Judgments

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A-481-77
Saskatchewan Power Corporation and Many Islands Pipe Lines Ltd. (Appellants)
v.
TransCanada PipeLines Limited and the National Energy Board (Respondents)
and
Attorney General of Canada and Attorney General of Saskatchewan (Intervenors)
Court of Appeal, Thurlow C.J., Pratte J. and Kerr D.J.—Ottawa, April 1, 2 and May 29, 1980.
Crown — Appeal from decision of National Energy Board ordering that appellants pay for gas purchased from respond ents at a price higher than the contract price — Whether the Board has jurisdiction under the National Energy Board Act to alter the terms of a contract — Whether ss. 50, 53 and 61 of the National Energy Board Act are ultra vires — National Energy Board Act, R.S.C. 1970, c. N-6, ss. 2, 18(1), 50, 51, 52, 53, 54, 60, 61, as amended — Petroleum Administration Act, S.C. 1974-75-76, c. 47, s. 63 — The British North America Act, 1867, 30 & 31 Vict., c. 3 (U.K.) [R.S.C. 1970, Appendix II, No. 51, s. 92(10)(a) — Natural Gas Prices Regulations, SOR/77-13.
This is an appeal from an order by the National Energy Board on an application by the respondent TransCanada Pipe Lines Limited made pursuant to sections 50 and 53 of the National Energy Board Act for orders fixing just and reason able tolls and disallowing any existing tariffs or rates or tolls. Appellants claim that the Board was wrong in prescribing a price at which Alberta gas, which was to be delivered under the terms of a contract fixing a much lower price therefor, might be sold by TransCanada to the appellants. Appellants' counsel argues first that the National Energy Board Act does not confer upon the Board any jurisdiction to alter the terms of a contract, here, the price for gas to be redelivered by Trans- Canada as distinguished from a toll to be paid for the carriage of gas, and second, that sections 50, 53 and 61 of the Act, if interpreted as the statutory basis for the Board's jurisdiction over the price, are ultra vires the Parliament of Canada. What is in issue is the portion of the new rates and tolls approved by the Board which sets out "Imputed Alberta Border Price".
Held, the appeal is dismissed. Sections 50 and 53 of the National Energy Board Act do not give the Board authority to prescribe or interfere with the selling price of gas beyond what may be involved in requiring the carrier to charge the appropri ate transportation tolls prescribed by the Board. However, the fact that the parties have contracted for the sale of gas at a certain price with no reference in the contract to any portion of the price being a transportation toll, does not deprive the Board of its authority under section 53 to disallow the contract as a
tariff of tolls when it considers that an unduly low, let alone negative tariff, is contrary to the provisions of the Act requiring that tolls be just and reasonable. Having disallowed the con tract as a tariff, the Board's authority with respect to it and the effect of section 61 of the Act were spent. In this view of the scope of Part IV of the Act, it is unnecessary to consider the submission that the Act is ultra vires in so far as it authorizes the Board to regulate the price at which the gas referred to in the contract may be sold. As for the "Imputed Alberta Border Price", it serves only as information as to an element of a price that has been or is about to be prescribed by the Governor in Council under the Petroleum Administration Act.
Per Pratte J.: Section 61 of the National Energy Board Act clearly empowers the Board to prescribe, in the circumstances contemplated by that section, the price at which gas may be sold by a pipeline company. With respect to the constitutional validity of section 61, it is clear that it is, in pith and substance, legislation relating to the operation of an interprovincial under taking since it was enacted on the assumption that one of the normal ways of operating an undertaking such as a gas pipeline is for the operator to transmit and sell its own gas.
APPEAL. COUNSEL:
G. Henderson, Q.C., M. Sychuk, Q.C. and Y. Hynna for appellants.
G. D. Finlayson, Q.C. and J. H. Francis, Q.C. for TransCanada PipeLines Limited.
T. B. Smith, Q.C. and P. G. Griffin for Attorney General of Canada and the National Energy Board.
E. Binavince for Attorney General of Sas- katchewan.
SOLICITORS:
Gowling & Henderson, Ottawa, for appel lants.
McCarthy & McCarthy, Toronto, for Trans- Canada PipeLines Limited.
Deputy Attorney General of Canada for Attorney General of Canada.
F. Lamar, Q.C., Ottawa, for National Energy Board.
Gowling & Henderson, Ottawa, for Attorney General of Saskatchewan.
