Bill C-15 (Historical)

Northwest Territories Devolution Act

An Act to replace the Northwest Territories Act to implement certain provisions of the Northwest Territories Lands and Resources Devolution Agreement and to repeal or make amendments to the Territorial Lands Act, the Northwest Territories Waters Act, the Mackenzie Valley Resource Management Act, other Acts and certain orders and regulations

Part 1 enacts the Northwest Territories Act and implements certain provisions of the Northwest Territories Lands and Resources Devolution Agreement. It also amends and repeals other Acts and certain orders and regulations.
Part 2 amends the Territorial Lands Act to modify the offence and penalty regime and create an administrative monetary penalty scheme. It also adds inspection powers.
Part 3 amends the Northwest Territories Waters Act to make changes to the jurisdiction and structure of the Inuvialuit Water Board, to add a regulation-making authority for cost recovery, to establish time limits with respect to the making of certain decisions, to modify the offence and penalty regime, to create an administrative monetary penalty scheme and to make other changes.
Part 4 amends the Mackenzie Valley Resource Management Act to consolidate the structure of the Mackenzie Valley Land and Water Board, to establish time limits for environmental assessments and reviews and to expand ministerial policy direction to land use planning boards and the Mackenzie Valley Environmental Impact Review Board. This Part also amends the administration and enforcement provisions of Part 3 of that Act and establishes an administration and enforcement scheme in Part 5 of that Act, including the introduction of enforceable development certificates. Moreover, it adds an administrative monetary penalty scheme to the Act. Lastly, this Part provides for the establishment of regional studies and regulation-making authorities for, among other things, consultation with aboriginal peoples and for cost recovery and incorporates into that Act the water licensing scheme from the Northwest Territories Waters Act as part of the implementation of the Northwest Territories Lands and Resources Devolution Agreement.

[Earl Dreeshen, Conservative, Red Deer, AB]

Thank you.

Of course, being new, I haven't had a chance to go through Bill C-15 in as much detail. However, when we were there, we did talk to folks from the Yukon. Many modern and efficient regulatory systems and settled land claims have resulted in tremendous success in the Yukon since 2003.

Also, of course, there's a wealth of oil and gas deposits in the Northwest Territories. I was just wondering what your level of confidence is in the potential of Bill C-15 to unlock the Northwest Territories' petroleum resources.

[Joan Crockatt, Conservative, Calgary Centre, AB]

I may come back to that, but I'd just like to move on to another point you made here first. You said, in talking about the competitive markets, that companies are always comparing one country to another, one project to another, to see how the timelines that are established here under Bill C-15 compare on an international basis. How do they compare internationally to those that competitors who are looking at coming into the north would be looking at?

[Jean Crowder, NDP, Nanaimo—Cowichan, BC]

I want to acknowledge the work that Mr. Bevington has done in bringing this forward. I know that we've had informal discussions around this, but I think what we've heard quite clearly is that there's pretty broad support for the devolution aspect of Bill C-15. What is more problematic are the changes to the MVRMA.

Unfortunately, as committee members know, I was not able to attend on Monday because of Canada's lovely weather system, but I did read the briefing notes that were prepared. There was pretty overwhelming opposition to some of the proposed changes in the MVRMA.

It would seem that with such significant changes that are going to have such a widespread impact, it would be important for the committee to have an opportunity to consider this bill separately. I think it's in everybody's interests to see the devolution aspect of the bill move forward quickly, but the other aspect, in my view, requires substantially more attention.

I was interested to note that in Mr. Bell's testimony he was talking about the fact that devolution is seen positively in terms of giving more control to the north, yet one of the major concerns that's been raised as a result of MVRMA section is that it will in fact give the minister more control. I won't take the committee's time to read all of the sections that result in the minister having more control, but I think this should be a major red flag for people who are seeing more northern control.

So, Mr. Chair, I would encourage members of the committee to support Mr. Bevington's motion.

[Bob Bleaney, Vice-President, External Relations, Canadian Association of Petroleum Producers]

Good morning, Mr. Chairperson and members of the committee.

My name is Bob Bleaney. I'm the vice-president of external relations for the Canadian Association of Petroleum Producers, or CAPP.

CAPP represents Canada’s upstream oil and gas sector. Our members find and develop about 90% of Canada’s oil and natural gas resources all across the country. Together, they invest over $60 billion annually and employ more than 550,000 people across Canada.

We appreciate the opportunity to contribute our perspectives regarding Bill C-15, the Northwest Territories devolution act. This is a historic bill, as the people of the Northwest Territories are set to take control of the future path of the development of the abundant natural resources in their region.

As you are aware, the bill was tabled in early December last year. Although we are still in the process of assessing all its implications, we can say that CAPP supports the intent and the spirit of Bill C-15 and views it as a positive step that will aid northern development.

To date, CAPP has primarily focused its review on part 4 of the bill, relating to the proposed amendments to the Mackenzie Valley Resource Management Act, or the MVRMA.

The federal government’s initiatives for regulatory reform have been a positive step forward towards improving regulatory efficiency and effectiveness while ensuring a continued high standard of environmental performance. Extending these reforms into the Northwest Territories will be important for attracting and enabling investment that creates jobs, economic growth, and prosperity for the Northwest Territories and all Canadians.

Regulatory process bottlenecks in the past have often led to project delays or outright cancellations, with the resulting adverse effects on economic and social benefits that could flow from these projects. Accordingly, CAPP is strongly supportive of the government’s objectives to improve the efficiency and the effectiveness of the northern regulatory regime.

The MVRMA is a core piece of regulatory legislation in the Northwest Territories, and the proposed changes to this are very important to our industry. For example, the ability for the minister to give binding policy direction to all MVRMA boards, including the land and water boards, the land use planning boards, and the environmental impact review boards should provide for a more cohesive, unified, and comprehensive review process, one that should be a benefit to all parties involved.

CAPP fully respects existing comprehensive land claim agreements and aboriginal treaty rights and supports the federal government’s protection of the these agreements and rights in the proposed amendments.

CAPP's view is that the regulatory bodies in the north should be efficient, timely, and ensure regional knowledge is appropriately considered in the review process. In this vein, we support the accommodation measure in the MVRMA that requires the chair of the Mackenzie Valley Land and Water Board to consider the inclusion of regional nominees when committees are dispatched to address proposed projects. This will be particularly important in respect of the proposed board amalgamation, in order to retain regional representation in their process.

