Stephen Armstrong

Stephen Armstrong spoke 125 times across 4 days of testimony.

  1. Stephen Armstrong, Counsel (POEC)


  2. Stephen Armstrong, Counsel (POEC)

    Good afternoon, Commissioner, Counsel, members of the public. My name is Stephen Armstrong, and I am Commission Counsel. I'm here today to present the overview report on early protest activities and legal challenges. This overview report summarises a sample protests and legal challenges relating to public health measures taken in response to the COVID-19 pandemic, and the timeframe is primarily 2020 and 2021, although we'll also touch on 2019 and 2022. This report is intended to provide some high level context to the very detailed evidence that we will hear in the coming weeks. What this report describes is the development over time of what could fairly be described as a mass protest movement against COVID related public health measures. The intent of this overview report is not to investigate the merits or demerits of any particular measure or of any particular protest. The report also addresses some of the legal challenges brought against these public health measures, and again it's not an investigation into the merits or demerits of any piece of litigation. Let me also say a few words on methodology. This report was compiled based on publicly available news sources that are indexed in the internet. We made a real effort to search for a variety of sources, and we tried to cover all of the regions in Canada. And given that broad scope, this overview report is not an exhaustive catalogue of all protests or all court challenges, and the absence of any event should not be taken as a suggestion by the Commission that it's irrelevant or less relevant. We've also made an effort in this report to just stick to the facts, the raw facts, the places, the dates, and numbers without any extra colour. So without further ado, I'm going to move through the report in chronological order. So I'll start at the beginning. Pages 5 to 6 of the report address a precursor event called the United We Roll convoy. On February 14th, 2014, a convoy of truckers known as United We Roll left Red Deer Alberta bound for Ottawa to protest the Federal Government's energy policies. Around 170 trucks of varying sizes left Red Deer as part of the convoy. Arriving in Ottawa on February 19th, 2019, the convoy participated in two days of demonstrations on or around Parliament Hill before dispersing. A Facebook page remains active. Although focussed on energy policy, the page still makes posts and has made posts in support of the Freedom Convoy in 2022. So turning to pages 6 to 10 of the overview report, this addresses the beginning of the protests movements in March 2020 to December 2020. And my colleague, Mr. Sheppard, already discussed the onset of COVID and the public health measures that were taken, and protests began pretty soon after those public health measures were adopted. There were protests reported in -- from major centres, such as Toronto, Vancouver, Edmonton, Calgary, Winnipeg, Saskatoon and Ottawa in April of 2020, and eventually we saw the beginnings of what appeared to be sort of loosely coordinated national protests by the summer. And so on, for example, July 19th, 2020, protests were held in cities all across Canada, and it was reported that these were part of a coordinated march to unmask movement opposed to mandatory masking. And momentum seemed to have grown or seems to grow from there as the protests grew in scale. On September 12th, 2020, for example, it was reported that several thousand people turned out to protest mask mandates and other measures in Montreal. As another example, in October of 2020, protestors rallied against lockdowns and other public health measures in Downtown Toronto, and it was reported that around 1,500 people were in attendance. And these protests were by no means limited to the big centres in Canada. For example, on November 7th, 2020, as many as 2,000 people marched through Aylmer, Ontario to protest public health measures, and it was reported that the protestors included many people from the town's large religious communities. And moving towards the end of the year, just another example, on December 19th, 2020, hundreds of people marched through Calgary, and as well through Montreal, and CTV News reported from Montreal that the protestors were marching in opposition to public health measures introduced by the Quebec Government. So turning to pages 10 to 28 of the overview report, this addresses events as they continue through 2021. And at the beginning of the year, Quebec had introduced a curfew, and it was reported that protests were held that same day, January 9th, 2021, in Montreal, Sherbrooke, and Quebec City. Protests were also reported in January and February in Moncton and Halifax, and as well, across the country. And these protests really seemed to pick up speed and reach a crescendo in the fall of 2021, overlapping with the federal election of that year. As well, in 2021, of course as my colleague mentioned, was around the time that mass vaccinations became available. So new measures were introduced, and protests continued in response to those new measures surrounding vaccination. And so going to the fall. From August 30th to September 5th, 2021, protestors demonstrated against vaccine mandates outside hospitals in major urban centres all across Canada, including St. John's, Newfoundland, Montreal, Ottawa, Winnipeg, Victoria, and Vancouver. Thousands of people were reported to come out and attend these protests right across the country. And the next weekend as well, on September 13th, 2021, protestors demonstrated across the country, including at Toronto General Hospital, and in Barrie, and London, Ontario, and various places across the country. And this was part of the protests organised by the Canadian Frontline Nurses. And then moving into the later part of the year is when the border measures for truckers and for other persons were announced in November, as my colleague discussed. As well, in November, Canadian Border Service Agency officers stopped a truck driver by the name of Brigitte Belton at the Windsor/Detroit crossing for failing to wear her mask, and she posted a video discussing the event on TikTok, and in the event she voiced frustration and emotion with the public health measures. She would later connect with Chris Farber on social media, and these people played a role in organising the convoy to Ottawa. So further protests continued into December 2021 and the New Year, and in the report, from pages 29 to 32, we provide a very basic skeleton of certain events leading up to the arrival of the Freedom Convoy in Ottawa in January of 2022. And so -- and it's in January of 2022, that we see the development of the Freedom Convoy idea and its launch. On January 13th, 2022, Chris Barber, Brigitte Belton, James Bauder, and others attend the Facebook Live event hosted by Pat King. The group discussed routes and logistics with the Freedom Convoy before an audience that reportedly reached 3,000 viewers at one point. On January 14th, 2022, Tamara Lich created a Facebook page and GoFundMe campaign for the Freedom Convoy. On January 22nd and 23rd, 2022, contingents of the Freedom Convoy departed from various points in British Columbia for Ottawa, and two other convoy contingents were planned to depart from Enfield, Nova Scotia, and Windsor later on in January, on the 27th. As of January 5th, 2022, the GoFundMe campaign had raised more than $4.5 million. News reports covered the progress of the convoy on a daily or near-daily basis as it crossed the country. Thousands of trucks and thousands of participants were reportedly participating in the convoy as it made its way to Ottawa. Freedom Convoy participants arrived in Ottawa on or around January 28th and 29th, 2022, and that takes us up to the subject matter of this hearing, and we anticipate that further evidence on the origins, development of the Freedom Convoy, the protest, and blockades will be adduced during these hearings. So Mr. Commissioner, that’s the Overview Report.


