Mr. Chair, the regulations have to be read as a whole. Section 122 of the air transportation regulations is not a stand-alone provision. It has to be read in conjunction with section 111, which also requires terms and conditions to be just and reasonable.
In the past 60 years, the Canadian Transportation Agency confirmed correctly that those provisions that require provisions about refunds in the tariff have to be read in conjunction with the requirements that those provisions be reasonable. “Reasonable” here means requiring airlines to, at the very least, refund passengers for flights that were cancelled, regardless of the reason for the cancellation. To have a provision about refunds for any reason, but then those provisions say, “no refunds”, would defeat the purpose of the law. It would not make any sense.