The following are the reasons for judgment rendered in English by
THURLOW C.J.: This is an appeal under subsec tion 18(1) of the National Energy Board Act (N.E.B. Act), R.S.C. 1970, c. N-6, as amended,
from order TG-1-76 made by the National Energy Board on November 26, 1976 on an application by the respondent TransCanada PipeLines Limited, (TransCanada). The appellants' case is that the Board exceeded its jurisdiction by prescribing a price at which Alberta gas, which was to be deliv ered under the terms of a contract fixing a much lower price therefor, might be sold by Trans- Canada to the appellants.
The contract was made in 1969 and is the contract which was involved in Saskatchewan Power Corp. v. TransCanada Pipelines Ltd. [ 1979] 1 S.C.R. 297. Under it Saskatchewan Power Corporation (SPC) sold gas to Trans- Canada for some years at 23.50¢ to 24.50¢ per M.C.F. and in 1976 became entitled to call for delivery to it by TransCanada, over a period of years of an equivalent quantity of gas at 23.50¢ per M.C.F. Between 1969 and 1976 the price of Alberta gas acquired by TransCanada for delivery to its customers rose very sharply. In the meantime in 1975, Natural Gas Prices Regulations, SOR/ 75-630, made under the Petroleum Administra tion Act, S.C. 1974-75-76, c. 47, came into effect and prescribed the prices at which gas produced in Alberta and entering into international and inter- provincial trade might be sold.
Almost all of the gas transported via Trans- Canada's pipeline is owned by TransCanada which buys it from suppliers, mostly in Alberta, and sells it to distributing companies. The difference be tween the price at which the gas is sold and the price paid for it represents TransCanada's gross earnings from acquiring, transporting and selling such gas. Minor quantities of gas owned by others are transported via the pipeline at rates fixed by the Board.
The Board's order read as follows:
UPON an application by the Applicant dated the 16th day of July, 1976, inter alia, for Orders under sections 50 and 53 of the National Energy Board Act fixing the just and reasonable rates or tolls the Applicant may charge for or in respect of gas sold by the Applicant in Canada and for transportation services to Saskatchewan Power Corporation, Greater Winnipeg Gas Company, Consolidated Natural Gas Limited and Gaz Mé- tropolitain, inc. and disallowing any existing tariffs or rates or tolls or portion thereof that are inconsistent with the just and reasonable rates or tolls so fixed, effective the 1st day of January, 1977; and an Order approving the tariff provisions filed with the application and disallowing any provisions exist-
ing in the present tariff or in contracts for the various services under consideration in the said application which are inconsist ent with the tariff provisions so approved;
IT IS ORDERED THAT:
1. The Applicant shall charge in respect of gas sold by it in Canada and in respect of its T-Service and Transportation Service, the rates and tolls specified in Schedule A hereto.
2. The Applicant's proposed tariff amendments in respect of its General Terms and Conditions, its Rate Schedules, and its Transportation Contracts, all as more particularly set forth under Tabs 1 to 7 inclusive under the heading "Tariff ' in the said application, and as set forth in Exhibit No. 54 filed at the hearing of the said application, be and the same are hereby approved.
3. The Applicant's proposed tariff amendments to its Rate Schedules and its Transportation Contracts, all as more par ticularly set forth in Exhibit No. 55 filed at the hearing of the said application, be and the same are hereby disallowed.
AND IT IS FURTHER ORDERED THAT:
4. The Applicant shall forthwith file with the Board and serve upon all parties to the hearing of this application, new tariffs, tolls and rates conforming with this Order.
5. Notwithstanding the filing of the said new tariffs, tolls and rates, the same shall remain suspended and be of no effect until the 1st day of January, 1977.
6. Those provisions of the Applicant's tariffs, tolls and rates, or any portion thereof, that are contrary to any provisions of the National Energy Board Act, or to any Order of the Board including this Order, be and the same are hereby disallowed, such disallowance to be effective on the 31st day of December, 1976.
The material parts of Schedule A are:
SCHEDULE A
TRANSCANADA PIPELINES LIMITED
RATES AND TOLLS FOR CANADIAN SALES, TRANSPORTATION & T-SERVICE
EFFECTIVE: 1 January 1977.
TRANSPORT- TRANSPORT- IMPUTED
ATION ATION ALBERTA DEMAND COMMODITY BORDER
PARTI- RATE RATE RATE PRICE CULARS SCHEDULE (S/MCP/M0) (¢/MCF) (¢/MMBTU)
Saskatchewan
Zone cD 0.711 0.975 105.228
The words "Transportation & T-Service" in the title refer to tolls for transporting gas not owned by TransCanada and neither they nor the rates and tolls to which they refer (which I have not set out) are significant for present purposes. Nor is the Transportation Demand Rate 0.711 or the Transportation Commodity Rate 0.975 challenged. What is in issue is the portion which sets out "Imputed Alberta Border Price (¢/MMBtu) 105.228".
