JUDICIAL REVIEW AND STATUTORY APPEAL - Standard of review - Reasonableness

Law360 Canada ( November 8, 2024, 5:01 PM EST) -- Appeal by appellants from a judgment of the Alberta Court of Appeal which affirmed a decision dismissing their application for judicial review. The appellants were owners of coal-fired electrical power generation facilities. They entered into off-coal agreements with the respondent, the Province of Alberta (Province), to eventually cease coal-fired emissions by 2030 in exchange for substantial sums paid annually by the Province to compensate for the loss of value arising from the reduced life of the appellants' facilities. The respondent, the Minister of Municipal Affairs (Minister), established the 2017 Alberta Linear Property Assessment Minister’s Guidelines (Linear Guidelines). For municipal taxation purposes, coal-fired electrical power generation facilities were assessed as “linear property”. The Linear Guidelines did not allow for off-coal agreements to be considered in assessing depreciation. The appellants were therefore ineligible to claim additional depreciation to account for the reduced life of their facilities. The appellants challenged the vires of the Linear Guidelines on two bases. First, they violated the common law rule against administrative discrimination; and second, they were inconsistent with the purposes of the Municipal Government Act (MGA). The chambers judge upheld the validity of the Linear Guidelines and found they did not discriminate against the appellants. She noted that, following Canada (Minister of Citizenship and Immigration) v. Vavilov (Vavilov), the reasonableness standard applied when assessing the vires of subordinate legislation. The Court of Appeal upheld the chambers judge’s decision....
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