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Republic of the Philippines Department of Transportation LAND TRANSPORTATION FRANCHISING & REGULATORY BOARD East Avenue, Diliman, Quezon City MEMORANDUM CIRCULAR NUMBER 2019-01 SUBJECT: CONSOLIDATED GUIDELINES ON THE PROCESS OF ISSUANCE OF CERTIFICATE OF PUBLIC CONVENIENCE (CPC) AND PROVISIONAL AUTHORITY (PA)/SPECIAL PERMIT (SP) UNDER THE OMNIBUS FRANCHISING GUIDELINES & PUBLIC UTILITY VEHICLE MODERNIZATION PROGRAM (PUVMP) WHEREAS, the Secretary of the Department of Transportation issued Department Order No. 2017-011, Re: OMNIBUS GUIDELINES ON THE PLANNING AND IDENTIFICATION OF PUBLIC ROAD TRANSPORTATION SERVICES AND FRANCHISE ISSUANCE, which adopted rules and procedures for the issuance of franchises for public transport routes and services; WHEREAS, on 13 March 2018, this Board issued Memorandum Circular No. 2018-006, entitled GUIDELINES FOR THE PUBLIC UTILITY VEHICLE MODERNIZATION PROGRAMS's INITIAL IMPLEMENTATION PURSUANT TO DEPARTMENT ORDER NO. 2017-011, OTHERWISE KNOWN AS THE OMNIBUS FRANCHISING GUIDELINES; WHEREAS, on 16 March 2018, this Board issued Memorandum Circular No. 2018-008, entitled CONSOLIDATION OF FRANCHISE HOLDERS IN COMPLIANCE WITH DEPARTMENT ORDER NO. 2017-011, OTHERWISE KNOWN AS THE OMNIBUS FRANCHISING GUIDELINES; WHEREAS, on 29 May 2018, this Board issued Memorandum Circular No. 2018-009, entitled IMPLEMENTING RULES ON SELECTION OF TRANSPORT OPERATORS FOR LGU-PREPARED LPTRPs UNDER DEPARTMENT ORDER NO. 2017-011, OTHERWISE. KNOWN AS OMNIBUS FRANCHISING GUIDELINES; WHEREAS, on June 6, 2018, this Board issued Memorandum Circular No. 2018-012, entitled GUIDELINES FOR DROPPING AND SUBSTITUTION OF PUJ UNITS UNDER THE, PUVMP; WHEREAS, on 27 June 2018, this Board issued Memorandum Circular No, 2018-013, entitled IMPLEMENTING GUIDELINES IN THE ACCEPTANCE OF APPLICATIONS FOR NEW CPC UNDER THE IMPLEMENTATION OF THE PUBLIC UTILITY VEHICLE MODERNIZATION PROGRAM; WHEREAS, in the implementation of the said issuances, which were intended to serve public clamor and demand for modern PUVs, there were issues that came up, which need to be clarified and addressed properly; WHEREAS, the purpose of this Memorandum Circular is to simplify and expedite the implementation of the PUVMP; NOW THEREFORE, premises considered, the Board hereby adopts the following consolidated guidelines and policies; -— 1) a ] Bes C spi) Dine oe ay aaeasee fn 5a. = fly Nos 426-2485 | 426-2501 2ETSTO 1 I PRINCIPLES A. This Memorandum Circular applies to the selection of operator and subsequent issuance of CPC —for_—existing, — rationalized = and new/developmental/missionary/P2P fixed routes (with origin and destination and detailed route description), be they inter-regional, intra-regional, intra- provincial, inter-provincial routes and in other metropolitan areas, B. The one route-one operator-one franchise scheme under the Industry Consolidation Component of the OFG/PUVMP is encouraged. Towards this end, Applicant-Operator/s intending to serve a particular route should be a legal/juridical entity who will be collectively responsible and accountable for the delivery of transport services in that particular route. Should there be reasonable/justifiable grounds to allow more than one (1) legal entity in one (1) route, a common fleet management with organized dispatch system is required; C. Qualified existing operator/s shall retain the franchise privileges on the route they are currently plying or rationalized routes (.e., existing routes modified by the approved LPTRP or DOTr rationalization study). Qualified existing operators are those which consolidated into a single legal entity (ie, cooperative or corporation), passed the minimum legal, technical and financial requirements as defined hereunder, and satisfied pertinent requirements for consolidation; D. Should the Applicant-Operator fail to consolidate all the authorized units in an existing route, the Applicant-Operator shall present justifiable ground/s therefor for the consideration