The appellants' first submission, as set out in their memorandum, was that
(a) the National Energy Board Act does not confer upon the Board any jurisdiction to alter the terms of a contract, in the instant case, the price which the appellants under the contract should pay for gas to be redelivered by TransCanada under the contract as distinguished from a toll which is to be paid for the carriage of gas;
(b) sections 50, 53 and 61 of the National Energy Board Act, if interpreted as the statutory basis for the Board's jurisdiction over the price in the contract, are ultra vires the Parliament of Canada.
In presenting his argument on (a), counsel, as I understood him, conceded the jurisdiction of the Board to fix the transportation tolls set out as Demand Rate and Commodity Rate but contended that what is referred to as the Imputed Alberta Border Price is not a rate or toll for the transporta tion of gas but represents the value of the gas as a commodity and is the commodity element in the total price at which the gas is to be delivered by TransCanada to the appellants. I agree with this position. In my view, the item, whatever its precise characterization may be, is not a rate or toll for the transportation of gas. It is the value or price, or part of the price to be paid for the gas.
I turn now to the extent of the authority of the Board under Part IV of the N.E.B. Act. The Part is entitled "Traffic, Tolls and Tariffs" and it applies to the transportation of gas and oil. It includes sections 50, 53 and 61.
At the relevant time the word "toll" was defined in section 2 as follows:
"toll" includes any toll, rate, charge or allowance charged or made for the shipment, transportation, transmission, care, handling or delivery of hydrocarbons, or for storage or demurrage or the like.
The word "tariff' was not defined. In the con text in which it is found in Part IV its ordinary meaning, in my opinion, is simply that of a list of tolls or rates. In some contexts it can connote a toll or rate but it does not bear that meaning as well in the context in which it is found in Part IV. Part IV speaks of tolls and rates and when it uses the word "tariff' it does so, in my view, only in the sense of a list of tolls or rates.
Sections 50 to 54 inclusive and 61 provide:
50. The Board may make orders with respect to all matters relating to traffic, tolls or tariffs.
51. (1) A company shall not charge any tolls except tolls specified in a tariff that has been filed with the Board and is in effect.
(2) Where the gas transmitted by a company `through its pipeline is the property of the company, the company shall file with the Board, upon the making thereof, true copies of all the contracts it may make for the sale of gas and amendments from time to time made thereto, and the true copies so filed shall be deemed, for the purposes of this Part, to constitute a tariff pursuant to subsection (1).
52. All tolls shall be just and reasonable, and shall always, under substantially similar circumstances and conditions with respect to all traffic of the same description carried over the same route, be charged equally to all persons at the same rate.
53. The Board may disallow any tariff or any portion thereof that it considers to be contrary to any of the provisions of this Act or to any order of the Board, and may require a company, within a prescribed time, to substitute a tariff satisfactory to the Board in lieu thereof, or may prescribe other tariffs in lieu of the tariff or portion thereof so disallowed.
54. The Board may suspend any tariff or any portion thereof before or after the tariff goes into effect.
61. Where the gas transmitted by a company through its pipeline is the property of the company, the differential be tween the cost to the company of the gas at the point where it enters its pipeline and the amount for which the gas is sold by the company shall, for the purposes of this Part, be deemed to be a toll charged by the company to the purchaser for the transmission thereof.
In my opinion these provisions are concerned entirely with the rates or tolls to be charged by a carrier in respect of the transportation of oil and gas. The rates and tolls are in respect of the transportation of gas and oil in international and interprovincial trade and what the Board may prescribe under sections 50 and 53 are the rates and tolls for such transportation. That, I think, becomes apparent from a perusal of the statute
and, particularly Part IV, as a whole. There is no requirement that the price at which gas or oil is sold shall be just or reasonable or that it be charged equally to all persons at the same rate. Nor is there any authority given to the Board by these provisions to prescribe or interfere with the price at which oil or gas is to be sold beyond what may be involved in requiring the carrier to charge the appropriate transportation tolls prescribed by the Board. On the other hand, the fact that parties have contracted for the sale of gas at a price to be paid for it at the point where it is to be delivered, with no reference in the contract to any portion of the price being a transportation toll, cannot deprive the Board of its undoubted authority under section 53 to disallow the tariff of transportation tolls represented by the contract, to require the carrier to substitute a tariff satisfactory to the Board and to prescribe a tariff of tolls for the transportation of the gas which is the subject matter of the contract in place of the tariff that has been disallowed.
In the present case the contract contained no provision allocating any portion of the 23.50¢ per M.C.F. as a toll for the transportation of the gas and as on the material before the Board the cost of the gas to TransCanada was much more than 23.50¢ per M.C.F., the result of the application of section 61 was that the toll to be charged was zero. In my view, it was within the authority of the Board under section 53 to disallow and disregard the contract as a tariff of tolls when it considered, as it did, that such a tariff was contrary to provi sions of the Act requiring that tolls be just and reasonable and be charged, under substantially similar circumstances and conditions with respect to traffic over the same route, equally to all per sons at the same rate.
It was also within the authority of the Board to prescribe the appropriate tolls for the transporta tion of the gas referred to in the contract and to require the carrier to file a tariff satisfactory to the Board.
However, in my opinion, having disallowed the contract as a tariff, the Board's authority with respect to it and the effect of section 61 were spent. The contract had been filed under subsec tion 51(2). The filed copies thereupon were
deemed to be a tariff. As the contract did not in fact purport to be a tariff and to fix tolls for transportation of gas, section 61 applied. But the result of its application was that there was nothing that could be regarded as a toll. The Board there upon disallowed the contract as a tariff and pre scribed what it regarded as appropriate tolls. Nothing in the Act, as I read it, authorized any further interference by the Board with the terms of the contract. Nor is there any further provision of the Act which affects or changes it. Moreover, the structure and purpose of section 61, in my view, do not lend themselves to an interpretation which would enable the Board, by the exercise of its power under section 50 to make orders respecting tariffs and tolls, to require that a price be charged for gas sold by TransCanada that would be high enough to recover the acquisition cost of the gas plus the transportation tolls so that the difference between that selling price and the cost of the gas could be deemed to be a toll. And in any event, the Imputed Alberta Border Price is not, as I under stand it, the cost to TransCanada PipeLines of the gas at the point where it enters TransCanada's pipeline, within the meaning of section 61, but is simply a figure arrived at by a mathematical formula devised for the purposes of the Natural Gas Prices Regulations.
In this view of the scope of Part IV of the N.E.B. Act it is unnecessary to consider or deal with the submission that the Act is ultra vires in so far as it authorizes the Board to regulate the price at which the gas referred to in the contract may be sold.
This brings me to the question of what it is that the order of the Board purports to do when it includes in Schedule A an "Imputed Alberta Border Price" on the same line with the transpor tation tolls prescribed by the Board. If it was intended thereby to prescribe the price at which the gas was to be sold it would, I think, be beyond the authority of the Board under the N.E.B. Act and would have no proper place in an order pur porting to be made under the authority of that Act. It ought, in that case, to be deleted.
But it is not to be lightly assumed that the Board exceeded its powers under the N.E.B. Act and if it is possible to do so the Board's order should be given an interpretation which is con-
sistent with and within the Board's authority under the Act.
In its reasons the Board, after reviewing the facts and submissions of the appellant and refer ring to the fact that the application of the rule of section 61 resulted in what the Board character ized as a negative transportation toll said:
Accordingly, the Board finds that there are not substantially dissimilar circumstances and conditions involved in the sale of the gas to SPC under the Contract, such as would warrant a departure from the statutory requirement for equality of tolls on the TransCanada pipeline system. Moreover in the Board's view, an unduly low, let alone negative, transportation toll is no more just and reasonable than an excessively high one. Having regard to the evidence adduced respecting this transaction, the Board finds a negative transportation toll of some 81.98 cents per Mcf would not be just and reasonable as required by section 52 of the Act.
In view of the various factors considered in the earlier sections of these Reasons, the Board finds that a just and reasonable transportation toll in respect of the gas to be sold to SPC in the test year under the Contract, would be the Sas- katchewan Zone CD rate set out in Schedule A to Order No. TG-1-76, which rate is applicable to all volumes of gas sold by TransCanada to SPC in the Saskatchewan Zone. [Emphasis added.]
It appears to me that what the Board is express ing in this passage is that the just and reasonable transportation toll in respect of the gas is the Saskatchewan CD rate set out in Schedule A to the order. But whether or not that is intended to include the Imputed Alberta Border Price, the wording of the order itself, that is effective to prescribe tolls, is that contained in paragraph 1 thereof. For convenience, it is repeated:
1. The Applicant shall charge in respect of gas sold by it in Canada and in respect of its T-Service and Transportation Service, the rates and tolls specified in Schedule A hereto. [Emphasis added.]
