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					Lawyers · Patent and Trade-mark Agents




                                         Understanding the Green Energy and
                                             Green Economy Act, 2009
                                                                    October 16, 2009
                                                 9th Annual Ontario Waterpower Association Conference


                                                      Linda L. Bertoldi                         John A.D. Vellone
                                          National Leader, Electricity Markets Group   Associate, Electricity Markets Group
                                             BORDEN LADNER GERVAIS LLP                 BORDEN LADNER GERVAIS LLP
                                                       (416) 367-6647                            (416) 367-6730
                                                  lbertoldi@blgcanada.com                   jvellone@blgcanada.com

                                                                                          Lawyers • Patent and Trade-mark Agents
Lawyers · Patent and Trade-mark Agents   Presentation Outline

                                             Background
                                             Context
                                             Overview of the GEGEA
                                             Changing Regulatory Framework
                                             Facilitating New Renewable Generation
                                                 The Feed-in Tariff Program
                                                 Renewable Energy Approval
                                           Climate Change Perspectives




                                                                                      2
Lawyers · Patent and Trade-mark Agents   Background

                                          Green Energy and Green Economy Act, 2009 (“GEGEA”)
                                               Feb 23/09 - introduced in the Ont. legislature
                                               May 14/09 – received Royal assent
                                               Sept 09 – part (but not all) of the Act proclaimed into force, 16
                                                new regulations released, Minister issued directives to Hydro
                                                One and OPA.


                                          The GEGEA has enacted a stand-alone Green Energy Act,
                                           2009 (the “GEA”) and amended and repealed numerous
                                           other statues.

                                          Targeted to create 50,000 direct and indirect new jobs in
                                           Ontario over the next 3 years.


                                                                                                                    3
Lawyers · Patent and Trade-mark Agents   Context
                                         Framework for Generation in Ontario before the
                                         GEGEA
                                          Ontario’s “hybrid” market – partly regulated:
                                                OPA contracts required to facilitate new generation
                                                OPA operated competitive procurements for large projects and
                                                 RESOP for small renewable projects
                                                Limited connection capacity and slow progress through queues
                                                Concerns around multiple approval process and NIMBYism in
                                                 respect of new generation
                                                     Class EA aimed to address this for hydropower
                                                Limited role for LDCs in generation
                                                OPG - regulated rate of return on nuclear and large hydro
                                                 assets and rebates on earnings over specified limits
                                                Ontario Hydro $38 billion stranded debt to be repaid – debt
                                                 retirement charge
                                                Coal phase out by 2014


                                                                                                                4
Lawyers · Patent and Trade-mark Agents   Context
                                         Renewable Energy Standard Offer Program

                                           Renewable Energy Standard Offer Program (“RESOP”)
                                                OPA introduced RESOP program in Nov. 2006, providing standard
                                                 offer pricing on 20 year contracts for renewable projects less than
                                                 10MW connected to LDCs
                                                     11c/kWh for wind & small hydro, 42c/kWh for solar

                                           May 2008 OPA announced a moratorium on new RESOP
                                            applications while it reviewed the program
                                                Oversubscription; prices to be reviewed; connection delays
                                                Existing contracts still valid
                                                Aug/09 – one year extension offered for non-waterpower RESOP
                                                 contracts

                                           Replaced by the new Feed-in Tariff Program
                                                FIT design intended to address some of the problems the OPA
                                                 experienced with RESOP. Security deposit requirements + new
                                                 connection process.


                                                                                                                       5
Lawyers · Patent and Trade-mark Agents   Context
                                         Integrated Power System Planning

                                            Integrated Power System Plan (“IPSP”)
                                                  June/06 Minister’s Supply Mix Directive to the OPA.
                                                  Aug/07 OPA filed its 20 year IPSP for approval with the OEB
                                                  Targeted renewable generation of 15,700 MW by 2025
                                                       Hydroelectric generation representing 10,768 MW of this total
                                                  OEB hearings on the IPSP began in September 2008

                                            Sept/08 Minister’s directive to revisit the IPSP, includes:
                                                  Amount & diversity of renewable energy sources in supply mix
                                                  Improvement of transmission capacity that is limiting the
                                                   development of new renewable energy supply
                                                  Potential for pumped storage to contribute to the energy supply mix
                                                   during peak times

                                            Status of IPSP is uncertain
                                                  On Mar. 12/09 OPA requested an extension as a result of GEGEA.
                                                   OPA intended to respond “in the summer,” depending on the
                                                   progress of GEGEA.