  3. Stephen Armstrong, Counsel (POEC)



  4. Stephen Armstrong, Counsel (POEC)

    Counsel, I just wanted to let you know that the document is available.


  5. Stephen Armstrong, Counsel (POEC)

    Good morning, Mr. Deering, and Ms. Hope Braun. My name is Stephen Armstrong and I’m Commission Counsel. Thank you for coming today. I have 45 minutes to ask you some questions, and because you’re a panel, I’m going to ask questions mostly one at a time. But when I have questions for you as a group -- sorry, you have to be sworn. I forgot about that. I got too eager.


  6. Stephen Armstrong, Counsel (POEC)

    So good morning again. As I was just explaining, because it's a panel I'm going to ask questions mostly one at a time, but when I have a question for you as a group, I'll try to make that clear; okay? So I understand, and this is for the panel, I understand that you've both provided statements to your counsel?


  7. Stephen Armstrong, Counsel (POEC)

    And have you had a chance to review those statements before testifying today?


  8. Stephen Armstrong, Counsel (POEC)

    And did you want to make any corrections to those statements?


  9. Stephen Armstrong, Counsel (POEC)

    Okay. And so in the interest of time, I'm not going to put them on the screen, but for the record, Mr. Deering's statement is produced at HRF00001598, and Ms. Hope-Braun's statement is produced at HRF00001606. So I just want to ask some questions about your background really quickly. So Mr. Deering, I understand that you're a veteran of the Canadian Armed Forces?


  10. Stephen Armstrong, Counsel (POEC)

    And you served a tour of duty in Afghanistan.


