Northback Holdings deep drilling permit at Grassy Mountain MUST be denied. ACT TODAY.

Your letter will be sent to the Alberta Minister of Energy and Minerals, as well as your Member of the Legislative Assembly.

Minister

Brian

Jean

Government of Alberta

Dear Minister Jean,

I am writing to express my profound concern regarding Northback Holdings (previously Benga Mining Ltd)'s application for a deep drilling permit associated with its plan to conduct a Coal Exploration Program onthe Grassy Mountain Deposit (Application 1948547) and I urge you to direct the AER to deny Northback Holdings Application 1948547.

In March 2022, the Government of Alberta issued Ministerial Order 002/2022, pausing all new coal exploration and development across the Eastern Slopes, with four exemptions for "advanced projects" - which, at the time, presumably included the Grassy Mountain Coal Project.

Sections 3, 5 and 6 of the order directs the Alberta Energy Regulator to suspend approvals, and to not accept new applications, for coal exploration and development on Category 3 and 4 lands, except those that are related to an advanced coal project or an active approval for a coal mine. The order defines "advanced coal projects" and "active approvals for coal mines" as follows:

(1) Advanced coal project - Proposed coal projects where applicants have submitted a project summary to the AER to determine whether an environmental impact assessment is required for the proposed project.

(2) Active approval for a coal mine - Existing coal projects that have been granted a licence to operate under the Coal Conservation Act.

Northback Holdings Corporation can only have an advanced project if there is a "project for which the proponent has submitted a project summary to the AER for the purposes of determining whether an environmental impact assessment is required."

Benga Mining, the predecessor to Northback Holdings Corporation, had such a project. Benga had applications under the Coal Conservation Act for a mine permit and mine license (Application 1844520) and for an approval to construct and operate a new coal-processing plant (Application 1902073). However, the Joint Review Panel report stated that: "[3050] Exercising our authority as the AER, we deny Benga's applications 1844520 and 1902073 under the Coal Conservation Act." With that decision Benga Mining no longer had an advanced coal project and so Northback Holdings Corporation as its successor cannot claim to have an advanced coal project.

Likewise, Northback Holdings Corporation can only have an active approval if it has a licence under the Coal Conservation Act. Benga Mining's application for such a licence was denied. Neither Benga Mining nor Northback Holdings Corporation have a licence and therefore neither can be said to have an active approval.

Therefore, if Grassy Mountain can no longer be considered and "advanced coal project" nor have an "active approval for a coal mine," it no longer qualifies as an exemption under Ministerial Order 002/2022 and the AER cannot accept a new application for coal exploration.

Sincerely,

{user_data~First Name} {user_data~Last Name}
{user_data~Postal Code}

CC: My MLA

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