                                                                                                                         6
Lawyers · Patent and Trade-mark Agents   Overview of the GEGEA


                                           GEGEA contains several important themes for
                                            hydro proponents, including:

                                             1. Changes in the Ontario regulatory framework

                                             2. Facilitating renewable energy generation
                                                 Renewable Energy Facilitation Office
                                                 Ontario’s Feed-in Tariff Program
                                                 Renewable Energy Approval Process
                                                     not applicable to waterpower projects

                                             3. Climate change considerations



                                                                                              7
Lawyers · Patent and Trade-mark Agents
                                         Changing Ontario Regulatory Framework


                                                        Previously                               Under GEGEA
                                          Ministry provides high-level                Ministry’s increasingly important
                                         oversight of industry / policy               central role in the electricity sector
                                           Limited directive power to OPA              New objectives
                                           Delegated to OPA, OEB, OPG and Hydro        New powers to issue directives

                                          One as necessary                              New power to undertake CDM programs




                                          OEB objectives focus on:                    Additional OEB objectives
                                           prices, reliability, quality of service     promote renewable energy generation
                                           economic efficiency, cost effectiveness     promote energy conservation

                                                                                        facilitate smart grid




                                               Consider:
                                                     Renewable generation is now an OEB objective.
                                                     Is there a new role to be played by renewable generators in
                                                      OEB regulatory processes?
                                                                                                                               8
Lawyers · Patent and Trade-mark Agents
                                         Changing Ontario Regulatory Framework
                                         Current OEB Initiatives


                                            A number of “separate but related initiatives” that “will lay the
                                             foundation for an integrated framework for electricity
                                             infrastructure development in Ontario”
                                                  Howard Wetston, OEB Chair, June 1, 2009

                                            OEB initiatives of interest to waterpower generators:
                                                  Connection cost responsibilities for generators connecting to the
                                                   transmission system and the distribution system
                                                  Connection process for generators connecting to the distribution
                                                   system
                                                  Guidelines for LDC owned and operated renewable energy
                                                   generation
                                                  Preliminary guidelines for distribution system expansion plans to
                                                   accommodate renewable generation and develop a smart grid

                                            The OWA is taking part in and has made detailed submissions
                                             in a number of these important initiatives.
                                                                                                                       9
Lawyers · Patent and Trade-mark Agents   Facilitate Renewable Generation
                                         Renewable Energy Facilitation Office (REFO)

                                           A single access point to facilitate access to information on
                                            developing renewable energy projects in Ontario.
                                                 Available to assist small and large scale waterpower
                                                  proponents of facilities in Ontario.

                                                 Falls under the umbrella of the Renewables and Energy
                                                  Efficiency department at the Ministry of Energy and
                                                  Infrastructure (Sue Lo, ADM).
                                                      Mirrun Zaveri is the Deputy Director of REFO.

                                                 Will act as an important resource for all potential participants
                                                  including developers, communities and municipalities that
                                                  require help to navigate the regulatory approvals process.

                                                 Contact: 1-877-440-REFO or REFO@ontario.ca

                                                                                                                     10
Lawyers · Patent and Trade-mark Agents   Facilitate Renewable Generation
                                         The Feed-in Tariff Program (FIT)

                                            Program launched October 1, 2009.
                                                  60 day launch period began.

                                            Standard offer long-term fixed price contract for electricity
                                             generated from renewable energy sources.
                                                  40 yrs for waterpower, 20 yrs for other renewable sources

                                            Provincial content requirements for solar and wind projects
                                                  Waterpower facilities are not affected.
                                                       Wind: starting at 25% domestic content and increasing to 50% on Jan.
                                                        1, 2012;
                                                       Micro solar PV (<10kW): starting at 40% and increasing to 60% on Jan.
                                                        1, 2011; and
                                                       Large Solar PV: starting at 50% and increasing to 60% on Jan. 1, 2011


                                            Program review every 2 years.