  11. Stephen Armstrong, Counsel (POEC)

    And I understand that you were wounded on that tour?


  12. Stephen Armstrong, Counsel (POEC)

    Can you briefly tell the Commissioner about that event?


  13. Stephen Armstrong, Counsel (POEC)

    That's okay, thank you. I also saw, sir, and we'll take a moment, I saw that you're wearing medals?


  14. Stephen Armstrong, Counsel (POEC)

    Can you just explain what the medals are?


  15. Stephen Armstrong, Counsel (POEC)

    And I understand now that you're retired from the Canadian Armed Forces?


  16. Stephen Armstrong, Counsel (POEC)

    And you reside in Hanwell, New Brunswick.


  17. Stephen Armstrong, Counsel (POEC)

    Thank you. Ms. Hope-Braun, I understand that you're from Peterborough, Ontario?


  18. Stephen Armstrong, Counsel (POEC)

    And you studied environmental studies at Sandford Fleming College?


  19. Stephen Armstrong, Counsel (POEC)

    Sir Sandford. And you're a mother to two children?


  20. Stephen Armstrong, Counsel (POEC)

    Thank you. So if I can ask Mr. Deering, I understand that you travelled to Ottawa to protest with the convoy. What made you want to come to Ottawa and protest?


  21. Stephen Armstrong, Counsel (POEC)

    And so when you travelled to Ottawa, what did you understand that you were there to protest?


  22. Stephen Armstrong, Counsel (POEC)

    And why was that important to you?


  23. Stephen Armstrong, Counsel (POEC)

    That's okay. I'll ask some questions now to Ms. Hope-Braun. I also understand that you travelled to Ottawa to protest. What made you want to come to Ottawa to protest?


  24. Stephen Armstrong, Counsel (POEC)

    And so when did you come to Ottawa?


  25. Stephen Armstrong, Counsel (POEC)

    And can you tell the Commissioner what your experience was with those protests?


  26. Stephen Armstrong, Counsel (POEC)

    And if I could ask, Mr. Deering, building on that, what was your experience with the protests and how did it compare, how was it similar to or different from Ms. Braun's -- Ms. Hope-Braun's?


  27. Stephen Armstrong, Counsel (POEC)

    I was just asking for your experience. And sorry, did you have anything more to add or were you done?


  28. Stephen Armstrong, Counsel (POEC)

    Please do, yeah.


  29. Stephen Armstrong, Counsel (POEC)

    And so for the panel, I understand that you both -- you were coming to Ottawa and then going home and coming back. Once the Emergencies Act was invoked, why did you either want to come to Ottawa or remain in Ottawa?


  30. Stephen Armstrong, Counsel (POEC)

    Ms. Hope-Braun?


  31. Stephen Armstrong, Counsel (POEC)

    So after the Emergencies Act was invoked, why did you want to come back to Ottawa or remain in Ottawa if you were already there?


  32. Stephen Armstrong, Counsel (POEC)

    And so building on that, Ms. Hope-Braun, once the Emergencies Act was invoked, what was your understanding of your ability to lawfully protest in the downtown area?


  33. Stephen Armstrong, Counsel (POEC)

    Well, that’s okay. We can come back to it. I’ll just ask Mr. Deering, what was your understanding once the Emergencies Act was invoked, of your ability to lawfully protest in the downtown area?


  34. Stephen Armstrong, Counsel (POEC)

    And so Mr. Deering, I understand that on February 18th, 2022, you were in Ottawa protesting as well; correct?


  35. Stephen Armstrong, Counsel (POEC)

    Where were you staying in Ottawa that day at that time?


  36. Stephen Armstrong, Counsel (POEC)

    Do you recall where on Bank Street you parked?


  37. Stephen Armstrong, Counsel (POEC)

    Was it in the downtown area?


  38. Stephen Armstrong, Counsel (POEC)

    And so you -- when you drove in, did you pass any police checkpoints or anything like that?


  39. Stephen Armstrong, Counsel (POEC)

    Okay. Ms. Hope-Braun, I understand that you were in Ottawa protesting on February 19th. That’s correct.