The proposed clarification of timelines for the environmental impact assessment process is also a very positive step. The historical lack of predictability—and the resulting uncertainty—of review timelines for project proposals in the central Mackenzie Valley has been a significant concern for project proponents.

Investment and operational decisions benefit from a predictable review process, particularly as to review scope and timing. This is essential for being able to manage work activities to fit within the limited seasonal operational windows that exist in the north. Unexpected delays in the timing of authorizations can disrupt project plans, which can translate, as I mentioned, to serious delays and missed opportunities.

Critical path decisions and investment timelines have been a systemic challenge to the north and are especially pronounced when compared to timelines in competing oil and gas jurisdictions. Our industry is global in scale, and northern oil and gas exploration and development projects have to aggressively compete for limited investment dollars against opportunities elsewhere in Canada and around the world. Reducing the risks and uncertainties in project review timelines, as proposed in this legislation, will serve to improve northern competitiveness.

Devolution of federal responsibilities to the Northwest Territories, coupled with increased exploration interest, facilitates the opportunity to make the needed improvements to regulatory efficiency and effectiveness. The transition stage from April 1 forward will be a crucial time.

CAPP appreciates the mirroring of the federal legislation that’s been mandated by the devolution agreement, which will support stability, continuity, and predictability of the regulatory regime through this transition.

Such a regime is fundamental to creating a positive environment for investment, which creates jobs and economic growth, and tax and royalty revenues to government. Industry invested about $600 million in the north over the past three years, and is expected to spend an additional $650 million based on existing land commitments alone. An improved regulatory framework should help to stimulate further investment.

The north is a key area of interest to our industry, an area of vast oil and gas potential but not without its challenges, which makes regulatory effectiveness and efficiency that much more crucial to success. Being a frontier area, there is a lack of infrastructure, likely the most limiting factor for exploration and development work in this region, whether it be with regard to physical infrastructure, like roads or pipelines or facilities; community infrastructure with respect to housing and recreation; workforce availability; or service sector support.

Although there is large resource potential, most of these resources await confirmation as to whether they are economically viable, and timely assessment through exploration will be key to their realization.

I should also note that the north is not alone in its challenges. Whether in producing jurisdictions such as B.C., Alberta, Saskatchewan, and the Atlantic Canada offshore, or potential new development areas, such as Quebec, New Brunswick and the Atlantic onshore, there are common challenges facing Canadian oil and gas development. They include access to domestic, North American, and other international markets; competitiveness in the areas of fiscal and regulatory policies; workforce availability; access to precious investment capital; and having the social license to operate with respect to public confidence and trust.

With devolution set to go live April 1, 2014, and the related legislative changes through Bill C-15, there is a historic opportunity for the Northwest Territories to start to address these challenges and advance its vision for oil and gas development. There will be ongoing regulatory work needed to be done to achieve this vision, as it will remain important to ensure the timely implementation of related changes to regulations and policies to support this legislative intent.

In closing, CAPP supports the federal government in its efforts to improve the regulatory framework in the Northwest Territories. These amendments have been under development and consulted upon for a number of years as part of AANDC's action plan on northern regulatory improvement. These amendments are a positive step forward on the long road towards expanded oil and gas exploration and development in the Northwest Territories.

We look forward to continuing to consult with the Northwest Territories and federal governments to work together to help this vision become a reality. I’d like to thank you for this opportunity to present to you today. I look forward to your questions.

[Rick Meyers, Vice-President, Technical and Northern Affairs, Mining Association of Canada]

Thank you.

For the record, my name is Rick Meyers. I'm vice-president of technical and northern affairs for the Mining Association of Canada. Previously, between 1998 and 2007, I was director of mineral resources for Aboriginal Affairs and Northern Development Canada.

My presentation today is based on a joint submission by the Mining Association of Canada, the NWT & Nunavut Chamber of Mines, and the Prospectors and Developers Association of Canada that was presented to Aboriginal Affairs and Northern Development in October of 2013.

In the interest of time, I'll give a very brief overview of Canada's mining industry and the contributions mining has made in the Northwest Territories, and then provide some comments that we wish to put forward on Bill C-15.

I believe most of you are familiar with the Mining Association, so I won't go into much detail here. We have more than 80 members working across all aspects of the sector. Our members are committed to sustainable development, and our performance has been publicly reported under our “towards sustainable mining” initiative

Mining contributes in a major way to Canada's economy in terms of employment and business development, capital investment, and taxes and royalties, and is the largest private sector employer of aboriginal Canadians. As a global competitor, Canada is a world leader in mineral exploration, development, and production, especially as a contributor to Canada's goods exports, at 20% of the total.

The NWT's mining industry today consists of four producing mines—three diamond mines, two of which are world-class mines, Ekati and Diavik, and a tungsten mine, Cantung, which is the western world's largest producer of tungsten concentrate—and some 33 past producers, which long ago established the Northwest Territories as a mineral-rich and productive territory.

Mining is the largest private sector contributor to the Northwest Territories economy. It does that in terms of employment; investment and spending; business development; contributions to northern infrastructure, including more than $100 million in contributions to community development; and workforce development, specifically in extensive programming in aboriginal skills training and education.

The value of the Northwest Territories' mineral production since 1999 is attributed largely to diamond production, which places Canada third by value in global production. Despite their high productivity, even some of the diamond mines are approaching their maturity. New discoveries will be needed if the Northwest Territories is to maintain the current level of economic prosperity that the mining industry has provided over the last number of years.

In terms of taxes and royalties, since 2002 the mining industry has been one of the highest-paying sectors in the territory. To the end of 2013, corporate taxes and royalties have amounted to approximately $3.6 billion. By 2020 they're projected to be in the order of $5.6 billion. The industry also contributes other major payments not included here, such as payroll income taxes and fuel and property taxes.

I'm not sure if you have a copy of the deck I'm using here, but in terms of aboriginal business development, our deck contains a list of more than 50 aboriginal companies that provide goods and services to the Northwest Territories mines. Fifteen year ago less than a handful of aboriginal companies had the capacity to do such business, so this is an incredible story of success for northern mining working so successfully with aboriginal communities.

With respect to Bill C-15, the mining industry sees devolution as an important step forward for the Northwest Territories, and long-awaited. As an indication of its recognition of the importance of our sector, the Government of the Northwest Territories has partnered with the NWT & Nunavut Chamber of Mines to produce its new mineral development strategy.