                                                                                                                                11
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         FIT Pricing




                                                                      12
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         FIT Pricing

                                            Waterpower price of 13.1c/kWh (10MW or less) and
                                             12.2c/kWh (10MW - 50MW)

                                            Time differentiated price for waterpower proponents
                                                 A Peak Performance Factor of 1.35*Contract Price applies
                                                  during on-peak hours (generally 11am-7pm ET on business
                                                  days) and 0.9*Contract Price during off-peak hours.


                                            Waterpower price indexed to inflation (100% pre COD;
                                             20% thereafter)

                                            Can qualify for Aboriginal and Community Pricing Adders


                                                                                                             13
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         Aboriginal and Community Projects

                                            Price Adders for Aboriginal and Community Participants
                                                  Varies based on the level of economic interest in the Project
                                                       A min. 10% economic interest leads to 20% of the max. price adder
                                                       A 50% economic interest leads to 100% of the max. price adder


                                            Lower security obligations
                                                  For example, Application Security is reduced to $5/kW from
                                                   between $10-$20/kW of Contract Capacity

                                            Eligibility
                                                  Aboriginal Community
                                                       a “band” under the Indian Act; Métis Nation of Ontario or any of its
                                                        charted community councils; a person deemed by the Gov of Ontario to
                                                        represent the collective interests of a community of Métis or aboriginal
                                                        individuals; or a corporation wholly owned by one or more of the above.
                                                  Community Investment Members
                                                       individuals, registered charity, not-for-profit corporation, or co-operative
                                                        corporation (not municipalities)



                                                                                                                                       14
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         Aboriginal and Community Projects


                                              Maximum Aboriginal and Community Price Adders

                                                                       Solar PV
                                                                                                           Landfill
                                            Renewable fuel      Wind (Ground      Water   Biogas Biomass
                                                                                                            Gas
                                                                       Mounted)


                                            Max. Aboriginal
                                                                 1.5      1.5      0.9     0.6     0.6       0.6
                                          Price Adder (¢/kWh)


                                           Max. Community
                                                                 1.0      1.0      0.6     0.4     0.4       0.4
                                          Price Adder (¢/kWh)




                                                                                                                15
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         Application Process Overview
                                                                                                    up to 6
                                                                                                    months
                                                                                  60 days




                                                                                                                           up to 6
                                                                                                                           months
                                                    FIT
                                                   Time
                                                   Stamp                  Capacity
                                                                          exempt
                                                                          facility?
                                                        Mandatory                 No
                                                                                       Connection Fail
                                          Apply                           Yes                                 Connection Pass FIT Contract
                                                       Requirements                    Availability
                                          to FIT          Met?
                                                                                                              Availability    Offer Notice
                                                                                          Test
                                                                                 Yes         Pass                  Fail
                                                                  No
                                                                                                                                              FIT
                                                                                                                                Accept Yes
                                                                                                                                           Production
                                                                                                                               Position?
                                                                                                                                              Line
                                                                                                                          economic No
                                                                                FIT Contract                   Economic
                                                                                                                                        Application withdrawn.
                                                                                Offer Notice                  Connection
                                                                                                                                         Security is refunded.
                                                                                                                 Test    not
                                                     Application is rejected.
                                                                                                                          economic Voluntary Withdraw
                                                       Application fee is
                                                             forfeit.
                                                                                                                                 FIT
                                                       Timestamp is lost.
                                                                                                                               Reserve
                                                                                                                                                          16
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         Eligibility and Application Requirements

                                            An applicant’s proposed facility must:
                                                  be renewable generation located in Ontario
                                                  not be more than 10MW (solar) or 50MW (hydro)
                                                  not be an existing generation facility unless expansion (addition of
                                                   generating units) or upgrade (refurbishment or replacement that
                                                   improves performance)
                                                  connect directly or indirectly to the IESO-Controlled Grid
                                                  not have had a prior contract (unless terminated in advance)

