Put another way, Mr. Sora testified that he had to not only build out, but up.
22Third, both the front and back doors would be equipped with mechanical lifts in the Sora Plan. During his testimony, Mr. Sora explained that a non-mechanical ramp requires excessive maintenance during the winter, namely, snow removal.
23Fourth, the Sora Plan recognized the need for alternative accommodation, but Mr. Sora only budgeted $6,000.00.
24Fifth, Mr. Sora proposed a different estimate for project management fees than Mr. Puddicombe, i.e., 6% of construction related costs vs. 10% of the total project value, respectively.
25Finally, the Sora Plan did not include a back-up generator, and he instead envisioned using lifts that would have integrated batteries (thereby allowing for a few uses during a power outage).
26In response to criticisms from Mr. Puddicombe (as detailed in his aforementioned rebuttal report), Mr. Sora proposed a second layout for the house (the “Second Sora Plan”, dated April 6, 2018). Briefly, Mr. Sora accepted that his original Plan could be modified to allow for a non-mechanical ramp off the front entrance. Then, even though the Second Sora Plan maintained a two-storey layout, Mr. Sora conceded that the applicants’ master bedroom and bathroom could remain on the main floor (with the other bedrooms and family bathroom moving to the new, second floor). Finally, by citing the limited number of power outages in the area (as well as the possible use of prosthetic legs in an emergency), Mr. Sora maintained his denial of the back-up generator.
27The respondent provided the Second Sora Plan to the applicants under a covering letter dated April 17, 2018. The respondent maintained its earlier position on the Puddicombe Plan, though it was open to considering the modifications proposed in the Second Sora Plan (with a $7,000.00 reduction in their agreed payment, if the applicants chose the cheaper, non-mechanical ramp off the front entrance).
Current Dispute
28According to the Tribunal’s orders from Vice Chair Kershaw (both dated November 21, 2018), the difference between the Plans amounted to $73,130.00 when the hearing was first set.
29However, during the final day of the hearing, the respondent changed its position on the back-up generator. It also conceded that it had to recalculate some of the cost estimates made by Mr. Sora, i.e., he used Toronto prices for his estimates, when he should have relied on the more expensive rates for construction outside of Toronto. Taken together, the respondent issued the applicants an additional payment of $55,939.50 on May 28, 2019 (with interest bringing the total payment to $67,684.54). Excluding the interest in this payment, the amount in dispute between the two Plans is now $17,190.50.
PARTIES’ POSITIONS
30The applicants argued that there was no dispute that they required a home that could accommodate two wheelchairs. Therefore, when the respondent received a plan that reasonably met this need, it should have been approved. Further, none of the parties’ experts disagreed that a one-storey house is preferable to a two-storey design when you are working with individuals with mobility needs.
31The respondent contended that the applicants have failed to meet their evidentiary onus. Specifically, the respondent submitted that only an occupational therapist can provide an expert opinion about one’s impairments and the modifications needed to address those challenges. Since the applicants’ occupational therapist did not comment on their proposed housing modifications, the only expert opinion I have is from Ms. Shaw who—in the words of respondent’s counsel—found a two-car garage was needed “to reintegrate [the applicants] into society and to ameliorate the impairments they are left with”.
32Further, the respondent added that one of the applicants asked for a two-car garage during the meeting with Ms. Shaw, so it is incorrect to say that this modification was solely the respondent’s idea.
33Finally, in regard to interest, the respondent argued that s. 38(15) of the Schedule requires an invoice to be submitted to an insurer before it can be said that an amount is overdue. Since no invoice has been produced by the applicant, there are no amounts overdue. The respondent also alleged that there is no evidence that the respondent was late in paying the amount it agreed to cover for the construction of their new house.
ANALYSIS
34Though the amounts in dispute are often far greater than other rehabilitation benefits, the analysis used to determine whether a home modification is payable remains the same. That is, the proposed modifications are compared with an applicant’s accident-related impairments to determine whether the expenses are reasonable and necessary.
35This analysis must also consider the specific purpose of rehabilitation benefits, as enumerated in s. 16 of the Schedule, i.e., “reducing or eliminating the effects of any disability resulting from the [accident-related] impairment or to facilitate the person’s reintegration into his or her family, the rest of society and the labour market.”
Applicants’ Accident-Related Impairments
36The applicants’ accident-related impairments are well documented and largely accepted by both parties. Specifically, the amputation of the applicants’ lower right legs (and the corresponding need for assistive devices) significantly affect their ability to navigate their home and community.
37Though the couple has made significant progress in adapting to their prosthetic legs, they are still dependant on their wheelchairs. In particular, due to some setbacks in her recovery, there are days when the wife is unable to wear her prosthetic leg at all. Then, for the husband, even though he is now able to wear his prosthetic leg for long periods every day, there are still times when he needs to use his wheelchair.