  40. Stephen Armstrong, Counsel (POEC)

    Where were you staying at the time or how did you -- how did you find yourself in Ottawa?


  41. Stephen Armstrong, Counsel (POEC)

    And when did you begin staying in that hotel?


  42. Stephen Armstrong, Counsel (POEC)

    Okay. And Mr. Deering, on the 18th -- and I’m going to stick with you for a few questions. On the 18th, where was the protest that I understand you participated in? Do you recall where in the downtown it was?


  43. Stephen Armstrong, Counsel (POEC)

    And why did you want to do that?


  44. Stephen Armstrong, Counsel (POEC)

    Were you told at any time or informed at any time that you couldn’t be there or it was unlawful for you to be there?


  45. Stephen Armstrong, Counsel (POEC)

    And I understand that you were arrested on the 18th. Is that correct?


  46. Stephen Armstrong, Counsel (POEC)

    Can you -- can you tell us briefly how you came to be arrested?


  47. Stephen Armstrong, Counsel (POEC)

    Just asking about how you came to be arrested.


  48. Stephen Armstrong, Counsel (POEC)

    Take your time.


  49. Stephen Armstrong, Counsel (POEC)

    It's okay, Mr. Deering. Your statement is in the record, so if I could actually move you back in time. What were you and your group doing just before you were arrested? What activity were you taking part in?


  50. Stephen Armstrong, Counsel (POEC)

    And at any time, either before you were arrested or after, were you given the option to go to another place in Ottawa to protest?


  51. Stephen Armstrong, Counsel (POEC)

    Okay. Ms. Hope-Braun, I think as we said earlier, I understand you were protesting on February 19th ---


  52. Stephen Armstrong, Counsel (POEC)

    --- in Ottawa? Where was that protest that you participated in?


  53. Stephen Armstrong, Counsel (POEC)

    And were you told before, or any point that day, or before or after your arrest that you were not allowed to be where you were?


  54. Stephen Armstrong, Counsel (POEC)

    What gave you the sense that you weren't welcome there?


  55. Stephen Armstrong, Counsel (POEC)

    And either before or after your arrest, were you given the opportunity or were you told about any kind of place you could go in Ottawa to peacefully protest?


  56. Stephen Armstrong, Counsel (POEC)

    And how did you come to be arrested? Can you tell us about that?


  57. Stephen Armstrong, Counsel (POEC)

    And just coming back to Mr. Deering, you had mentioned just before your arrest, you'd said something about an unlawful order. I just wanted you to clarify what you -- what were you referring to? What was the unlawful order? Take your time.


  58. Stephen Armstrong, Counsel (POEC)



  59. Stephen Armstrong, Counsel (POEC)

    You had mentioned an unlawful order, and I just wanted you to clarify what you were referring to.


  60. Stephen Armstrong, Counsel (POEC)

    So I think the context was I had asked you why you were there and you said that you were there -- well, I don't want to put words in your mouth, but I understood it to be sort of in defiance of an unlawful order, or you weren’t leaving because of an unlawful order?


  61. Stephen Armstrong, Counsel (POEC)

    And what is the mandate?


  62. Stephen Armstrong, Counsel (POEC)

    And for the panel, can you just tell us what was the impact (indiscernible)


  63. Stephen Armstrong, Counsel (POEC)

    We’ll put it that what was the impact of these events?


  64. Stephen Armstrong, Counsel (POEC)

    On you personally.


  65. Stephen Armstrong, Counsel (POEC)

    Sorry; on -- the events in Ottawa.


  66. Stephen Armstrong, Counsel (POEC)

    And ---


  67. Stephen Armstrong, Counsel (POEC)

    And Mr. Deering did you, did you want to answer that as well?


  68. Stephen Armstrong, Counsel (POEC)

    I’m wondering what the impact of your experience in Ottawa was and how it ended on you as a person?


  69. Stephen Armstrong, Counsel (POEC)

    Yes, Ms. Hope-Braun?


