Hello News GroupHello News Group We have received something we would like to share with the News Group. An individual (he is not a shareholder or related in anyway) has informed PBM of his interest in the Morrison project and of the communications between him and the Ministry of Environment/BCEAO. First, his story of why he became interested in the Morrison: My best friend is a Gwichin trapper who, now 80, still feels it necessary to practice his traditional livelihood. Hes carrying a momentum generated by decades of experience and interest. After 25 years as a research scientist with the Geological Survey of Canada and 10 years teaching at Queens University, I similarly felt compelled to share what I had learned. Nipissing University, in North Bay, Ontario, needed a stand-in to teach their Earth Resources course and so provided this outlet to me. I had essentially carte blanche, a few lines in the calendar outlining coverage of minerals and oil and gas, but beyond that, the course was wide open to my interpretation. My First Nations friend figured prominently later in the course, when I brought in cultural resources. But I was just as keen to honour the brief official description. When it came to finding minerals, I fell back on my first experience in geology, hired in 1966 by Noranda Exploration. Noranda was exploring two properties, one beside Babine Lake that became the Bell Mine, the other on Morrison Lake, the property that is now under development by Pacific Booker. The experience I gained was invaluable, setting up camps, running a freight boat, driving a small bulldozer, splitting and logging core, cutting roads for drill rigs and much more. At the end of that summer, the junior geologist recommended a summer with the Geological Survey of Canada. I took this advice to heart and that led away from mining exploration. But I never forgot the experience. Much later, in the Geological Survey, I was required to offer technical comment on environment impact assessments, mainly carried out by mining proponents in the North West Territories and Nunavut. The regulator was the then federal Department of Indian and Northern Affairs. Other federal departments were required to supply expertise for technical review and I helped to supply this in fields familiar to me. My job was to be as thorough and detailed as possible in pointing out deficiencies in how the proponent planned to eliminate or minimize environmental impact. I occasionally had to testify under oath and was subject to questioning by proponent experts. In preparing for my course at Nipissing, I discovered that the property I had worked on in the 1960s had entered a whole new phase of development and was set to become a mine. This is when I began to discover the trials and tribulations of the new owner; the $10 million that had been invested in environmental studies and a mounting lack of clarity in the explanation of why British Columbia, as the regulating authority, was reversing its initially favourable assessment. The Morrison Copper and Gold Project seemed like an ideal example for explaining to students that the road to opening a mine is not just a matter of prospecting, drilling, assembling machinery and reclamation. There is much influence from political and social forces as well. Late this summer, I had time on my hands as I waited in Cranbrook for forest fire smoke to clear. I and my partner had been flying a small plane from North Bay to Vancouver and had just barely been able to see our way from the Crowsnest Pass to the Cranbrook airport. It was time to check on the latest news about Pacific Booker and I discovered the Management Discussion and Analysis dated June 22, 2020. This historical summary brought into detailed clarity the nature of the long process that Pacific Booker has been going through to understand why the provincial government withdrew its intention to issue an environmental assessment certificate in 2012. Up to this time, the company had been formulating design requirements based on environmental assessment findings and had been pursuing consultations with First Nations from the time that feasibility studies began. All these activities are itemized in the Recommendations of the Executive Director (of the BC Environmental Assessment Office) report that ends with the denial of the EA Certificate. I have not familiarized myself in detail with the decision of the BC Supreme Court that Pacific Booker had been unfairly treated by the BC EAO. But the court decision is not surprising in light of the unexplained about-face taken in the Recommendations Report. Many letters gathered by Pacific Booker suggest reasons for the about-face. Letters from First Nations band councils and hereditary chiefs express opposition to the project with no reference to the consultations engaged in with PBM. Letters commenting on technical matters associated with waste rock disposal redesign seem to ignore PBMs acquired understanding of the reclamation process. A Ministry of Energy and Mines representative recommends a double handling of waste rock to minimize acid rock drainage, seemingly ignoring the fact that PBM would already be collecting any leachate before placement in the finished open pit. The subsequent dealings with the EAO are as if PBM had carried out little environmental assessment work. The company was essentially required to carry out a reassessment, during which their retained expertise revisited all issues raised by an EAO-appointed technical working group. Then, on July 7, 2015, the company was issued an Order of Further Assessment and from this time on, it seemed as if the environmental assessment process had been reversed, with the EAO now requiring a Supplemental Application Information Requirement (SAIR) request, whereby the proponent indicates to the government what further information is required. This is the stage in my readings when I decided a letter to the Minister of Environment was required, asking if this was really the way environmental assessment was practiced in BC. The company was at a loss as to how to respond in the SAIR, but did, proposing a series of discussion meetings on December 15, 2015 to clarify exactly what was required by the EAO. As of January 13, 2020, it seems that this clarification was still outstanding, despite successive entreaties and the meeting on September 12, 2019 between the company, its technical experts and the BC EAO. My reply from the Minister was a rather condescending suggestion that I not use the Morrison Project as a teaching example of mineral exploration, citing Morrison as not typical but that many 'typical' examples could be supplied. In my reply, I indicated that not only did I consider the Morrison typical, but also very interesting, given my personal connection and the nature of the delays experienced by the proponent. I wonder that the whole episode is not a face-saving endeavour on the part of the BC government. Dr. Andrew Weaver, then leader of the BC Green Party, rose