of the Board or the Regional Director concemed; E. Issuance of CPCs for new/developmental/missionary/P2P routes is open to all interested applicants but with preference to existing area-based operators. F. All qualified Applicant-Operators_ for_~=a_—_ particular new/developmental/missionary/P2P route shall be ranked according to the availability of compliant units. In case of a tie, preference shall be accorded to qualified existing area-based operators. If no existing area-based operator qualifies and a tie results in, a public lottery shall be conducted to determine which qualified Applicant-Operator shall proceed with the CPC application. VEHICLE SPECIFICATIONS, ‘A. Only Public Utility Vehicles (PUVs) with at least Euro-4 compliant engines and compliant with the vehicle specifications provided under Department Order No, 2017-011 and vehicle standards based on the Philippine National Standards (PNS) shall be accepted as authorized units. PUB | PUBs within highly urbanized independent cities, speed limiter, and and | dashboard camera (at least 24 hours of recording) compliant with LTFRB Mini-Bus B. Further, all PUVs shall be installed with OFG-required devices as follows: GNSS Receiver, Free Wi-Fi, past 72 hours of operation), Automatic Fare Collection System (AFCS) for specifications; with lay-over/garage sufficient space for all units , plus additional space of at least 30% of the total PUV space requirement ui ent ‘UV within highly urbanized independent cities, speed limiter, and [ine Ruts sor Ron dashboard camera (at least 24 hours of recording) compliant with LTFRB GNSS Receiver, Free Wi-Fi, CCTV with continuous recording of past 72 hours of operation, Automatic Fare Collection System (AFCS) for PUJs and ifichtions; with lay-over/garage sufficient space for all units, plus D MAR 15 2019) addi tional space of at least 30% of the total PUV space requirement rE Cc Tine i) Page 20f7 Ee = I APPLICANT-OPERATOR QUALIFICATION REQUIREMENTS All Applicant-Operators shall pass the following minimum qualifications before they can be considered for CPC issuance. A. Legal Qualification Filipino citizen who is at least eighteen (18) years old i, Certified true copy of Birth Certificate duly issued by the Philippine Statistics Authority (PSA); ii, Income Tax Return (ITR) duly stamped received by the Bureau of Internal Revenue (BIR) or Certificate of Registration (COR) issued by the BIR for new registrants; iii, Certificate of Business Name issued by the Department of Trade and Industry (DTI); Filipino domestic juridical entity whose purpose is to provide transportation services; If corporation or partnership including joint ventures or consortia of local firms, Certified True Copies of Certificate of Incorporation, Articles and By-Laws, and latest General Information Sheet duly received/issued by the Securities and Exchange Commission; If consortium/joint venture is not yet existing, a duly-notarized Memorandum of Agreement by and between the members that they will form a special purpose legal entity, including individual Certified True Copies of Certificate of Incorporation, Articles and By-Laws, and latest General Information Sheet duly received/issued by the Securities and Exchange Commission of each would-be consortium members, if Applicant-Operator is selected; If cooperative, Certified True Copies of Certificate of Registration, Articles and By-Laws and latest Cooperative Annual Performance Report duly issued by the Cooperative Development Authority (CDA), and Certificate of Accreditation issued by the Office of Transportation Cooperative (OTC); If not yet consolidated cooperative/corporation, evidence/proof of application for consolidation from SEC/CDA with individual affidavits of conformance/approval from members willing to have their CPCs cancelled in exchange for a single consolidated CPC in favor of the Applicant-Operator. B. Technical Qualification 1 7, Law cent! . sounesieegompliant with fare media related technical specifications as determined by AR 15 2019 . Number