This strategy is intended to focus on five key pillars to improve competitiveness and enhance northern opportunities: creating a competitive edge, with the NWT as an investment destination of choice; improving the Northwest Territories regulatory environment; enhancing aboriginal engagement and community capacity; promoting sustainability; and enriching workforce development and public awareness. These are all positive initiatives.

In terms of industry's participation and input, again I refer to my deck. There is a table that shows the involvement that industry has had in northern regulatory improvement over the years. I won't go into it in much detail, but the table indicates that we have been fully engaged from the beginning in several of the government's northern initiatives during the past decade.

They include, particularly, Minister Strahl's northern regulatory improvement initiative, Minister Duncan's action plan on improving regulations, and now the amendments to the Mackenzie Valley Resource Management Act under Minister Valcourt. We have been there pretty much every step of the way.

The MVRMA defines the regulatory framework for most mining projects in the Northwest Territories, and the key proposed amendments under consideration are the addition of timelines to bring the northern processes in line and create equivalency with the Canadian Environmental Assessment Act.

The authority for ministerial policy direction to boards, the consideration for the life of project water licences, and of course the restructuring of the land and water boards are all generally considered to be improvements, or at least potential improvements, to the act. However, there are other opportunities that we think are important that we'd like to put forward. I have five points I want to make.

The first relates to timelines. Our issue is with the requirement for the completion of an environmental assessment, which can take 12 to 24 months, prior to the commencement of an environmental impact review, which is another 24 months, and that is if there is no public hearing. The solution we propose is that if an EIR is required, we recommend consolidating both processes into a single 24-month process, with full consideration for any and all evidence presented in any earlier environmental assessment process.

The second one is unwarranted referrals, and this is in reference to what we believe to be unwarranted referrals to environmental assessment of low-impact activities such as grassroots exploration projects, small drilling projects, geophysical surveys, and the like, based on undefined public concern. Our recommendation here is to put some definition on “public concern” and its scope, and apply the definition appropriately.

The next point relates to proportionality. We advocate for the flexibility for a board to tailor the scope of an environmental assessment in proportion to the magnitude and expected impacts of a project, rather than a one-size-fits-all approach.

The fourth is in reference to the restructuring of the land and water boards. We recognize that this proposal presents concerns and we also understand that there are advantages and efficiencies with this approach. However, in recent years we've seen an increase in the maturity and professionalism in board management and the processes that they administer. Our members have established productive working relationships with the regional panels. I particularly want to point out the Wek’eezhii board here.

We want to emphasize the importance of those relationships, going forward. We also want to stress the importance of ensuring that community representatives continue to be involved with projects coming forward in their regions.

Finally, with respect to the duty to consult, we have seen much of the responsibility for consultation delegated to industry over the past number of years, so we therefore welcome the provision to create regulations to address this. But these regulations will probably take a few years, so in the interim we suggest that this is perhaps an area where the minister could apply his or her policy direction to the boards for the clarification of responsibilities when it comes to consultation.

Looking to the future across Canada, the Mining Association of Canada has estimated some $140 billion in proposed mineral development projects that are currently in environmental assessment and permitting processes. In the Northwest Territories, most of the projects coming forward are included in this estimate. In the north, mineral development is the primary and frequently the only opportunity for economic development for many, if not most, northern remote communities. Future development in the Northwest Territories will be dependent on its ability to attract investment. Therefore, the Northwest Territories investment climate will be a highly motivating factor.

In summary, successful development attracts new investment; however, this investment cannot be taken for granted. Capital is mobile and competition for it is global.

Investment decisions are made on fairness and predictability of process, so confidence in the regulatory process is paramount. An improved regulatory environment will help provide certainty for northern operators, and Bill C-15 has the potential to support this objective. We encourage you to consider the recommendations that we're putting forward here today.

Thank you very much for the opportunity.

[The Chair, Conservative, Chris Warkentin]

I call this meeting to order. This is the 11th meeting of the Standing Committee on Aboriginal Affairs and Northern Development.

Today we continue our study on Bill C-15, our review of the bill.

We have three witnesses for our panel this afternoon. From Dominion Diamond Holdings Ltd., we have Brendan Bell, the president. Thank you so much, Brendan, for joining us.

We have, from the Mining Association of Canada, Mr. Rick Meyers. Thanks so much as well for joining us.

Also Bob Bleaney is here representing the Canadian Association of Petroleum Producers.

Usually in committee we turn the floor over to our guests to give an opening statement of 10 minutes or less. We'll do that, and then we'll have some questions for you. We thank you for joining us today. We know that you're all very busy and have other things to do, but you have taken the time to join us and we certainly appreciate that.

Before we turn it over to our guests, I want to note that this is the continuation of our hearings. We just came back from Yellowknife. I want to take the time to thank our staff, our analysts, our clerk, as well as our logistics officers, who undertook the work that was necessary to get us to Yellowknife and back on time and on schedule, taking care of all the needs that we had. We certainly appreciate our staff, their diligence, and their continued work, as well as the work of the interpreters who travelled with us. All of them are still at work and we appreciate that.

Let's turn it over to our guests. We'll start with Mr. Bell and his statement, and then we'll turn it over to the other gentlemen before we ask questions of you all.

Northwest Territories Devolution Act

[Dennis Bevington, NDP, Western Arctic, NT]

Mr. Speaker, on Monday, the aboriginal affairs committee held hearings in Yellowknife on Bill C-15, which combines devolution with the elimination of regional land and water boards.

A clear message from the hearings was that there is a strong opposition to the Conservative plan to shut down these regional boards.

These boards give a local voice to development decisions, which is a system that works. They were created through constitutionally protected land claims agreements. Even the chamber of mines said they have a good working relationship with the local boards.

The aboriginal governments of the Gwich'in, Sahtu and Tlicho have pledged that they will use every avenue available to fight these changes, meaning greater delays for future development.

“Canada has returned to the old colonial ways of thinking they know what is best for us. They are silencing our voice. This is not the constitutional promise made in the Tlicho agreement,” said Tlicho Grand Chief Eddie Erasmus.

[Christine Wenman]

We have submitted a rather comprehensive brief to the committee, and we're cognizant that we are the last witnesses here this afternoon so we will make this brief. We would like to emphasize three main points that were included in the brief. Our analysis is focused on the changes to the MVRMA that are included within Bill C-15.