                                            Mandatory application requirements include:
                                                  Application Fee (<$5k) + Application Security ($10k/kW CC hydro)
                                                  Demonstrated Access Rights (option, lease, crown land priority
                                                   permit, applicant of record status, band council permissions)
                                                  Must rescind prior impact assessments and CCAs (unless capacity
                                                   exempt or construction started pre Sept. 24, 2009)
                                                  Authorization letter, connection details, email address …

                                            Consider:
                                                  Incremental Projects + Existing Facility no more than 50MW limit
                                                                                                                          17
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         Program Launch Period

                                            Began October 1, 2009 and continues for 60 days.

                                            Why? For an earlier FIT Time Stamp to gain a higher probability
                                             of getting access to limited connection resources

                                            Launch Applications
                                                  Criteria Points:
                                                        REA-exempt projects;
                                                        major equipment component contract;
                                                            major equipment component for waterpower (>10% of Project costs)
                                                        experience with similar facilities; and
                                                        financial capacity ($500 net worth per kW CC).
                                                  # COD Acceleration Days (min 0 - max 365 + 90 per Criteria Point)




                                                                                                                                18
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         Program Launch Period – FIT Timestamp

                                           Time Stamp Assignment
                                            Facilities with a higher # of COD Acceleration Days are
                                              assigned an earlier timestamp and in the event of a tie:

                                                  Facilities with a higher # of Criteria Points are assigned an
                                                   earlier timestamp and in the event of a tie:

                                                       Facilities with an earlier Access Rights date are assigned an
                                                        earlier timestamp and in the event of a tie:

                                                           A random draw is used to assign the FIT timestamp.




                                                                                                                        19
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         Transition Provisions for RESOP Contracts

                                            Transition provisions for RESOP contract holders during
                                             the first 30 days.
                                                 Must not have reached commercial operation

                                                 RESOP contract holders have the option to:
                                                      Rescind existing RESOP contracts & apply under FIT.
                                                          Will proponents or financiers be willing to accept the risk?
                                                      Limited option to amend RESOP contracts
                                                          Limited to wind facilities that have their Certificate of Approval
                                                           (Noise)?


                                            Deadline: October 30, 2009.



                                                                                                                                20
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Program
                                         General Comments

                                            Security is “at risk” and remains so until
                                                  An applicant takes one of the limited number of “off-ramps”; or
                                                  An applicant signs a FIT contract & achieves commercial operation

                                            OPA has significant discretion during the Application process
                                                  OPA reserves the right to cancel or suspend all or part of the FIT
                                                   Program at any time and for any reason
                                                  OPA reserves the right to, at its sole discretion, reject any
                                                   Application whether or not completed properly or containing all
                                                   necessary information
                                                  OPA will not be liable to pay an Applicant’s costs or expenses
                                                   under any circumstances

                                            Applicant is not permitted to assign an Application or permit or
                                             allow a change in Control of the Applicant until 1 year following
                                             the submission of the Application, and in any event, not without
                                             the prior written consent of the OPA, which consent may not be
                                             unreasonably withheld.

                                                                                                                        21
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Contract
                                         General Comments

                                            Term - 40 yrs for hydro, 20 yrs for other renewable sources
                                                  Completion and Performance Security required when signing FIT contract
                                                  Incremental NTP security required when NTP issued

                                            Design and Construction of the Facility
                                                  Obligation to design and build to meet Good Engineering and Operating
                                                   Practices and all applicable laws.
                                                  Must arrange all connection & metering requirements

                                            Notice to Proceed (NTP)
                                                  Must be requested by Supplier
                                                  Before requesting NTP, a Supplier must:
                                                        Complete its REA (or equivalent);
                                                        complete its CIA/SIA;
                                                        complete a financing plan (demonstrated commitment); and
                                                        complete a domestic content plan (if applicable)
                                                  Upon receiving a request for NTP, the OPA may
                                                        issue NTP
                                                        defer issuing NTP for up-to 365 days, or
                                                        terminate the FIT contract
                                                  OPA or Supplier may terminate the contract before NTP
                                                  OPA’s liability is limited prior to NTP being issued ($500,000+$20,000/MW)
                                                                                                                                22
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Contract
                                         Milestone Date for Commercial Operation