of compliant units available with OR/CR and undertaking that the remaining units will be made available within three (3) months as certified by the vehicle manufacturer/supplier, reckoned from the date of submission of qualification documents, If no compliant units are available, undertaking that 25% of the number of required units within three (3) months, 50% within six (6) months, 100% within nine (9) months will be delivered as certified by the vehicle manufacturer/supplier, reckoned from the date of submission of pre- qualification documents, Undertaking that the units shall be compliant with the specifications and standards under OFG and DTI-PNS as herein aforementioned; If the route applied for are not yet covered by LPTRP or DOTr rationalization study, undertaking that they will immediately comply with the approved rationalization study; When applicable, undertaking pursuant to Memorandum Circular No. 2018- 015 for lease/lease-to-own units; Fleet Management System with organized vehicle dispatch procedures; Evidence of formal arrangement with Automatic Fare Collection (AFC) service-provider that will offer inter-operable AFC service that is fully “TERB, in case the Applicant-Operator is selected; i Page 3 of 7 | ~ 8. Copies of Letter of Support from property owners/managers regarding access to, or use of, each off-street loading and unloading area in the route map; 9. Proposed garage/depot space pursuant to Memorandum Circular No. 2017- 027, or undertaking to have a compliant garage with zoning clearance immediately upon availability of compliant PUV units which is to be submitted on or before the issuance of Provisional Authority for said units C. Financial Capability 1. Original or Certified True Copy of the latest Audited Financial Statement and duly stamped "received" by the Bureau of Internal Revenue or its Authorized Agent Banks; or Certificate of Registration from Bureau of Internal Revenue for newly formed legal entities, 2. Manner of acquisition for the compliant PUV units identifying the funding source and with detailed financing plan when applicable; proof/s of support from funding source; 3. Proof of financial capability of at least equal to the set-aside bank deposit, duly certified by the depository bank, which is equivalent to one hundred thousand pesos (Php 100,000.00) for Public Utility Buses/Mini-bus, and fifty thousand pesos (Php 50,000.00) for UV/Public Utility Jitney Services, multiplied by the total number of vehicles for the route that the Applicant- Operator is applying for, inclusive of the paid-up capital posted by the applicant. This amount is to be used for PUV maintenance, repair and operation; 4. Financial projections for the first five (5) years of operations, showing detailed revenues and costs, as well as projected demand, including assumptions made IV. THE QUALIFICATION COMMITTEE For purposes of this Memorandum Circular, a Qualification Committee shall be created consisting of at least the following: A. For inter-regional routes and NCR routes: Chairperson LTFRB Executive Director Vice-Chairperson ial Director Member Member LTERB Legal Division Chief Member LTERB ISMD Division Chief Observer OTC Representative Observer 2 COA Representative Observer DOTr Representative B. For intra-regional routes (excluding LTFRB-NCR). Chairperson To be assigned by the Regional Director concerned Member Technical Member 2 Legal Observer 2 COA Representative Observer 2 DOTr Representative ‘The Board may create additional committees when the need arises. Duly-authorized representative for each member may be allowed, except for the Chairperson and Vice-Chairperson. The Qualification Committee shall undertake the following procedures in the Performance of its functions. Page 4 of 7 Y. PROCEDURES FOR QUALIFICATION and SELECTION OF APPLICANT- OPERATORS A. Existing/Rationalized Route 1. The Applicant-Operator shall submit to the concerned Qualification Committee, a letter of intent including its qualification documents (per Section IIT hereof) which