The first point we'd like to make is that the changes to the MVRMA must be decoupled from the rest of the bill. Parliament needs to be free to debate those changes separately from the rest of Bill C-15. If these are not separated, they will be unable to show and discuss the problems with the MVRMA changes without also suggesting that they do not support devolution. These are very different issues.

We'd also like to bring forward, as has been heard here today, that the changes to the MVRMA are not in keeping with the spirit of devolution. There has been no evidence brought forward either today or previously that the changes proposed, such as amalgamating the boards or bringing more ministerial authority, will help the regulatory system to be more effective, efficient, or equitable.

Finally, as we've also heard here today very clearly, there is very little consensus on this section of the bill. This will detract from the effort to create the proper conditions for economic growth, jobs, and long-term prosperity in the NWT, which is supposed to be the intent of Bill C-15.

The second point we'd like to bring forward is that, uncoupled or not from the rest of the bill, the changes to the MVRMA need to be amended. First of all, there should be no dismantling of the regional land and water boards. The integrated co-management system that we have now works in the regions where land claims are settled. As was brought forward earlier by Mr. Willard Hagen, analyses have shown previously that the bulk of project proposals that are being sent to environmental assessment have been proposed in regions where land claim agreements have not been settled. If, however, we look to the settled regions, we can see substantial evidence that the current system can effectively fulfill the integrated co-management responsibilities that were intended in the writing of the act. Eliminating the regional boards and the regional panels will create more challenges than it will solve, for instance, by reducing clarity and increasing an adversarial environment and also by creating logistical challenges. For instance, we heard today that there is an opportunity for project panels with three board representatives. These will inevitably bring problems of quorum and also not ensure regional representation. Although it may allow for regional representation, that's not required by the legislation within the panels.

It's also unclear whether the proposed changes will lead to the closing of the regional board offices or result in cuts to the staff. Certainly it is clear that those board offices are not guaranteed in the changes to the legislation. This would diminish the regional access to board services. It would diminish the roles that the regional boards play in liaising in the regions, with the communities, and with the first nation governments. It will create a communications and relationship gap between people and decision-makers. This will be difficult not only for the first nations but also for the existing project proponents and industries that have working relationships in those regions, as we heard just recently from Mr. Hoefer. In other words, there is very little evidence that has been brought forward that these changes will in fact fix the system. They are likely to create a more adversarial environment and cause less clarity.

We would also like to emphasize the point that the changes should not be increasing the federal or ministerial authority, thus in turn diminishing the board's authority. For example, we see increased ministerial authority in setting timelines. These authorities should be kept within the discretion of the board and not of politicians. The boards are intended to perform arm's-length, independent, quasi-judicial roles. Politicizing the regulatory decision-making system in fact jeopardizes that role of the board and results in less clarity for project proponents. The increase in federal and ministerial authority diminishes co-management principles, which are quite fundamental to the whole regulatory process and fundamental to land claim agreements.

The final point we would like to make is that there is a review mechanism that's included within the MVRMA, in section 148, and this review mechanism is the environmental audits. Two audits have been completed to date: one in 2005, and one in 2010. These have been done in a comprehensive manner. They are mandated in the legislation. They involved proper consultation with all stakeholders. In spite of this, little to no progress has been made on many of the key audit recommendations, and the federal government has never issued a formal response.

I would like to bring a caveat to that point, which is that working groups at the board level did emerge in response to the recommendations in the audit, and that many of these working groups began prior to Mr. McCrank's report and were in response to the audits themselves, showing that the regulatory and adaptive management mechanism works well.

Unlike some of the changes proposed in Bill C-15, these recommendations are based on empirical evidence and analysis of those projects that have been referred to environmental assessment. They offer useful and proven recommendations of how to improve the overall land management in the NWT, and they should have been the foundation of any proposed changes.

[Tina Gargan, President, Northwest Territories Association of Communities]

Mr. Chairman, committee members, and committee staff, welcome to the Northwest Territories and our capital city of Yellowknife.

I am Tina Gargan, president of the Northwest Territories Association of Communities. I'm also the mayor of the hamlet of Fort Providence.

The NWTAC welcomes this opportunity to provide comments on Bill C-15, the Northwest Territories devolution act.

The NWTAC is a non-profit, non-governmental organization representing the interests of 32 incorporated NWT communities. The NWTAC represents a unified voice for communities on municipal goals and issues, based upon the membership's democratic adoption of resolution and policy. We promote these priorities through advocacy to the territorial and federal governments and through our membership in the national Federation of Canadian Municipalities.

Our members are significant municipal landowners and developers; are major users of water for supply of municipal water services, have local responsibilities for economic development, environmental affairs, and emergency services; and are key partners with the territorial government in all matters relating to the delivery of municipal government services to citizens. As such, we have a keen interest in the transfer to the territorial government of resource management responsibilities that affect these interests and in responsible environmental management throughout the NWT.

Bill C-15 is a very large and detailed piece of legislation. My presentation will speak to the NWTAC's principled positions on the new legislative arrangements proposed by Bill C-15.

The NWTAC strongly supports the devolution of resource management responsibilities to the Government of the Northwest Territories as proposed in Bill C-15. For NWT municipalities pursuing their mandates, the federal resource management regime and existing programming to date, while generally effective, has presented challenges, owing to the lack of territorial control over the legislation and over the design and delivery of programs serving communities' needs.

Changes to the legislation and even to regulations have relied upon the ability to get territorial business onto the very busy national legislative agenda. It's often a simple matter of geography. Ottawa is far away, and the basic functions of meeting, discussing, and acting are aggravated by time and distance. As the advocate of municipal interests, the NWTAC has had to focus lobbying efforts at the national level on matters related to local resource management in the Northwest Territories.

The NWTAC anticipates that the transfer of resource management responsibilities to the local and accountable territorial government will make a major contribution to the ability of local government and territorial legislators to work in partnership for the continuing improvement of public services. Living, working, and leading in the Northwest Territories, our territorially elected legislators will enjoy improved opportunities to bring their local knowledge to bear, to work in even closer partnership with municipal governments and representative bodies, and to far more quickly make the legislative, regulatory, and program improvements needed to serve our citizens. The development of programs and services for related or interlocking responsibilities can more effectively be coordinated within one government administration.

Improvements in the creation of law and programs with improved sensitivity to and knowledge of territorial realities have been obvious throughout the long history of the devolution of authorities to the territorial government level. A prime example of these improvements in the resource management field has been the transfer of forest management responsibilities to the GNWT. A host of opportunities for continuing improvements will come about as a result of the Bill C-15 devolution of powers.

