Mr. Streiner, the reason I mention this is because the organization Air Passenger Rights wrote to the CTA during the crafting of those regulations and said very specifically:
APR is deeply concerned about the omission of a number of important issues from the Proposed Regulations. This state of affairs creates the incorrect impression that airlines are free to do as they please in these areas. APR strongly believes this was not Parliament's intent.
So here they are; they've identified the gap and they're bringing it to your attention. Was there nothing that the CTA could do to address the situation in the regulations?