are to be submitted in the following manner: one (1) original copy and four (4) photocopies containing a Table of Contents and bound together in ring binders or folders SEALED in an envelope or a box and appropriately addressed and marked; 2. The Committee shall examine the Qualification Documents within three (3) working days after the submission date of Qualification Documents. The detailed evaluation of the compliance by the Applicant-Operator with the Legal, Technical and Financial Capability qualification requirements shall be based solely upon the Qualification Documents submitted. The Committee may also make inquiries with any person, government authority, client organization, officer, director, employee or other agent of any Applicant-Operator and/or its AMfiliate for the purpose of clarifying any matter included in the Applicant's qualification documents; 3. All submitted information and any clarifications requested by the Committee shall be assessed against the criteria for qualification as set out above and generally rated on a "PASS-or-FAIL" basis. An Applicant-Operator will be rated as "QUALIFIED" if each criterion is rated "PASSED" and each required Qualification Document and attachment is completely submitted. The Applicant-Operator will be disqualified if any criterion is rated "FAILED" or if any required Qualification Document or attachment is missing; 4, If Applicant-Operator is found qualified and compliant with all the foregoing requirements, including the Affidavits of conformance of existing individual operators within the route applied for, a new case number will be issued; 5. Should there be more than one legal entity intending to consolidate in a given route due to justifiable reason/s, said legal entities must execute an undertaking to commit to a common fleet management with organized vehicle dispatch system with other legal entities to serve the route; 6. Should there be a need for any additional units on an existing route as a result of LPTRP or DOTr Route Rationalization Study, the consolidated operator shall be given priority to increase their authorized units to meet the demand. If the consolidated operator fails to meet said additional demand in their given route after the period as the Board may subsequently determine but in no case more than six (6) months, new entrants may be entertained; The selection of the new operator shall be based on the procedures as prescribed under Section VB below; Should there be a decrease in units on an existing route as a result of LPTRP or Route Rationalization Study, the consolidated operator shall file a petition assigning its excess units to the nearest adjacent route covered under the consolidated operator's area of operation; 7. The Regional Franchising and Regulatory Office (RFRO) concerned shall inform the Board on the matter before opening the route to new entrants to fill the required additional PUV units; 8. If no existing operator shall file for consolidation in an existing route within a reasonable period of time as maybe determined by the Board, provided that it is within the transition period, and same route has been retained after the approved LPTRP/Route Rationalization Study, the route shall be opened to new entrants whose selection for operator shall be based on the procedures set forth under Section V-B below. “U.P, LAW CENT | of me RATIONAL ADMINS femaeaie Rese Fes Dimer et 15 208 } | SECEL YE. || Pages of 7 Seer B. For New/Developmental/Missionary/P2P Routes 1. The LTFRB shall cause. ~—the-—posting/publication of, new/developmental/missionary/P2P routes, as may be approved by the Board, prior to accepting any application; Posting/Publication shall include routes' origin- destination, detailed route description, route distance, fare, vehicle denomination and classifications, number of units required, date/venue of submission of documents/qualification conference schedule, In case of invitation for opening of denomination with cap, the Board shall determine the minimum number of units that each Applicant-Operator can apply. 