As landowners and developers, NWTAC member communities will benefit from the transfer of federal lands to territorial control and in future will be able to deal with one management authority for lands outside municipal boundaries. Municipalities expect to benefit in areas where there is an overlap of authorities between federal laws or in instances where the sound administration of municipal law is affected by federal legislation that is difficult to change.

For example NWTAC members have long voiced concern by resolution with legislative provisions to allow for the staking of mineral claims within communities. The concentration of authority for both mining law and land law under one government authority is expected to provide a more responsive and coordinated forum for the resolution of these and similar issues. This is just one example of the benefits expected from the concentration of legislative and program authority within one government.

Coordination in the planning and development of major infrastructure, such as integration in the development and management of territorial and municipal road systems, will be enhanced. With the transfer of funding program resources and responsibilities to the territorial government, more locally coordinated arrangements for planning and development of major intra-territorial capital projects will be possible.

Municipalities also look forward to the increase in revenue flowing to the territorial government, which is the supplier of the majority of the municipal funding. With increased territorial revenues, our member communities look forward to the prospect of increased territorial capacity to meet municipal fiscal needs. The NWTAC and our member municipalities enjoy a very positive and constructive working relationship with the Government of the Northwest Territories. With the vesting of resource management authority at the territorial level, the NWTAC and our municipalities will continue to build cooperation for the improvement of services to our citizens.

Regarding the proposed C-15 arrangements for changes to environmental legislation, the NWTAC supports the continuing and responsible improvements of environmental processes and protections. As the advocate of municipal government interests, the NWTAC places a priority upon the ability of environmental processes to respect and be responsive to local and regional interests. The proposals contained in Bill C-15 are of critical importance to the future of public government in the Northwest Territories. They are the latest stage in the historic development of the Northwest Territories toward full responsible government.

I congratulate and thank the committee for ensuring that a portion of these deliberations have taken place here in the NWT and that our citizens have had the opportunity to present their views for your thoughtful consideration.

On behalf of the NWTAC and its membership, I thank you and wish you well and safe travels home.

[Allen Stanzell]

Just briefly, we would look at Bill C-15 as a bit of a beginning. We would have the confidence that changes could continue to be made. If you look at the relationship between businesses and government throughout the course of history, that's the way things have worked.

[Sandra Lockhart]

I'd also like to go back to the statement we made that Bill C-15 should really be split into two. What's hidden inside is kind of like an omnibus bill. You have the devolution and then you have the whole Mackenzie Valley Resource Management Act hidden inside of that.

We would say there is a will to support devolution, but not in the current manner in which it's being presented. It's one that is not worthy of a government wishing to be transparent and democratic, and the government represents us, both the federal and the GNWT.

So it's no—not the way it's currently being presented.

[Sandra Lockhart, Regional Vice-President, Somba K'e, Northern Territories Federation of Labour]

With the elimination of regional land and water boards, significant trust is lost. There will surely be a negative impact on the relationship between public government and the first nations people, especially in those regions that have signed treaties. Any collaborative spirit that might otherwise have underpinned an environmental assessment process will likely be lost.

Bill C-15 establishes a board system that is fundamentally different from and even hostile to that which was developed in accordance with the treaties of the Gwich'in, the Sahtu Dene, the Tlicho, the Dehcho, and the Inuvialuit. This unilateral attempt to reinterpret the purpose and intent of these land claim agreements, all of which were negotiated and signed in good faith, is unfortunately going to lead to strife and conflict.

This is regrettable, and it is a huge setback to the political development of the NWT. A more centralized regulatory system will inevitably threaten the growing sense of ownership and responsibility over regional boards that has been developing. Having one individual speaking on behalf of their region to a room full of representatives from other regions, who then get to vote and decide on a proposal, certainly does not guarantee that the desires of that region, of those most directly affected by the proposal, will be achieved.

There is also the issue of whether the new board will have the physical capacity to handle all environmental assessments in a timely manner. Where there was once a board in each region to handle proposals brought forward, now there will be only one, with a substantial workload.

Recent austerity measures have eliminated positions within the federal government, including those of professionals in the environmental field. These employees could have and would have been called upon to assist with environmental reviews. Is the necessary federal funding going to be allotted for needing staff to cover the dramatic increase in proposals that can be expected to be brought forward from proponents from the regions? Many northerners are concerned that the handover to the NWT of authority for the enforcement of regulations does not come with the resources necessary to do it.

Leaders are aware that many of the federal personnel employed during environmental assessment work have chosen to retire rather than transfer to the GNWT. This raises a concern about whether there are significant training dollars available so that newly hired local personnel can properly manage and enforce existing programs, not to mention implement new ones.

We also note with some disappointment the apparent lack of reference to and respect for local people who are well versed in traditional knowledge and who have much of value to say in environmental assessment matters. If they are unable to interpret regulatory legalese and to communicate these ideas to the public at large, much is lost. A mega-board hundreds of miles away in Yellowknife is not going to be able to take advantage of what these people have to offer.

Our recommendations are as follows: one, that the regional boards remain in existence to assist with the relaying and gathering of information from those who reside within the regions; two, that regional boards review any development proposal within their jurisdiction and create a regional position that reflects the informed views of those who reside within that proposed area; three, that a fail-proof auto-sent notification system be utilized to ensure email communication does not break down, and that accommodation, with time extensions, is permitted when it does; four, that procedures be put in place to ensure flight delays or cancellations don't deprive any board members of their right to participate in meetings; five, that the bill be amended to empower the regional and central boards to extend the 45-day time limit should it be necessary for the proper evaluation of a proposal; and six, that the bill require the government to adequately staff, train, and otherwise resource the boards, and should this not be done, that the time limits be waived.

In conclusion, we believe that the federal government has misplaced the priorities by putting forth Bill C-15 prior to settling the land claim agreements with the Akaitcho and the Dehcho. Recognizing the existing rights of all aboriginal peoples must be the first priority. After this is done, and only then, will Bill C-15 amended as we have suggested become a more palatable pill to swallow.

Finally, the Northern Territories Federation of Labour as a member of Alternatives North wishes to go on record as fully supporting and endorsing the analysis and recommendations in their brief.

Thank you again for your time.

[David Bob, Vice-President, Northern Territories Federation of Labour]

Mr. Chair and members of the committee, for the record, my name is David Bob, and I am the vice-president for Northern Territories Federation of Labour. With me is Ms. Sandra Lockhart, the regional vice-president for Tlicho/Somba k'e.