The rates and tolls specified in Schedule A in respect of gas sold by the applicant, TransCanada, are those which follow the title. But as only two of the figures given are rates and tolls in respect of the transportation of gas and are clearly so entitled and as the title above the other figure does not even purport to indicate that what is below it is a transportation charge or even that it is a rate or a toll, I am of the opinion that the third column is not referred to in the order and is not prescribed by it, and that it is only the rates and tolls shown under the headings, "Transportation Demand Rate" and "Transportation Commodity Rate"
that are prescribed by the order. The figures under the column headed "Imputed Alberta Border Price", in my view, serve no purpose in the order other than as information as to an element of a price that has been or is about to be prescribed,' not by the Board by the order under appeal or any other order of the Board, but by the Governor in Council (albeit with some assistance from and on the recommendation of the Board), under the Petroleum Administration Act. The validity of the prescription made under that Act is not in issue on this appeal and does not require consideration.
Further, on examining the items referred to in paragraph 2 of the order, I find nothing that is inconsistent with this interpretation of it. By para graph 2, the applicant's proposed tariff amend ments are approved and by paragraph 4 Trans- Canada is ordered to file new tariffs, tolls and rates conforming with the order. This, I take it, would require TransCanada to file a new tariff which would include a paragraph as follows:
3. RATES
3.1 The applicable rates and Rate Schedule for service hereunder in each zone are as follows:
TRANSPORTATION
Applicable Imputed
Rate Alberta Demand Daily Schedule Border Commodity Rate Demand
and Rate Price Rate $/Mcf/ Rate per Zone ¢/MMBtu ¢/Mcf Month MCF
CD-S—Sask. cD-M—Manitoba ci-w—Western CD-N—Northern cD-E—Eastern
This however, in my view, cannot change what is in substance a price into a rate or toll for transportation and I do not think it even purports to do so. This is not a case of a tariff setting out a single price which includes both the value of the commodity and the charge for its transportation. In this tariff, the several items are specified as
' See Order in Council P.C. 1976-3122 [SOR/77-13] made on December 16, 1976 and effective from January 1, 1977.
being the Imputed Alberta Border Price and the several rates for transportation to the various zones. It is apparent that the Imputed Alberta Border Price is not a rate or toll for transportation and its presence in the tariff required to be filed has no more effect than it has in paragraph 1 of the order.
In this view, there is nothing of substance wrong with the order. The figures in question could be deleted but can equally well be allowed to remain. But in order to make somewhat plainer what the scope and effect of the order are, I would vary paragraph 1 by inserting before the word "rates" in the third line, the word "transportation" and paragraph 4 by inserting before the word "con- forming" in the fourth line the words "for trans portation". These variations having been made, I would dismiss the appeal.
Having regard to Rule 1312 there should be no award of costs.
* * *
The following are the reasons for judgment rendered in English by
PRATTE J.: I have had the advantage of reading the reasons for judgment prepared by the Chief Justice. I regret not to be able to share his views as to the powers of the National Energy Board and the meaning of the order under attack.
By that order, as I understand it, the Board has in effect determined that the appellants would have to pay, for gas they had purchased from TransCanada PipeLines Limited for delivery in 1977, a price much higher than the sum of 23.5 cents per Mcf that the parties had agreed upon in a contract dated November 1, 1969, pursuant to which those purchases had been made. The appel lants contest the authority of the Board to make such an order which, according to them, has the effect of varying the terms of the contract of November 1, 1969.
That contract of November 1, 1969, between the appellants and TransCanada was a long term gas supply contract made for a period of twelve years expiring on October 31, 1981. It provided that, from November 1, 1975, until the expiry of the contract, the appellants would have the option, if they so desired, to buy certain volumes of gas
from TransCanada at the price of 23.5 cents per Mcf. That gas was to be delivered at Trans- Canada's main transmission line at a point situat ed near Success, in Saskatchewan. The appellants took advantage of that option and sent written notices to TransCanada indicating the volumes of gas they had decided to buy during the contract years commencing on November 1, 1976, and November 1, 1977. TransCanada transmitted those notices together with the contract of Novem- ber 1, 1969, to the National Energy Board for filing pursuant to subsection 51(2) of the National Energy Board Act. Finally, on July 15, 1976, TransCanada filed with the National Energy Board the application which led to the order under attack. That was an application under sections 50 and 53 of the National Energy Board Act for orders, inter alia, "fixing the just and reasonable rates or tolls the Applicant may charge for or in respect of gas sold by the Applicant in Canada ... and disallowing any existing tariffs or rates or tolls or portion thereof that are inconsistent with the just and reasonable rates or tolls so fixed, effective January 1, 1977." In that application, Trans- Canada, after referring to the contract of Novem- ber 1, 1969, and to the fact that the appellants had exercised their option under that contract, express ly requested "disallowance of the sales prices set out in the said contract and substitution therefor of the Saskatchewan Zone CD rate proposed in the present application."