2. The Committee shall proceed with the selection process starting with the steps under Sections V-A-1 to V-A-3, but emphasizing that late submission/s shall be rejected outright and returned unopened; 3. The Applicant-Operators who PASSED the legal, technical and financial qualifications shall be ranked based on the availability of the required number of compliant units. Higher rank is accorded to an applicant with the highest number of ready and available units, then on the schedule of delivery of the units (as certified by the supplier/manufacturer) on a first-in-time basis; 4. Ifa tie results, preference shall be given to existing area-based operators. If no existing area-based operator qualifies, a public lottery shall be conducted in the presence of applicants to determine who among the qualified applicants will proceed with the CPC application; 5. The Committee shall submit to the Board or to the concerned Regional Director, as the case may be, its Recommendation for the latter’s approval which shall issue aNotice of Selection; 6, The selected operator shall file an Application for the issuance of a Certificate of Public Convenience (CPC) and with a prayer for a Provisional Authority (PA) for available compliant units within three (3) months after issuance of the Notice of Selection. The CPC will be granted when at least fifty percent (50%) of the required units for the route applied for is already available; 7. Applications for CPC shall be processed pursuant to the existing Rules of Practice and Procedures of the Board, with the submission of all of documentary requirements in accordance with the Board's existing relevant issuances on land transportation franchising. VI. GUIDELINES ON INTERIM SERVICE A. For existing operators who consolidated to operate on their existing routes with or without LPTRP or DOTr Route Rationalization Study, a 90-day PA will be issued to their existing units (including UV units not older than 3 years old at the time of application) subject to road worthiness certificate from LTO and provided that a photocopy of the passenger insurance policy for each unit and proof of compliance with garage requirements are submitted. This PA is renewable until these existing units are dropped and substituted with compliant PUV units in accordance with the submitted delivery schedule in the Technical Qualification documents. For UV Service, only Class 3 PUS units shall be accepted, B. For new/developmental/missionary/P2P routes, 1. The selected operator will be required to operate an interim service within fifteen (15) days from Notice of Selection with a minimum of two-thirds (2/3) of the total number of required vehicles through issuance of 90-day Special Permit (SP) renewable upon justifiable reasons. The Applicant-Operator will be permitted to use either its own units or units that are leased or chartered from other operators, manufacturers or des Up, LAW CENTER 1 aTONAL ADIN Aamnraie Res 98 hn MAR 15 2019 | \ECEL YE. 2. Upon availability of compliant units, a 90-day Provisional Authority (PA) will be issued to such units provided that a photocopy of the passenger insurance policy and proof of compliance with the requirements for garage are submitted. Said PA is renewable until the CPC is issued; 3. In no instance shall the total number of units for SP and PA shall exceed the required units per route C. The additional amount as described in table below (Per DOTC Department Order No. 2001-82) shall be paid by applicants if they pray for the issuance of SP/PA in the Application or in a separate motion. Vil. PENALTY CLAUSE If the selected operator fails to meet the submitted delivery schedule of compliant units, the selected operator may file a petition for extension of time for the delivery of units citing justifiable reasons that are beyond the control of the operator and supplier/manufacturer for the consideration of the Board/Regional Director concerned, Should the Board/Regional Director concerned