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Compliance Coal: EAO not treating fairly the Raven EA review.

Letter to the BC EAO, Compliance Coal Corp., August 25, 2015

550 – 800 West Pender Street
Vancouver, BC V6C 2V6
Tel: 604-689-0489 Fax: 604-681-5910

August 25, 2015

Ms. Shelley Murphy
Executive Project Director
BC Environment Assessment Office
PO Box 9426 Stn Prov Govt
Victoria, BC V8W 9V1

Via email ( and mail

Re: Reference 286854

Dear Ms. Murphy,

I am sending this in reply to your letter of August 5 2015, Reference 286854, regarding Compliance Coal Corporation’s plans regarding the proposed Raven Underground Coal Project.

You are correct in stating the date of our withdrawal of our Application, however the reasons behind the withdrawal included many considerations in addition to those stated in our letter. Given the history of the protracted process in developing and receiving approval of the AIR, an AIR which is one of the most comprehensive ever developed for a mining project in BC, and given the EAO's reluctance in accepting the Application and Addendum, which total over 14,500 pages, into the Application review process, I see little merit in sitting down with the EAO to review EA options for the Raven Project. This process has been protracted over an excessive period of time and has been exceedingly costly. It has discouraged two major international firms (Itochu and LG) who have involvement in coal projects in many countries to exit from the project after making a substantial investment in Raven.

It has become a concern to Compliance Coal that the EAO will continue to place roadblocks ahead of the Application for the Raven Underground Coal Project and into the Application review irrespective of whether the Application meets or exceeds all of the AIR requirements. This is evidenced by the fact that information the Working Group members indicate is deficient is in fact in the Application. In addition, the makeup of the Working Group includes members who have publicly opposed the Project from the outset based on information not related to the technical merits of the Project.

We realize that the expiry of the AIR was June 7 th 2015 under the Environmental Assessment Act, Prescribed Time Limits Regulation and that suspension or termination of the EA may occur. We believe however that the EAO are not treating the proposed Raven Underground Coal Project in a fair and transparent manner and that the Project would never be able to achieve an EA Certificate given the built-in biases in the review process, the lack of Working Group expertise in screening the Application, and the EAO's reluctance to acknowledge that in fact the AIR has been complied with. The very commitment ofthe BCEAO in working towards an effective EA on the Raven project is in doubt. To this end, we are currently considering our options and seeking advice on how to address this issue.

This letter is without prejudice.



Stephen Ellis
President and C.O.O.
C: (250) 871- 7910

Click here to download the Compliance Coal Corp. letter to the EAO

Click here to download the letter from Shelley Murphy of the EAO to Compliance Coal Corp.