With respect to this request, the Board found
(a) that the gas purchased by the appellants would be transmitted through TransCanada's pipeline from Alberta to its point of delivery, near Success, in Saskatchewan;
(b) that the cost of the gas to TransCanada, at the Alberta border, was the "imputed Alberta border price" of 105.228¢/MMBtu;
(c) that, under the contract of November 1, 1969, TransCanada was obliged to sell and deliver that gas to the appellants for a price considerably lower than that "imputed Alberta border price";
(d) that there were no reasons why the appel lants should not pay for gas purchased from TransCanada, the same price as other people in Saskatchewan who had to pay the Saskatche- wan Zone CD rate, which rate included, in
addition to the imputed Alberta price, reason able transportation charges.
As I understood the argument made by Mr. Henderson on behalf of the appellants, he did not contest any of those findings. He merely chal lenged the conclusion that the Board drew from those findings, namely, that the appellants would have to pay the Saskatchewan Zone CD rate for gas purchased pursuant to the contract of Novem- ber 1, 1969. Mr. Henderson challenged that con clusion on two grounds. He said, first, that the National Energy Board Act did not empower the Board to vary the terms of a contract for the sale of gas and, second, that, if that Act were to be interpreted as conferring that power upon the Board, then it would be unconstitutional and ultra vires the Parliament of Canada.
The relevant provisions of the National Energy Board Act are found in Part IV of that Act, under the headings "TRAFFIC, TOLLS AND TARIFFS". Those provisions must, of course, be read in the light of the definitions found in section 2:
2. In this Act
"Board" means the National Energy Board; "company" includes
(a) a person having authority under a special act to construct or operate a pipeline, and
(b) a body corporate incorporated or continued under the Canada Business Corporations Act and not discontinued under that Act;
"pipeline" means a line for the transmission of gas or oil connecting a province with any other or others of the prov inces, or extending beyond the limits of a province ...;
"toll" includes any toll, rate, charge or allowance charged or made for the shipment, transportation, transmission, care, handling or delivery of hydrocarbons, or for storage or demurrage or the like.
Most of the provisions of Part IV of the Act apply to companies operating either oil or gas pipelines. The most important of those provisions read as follows:
50. The Board may make orders with respect to all matters relating to traffic, tolls or tariffs.
51. (1) A company shall not charge any tolls except tolls specified in a tariff that has been filed with the Board and is in effect.
52. All tolls shall be just and reasonable, and shall always, under substantially similar circumstances and conditions with respect to all traffic of the same description carried over the same route, be charged equally to all persons at the same rate.
53. The Board may disallow any tariff or any portion thereof that it considers to be contrary to any of the provisions of this Act or to any order of the Board, and may require a company, within a prescribed time, to substitute a tariff satisfactory to the Board in lieu thereof, or may prescribe other tariffs in lieu of the tariff or portion thereof so disallowed.
54. The Board may suspend any tariff or any portion thereof before or after the tariff goes into effect.
55. A company shall not make any unjust discrimination in tolls, service or facilities against any person or locality.
There are three provisions in Part IV, however, that apply exclusively to gas pipeline companies: subsection 51(2) and sections 60 and 61. They read as follows:
51....
(2) Where the gas transmitted by a company through its pipeline is the property of the company, the company shall file with the Board, upon the making thereof, true copies of all the contracts it may make for the sale of gas and amendments from time to time made thereto, and the true copies so filed shall be deemed, for the purposes of this Part, to constitute a tariff pursuant to subsection (1).
60. Where the Board finds such action necessary or desirable in the public interest, it may direct a company operating a pipeline for the transmission of gas to extend or improve its transmission facilities to provide facilities for the junction of its pipeline with any facilities of, and sell gas to, any person or municipality engaged or legally authorized to engage in the local distribution of gas to the public, and for such purposes to construct branch lines to communities immediately adjacent to its pipeline, if the Board finds that no undue burden will be placed upon the company thereby, but the Board has no power to compel a company to sell gas to additional customers if to do so would impair its ability to render adequate service to its existing customers.