  70. Stephen Armstrong, Counsel (POEC)

    Okay. And I’d just like to close out with the panel. I’m going to ask both of you -- let’s start with Ms. Hope-Braun; is there anything that I didn’t ask you about that you wanted to say, that we didn’t get to talk about?


  71. Stephen Armstrong, Counsel (POEC)

    Mr. Deering?


  72. Stephen Armstrong, Counsel (POEC)

    Thank you. Those are all my questions.


  73. Stephen Armstrong, Counsel (POEC)

    I, if I can answer ---


  74. Stephen Armstrong, Counsel (POEC)

    No re-examination, Commissioner.


  75. Stephen Armstrong, Counsel (POEC)

    No, Mr. Commissioner. Thank you. Okay. Well, thank you for your testimony, Mr. Mackenzie, and good luck with your trials.


  76. Stephen Armstrong, Counsel (POEC)

    Good afternoon, Mr. Keenan, and Mr. Dea. My name is Stephen Armstrong. I’m Commission Counsel. I’m going to be asking some questions about the economic impact analysis from the border blockades, and my questions are primarily for Mr. Dea, but Mr. Keenan, if you have anything to add, please do. So Mr. Dea, I understand that your directorate has previous experience analyzing trade shocks? Is that correct?


  77. Stephen Armstrong, Counsel (POEC)

    Can you tell the Commissioner about some of that experience?


  78. Stephen Armstrong, Counsel (POEC)

    And just in terms of understanding the impact on border blockades, the Commission understands from the Institutional Report that the nature of trade between Canada and the United States, I guess some of the features of the economy are an important background. Can you describe or provide some context on that?


  79. Stephen Armstrong, Counsel (POEC)

    If I could jump in, sorry?


  80. Stephen Armstrong, Counsel (POEC)

    Could I just ask, I guess, more specifically of the ports of entry that experienced blockades in February 2022, which were the most concerning from an economic perspective and why?


  81. Stephen Armstrong, Counsel (POEC)

    Thanks. And I just wanted to pick up on a point I think that you were just getting into there, is that some of these goods that you were looking at is critical goods; correct? Or something that could be deemed critical goods. Can you explain to the Commissioner what are critical goods? What is the significance of that?


  82. Stephen Armstrong, Counsel (POEC)

    Right. But I just want to tie back to the critical goods for a second. I think you linked that to sort of the wellbeing -- the goods that are essential for wellbeing and health. Is it fair to say that if we’re looking at critical goods, that imports are more important than exports? Or are they equally important?


  83. Stephen Armstrong, Counsel (POEC)

    So Mr. Clerk, I’d like to call up the Institutional Report. It’s at DOJ.IR. several zeros, number 5. And if we could turn to page 22, please? And I guess I’m going to ask about paragraph 89 here. You have some figures. So this is focusing on the Ambassador Bridge. And am I correct in understanding that, for example, where it says “agri-food” in the bullet, it’s 10.7 percent of all exports. Is that a percent of agri-food exports nationwide that are going through the Ambassador Bridge?


  84. Stephen Armstrong, Counsel (POEC)

    And that would apply to pharmaceuticals and critical minerals.


  85. Stephen Armstrong, Counsel (POEC)

    And so in paragraph 90, you address western Canada. And in the second -- the second sentence there -- I’m sorry. I shouldn’t say “you”. It’s the institutional report. But it refers to western Canada as one to two percent of critical exports and imports. Is it fair to say that when we’re talking about critical goods, is the main concern the Ambassador Bridge?


  86. Stephen Armstrong, Counsel (POEC)

    Okay. And then on paragraph 91, the report addresses the impact on automobile manufacturers. Can you tell the Commissioner, how did you come to learn -- how did Transport Canada come to learn about the impact on automobile manufacturers, and can you just expand on that a bit?


  87. Stephen Armstrong, Counsel (POEC)

    And did you consider in your analysis whether these auto manufacturers could make up production after the blockade’s ended?


  88. Stephen Armstrong, Counsel (POEC)

    I’d like to paragraph 92. It’s on the screen already. Here you address the food and beverage industry and it says that it appeared likely at the time that some manufacturers would have to shut down if the blockade persisted, which in turn could lead to less availability of food and beverage products and higher prices. Can -- do you know -- how did you come to the opinion that that appeared likely? What was the source of that?