                                            A Supplier must meet the Milestone Date for
                                             Commercial Operation
                                                 Milestone date is measured from the FIT Contract Date and
                                                  is
                                                      three (3) years for solar PV, bioenergy and wind
                                                      four (4) years off-shore wind
                                                      five (5) years for waterpower
                                                 Minus # of COD Acceleration Days for launch applications




                                                                                                              23
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Contract
                                         Milestone Date for Commercial Operation

                                            What happens if you fail to meet the milestone date?

                                                 Failure reduces the Term by the # of days the facility is
                                                  delayed (subject to the OPA’s right to extend), unless
                                                  Supplier pays $0.15/kW per day delay to keep the original
                                                  Term

                                                 A failure to meet the milestone date by more than 18
                                                  months is an event of default – the OPA may terminate the
                                                  FIT Contract and has the option to (i) claim the security
                                                  deposit as liquidated damages or (ii) pursue a claim for
                                                  damages in court.




                                                                                                              24
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Contract
                                         Events of Default

                                            Notable Supplier Events of Default:
                                                  failure to deliver and/or maintain the Completion and Performance Security;
                                                  failure to perform any material covenant or obligation under the FIT Contract
                                                   if not remedied 15 Business Days after written notice thereof (cure period
                                                   may extend to 30 Business Days);
                                                  modifying, varying or amending in any material respect any of the features or
                                                   specifications of the Contract Facility or the Facility as outlined in the
                                                   Application or the FIT Contract Cover Page or making any change as to the
                                                   Facility's status as a Registered Facility that was not first consented to by the
                                                   OPA;
                                                  failure to meet the Commercial Operation Date on or before the date which is
                                                   18 months after the Milestone Date for Commercial Operation;
                                                  undergoing a change in Control without first obtaining written approval of the
                                                   OPA if required under the FIT Contract;
                                                  amalgamation, merger or transfer of the Facility without a permitted and valid
                                                   assignment; and
                                                  assigning the FIT Contract without first obtaining consent of the OPA if
                                                   required under the FIT Contract.




                                                                                                                                       25
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Contract
                                         Consequences of Default

                                            Upon an Supplier Event of Default, the OPA has the right to:
                                                  terminate the FIT Contract; or
                                                  draw down the Completion and Performance Security and require
                                                   the Supplier to replace such drawn down security with new
                                                   security.

                                            If the OPA elects to terminate, it may either:
                                                  Pre-COD - require the Supplier to pay as liquidated damages a
                                                   sum equal to the amount of all Completion and Performance
                                                   Security posted as of the Termination Date plus claim as damages
                                                   in courts for the remaining amount of Security which should have
                                                   been posted as of the Termination Date; or
                                                  Post-COD - retain all Completion and Performance Security
                                                   provided by or on behalf of the Supplier and can exercise all other
                                                   remedies available to it at law including pursuing a claim for
                                                   damages.



                                                                                                                         26
Lawyers · Patent and Trade-mark Agents   The Feed-in Tariff Contract
                                         Assignment and Change of Control

                                            FIT Contract until COD
                                                  Supplier has a limited right to assign the agreement, upon prior written
                                                   consent of the OPA
                                                        Only in circumstances where the location or structure to which the facility is affixed
                                                         has a primary commercial purpose other than the operation of the facility and such
                                                         location or structure is being sold, transferred or otherwise conveyed to the
                                                         proposed assignee to the Agreement.
                                                  Supplier may assign to an Affiliate without consent.
                                                  A change of Control of Supplier is permitted without consent of the OPA in
                                                   limited circumstances, otherwise no other change of control of Supplier is
                                                   permitted without the prior written consent of the OPA, which consent may be
                                                   unreasonably withheld in the OPA's sole discretion.