finds no justifiable grounds to allow the time extension prayed for, a fine/penalty equivalent to twenty percent (20%) of the acquisition cost per undelivered unit shall be imposed on the selected operator but without prejudice to said operator's appropriate action against the party which primarily caused the delay. VII. LIBERAL INTERPRETATION PROVISION The provisions of this Memorandum Circular shall be liberally construed in favour of the applicant/operator. IX. REPEALING CLAUSE Memorandum Circular Nos. 2018-006, 2018-008, 2018-009, 2018-012, 2018-013 and all other issuances or parts thereof inconsistent herewith are hereby modified, amended, or superseded accordingly, X. SEPARABILITY CLAUSE If any provision of this Memorandum Circular.is declared invalid, the provisions thereof not affected by such declaration shall remain in full force and effect. XI EFFECTIVITY This Memorandum Circular shall take effect immediately following its publication in a newspaper of general circulation and the filing of three (3) copies hereof with the UP Law Center pursuant to Presidential Memorandum Circular No. 11, dated 09 October 1992. SO ORDERED. Quezon City, Philippines, 45 WAR 2019 = Atty. MARTIN B. DEYGRA III Chairman' Se i OWN Engr. Ri IRPUS Gen. ANTONIO N. GARDIOLA, Jr. (Ret.) rd Member Board Member Attested by: = a | | Atty. SAMUK JARDIN p Exed or Page 7 of 7 ECELY #. THE PHILIPpNE STAR business AVIUORITY (eAVBPECIAL PERMIT (sP) UNDER THE OMNIBUS FRANCHISING Guimetanes “PUBLIC! UTILITY ‘VEIICLE MODERNIZATION. FROGRAM Gove WHEREAS Sess of a Depuineat f Tumori nnd Depart Orie ‘Np 2017011, Re: OMNIBUS GUIDELINES ON THE PLANNING AND IDENTITCATION ‘OP FUBLIC EOAD TRANSPORTATION SERVICES AND FRANCHISE ISSUANCE whch ‘Moped esa pocauesfor he haan Of facsue piano fae ed JHEREAS on 13 Mach 2018, hs Bow sed Memoranda No. 2018-0, ‘ques GuibeaiNe FOR Tee FUBLIC "vac, ON ‘unre ‘MODERNEZAN FROGRAMSY INTIAL 1aPL MGNTATION PURSUANT TO DEPARTMENT ORDER NO. {BIPOH, OTHERWISE KNOWN AS THE OMNIBUS FRANCHISING GUIDELINES, WIIEREAS, on 1s 6, 201%, is Bord sed Memoria Cele No. 2018.02, MRP OUbELINES or ore ano Suusaturion Or Ps UNITS UNRATE UREA ot 2 Jn 208 hi Bo ind Menara Ci Yo. 201012, sau Remains Shes nie AccoreNce op emai ek ‘Mobetnzation ognaag TAT Ba WHEREAS, ath implemented inn wich wes ned see ‘ite cor nd demande moacn Vi hr wes at cei edo ‘ai an dred pons . a WHEREAS, he pues of hi Memernd Coal i the ‘planation of he UVR ee [NOW THEREFONE, promis cenwe, the Hott bithy adopt be llown sonst pines ou pt sai ® 1 PRunewrixs [A TisMtoocndum Cal opi the eon of pu sd won, isowmee at CRC ae ening, Peter and Te one fouteone oprocane facie shame wer the idiey Senin Conon GCP naar Tow ©. Quaid exiting opr sal sin te eh pve oo he rote (heya cer ing orton ease ens wad by So Sppowed Loa cr DOT sneatonen sty) Goes ag Shou he Apes petri ceo al te aero waa Soe Es haerorat sl joa woah | sarunpay | march 16.2018 tL veincur sreciricATIONs ‘A Ont Poi ey Veblen PUY wi a ase Wa supa engines = sit the tee spices provided under Depa ‘ede Ne 201751 ond cic tambo Fine Nc ‘Ss Saal be seep os toric one rel PUVE al be el wit OF egies low: GRSE Reaver Fics We, CCT (ec man ve fs Taboo opens Fare Cleo Sym (APCS) or PUB |FUbe non tity wie cree ch speed me, nd ions pace a Sonata oad PV augment Ties We, COTY wih cana rca af pa 72 usu | asst open suman Fre Coben Sten (APCS) x PUlrand fn) SIL APPLICANT-OFERATOR QUALIFICATION HEQUIKESIENTS, ‘At relict Opec sal pete aowng mia gaia bere thy cn be ‘A Leal Quienion 1. po zn who sage (10 ye cele Cotte ted 9 Pte ‘Sts ty SA 1 Inco ox Rat () ly sang read by he Hees of tc Revence QR) er art oF Rapatan (COR te Tenia ersew tts 8 See ety he gwen ot ‘eda 1D 2. iio ese ley wove pon 1 pride amponon 3, Ieorratin er panei int it vee o contin of et fu Ceres me Cope of Cathe af Ieapraon, AUC ‘yaw, aa Gaal iar Shest aly fervent yt ‘retin sed Pach Commision: i? ests et aig «laced Monona, ‘Somanceupronl em ener wing hae te CPCs era In ‘Stage oradngecomabard CP nvr the Apane Op 1B, Tech Quien 1. Ne