38Therefore, I conclude that—to meet the standard under s. 16 of the Schedule—the home modifications need to allow both applicants to use their wheelchairs to freely move throughout their pre-accident house at the same time.
Application to the Present Dispute
39As established through the evidence presented to the Tribunal, Mr. Puddicombe sought to develop a layout that would allow the applicants to accommodate their new mobility needs in a manner that mirrored the living conditions they appreciated in their original home. That is, with the one-storey layout of the house being preserved in the Puddicombe Plan, the applicants were able to retain an essential aspect of their pre-accident lifestyle—all the while meeting the needs of a two-wheelchair household. Though the respondent is correct in arguing that the test under the Schedule is one of needs, not preferences, I accept that a plan which meets both (all without proposing excessive costs) is necessary and reasonable.
40This conclusion does not ignore the potential safety issues that could have arisen with a one-car garage. For instance, in her Assessment of Attendant Care Needs Report for the husband (dated April 25, 2016), the couple’s occupational therapist noted that he had “reported two falls on ice in his driveway…due to loss of control of his prosthetic leg” during the previous winter. In fact, while speaking with Ms. Shaw, the husband described falling as “[o]ne of the worst fears I have” (report dated February 1, 2017).
41Further, since the husband drives to work, work days during the winter may pose an extra challenge for the wife when she wants to access the second family vehicle.
42However, a balancing act is needed when home modifications are considered, because there is no perfect design that will fully address an applicant’s list of accident-related needs. Therefore, the trade-off for this smaller garage must be weighed against the ability of the applicants to access their bedroom, kitchen, and main floor bathroom without the need for a lift. With this framework in mind, it was reasonable for the applicants to choose a layout that allowed for easy access to amenities they both needed for daily living, as opposed to one that addressed the occasional hardship they might have faced when they both wanted to leave the house (going to different places) during inclement weather.
43I would also add that, as noted in Ms. Shepherd’s Assessment Report (dated July 31, 2018), the wife tends to avoid driving in inclement weather.
44Mr. Puddicombe’s rebuttal report also raises an important point about future lift maintenance becoming a significant barrier to the applicants:
In these periods when the elevator is out of service, which could be as short as a day and as long as a week, [the applicants] will be forced to climb a full staircase with their prosthetic legs, which is not recommended by their occupational therapist, in order to access their bedroom and bathroom or, if reliant on a wheelchair at that time, will be unable to access their bedroom or bathroom for up to a week at a time.
45In addition to the health and safety concerns raised by Mr. Puddicombe, these extended periods of lift maintenance would also limit the applicants’ ability to choose whether to use their wheelchairs as opposed to their prosthetic legs. I do not find that removing the ability of the applicants and their healthcare providers to choose how they will accommodate their accident-related mobility needs is in line with purposes described in s. 16 of the Schedule.
46Mr. Sora addressed this concern in his Second Plan, as he found that regular service on the lifts would “provide uninterrupted service for years to come.” He also relied on findings from Ms. Shepherd that the husband had returned to full time work in July 2017 at a work site with multiple staircases. I do not find this response convincing, as it does not address the emergency situations that Mr. Puddicombe was envisioning. That is, Mr. Puddicombe was not concerned about the applicants when there is a functioning lift, nor is there is a concern at work when he has time to navigate the stairs. Rather, he was concerned about how the applicants will manage a two-storey house when there is an emergency requiring them to evacuate post haste.
47The husband’s testimony also challenged the premise of Mr. Sora’s response, as he requires assistance when working particular shifts, because he, in his words, cannot “quickly enough… evacuate on my own.”
48Additionally, as noted by Mr. Puddicombe in his testimony, a two-storey layout will ensure greater wear and tear on the indoor lift. Therefore, even if the applicants’ bedroom is left on the main floor in the Second Sora Plan, there will still be more need for maintenance and replacements of the indoor lift in the years to come, because a second floor will require more usage of this device.
49Similar concerns can be raised with Mr. Sora’s initial preference for both entrances to be equipped with a mechanical lift. As such, I accept the necessity of one non-mechanical entrance and exit (as proposed by Mr. Puddicombe).
50Finally, I am satisfied that the retention of a bungalow-style floorplan was important to the applicants, as it was a central consideration in the original design of their pre-accident house. Section 16 of the Schedule does not specifically mention an applicant’s preferences as one of the goals of rehabilitation, but it is not a far stretch to say that the family home is an integral part of how an individual interacts with his or her loved ones. As such, it is then reasonable to infer that—in the present case—the goal of facilitating “the person’s reintegration into his or her family” is best met by maintaining a fundamental aspect of the pre-accident home and, by extension, the family’s pre-accident lifestyle.
Respondent’s Arguments
51By concluding that the applicants have put forward a reasonable and necessary set of home modifications, I can then turn to the respondent’s arguments.