                                            COD until expiry of Term
                                                  Supplier may assign the agreement if it receives prior written consent from
                                                   the OPA, such consent not to be unreasonably withheld.
                                                  Supplier may assign to an Affiliate without consent.
                                                  A change of Control of Supplier is permitted following COD, provided the
                                                   Supplier provides the OPA with notice of such change of Control and such
                                                   additional information as the OPA reasonably require (names of new owners)
                                                   within 10 business days after such a change of Control having effect.



                                                                                                                                                  27
Lawyers · Patent and Trade-mark Agents   Renewable Energy Approval


                                           The REA is a new streamlined environmental approval process for most
                                            new renewable energy projects
                                                 Does not apply to waterpower projects
                                                 The Class Environmental Assessment continues to govern

                                           7 Regulations enacted 9/24/09
                                                 550m setbacks for wind large projects (>50kW)
                                                 Max. 40dB noise restriction on ground mounted solar
                                                 Various odour setbacks for bio-energy facilities
                                                 Includes detailed consultation requirements and protection of natural,
                                                  archaeological and heritage sites

                                           Appeals
                                                 A new procedure for challenging REA decisions by way of an ERT hearing
                                                  under the EPA, rather than leave-to-appeal under the EBR
                                                 6-month ERT process if an appeal meets the grounds for a hearing




                                                                                                                           28
Lawyers · Patent and Trade-mark Agents   Climate Change Considerations

                                           The Province’s commitment to phase-out 6,315 MW of
                                            coal-fired generation by 2014 is proclaimed “the single
                                            largest climate change initiative in North America.”
                                                 Early closure of 4 coal units in 2010 (four years ahead of
                                                  the previously announced closures) in September.


                                           GEGEA can also be seen as a climate change initiative
                                                 The increased development of renewable energy projects
                                                  will help reduce Ontario’s overall carbon footprint over time
                                                 This will have implications for the Province’s contribution to
                                                  federal and other emissions reductions targets




                                                                                                                   29
Lawyers · Patent and Trade-mark Agents   Climate Change Considerations
                                         GEGEA and Cap and Trade

                                            Bill 185 (introduced May 27/09) framework legislation aimed at
                                             implementing a GHG cap and trade system in Ontario
                                                  Currently at the committee stage of its Second Reading
                                                  Oct 7/09 MOE released draft a GHG Emissions Reporting
                                                   regulation and guideline; will form the basis of a provincial cap and
                                                   trade system

                                            Ontario plans to launch a cap-and-trade program for GHG
                                             emissions starting in 2010 covering facilities emitting more than
                                             100 Kt CO2e
                                                  Ontario is aiming to get a head start prior to the first Western
                                                   Climate Initiative compliance period beginning in 2012;
                                                  The Province is also following developments in the US around
                                                   Obama’s proposed federal cap-and-trade system;
                                                  Awaiting draft regulations for proposed Canadian federal cap-and-
                                                   trade system since fall 2008.

                                            The OPA will continue to take ownership of all “environmental
                                             attributes” for new renewable energy generation projects under
                                             the FIT
                                                                                                                           30
Lawyers · Patent and Trade-mark Agents   Conclusions
                                         What has changed under the GEGEA?

                                            Under GEGEA:
                                                 Minister has an increasingly important central role in the sector
                                                 OPA contracts still required to facilitate new generation
                                                      FIT available for new renewable generation - OPG may apply under FIT
                                                 OPA undertaking direct negotiations for existing hydro projects
                                                 Demonstrated effort to address connection capacity constraints and
                                                  connection procedures
                                                      Hydro One directed to expand the provincial transmission system
                                                      LDCs required to submit system expansion plans to facilitate new
                                                       renewable generation
                                                      OEB objectives now include facilitating renewable generation
                                                 New REA approval process
                                                 New role for LDCs in generation?
                                                      Can’t rate-base generation and must maintain separate accounts.
                                                 Coal phase out by 2014


                                                                                                                              31
Lawyers · Patent and Trade-mark Agents




                                                     If you have any questions, or
                                                     would like more information,
                                                     please feel free to contact:


                                               Linda Bertoldi or John Vellone
                                               Borden Ladner Gervais LLP
                                               416-367-6647 or 416-367-6730
                                               lbertoldi@blgcanada.com or jvellone@blgcanada.com




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