  89. Stephen Armstrong, Counsel (POEC)

    How did you come to understand that that occurred?


  90. Stephen Armstrong, Counsel (POEC)

    Mr. Clerk, can we please go to page 23 of the report, the next page. There’s a chart in the middle of the page. We can scroll up or down if you want the context, but Mr. Dea, could you walk us through this chart, briefly?


  91. Stephen Armstrong, Counsel (POEC)

    So trade -- sorry to interrupt. So just to get clarity on some of the terms, I guess -- and I know they’re -- I think they’re explained in the paragraphs above, but trade per day, that includes imports and exports; correct?


  92. Stephen Armstrong, Counsel (POEC)

    And what is -- what is “trade impact”? What is that figure ultimately showing us?


  93. Stephen Armstrong, Counsel (POEC)

    Right. But it doesn’t purport to be the cost to the Canadian economy; correct? It’s - --


  94. Stephen Armstrong, Counsel (POEC)

    Okay. And then at paragraph 97 here, we have a figure that says that the total number of trucks entering or returning to Canada from the United States was down five percent in February 2022 relative to the same period in 2021. Are you able to say what the cause of that five percent reduction was, what was the cause?


  95. Stephen Armstrong, Counsel (POEC)

    Are there any other factors that would impact, if you just looked year over year from 2021 to 2022, that would impact the flows?


  96. Stephen Armstrong, Counsel (POEC)

    And do you know how much of the 5 percent, do you know how much that represents critical goods flowing across? Was that impacted?


  97. Stephen Armstrong, Counsel (POEC)

    And at paragraph 98, the report notes that a reduction in traffic was observed in Western Canada, and the number of trucks entering or returning to Canada decreased by 48 percent at Coutts and 29 percent at Emerson. Do you have the information for whether there were corresponding increases at the other nearby ports of entry in Alberta and Manitoba?


  98. Stephen Armstrong, Counsel (POEC)

    And was it?


  99. Stephen Armstrong, Counsel (POEC)

    Okay. Mr. Clerk, I’d like to go to the next page, please? So it sort of ends the economic impact section here of the report, saying, it’s clear that there has been a impact; however, it’s hard to attribute the shifts noted above solely to the impact of the blockades. Can you tell the Commissioner, I guess, some of the challenges in making that assessment, and why that’s not possible?


  100. Stephen Armstrong, Counsel (POEC)

    And if that’s the case, then how can it be clear that the blockades have an impact?


  101. Stephen Armstrong, Counsel (POEC)

    And I’d like to talk about that now, actually. So Mr. Clerk, if you could pull up PB.CAN.00000840? (SHORT PAUSE)


  102. Stephen Armstrong, Counsel (POEC)

    So Mr. Dea, I think you’ve been alluding to this document. This is a document that your -- I understand your Directorate prepared; is that correct?


  103. Stephen Armstrong, Counsel (POEC)

    And we have some -- a Key Messages box here that summarizes the analysis. Could you walk the Commissioner through some of the key messages?


  104. Stephen Armstrong, Counsel (POEC)

    Okay. So ---


  105. Stephen Armstrong, Counsel (POEC)

    And can I ask, what kind of assumptions went into the $45 million a day scenario?


  106. Stephen Armstrong, Counsel (POEC)

    And there’s a reference in the -- when you’re describing in the Key Messages the $45 million a day scenario says: “...$45M/day over the first week based on current mitigation efforts put in place by shippers and available alternative options.” What assumptions were you making about mitigation efforts for that scenario?


  107. Stephen Armstrong, Counsel (POEC)

    Okay. Mr. Clerk, I’d like to go to another document, it’s SSM.CAN.00003798. And if you could go to the bottom, it’s an email chain. Okay. So Mr. Dea, I don’t have any questions about this first email, but I just would pause on it to let you refresh your memory. Okay. And can we scroll up to the next email? So here, Mr. Dea, you’ve responded to Ms. Turcotte on February 10th, on economic impacts of the blockades at border crossings. And Mr. Clerk, could you scroll down? And so in these three scenarios you outline here trade shock 1, 2, and 3. Do these correspond to the scenarios that we were just talking about?