52First, I find that the applicants have, in fact, met their evidentiary burden. While Ms. Shepherd’s Reports do not specifically address the modifications proposed in the Puddicombe Plan, her commentary about the couple’s needs and abilities still allow me to understand whether they are reasonable and necessary. For example, in her April 25, 2016 Report, she commented on how “there is restricted space in the master bedroom and hallways for two individuals in wheelchairs to move quickly and efficiently”, a situation that increases the chances of night time emergencies. In this same report, Ms. Shepherd further concluded that “attendant care needs…will decrease when home accessibility barriers are eliminated.”
53I also do not accept the respondent’s argument that these amounts never came due under s. 38(15) of the Schedule. As noted at the start of the decision, this dispute involves two competing sets of hypothetical home modifications. Therefore, to require an invoice is not feasible in the present dispute, especially since the respondent received documentation detailing the construction of the applicants’ new home.
54Finally, the respondent argued that, when applying the reasonable and necessary analysis, I should consider each element of the Plans. That is, it is not enough for me to say that one Plan is superior to the other, but rather my analysis must determine which of the two proposed kitchens, garages, etc. are best.
55The two Plans before me both envision a complete restructuring of the applicants’ pre-accident house. Aside from a few, discrete items (like the back-up generator and the allowance for alternate accommodations), it is not reasonable to conclude that an element of one Plan could be simply added to the other. For instance, how could the Puddicombe Plan function if I found that the house required a two-storey design as proposed by Mr. Sora? The parties’ Plans are holistic proposals that—for the most part—cannot be split into their constituent parts.
56Therefore, in this case, it is not a question of comparing each Plan’s proposed kitchens, bedrooms, etc. to see which version is more reasonable and necessary. Rather, by accepting the necessity of a bungalow-style house, I am then satisfied that the other housing modifications proposed in response to this overall layout are reasonable and necessary. That is, as described above, the Puddicombe Plan satisfied much of the applicants’ new mobility needs by expanding the rooms and doorways throughout the main floor of the original house, all the while building in amenities and lifts that would ensure safety and accessibility.
Reasonable Expenses
57I would then note that I do not find the additional costs proposed in the Puddicombe Plan to be excessive. Beyond the fact that the difference between the parties’ Plans have shrunk considerably since the start of this proceeding, I accept the reasoning provided by Mr. Puddicombe for why his proposed expansion of the pre-existing floor plan would have been more expensive than building a second storey. That is, new construction includes expenses not needed when building on top of a pre-existing structure, namely the “significant cost” of a new foundation.
58I also find the standalone elements of the project management fees and the alternative accommodations are reasonably priced as well. First, considering Mr. Puddicombe’s testimony about what is involved at this stage of the project, I did not find the difference between his estimate of the project management fees to be excessive when compared to Mr. Sora’s estimate. Then, considering the need for the applicants to rent temporary housing that would accommodate their mobility needs (as opposed to any available rental unit on the market), I accept Mr. Puddicombe’s higher estimate of $12,000.00.
AWARD
59Section 10 of Regulation 664 permits the Tribunal to “award a lump sum of up to 50 per cent of the amount to which the person was entitled at the time of the award together with interest on all amounts then owing to the insured” if the Tribunal “finds that an insurer has unreasonably withheld or delayed payments”.
60The applicants submitted that the respondent engaged in a pattern of improper conduct that should entitle them to a 50% award, especially since they are from a vulnerable population protected by the Human Rights Code.2 First, they argued that the Sora Plans proposed putting them in harm’s way, e.g., if an emergency coincided with a power outage, the lack of a non-mechanical exit would have required them to wait for first responders. Second, there were significant delays in obtaining the respondent’s expert reports—delays that required them to reside in a house that did not meet their needs. Finally, the applicants argued that it was simply incorrect to deny them the back-up generator, regardless of what Mr. Sora concluded.
61As part of the award, the applicants have also requested that interest be awarded “at 24 per cent per annum compounded monthly from June 14, 2016 to the date of [the Tribunal’s] decision.”
62Therefore, according to the applicants, if the total of the original disputed amount (i.e., $73,130.00) is combined with the interest owing to the date of the hearing (i.e., which they estimated to be approximately $75,000.00), the respondent has withheld approximately $150,000.00. As such, they are entitled to a 50% award totalling $75,000.00.
63In addition to stating that it acted in a reasonable and honest manner, the respondent again relied on its earlier argument that the payments in dispute have not come due in accordance with the Schedule, namely, there was never any invoice produced by the applicants.
64Even though I accepted the applicants’ proposed modifications over the respondent’s, perfection is not the standard for measuring the reasonableness of an insurer’s actions. As such, I am largely satisfied that the respondent took adequate steps to determine the reasonable and necessary nature of the Puddicombe Plan, namely through its decision to obtain multiple expert opinions from Mr. Sora and Ms. Shaw.
