I. INTRODUCTION

1. The Investor set out its costs and positions on the “Investor’s Statement of Costs” on March 3, 2015. The disputing parties agreed to file a Statement of Costs rather than filing extensive submissions which would ordinarily contain extensive details on each and every cost incurred in the arbitration. The Investor maintains the contents of that submission. The present submission is limited to issues raised by Canada in its March 3, 2015 Submission on Costs.

2. Arbitration must be undertaken in a reasonable, efficient, and practical manner directed at resolving a dispute. These objectives guided the Investor’s conduct throughout these proceedings.

3. Generally, costs should follow the cause. Costs may also address conduct that imposes undue or frivolous burdens upon the Tribunal or disputing party. Such conduct must be distinguished from situations where one party is merely asserting its rights and interests based on reasonable grounds, or upon a reasonable belief.

4. In this submission, the Investor refutes Canada’s assertions. Canada’s conduct has caused unjustifiable inefficiencies in these proceedings resulting in longer delays and increased workloads for both the Investor and the Tribunal. In these instances, costs should be assessed against Canada to address actions that imposed unnecessary burden on the Tribunal and the Investor.