  108. Stephen Armstrong, Counsel (POEC)

    So this is about the Ambassador Bridge.


  109. Stephen Armstrong, Counsel (POEC)

    And Mr. Clerk, could we scroll up again? And so Ms. Turcotte responds to your email and she had some questions for you. Well, first she says: “At first glance, impacts seem large to us, especially scenarios 2-3, implying limited diversion options and high sensitivity to any delays.” Do you have any response to that comment?


  110. Stephen Armstrong, Counsel (POEC)

    And so she had a number of questions for you. I’m -- I think mostly just looking to highlight the first one, she asked: “What do you assume in terms of % of [impact] shipments that are able to divert to other crossings (e.g., Sarnia/Niagara land crossings; rail [and] air)?” And Mr. Clerk, if we could go up to the next email, I believe Mr. Dea, you’ve responded. If we could go up to the next page as well; this is the beginning of your email. Well let’s find the -- yeah, so this is Mr. Dea’s response on February 11th. If we could scroll down a bit. Here we see some of the information from the backgrounder that we just looked at. If we could scroll back down to the other page. So my understanding, Mr. Dea, if you recall this email, is that the questions are in the bullet points, and your response is below in a different sort of colour; is that right?


  111. Stephen Armstrong, Counsel (POEC)

    And so your response to the question about your assumption on diversion, it looks like you said, "Our scenarios do not consider any diversions to other crossingS." Is that correct?


  112. Stephen Armstrong, Counsel (POEC)

    Okay. And so does your comment about the scenarios not considering diversion, does that apply to scenario 1 as well, the $45 million a day?


  113. Stephen Armstrong, Counsel (POEC)

    Sorry, I'd like you to clarify on that. So does that mean there's no diversion on just day one of the one-week closure, or any of the seven days of the week?


  114. Stephen Armstrong, Counsel (POEC)

    And ---


  115. Stephen Armstrong, Counsel (POEC)



  116. Stephen Armstrong, Counsel (POEC)

    So, Mr. Clerk, could we go up to the first part of Mr. Dea's response? Yeah, you can pause right here. So at the bottom of the screen, I just -- there's this -- looks like you got some data here on diversion. And so I'm just -- I would ask you some questions about that. Where did you get this information from?


  117. Stephen Armstrong, Counsel (POEC)

    And so were you able to factor that into your scenario one, or is that not factored in?


  118. Stephen Armstrong, Counsel (POEC)

    Mr. Clerk, can we scroll up to the next email in the chain? So, Mr. Dea, I think you're not on the chain anymore, but I wanted to get your response because finance officials continue to comment on the scenarios. And in the first bubble, they say, "Based on description scenarios 2 and 3, I'm not sure we should include these [...], especially given that [the] Ambassador['s] open again." And then in bullet two, they say, "Scenario 1 seems like a reasonable upper-bound for the daily cost [...]. They could easily get there, and they see it as an upper bound. Do you have any comment on that point, or anything to add?


  119. Stephen Armstrong, Counsel (POEC)



  120. Stephen Armstrong, Counsel (POEC)

    Mr. Clerk, could we scroll up and see the date?


  121. Stephen Armstrong, Counsel (POEC)



  122. Stephen Armstrong, Counsel (POEC)

    February 14th.


  123. Stephen Armstrong, Counsel (POEC)

    And at the end of the second bullet, I just want to get your comment on the remark that, "The costs are also probably mostly transient with catch-up production expected [in] the coming weeks." Do you have any response to that?


  124. Stephen Armstrong, Counsel (POEC)

    And if I could just follow up on that with one question, the concerns you outlined, Mr. Keenan, about the automotive industry and about Canada’s reputation and attracting investment, was that more top of mind than the importation of critical goods? What was most important in your mind at that time?


  125. Stephen Armstrong, Counsel (POEC)

    Thank you. Those are my questions. My colleague, Mr. Cameron, has some more.