65I am also satisfied that the period of time the respondent took to obtain these professional opinions was warranted in this case. As Mr. Sora testified, he experienced significant challenges in developing what he believed to be a viable layout. He also had to address two treatment plans proposing identical changes to the house. Therefore, while I recognize that the applicants had to stay in a house that did not address their mobility needs for an extended period of time, I do not find the delay between Ms. Shaw and Mr. Sora’s in-home assessment on October 25, 2016 and release of their report on February 15, 2017 to be unreasonable.
66I also do not find the delay unreasonable between Mr. Puddicombe’s rebuttal report on October 24, 2017 and the release of the Second Sora Plan on April 17, 2018. My understanding is that this rebuttal report was not referred back to Ms. Shaw and Mr. Sora until February 2018. Though this delay on the insurer’s part is questionable, I do not find it rises to the level of unreasonable withholding requiring an award. Furthermore, once the assessors had the applicants’ rebuttal report, they released their response within a short period of time.
67However, even considering these findings, I still find that the respondent’s initial denial of the back-up generator was an unreasonable delay of this payment. While it is often defensible for an insurer to accept the conclusions of their assessors, there are situations where an insurer’s ever-present discretion should be used to approve benefits where an expert opinion is found to be lacking. That is, regardless of how many reports it may obtain, an insurer ultimately makes the final decision whether to pay a benefit. I have found that this present case is one where the respondent’s discretion should have been exercised to pay for a generator.
68The evidence before me is clear that a back-up generator was needed to ensure the applicants’ safety. The mere possibility that they could have been stuck in the basement with their wheelchairs during a power outage should have given the respondent pause when neither of the Sora Plans included this element from the Puddicombe Plan. That is, the basement is the one area of the house that would have lacked non-mechanical access to the necessary areas of the house (namely, the front door) during a power outage. Therefore, without a back-up generator, the applicants could have been found themselves in situations where their safety and mobility would have been significantly impaired.
69Beyond safety, there is also the need for ensuring that the applicants have the freedom to choose how they will accommodate their mobility needs. That is, even though Mr. Sora testified that power outages could happen while the pair are sleeping (meaning they would be unaware of the outage), this lack of power might still mean their prosthetic legs will not be fully charged in the morning. As such, they will be limited to using their wheelchairs until the legs are powered. By denying a modification that could have granted the applicants more freedom to make choices about how they will accommodate their accident-related impairments, I find that this denial was not just incorrect, but unreasonable.
70Finally, as I found above, the back-up generator is one of the few, standalone elements of the Puddicombe Plan that could have been added to the Sora Plans without changing the overall layout. In this way, the respondent did not have to wait for its expert to draft a plan that included a back-up generator.
71Taken together, once the respondent received the Second Sora Plan, it should have acted swiftly to inform the applicants that it would pay for a back-up generator, regardless of which Plan it would eventually decide to approve.
72Therefore, the generator should have been approved no later than ten business days following the release of the Second Sora Plan on April 6, 2018. Even though the respondent eventually accepted the reasonableness of this modification (with a payment issued on May 28, 2019), this delayed reversal does not remedy the unreasonableness of its initial denial.
73I do not find this denial amounted to bad faith, as, again, it is often reasonable for an insurer to accept the opinions of its assessors. Instead, this behaviour is best characterized as careless, because the respondent accepted its experts’ conclusions without engaging in its own analysis.
74Without malice on the part of the respondent, I find an appropriate remedy for this delay is an award amounting to 25% of the value of the generator (inclusive of HST). In accordance with the rate and rule enumerated in s. 10 of Regulation 664, the value of this overdue generator also includes any unpaid interest that accumulated during the period starting ten business days after April 6, 2018 until May 27, 2019 (i.e., the day before the payment was provided for the generator).
75As a final note, I do not accept the respondent’s argument that this amount was never “due”, as the applicant did not comply with s. 38(15) of the Schedule. The need for this back-up generator should have been readily apparent to the respondent, so—at the very least—it should have informed the applicants that it would accept this standalone element of the Puddicombe Plan (as opposed to waiting for the satisfaction of technical requirements from the Schedule).
ORDER
76The applicants are entitled to the outstanding difference between the amount proposed in the Puddicombe Plan and the amounts that the respondent has paid to date. They are also entitled to interest on this overdue payment, in accordance with s. 51 of Schedule.
77Finally, the applicants are entitled to an award amounting to 25% of the value of the back-up generator proposed in the Puddicombe Plan (inclusive of HST and any unpaid interest from the period starting ten business days after April 6, 2018 until May 27, 2019).
Released: September 2, 2020
______________________________
Craig Mazerolle
Adjudicator
Footnotes
- Effective September 1, 2010, O. Reg. 34/10.
- R.S.O. 1990, c. H.19.