in the legislature to draw attention to the unfair treatment PBM has received. He pointed out the First Nations intention to oppose LNG development if the PBM environmental certificate was issued. First Nations entities appear to consider a certificate as commensurate with a go-ahead to mine. This is not the case, as actual permits must still be sought and granted. With the EAO becoming more and more obtuse in its response to PBMs attempts to satisfy open-ended reassessment requests, a certificate issuance could be delayed indefinitely. I can only conclude that PBM has been dealt the status of pawn by a government that has decided to ignore thorough environmental impact analysis in favour of political expediency. Here is the text from the letters mentioned (note: I have removed any disclosure of the individuals identity): Letter dated September 16, 2020, sent to Minister Heyman "This letter concerns the proposed Pacific Booker mine near Morrison Lake. I have no material interest in this enterprise. However, I worked on the property as a geology student back in the late 60s when it was owned by Noranda Exploration. I would like to use this property in a university course I teach as an example of how long it can take to bring a mine into production. I would include a discussion of the attitude of your department and government towards this project. In my tenure as a research scientist with the Geological Survey of Canada, I was frequently called upon to review environmental impact assessments submitted by mining proponents. I limited my reviews to technical areas with which I was familiar. If I noted shortcomings or incomplete information, I identified, as specifically as I could, the nature of further information required. In reading Pacific Booker's latest Discussion and Analysis (dated June 22, 2020), I note that officials with the BC Environmental Assessment Office placed the responsibility for identifying deficiencies on the proponent. This requirement was duly fulfilled to the extent that the proponent could identify deficiencies which had not been identified. The BCEAO replied that the proponent's understanding had improved but was still deficient. Is this how environmental assessment works in BC? I would like the approach, as it seems to be practiced, confirmed, so I can contrast BC with other jurisdictions. The only advantage to a regulator of placing an unidentified target is that more time is gained for indecision. I would very much appreciate an explanation of why your government follows such an approach to environmental impact assessment. A response was received dated November 10, 2020 from Elenore Arend, Associate Deputy Minister and Chief Executive Assessment Officer, BCEAO "Thank you for your letter of September 16, 2020 addressed to the Minister of Environment and Climate Change Strategy, regarding Pacific Booker mine. The Office of the Minister has referred your correspondence to me to respond on behalf of the Minister. On July 7, 2015 the Morrison Mine received an Order for Further Assessment, issued by the Minister of Environment and Minister of Energy and Mines under the Environmental Assessment Act (2002) (the former Act). This Order clearly sets out the scope of the further assessment process and does not require the proponent to identify the deficiencies, as stated in your letter. Pacific Booker Minerals must follow the clearly outlined steps provided in that Order to continue in the environmental assessment process. Environmental assessments in British Columbia (B.C.) follow a clearly defined process that ensures that any potential environmental, economic, social, cultural and health effects that may occur during the lifetime of a major project are thoroughly assessed. If you would like more information about the process and timelines of a typical major project proceeding through the environmental assessment process, I encourage you to visit our website at https://www2.gov.bc.ca/gov/content/environment/natural-resource-stewardship/environmental-assessments/the-environmental-assessment-process. Because Pacific Bookers Minerals has not yet provided the further assessment information, and because the issuance of an Order for Further Assessment is rare, the Morrison Mine is not a good example for your university course of the typical timelines associated with the environmental assessment process for a mine in B.C. There are several other mining projects that have proceeded through the environmental assessment process and received an Environmental Assessment Certificate. These would be more typical examples of environmental assessment timelines for mining projects in B.C. and can be found at our website here: https://projects.eao.gov.bc.ca/. His response on November 19, 2020 to the letter from Elenore Arend, Associate Deputy Minister and Chief Executive Assessment Officer, BCEAO was as follows: "Thank you for your reply of November 10 re my enquiry of September 16, 2020 to Minister Heyman, regarding environmental impact assessment in BC, with reference to the Morrison Project. I have spent considerable time reviewing documents from both the BCEAO and Pacific Booker Minerals pertinent to the assessment of this project. As I stated in my letter to Minister Heyman, I helped with the exploration of this property in the earliest years of my geology career and have something of a personal attachment to it, given the valuable experience I gained. Your encouragement that I seek out an alternative typical major project for teaching purposes is puzzling. Not only is the Morrison project typical, but also very interesting, given my personal connection and the nature of the delays experienced by the proponent. You refer to the Order of Further Assessment communicated to Pacific Booker on July 7, 2015. You point out that Pacific Booker Minerals must follow the clearly outlined steps provided in that Order to continue in the environmental assessment process. Although definitely outlined, the steps evidently needed further clarification, given the series of discussion meetings proposed in the companys Supplemental Assessment Information Request of December 23, 2015. As of January 13, 2020, it seems that this clarification was still outstanding, despite the meeting on September 12, 2019 between the company, its technical experts and the BCEAO. Im sure you are familiar with Pacific Bookers and their technical experts entreaties for clarification on the scope of additional information required. The whole process, as described in detail in Pacific Bookers June 22, 2020 Discussion and Analysis, is illustrative of the pitfalls that can befall a mining sector proponent. The road from initial prospecting to mine closure is a long one and I shall continue to highlight the Morrison Project as one of the more extreme examples. It appears that a knowledgeable person can see the "unusual nature" of our dealings with the Environmental Assessment process. Doesn't it make you wonder why the BCEAO does not see that?