61. Where the gas transmitted by a company through its pipeline is the property of the company, the differential be tween the cost to the company of the gas at the point where it enters its pipeline and the amount for which the gas is sold by the company shall, for the purposes of this Part, be deemed to be a toll charged by the company to the purchaser for the transmission thereof.
As I read them, those provisions were enacted on the assumption that gas pipelines could normally be operated in two ways. First, a gas pipeline company could act merely as a carrier who, for a remuneration, transports his customers' goods. That is the method of operation contemplated in the provisions of Part IV which apply to both gas and oil pipelines. The second method of operating a gas pipeline is referred to in subsection 51(2) and sections 60 and 61, which all contemplate that the gas pipeline company will operate its undertak ing by transmitting and selling its own gas. When a gas pipeline is operated in this manner, section 61 provides that:
... the differential between the cost to the company of the gas at the point where it enters its pipeline and the amount for
which the gas is sold by the company shall, for the purposes of this Part, be deemed to be a toll charged by the company to the purchaser for the transmission thereof.
The effect of that section, which deems the "dif- ferential" to which it refers to be a toll charged for the transmission of gas, is to confer on the Board the same powers with respect to that differential as those possessed by the Board in relation to mere transportation tolls. As the Board may disallow a tariff specifying unreasonable tolls and prescribe tolls that it considers to be just and reasonable, it may, in the same manner, disallow a contract for the sale of gas entered into by a pipeline company and prescribe the "differential" that must exist between the cost of the gas to the company and the price for which it is sold.
This being my interpretation of section 61, it follows that, in my view, that section clearly empowers the Board to prescribe, in the circum stances contemplated by section 61, the price at which gas may be sold by a pipeline company. For that reason, I do not find merit in the appellants' first submission that the Board exceeded the powers conferred on it by the statute in making the order here in question.
The appellants' second ground of attack relates to the constitutional validity of section 61 of the National Energy Board Act. If that section, it is said, purports to confer on the Board the authority to alter the price agreed upon in a contract for the sale of gas, then it constitutes legislation in rela tion to property and civil rights exceeding the
constitutional competence of the Parliament of Canada.
In answer to that proposition, it is first neces sary to observe that the legislative competence of provincial legislatures in the field of property and civil rights is not exclusive and does not extend to all the matters comprised in that field. Parliament also has the right to legislate on that class of subject in all cases where section 91 or paragraph 92(10)(a) of The British North America Act, 1867, [R.S.C. 1970, Appendix II, No. 5] authorize it to adopt such legislation. Under paragraph 92(10)(a), Parliament has legislative jurisdiction over interprovincial undertakings like the gas and oil pipelines to which the National Energy Board Act applies. It is not disputed that, in the exercise of that jurisdiction, Parliament is empowered to regulate the transportation rates to be charged by pipeline operators and to render ineffective trans portation contracts providing for rates different from those fixed in accordance with the scheme approved by Parliament. Now, the regulation of the conditions of a contract of transport is as much a matter of property and civil rights as the regula tion of the conditions of a contract of sale. There is nothing sacrosanct in a contract of sale that would make it less amenable to federal control than other kinds of contracts. In my view, the sole question to be determined here is whether section 61, which subjects in certain cases contracts for the sale of gas to the regulating authority of the Board, is, in pith and substance, legislation relating to the oper ation of an interprovincial undertaking. In my view, it clearly is since it was enacted on the assumption, which I believe to be founded in fact, that one of the normal ways of operating an undertaking such as a gas pipeline is for the operator to transmit and sell its own gas. 2
For these reasons, I would dismiss the appeal.
* * *
2 A similar opinion was expressed by Gibson J. in Northern and Central Gas Corp. v. National Energy Board [1971] F.C. 149.
The following are the reasons for judgment rendered in English by
KERR D.J.: The relevant facts and issues are set forth in the reasons of the Chief Justice, which I have had the benefit of considering.
The National Energy Board, (hereinafter called the "Board"), is a creature of statute, and the general principle applicable to such a body is that its jurisdiction is what the statute gives by express terms or by necessary implication. There is section 63 of the Petroleum Administration Act which reads as follows:
63. In the event of a conflict between any price prescribed under this Part and any price established under Part IV of the National Energy Board Act, the prescribed price under this Act prevails.
That section does not confer a power, but there may be implication in it that the Board has power under Part IV of the National Energy Board Act to establish a selling price for gas where necessary to do so incidentally to the exercise of its regula tion of tolls.
In Saskatchewan Power Corp. v. TransCanada Pipelines Ltd. [1979] 1 S.C.R. 297 at page 309, the judgment of the Supreme Court of Canada set forth the following addendum to the reasons for decision of the Board (the same reasons that are before this Court in this appeal):
Subsequent to the filing of this application with the Board, the Governor in council prescribed prices at which natural gas produced in the Province of Alberta is to be sold on and for delivery in areas or zones of Canada outside that Province, pursuant to section 51(1) of the Petroleum Administration Act. By Order in Council, P.C. 1975-2533, as amended by O.C. 1975-2731, the Governor in Council has prescribed prices applicable to, inter alia, sales in the Saskatchewan zone by TransCanada of natural gas produced in the Province of Alber- ta. It appears to the Board that the price stipulated in the 1 November 1969 contract, apart from being subject to regula tion under Part IV of the National Energy Board Act, is subject to the prices prescribed pursuant to the Petroleum Administration Act.
By a further amendment made to the Natural Gas Prices Regulations on December 16, 1976 the Governor General in Council prescribed the price at which TransCanada was to sell gas, inter alia, under CD service in the Saskatchewan zone effec tive January 1, 1977. The price so prescribed was the aggregate of
Imputed Alberta Border Price 105.2280/MMBtu
Transportation Demand Rate $ .711/Mcf/Month
Transportation Commodity Rate .9750/Mcf. (P.C. 1976-3122 SOR/77-13)
In its reasons for decision the Board stated at page 2-2:
Under the terms of the Federal/Alberta agreement dated 23 June 1976 the price of Alberta gas sold in TransCanada's Eastern zone will increase from $1.405/MMBtu's to $1.505 on 1 January 1977 for CD Service at 100 per cent load factor.
and at page 7-12 the Board stated:
... Alberta gas, under the scheme of gas pricing established under Part III of the PAA would enter the TransCanada system at the Alberta border at a cost to TransCanada of 105.228 cents per MMBtu, as shown at page 2-2 of these Reasons.
It is clear that the Board had regard for the provisions of the Petroleum Administration Act and the prices prescribed pursuant to that Act.
The prices set forth in the Board's order No. TG-1-76 under appeal herein were identical to the prices prescribed by said P.C. 1976-3122, and effective the same day, January 1, 1977.
The Board evidently reached a conclusion that the price stipulated in TransCanada's contract of November 1, 1969 is subject to the prices pre scribed pursuant to the Petroleum Administration Act.
I think that it is reasonable to infer from the Board's reasons and the material before the Court that it was of the opinion that because of that conclusion, apart from its conclusion that the price is subject to regulation under Part IV of the National Energy Board Act, the prices prescribed by said P.C. 1976-3122 should be included in the new tariffs, tolls and rates to be charged and filed pursuant to its said order.
I have no doubt that the Board has power under Part IV of the National Energy Board Act to require, and if need be to prescribe, in relation to
the public interest, tolls for transmission of the gas to which this appeal relates that in its opinion will be just and reasonable and not unjustly discrimina tory. I think also that, in forming its opinion as to such tolls, (in the cost of service, rate base, rate of return regulatory method that the Board applies, which is intended by the Board to be just to users of the utility's facilities and to provide to the utility a fair return in the foreseeable circum stances), many factors have to be taken into account, including the cost of service, in which the cost to the utility of the gas owned by it forms a part.
Whether or not the Board has power under said Part IV to itself independently fix the selling price of the gas I think that where the selling price is otherwise conclusively fixed and is binding on the Board and on the utility and on the users of the facilities and services of the utility, there is no occasion for the Board itself to fix a selling price. I think that in this case the Board accepted and used the prices prescribed pursuant to the Petroleum Administration Act because it was of the opinion that those prices were the prices lawfully charge able. That opinion was, I think, well founded, and if it was I am disposed to think that the Board in the exercise of its administrative and regulatory jurisdiction could order that the prices be included in the new tariffs to be filed. Those prices and the transmission tolls, in the aggregate, were what would provide the return that the Board con sidered TransCanada should be permitted to earn from its pipeline enterprise. The law does not dictate the order to be made or what order is proper in a given case.
Overall, and considering the end result of the Board's order, I am of the opinion that a sufficient case has not been made for granting the order sought by the appellants to set aside the Board's order.
Therefore, I would dismiss the appeal.
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