compat wits male wth OR/CR ad aeang at be ‘ong ts br wade namie hie re) oh ceed ty ‘ievetite nantoucampeier cane ome se of ben of ‘no Compas ue are avaiable ndenaking that 25% of te amber of ere Road po eh ication docuncets, 2. Undenaling tat he ie sal Be comptot wth the speifetons and Sets anineca ar ee Resear rtm es ges aaa, Ee etme Se nae eae weetathanee cesentaetr oe Sinan acorn « Epeciane Se epee enue i | Gite chitary tte e enplargwage wih tog eens mushy ogee vey of comin UV wns wich 19 ‘mie on bate mune ova fae rd ite ©. ani Capsity 1. Of oc cert Tae Coy oft at Aid Fai Sie ‘Sioa rte by ean fart Rover sad ‘Re ans Geren of Regurion tom rey fier Reve “4. Enanitpreens fr the fat Sie (5) yet of apron, ening St nt ey we Fe Zo ang “THE QUALANCATION contr, Fox eon fis Menrinon Cc,» Qulifeton Commit all be eed pata ong ‘orien tes NCR res Suis Vee i Menber Monee Sere 1 Feta ser oes (xh LTFHD.NCR ‘Catipesor Sete et ye Reon Dic amare Member Newer Le Ober CBr eagesnsive Osenee Dorrntpescusive “Teo may tenance ban eed on Dutysudeza spine fer eich member my be atowed, ent the ‘Chparan end ie Cpe ‘The Quien Conmitoe sal wlan the fwing proceues the Pevenmne a ts nai [PROCEDURES FOR QUALIFICATION and SELECTION OF APPLICANT. ‘Orenarons ‘A tsiop atone Rute stat sibit te the conned Gulon cliceraitomttne . ee eae Sacer acaseinas mento iivhawaeerarcnetnememanat Feet epee tor Da igestederemetis Siasatass ies Sariesiserientescamesemeres Bees ian naieeee sais eater ster ceweate SES SASS con ar omen Teneaieuectepe death ants Fees peur eres + aca Sicmy cece: eee eas ee Sars wantin inant mae Za ‘Vi-_ GUIDELINES on werERIM SERVICE tesla oprr il to met sbi diver she of comp it te ‘ced oper may He peo oe even of tine he evry wis ing Janie reso re Geen he nel of he oper td tpledeartcre ot fhe onsconton of be osramagos! rear cfeanes hoa oe earameiona ‘Brest enconad ads no Jai gran 0 sw te tne extern peed fecal een ‘Sutemyocd one sled opr Gu wet pe tad oper propa ‘engi te pu ch ily ue te ey ‘Vl, LIBERAL EVTEHPRETATION PROVISION “The evn fhe Memon Cc hl be ely cond in vor of he teeta. Manoeadim Cia Nes 2018406, 2018-08, 018.009, 2018612, 201.013 anda ‘hr nec or putea ona bruh ey med, amended, ‘Surat sogi X_ SHPARABILITY CLADSE {Cay provi of it Monreal, the provisos hea nt coy cheeses ten fal fos fe. “Ts Manoradun Choa sll tke oct iumditly owing pation ina zmpapr of tel con an he ing of ee) ses hee wih he UP Lae ‘Comer panan o Peel Narn Clr NO Iv el 0? Over 1952 wm fmets 3. VerNewDescepmensiinionryP2? Routes i, SM St coe te tne St lan ty Ct sium eee hedonic ot Sita maaan hema cs ia aces eo ead Seo tenia hl weed i ESTES vee rename relates * Sees hae iammmaa ts Ee ot ee Suateeneren te a mh eect footy ee terrae arta etna ae Sat curoecemies meee Hee chemeccegatteas TS ae va Euan anntranme mre ts Sarre eeceneees ‘proceed with the CPC application, hae « Ree ea Seo aeemmentiecret oes: |ANetice of Selection, ae EE arn cememre meme tecment Sears neon trace ieee Ceasar eras ‘eguted wer he ate pd arg asta eat, Eero sarees Sorensen ees =i ‘A. Fe aig oper who consist opt on hi ting rss who ‘wth UBENP or DOW, Rone Ratalann Sy.» Bsn PAs fd Tlecsng we (lng UV we a ler an} yor ld tose Of ‘pation joo ral vonine caieteKom LYO tah roves ft ocony of 1, Fer tmuerdopmeniniory 2 mas, 1 "Fhcactanel ope alt ured spre mint erie win item (3a om oes of Seon wha manram of two iar) ah to moe of req veces trough tance of 2.uy Spec Pore (3) ‘ereabl upon tise reo ix pint Ope wt oe praia o SE Ween one twit she om ee pa, 2 Upon vay compan ui 90-y Pvisaat abot (PA) wiv ‘eed omaha rnd tte peop aw psonge innate oy iodo wih nore pro oad SP 2 Insp ius al he ot mar of wl fr SP and PA sal xz moetedine renee . Todor noun desi in le low (Per DOE Deparment Oe a1 mat be aby apap yay or ance oF SPA ‘ppteton rina au atin ts ten poet G0) of ha aguton cant pr mace ot erreceiviry So ORDERED. eon chy. ibis, 45 yk 29 ann itn gona ‘chron Ou RLS (Gn ANTONIO X.CANDIOLA et) otal ny. saneyfc aR aanors

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