On behalf of the more than 9,200 members of the Northern Territories Federation of Labour I would like to thank you for providing this opportunity to express our views on part 4 of Bill C-15.

The NTFL is comprised of many different unions representing workers from a full range of occupations in both the Northwest Territories and Nunavut. We have been chartered with the Canadian Labour Congress since May 1980 and are dedicated to ensuring the protection of both organized and unorganized workers' rights.

At the outset, it is important to state that we are concerned that only one day of meetings has been scheduled and that the meetings are only in Yellowknife. Bill C-15 is very important legislation that fundamentally changes how we operate in the Northwest Territories. While it is generous of you to have provided financial assistance for travel to Yellowknife, there are many other effectively silenced voices in our territory that also deserve the opportunity to be heard.

Bill C- 15 should really be split into two distinct bills that can be debated and voted on separately. Combining devolution legislation with amendments to the Mackenzie Valley Resource Management Act is a tortured exercise and one not worthy of a government wishing to be transparent and democratic. While some may quibble over the details and outcomes of devolution, that part of the bill will probably earn general consent from the people of the NWT.

The part of the bill that completely disrupts our existing regulatory system, however, is sure to elicit substantial adverse reactions. The intent of devolution is to transfer greater authority over land and resource decisions to the north and northerners, but we do not believe this would be achieved by the proposed changes to the regulatory regime contained in part 4 of the bill.

To make it perfectly clear, our primary concern is with the proposed elimination of regional boards. In our opinion and the opinion of what we believe is the majority of the people in the regions of the NWT, creating one mega-board will only allow greater outside political interference in the development decision-making and will adversely affect working people in the Northwest Territories.

Jobs are the essential driving force of the local economy in our communities. Many in the outlying communities continue to suffer from impacts of the current recession. Good well-paying jobs are very hard to come by. We are not arguing that regional boards should be operated solely as a make-work project, but we argue that some of the professed savings that are claimed to result from the creation of the mega-board are at the clear and direct expense of the economies and local communities where the regional boards now reside. The loss of these local jobs takes money out of the community. That in turn impacts local often struggling businesses that rely on these consumers' dollars.

We believe that these harmful effects have not been given the weight they deserve in the drive to centralize regulatory affairs in a mega-board far from the communities its decisions affect. The development of a mega-board based in Yellowknife will surely limit the regional input, reducing people's sense that they have a meaningful say in decisions that will affect their very way of life today and forever.

Consultation and effective democratic control over development decisions are being sacrificed in the drive for some ephemeral efficiency that may or may not be achieved through the workings of Bill C-15. Though quick decision-making may help a proponent get a faster response to the proposal, it does little help to ensure that the decisions are in the wider public interest. The Northern Territories Federation of Labour believes that the timeline provided for Bill C-15 places undue hardship on the individuals who represent their regions.

An average person's ability to fully understand the language contained within a proponent's proposal may be challenging at times. The burden this places on a board member to efficiently and fully communicate the nature of the proponent's proposal to the members of his or her community is difficult. Also, to gather and represent the region's concerns can be very challenging. Making their job harder by imposing arbitrary, unrealistic, or unnecessary deadlines is counterproductive.

In particular, those who sit on the new mega-board would face increased challenges in the collection of information if they represent regions that do not have fibre optic and high-speed connectivity. It is well-known that communities outside of Yellowknife that transmit signals through means other than fibre optic cable, and this is most of them, have regular interruptions of service. The lack of reliable communication infrastructure in much of the NWT makes emailing a risky business with many outages and dropped messages.

Communications problems are compounded by the seasonal nature of winter roads and the closure of highways and airports due to weather. Even mail service cannot be counted on at all times in the NWT. These are the realities that northern members of boards and agencies deal with day in and day out.

Having board facilities, services, and meetings in Yellowknife will greatly reduce the smooth and reliable flow of information, both inwards and outwards. The very attendance of board members and their ability to stand and speak for the concerns of those who reside within their regions are jeopardized by moving decision-making out of their communities and regions.

[Allen Stanzell, First Vice-President, Northwest Territories Chamber of Commerce]

Mr. Chair, and committee members, thank you for coming to Yellowknife and providing us with an opportunity to speak with you today.

The NWT Chamber of Commerce is the largest business organization north of 60 and we've long been a champion of devolution. We firmly believe the closer the authority is to the affected jurisdiction, the better the overall decision-making in the interests of that jurisdiction. As part of our preparation for this address, we polled our members to get a collective opinion regarding our position. With few exceptions, our members of the chamber network from Hay River to Inuvik support the points we wish to leave with you today.

First and foremost, the business community of the Northwest Territories supports the legislation as a whole and wishes to congratulate the federal and our aboriginal and territorial governments for their hard work and foresight in moving related agreements and this legislation forward. Is Bill C-15 perfect? No. Nothing visionary is ever perfect. In our view Bill C-15 is indicative of the vision shared by the people of the NWT.

To reinforce that statement I wish to refer to a poll conducted in early March 2013. The research was commissioned by an independent third party and conducted by an independent research firm. The methodology included interviews with 400 NWT adults balanced between larger centres and small communities. The key finding of that research was that nearly 7 in 10 respondents were either in favour of the devolution agreement or not opposed to it, while fewer than 2 in 10 were opposed. Clearly devolution of resource land and water authorities is a vision shared not just by the NWT business community but also by the vast majority of NWT residents.

We know some groups would have us roll back the hands of time and leave things as they were. While we respect their voice and thank them for their contribution, we disagree. We believe it's time for the NWT to make meaningful progress towards its maturity as a larger, more important contributor to the nation that is Canada.

We support the overarching intent and spirit of proposed amendments to the MVRMA and believe they are a positive step toward development and resource management in the NWT. We also believe there is more work to be done and challenges to be addressed. The NWT ranks very high in resource potential but very low with regard to mining and oil and gas investments because of regulatory infrastructure and other issues.

In short, Mr. Chair, we have a lot riding on the success of devolution and the efficacy of regulatory reform.

I think we would all agree that it's difficult to optimize devolution of authorities without effective legislation and regulations. Therefore in the limited time we have, I will focus on the five key points of MVRMA reforms that we hope will be addressed by the federal government.

First, the NWT Chamber of Commerce advocates for clear criteria to define projects of public concern and subsequently advocates for the NWT's regulator to make that determination rather than Ottawa. Specifically, there needs to be statutory criteria for the expansive interpretation of what might be of public concern in section 125 of the MVRMA. Clear criteria do not exist for determining public concern and that leaves the regulator with an open-ended obligation to accept such interventions without regard for merit.

There's an underlying belief that AANDC does not have authority to amend section 125 because it may violate land claim agreements. We believe that section 125 can be amended without contravening land claim agreements and in a manner that would better align the MVRMA with those agreements. The critical point here is to establish criteria for defining projects of public concern or thresholds that limit interventions to those of merit. As importantly, we believe the determination for defining a project of public concern should continue to reside with the territorial regulator, which would filter interventions through the new criteria.

Second, the NWT Chamber of Commerce advocates for more specificity with regard to referral of projects to preliminary screening in section 124 of the MVRMA. None of the amendments to the MVRMA address the issues related to preliminary screening of applications. Too often, proponents are ordered to undertake environmental assessments regardless of the scale of projects. We're aware of simple exploration drilling applications being referred to EA. When the process costs more than the project, proponents have no choice but to withdraw their applications.

Such actions only drive investors out of the NWT. For a variety of reasons, we are already one of the most costly jurisdictions in the country in which to undertake exploration and project development. It makes no sense to burden resource investors with process costs that are unwarranted.

To be clear, we are not advocating for the elimination of the environmental assessment process; we are advocating for a more reasonable definition for project referral to an EA, perhaps based on the scale of projects.

Third, the NWT Chamber of Commerce advocates for environmental assessment and environmental impact review decision-making caps of not more than one year for simple applications, including brownfield projects, and not more than two years for greenfield projects.

We are aware of projects taking far too long to get to approval. De Beers' Gahcho Kué project took seven years to receive approval. In fairness, the proponent slowed the application process during the global recession of 2008. However, the uncertainty related to regulatory decisions in the NWT is one of the major concerns of mining and oil and gas executives around the world. Capital goes where it can grow, so investors move on to other jurisdictions that provide greater certainty. We are fortunate that De Beers is committed to northern projects and is very well capitalized. Other investors would not take the chance on a regulatory process that has no defined decision-making caps.

The duration and cost of the decision-making process affects every applicant, including the crown. It took more than two years for the Northwest Territories Power Corporation to receive a water licence renewal for the Taltson power plant. The plant has been operating since 1965. The corporation filed for a 15-year licence renewal, which is standard. The facilities were not being altered. Stream flows were not being altered. Yet the crown corporation was subjected to a costly two-year process, a cost that ratepayers had to pick up.

The current legislation and regulations need to be tightened up so that common sense may prevail. In our view, that begins with decision-making caps. The Yukon Territory provides applicants and investors with decision-making certainty through the Yukon Environmental and Socio-economic Assessment Board. The NWT must absolutely provide the same degree of certainty.

Fourth, the NWT Chamber of Commerce supports the creation of a single regulatory board for the entire NWT. We realize that this is a point of contention. However, in our view, federal legislation enables the government to create a single board with overarching authority. Notwithstanding that local boards have some merit, we don't believe the volume of applications in the NWT warrants multiple boards. Smaller boards don't have the resources to review complex applications. A single board would afford appropriate resources.

When powers were devolved to the Yukon, the Yukon environmental and socio-economic board was created as a central decision-making body for the territory. YESAB retained a local presence by establishing six designated regional offices that act as entry points for applicants. The same could happen in the NWT, where regional boards exist today. In that manner, a local presence and community ties are maintained when reviews take place in a central organization with the technical capacity to manage them efficiently.

Fifth, the NWT Chamber of Commerce advocates for a single-window application process for the NWT resource exploration and development projects—that is, a one-stop window for land and water use permits as well as licences.

Again, when powers were devolved to the Yukon, the right to issue mining licences remained with the federal government. In discussion with our industry colleagues in the Yukon, it seems that was an oversight. We have the opportunity here to ensure that the authority to issue licences resides in the NWT.

We are advocating for a single application window. In simple terms, when an application arrives for a resource exploration or development project, it triggers the system to address all aspects of the application concurrently, including all related federal and territorial authorities. This model is employed elsewhere in Canada. It creates vast efficiencies relative to the current system, where federal and territorial authorities work in a disintegrated fashion that leads to inconsistencies and regulatory duplication.

In the past 30 years, the transfer of responsibilities to the Government of the Northwest Territories has taken place for several programs and services, including the delivery of health care, social services, education, administration of airports, and forestry management. In our view, Bill C-15 is the next logical and single biggest step forward in history in the devolution of powers to our territorial government.

We are a resource-based economy. Managing our resources effectively and creating a healthy investment climate will support a strong local and national economy, and provide significant benefits to all of our communities and all of our residents.

Bill C-15 is a new beginning for the Northwest Territories.

That concludes our remarks, and again, thank you for the opportunity.

[Tom Hoefer, Executive Director, NWT and Nunavut Chamber of Mines]

Thank you very much, Mr. Chair and the folks here. My name is Tom Hoefer. I'm the executive director of the NWT and Nunavut Chamber of Mines.

We are an industry association and champions for mining in the two territories. Our review of Bill C-15 was also done collectively with our sister national organizations, the Prospectors and Developers Association of Canada, and the Mining Association of Canada.

I'm joined by our legal counsel, Michael Hardin, who has helped us with our submissions and who has a wealth of northern regulatory knowledge, having worked with us for over 20 years.

We would like to start by thanking the minister of AANDC and his staff for their consultations with us and for the very detailed response to our concerns. Although we did not get everything we were hoping for in Bill C-15, we are thankful for the improvements being proposed and for the minister's assurances of our continued involvement in the regulatory improvement process.

We have submitted to you a detailed brief, and I will now take you through the deck that we also provided in advance.

Turning to slide 2, we have a number of key messages. Our minerals industry is the foundation of the NWT economy. We support the devolution of land and resources to the new landlord, the Government of the Northwest Territories, and our interest in Bill C-15 will focus on regulatory improvement, specifically amendments to the MVRMA.

There has been a significant decline in exploration spending. We are encouraged by amendments to the MVRMA that can help turn this around, but more amendments are needed, especially with respect to unwarranted referrals of small exploration projects to environmental assessment. Therefore we believe that more changes are required to create certainty again for investors.

I'll turn to slide 3 to introduce the importance of our industry. Over the past 80 years the value of NWT mineral production has exceeded $60 billion.

