The appellant ("Elim"), a B.C. non-profit organization, sought the enhanced (83%) public service body HST rebate respecting a long-term care facility with up to 118 residents (mostly with dementia, severely impaired mobility, complex medical issues and a life expectancy of between three months and three years), which was constructed and operated by it (the "Harrison"), on the basis that it was making "facility supplies." There were five nurses and 16 care aides available to provide care during the day. Before allowing Elim's appeal, Woods J found: