After re-reading the letter from the Ministry that BOAZZ posted this morning, some things come to mind . The highlighting below I reposted in that letter is my doing.
The key word in the first highlighted sentence is RENEWAL .. It seems the MInistry is not asking for this $50K per permit as an new permit application payment but as proof that within the two years one has held a permit , the property has had that amount of money put into it,. That being the case, NAG or anyone else has two years before renewal of a permit is due to show this expenditure. They can be having great drilling success on some of the permits, the stock price going up because of it and so be making money to put into their other permitted acreage. Also as mentioned earlier by other posters, there are JV's to take into account. If there hasn't been the monies spent on a permitted area in the two years prior to renewal then they company loses the land. So it is potentially a bit of a gamble just how much a company wants to take on in permits.
Also a potential big deal is the ability to credit expenditures on one permitted area to other contiguous claims. So one cormer of one permitted claim that has received alot of exploration money can be spread out over three others.
Of course there has to be something in that corner worth looking at but hey it's a bit of a break.
Since all the companies have till the 29th of this month to put forward their commnets you would bet they are asking all the questions they can. How else could they put together serious comments?
And lastly --- it ain't a law yet.......
Dear Applicants,
The Ministry was asked to clarify what will be acceptable in term of exploration requirements and expenditure allocation. Consequently, the Ministry is seeking industry input on the following proposals. Given the urgency to issue coal permits, comments shall be received by the Director, Mines Branch, no later than August 29th, 17:00.
1. Amount of exploration work per permit
The amount of work required is important when seeking the renewal of a permit [Section 12(2)(a)] and critical when applying for a lease [Section 14(2)(c)]. It was indicated earlier that each permit will require the drilling of a coal exploration hole, or equivalent work. Since then, questions were raised about value of work, deep hole and other means of exploration.
The Ministry is of the opinion that a coal permit minimum exploration requirement shall be 100 meters of drilling, or when no drilling is done, $ 50,000 worth of exploration. “Drilling” and “exploration” only refer to works whose results have been accepted by the Ministry.
The Ministry recognizes the unpredictable nature of exploration and will review on a case-by-case basis work submitted that deviates from the above requirements for reasons beyond the control of the disposition holder.
2. Allocation of exploration expenditures between permits
The expenditure corresponding to exploration work covering several permits can be shared between these permits.
Portion of exploration expenditure that exceeds the minimum requirement on a disposition can be allocated to contiguous dispositions. A common corner will suffice to make dispositions contiguous