In the next slide you will see that mining is the biggest business in the Northwest Territories. We're the largest single private-sector contributor to the economy, and we add even further benefits through construction, transportation, and real estate.

In the next slide, mining creates huge value for the NWT as data from Natural Resources Canada demonstrates. As you can see, the value of NWT mining production is many times greater than that of Nunavut and the Yukon.

In fact in the next slide you can see that we're globally significant. Our diamond mines have established the Northwest Territories and Canada as the third most valuable producer in the world.

In the next slide you will see that our mines turn that production value into benefits for the NWT and Canada, and for aboriginal and northern residents and businesses. For detail beyond the figures shown here, I encourage you to download from our website the publication “Measuring Success”. There's a picture of the cover shown on that slide.

The next slide shows the unfortunate reality that no mine lasts forever. This chart shows the current lives of our NWT mines. While we are hopeful that their owners may be able to find ways to extend them in the future, there is no guarantee of this. Importantly since discovering and permitting a mine is a 10-year-plus process, we need to be attracting a constant flow of exploration investment annually. This is where the dilemma lies.

The next slide shows the annual exploration spending. I draw your attention to the Northwest Territories in blue. Note how it declines and essentially flatlines compared to our neighbours. Note how successful Nunavut and the Yukon have been in attracting investments over the same time period. Since our mineral potential is at least equal to that of our neighbours, we know something is structurally wrong here in the Northwest Territories.

Let me emphasize that in the next slide, which reveals a steady decline in the NWT's competitiveness and our loss of Canadian market share. Let me note too that the small uptick projected for 2013 is not due to an increase in exploration but is rather due to investment in just a very few of our advanced projects.

Why, you will ask, have exploration dollars fled the Northwest Territories? The next slide gives two principal reasons. First is the uncertainty caused by unsettled land claims in two of the most prospective parts of the territories, namely the Akaitcho region and the Dehcho region.

The second reason is the complex, costly, and unpredictable nature of the regulatory process under the Mackenzie Valley Resource Management Act. For these reasons, we continue to emphasize the urgency of quickly settling land claims. We also look to devolution to play an important role, particularly with the NWT government's launch and implementation of its first-ever NWT mineral development strategy. We are also hopeful that the amendments to the MVRMA proposed in Bill C-15 will be seen by investors as a step in the right direction.

However, we respectfully submit that the Bill C-15 reforms will not achieve the full turnaround that is needed without additional key amendments to the MVRMA beyond those in the current bill.

The next slide shows our many attempts to get regulatory improvements to the MVRMA just over the past six years. During the same period, we watched the steady decline of investment in the Northwest Territories. If we are to sustain the great benefits our industry is providing, we must seek improvements in the MVRMA to rejuvenate exploration investment. We're hopeful that following our submission today, the committee will help drive that point home and get additional changes made.

Let me speak now to the important changes that we support in Bill C-15, as shown on the next slide. Overall, we are happy to see definitive timelines. However, there is one proviso to this, which I will speak to when we reach the next slide.

We also support the expanded ministerial authority to issue policy directions to the Mackenzie Valley Environmental Impact Review Board. As well, we're happy to see that there is a clear mechanism included to authorize changes to the new development certificates without the need for a project to undergo a new environmental assessment.

Amalgamation of land and water boards has attracted considerable commentary. We recognize that the aboriginal community is validly concerned by the loss of the existing regional panels. You should know that a number of industry members, especially those who have developed close working relationships with the regional boards, have likewise expressed reservations.

On balance, we support the amalgamation proposal provided that it does not negate the existing working relationships that applicants and licence holders have developed with the regional board panels, that the amalgamated board maintains a strong regional presence, and that the board chair is authorized to appoint a representative from the settled land claim area that hosts the project under review. We're encouraged that the minister has indicated that AANDC will take this into consideration.

I will turn now to our final slide. We believe that further reform to the bill is needed in five key areas.

First is the unwarranted referral of the small exploration projects to environmental assessment. Mineral investors repeatedly identify the risk of an unwarranted referral as the number one reason to vote with their feet and invest elsewhere. These referrals are frequently made on the basis of public concern, an important term that is not defined anywhere in the act. Therefore, we recommend that the MVRMA set down clear and consistent standards for referring any development proposal to environmental assessment, especially those for small preliminary exploration programs. Unless that fundamental change is made, we fear that exploration spending in the NWT will continue to fall behind activity in competing regions.

The second area for reform relates to the need for proportionality in environmental assessments and the importance of ensuring a balance between environmental and economic objectives throughout the regulatory regime. With respect to proportionality, we have suggested a change to the MVRMA to establish that the scope and intensity of the process be scaled according to the potential adverse impacts of the projects in question. In the same section, we have proposed an amendment that expressly acknowledges the need to balance environmental and economic objectives and priorities.

Our third recommendation relates to timeframes. We support the approximate two-year timeframe for an environmental review. However, the proposed bill carries a real risk where a project nears the end of a two-year environmental assessment process and is then bumped to another conceivably two-year environmental impact review process. The result could be a two-plus-two, or a four-year review process. While the bill does allow for information from an EA to be considered in an EIR, there is no guarantee that this will occur. We recommend, therefore, that the act be amended so that the total time for an EA-to-EIR process is two years. Otherwise, it drives the unintended consequence of proponents demanding at the outset the highest level of review, an EIR, to guarantee them a two-year timeframe.

Our fourth concern is around aboriginal consultation. In November 2012, AANDC's minister indicated that the MVRMA would be amended to clarify the roles and responsibilities related to aboriginal consultation. However, Bill C-15 includes only a preliminary step in this direction, namely, a provision to enact regulations for this critically important area. While we are pleased that AANDC is committed to involving our industry in the development of these regulations, we believe their creation will take some time. We recommend, therefore, that consideration be given to using the expanded ministerial powers to issue policy directions to more quickly bring greater clarity and certainty to this area.

Our final concern is with the proposed cost-recovery regulations. The NWT is already one of the highest-cost jurisdictions in the land. Therefore, we urge a cautionary approach to minimize killing the goose that lays the golden egg by imposing burdensome financial requirements that will be another deterrent to investment in the NWT. We do look forward to contributing to the development and review of these regulations, or in fact, the decision to postpone putting them into place.

That brings us to the end of our presentation. Thank you for your attention to our comments.

My colleague Mike Hardin and I would be glad to answer any questions.