1. On 2 May 2016 Moose Consortium Inc. (Moose) submitted to the Canadian Transportation Agency (the Agency) a request for determination of jurisdictional authority relating to the Maniwaki Subdivision (mileage 0.0 to 20.3) between Gatineau and La Pche (Quebec).
2. On 21 Jul 2016 the Agency issued a staff letter (#16-02997) to report their conclusion that, based on their search of records relating to this railway, it is no longer part of the federal transportation system because:
2.1. Canadian Railway Board Order No. 112001 of 8 Jun 1966 authorized Canadian Pacific to abandon the operation of the section of the Maniwaki Subdivision between Miles 0.0 and 2.23.
2.2. Subsequently, Commission Order No. R-37548 of 11 Dec 1984 authorized CP to abandon the operation of the section of the Maniwaki Subdivision Mile 3.0 and Mile 80.7.
3. Between July 2016 and July 2017 Moose Consortium Inc. has undertaken an additional search for relevant documents. The company hereby submits its findings, and in light of the following facts Moose makes the following two requests:
3.1. Moose requests that the Agency, pursuant to Section 32 of the Act, review the decisions and orders of 1966, 1984, and 1985 relating to discontinuance of the Maniwaki Subdivision (mileage 0.0-20.3) in light of the historical facts (sequence of legislative acts and regulatory determinations, subsequent actions, and physical factors). Moose submits that there have been changes in the facts and circumstances pertaining to these decisions and orders of sufficient importance to warrant their review, rescission, or variance.
3.2. Moose asks that, pursuant to Section 28 (2) of the Act, the Agency take steps immediately to issue an interim order for the Municipality of Chelsea, and all related parties acting as agents or representatives or all bodies having a contract or agreement with the Municipality of Chelsea, refrain from dismantling any railway structure of the Maniwaki Subdivision, pending:
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Joseph Potvin - Director General Moose Consortium Inc.