MEMORANDUM OF JAMES HUNTER Q.B. No 1082 of A.D. 1994

Q.B. No 1082 of A.D. 1994

IN THE COURT OF QUEEN'S BENCH FOR SASKATCHEWAN
JUDICIAL CENTRE OF SASKATOON

B E T W E E N:

THE GOVERNMENT OF SASKATCHEWAN
SASKATCHEWAN ENVIRONMENT AND PUBLIC SAFETY
MINES POLLUTION CONTROL BRANCH OF SASKATCHEWAN ENVIRONMENT
AND PUBLIC SAFETY

DEFENDANTS (APPLICANTS)

- and -

JAMES GARRY HUNTER

PLAINTIFF (RESPONDENT)


MEMORANDUM OF JAMES HUNTER

JAMES G. HUNTER
P.O. BOX 7645
SASKATOON, SASKATCHEWAN
S7K 4R4

MEMORANDUM OF JAMES HUNTER

1. This Memorandum is filed in support of the relief requested in the affidavit of the Respondent filed in these proceedings.

The "Serious Issue" Requirement

2. Paragraph 4 of the Statement of Claim says "failed in its mandate to protect the environment and public safety with respect to the---" and then it lists the spills. 160 tons of yellowcake at the bottom of the Rabbit Lake Pit is a Serious Issue. Thousands of litres of fuel is in a cavity in the perm-frost at the Rabbit Lake Mine. That is a Serious Issue. A transport truck spilling yellowcake. That is a Serious Issue. The laws say that the spills must be cleaned up in accordance with the law. They have not been. That is a Serious Issue. The Laws say that reports of spills are to be investigated in accordance with the law and they have not. That is a Serious Issue. The Laws say that there are penalties for spilling and there have been no penalties. That is a Serious Issue. The laws say that the environment is to be protected in accordance with the law and the Government is responsible for the enforcement the laws. This has not been done. That is a Serious Issue. The Laws say that the transportation of yellowcake must be done in accordance with the law. This has not been done. That is a Serious Issue. The yellowcake and fuel are still contained in the pit and cavity. They will eventually get into the environment and destroy it. That is a Serious Issue. The Laws are to protect the environment. With no watch dog, there is nothing to prevent a reoccurrence. I live 5 city blocks from the Cameco warehouse. I do not want yellowcake spilt in my neighbourhood again. That is a Serious Issue.

3. The issue of standing may be determined as a preliminary matter. In Finlay, Le Dain at p. 612 states:

"Assuming that the question whether an issue of standing to sue may be properly determined as a preliminary matter in a particular case is one which a court should consider, whether or not it has been raised by the parties, I agree with the view expressed in the Australian Conservation Foundation case. It depends on the nature of the issues raised and whether the court has sufficient material before it, in the way of allegations of fact, considerations of law, and argument, for a proper understanding at a preliminary stage of the nature of the interest asserted....." (emphasis added)

4. The AECB Report has been submitted to the court attached to the affidavit of Peter Courtney. Paragraph 3 of the introduction to the Applicants Memorandum says that they are not going to rely on it for the purposes of this motion. If this is the case then why was it filed. Paragraph 5 of the Statement of Claim makes reference to a permit issued by the Applicants to burn solvent contaminated by uranium oxide. Why is the Report filed and the permit is not. The Statement of Claim says that the Report is a fabricated fact. I can prove this. I should not have to prove this in Chambers. The court should not be used by the Applicants in an attempt to add credibility to its evidence in the case. If I had not filed an affidavit in response to the Report being filed I would not have received a call by the Applicants lawyer requesting a postponement. The motion would have been heard and a decision made based on the Report. This is not appropriate. The Report should not have been filed and I should not be required to argue in Chambers that the Report is a fabricated fact. It is a matter for discovery and trial. Any discussion based on any of the contents of the Report is not appropriate. The Report has my name on it. I have a right to challenge the contents of the Report in court. The Applicants have informed me that they are going to argue that my affidavit is not admissible. If the Report is admissible then my affidavit should be admissible.


The "Genuine Interest" Requirement

5. Mr. Justice Thurlow in the Federal Court of Appeal decision ((1983) 146 D.L.R.(3d) 704 at page 711) where he stated "...what is at stake is the right of the citizens of Canada to have the Consolidated Revenue Fund applied in accordance with the law". I have a right as a citizen of Canada to have the Environmental Laws applied in accordance with the law. I have a right to be protected by the laws

6. Cory, J. in the Canadian Council of Churches ruling in the Supreme Court of Canada stated at 132 N.R. 260 (paragraph 39) "...has demonstrated a real and continuing interest in the problems..." I reported the spills to the mine. I reported the spill to the transport company. I requested changes to the unloading faculties. I reported the spills as required by law. I brought details of the spills before a Justice of The Court of Queen's Bench. I wrote to the Ministers responsible. I wrote to Members of Parliament. I organised loads received by the mine from December 1985 to February 1986 including date, product, load number, bill of lading number, truck number, trailer number, driver's name. I organised hundreds of fuel meter readings into consecutive order for three unloading sites. The meter readings took me 2 years to organize.
I know the who, what, why, when and where of the spills. I am the only one with this information.

7. In paragraph 59 of the Applicants Memorandum they say " However there is no evidence before this Honourable Court to suggest that the Respondent has established a past record of environmental concerns and activities that would allow him to satisfy the "genuine interest" criterion." In my early teens I caught yearling bears in garbage cans in North Vancouver to keep them from being shot. I hiked throughout the mountains of North Vancouver. The area is a watershed with no access to the public. I played hooky to hike and explore. I collected rocks, fossils and pine cones.

8. During the summer holidays, I hitchhiked to Wells Grey Park in Northwestern B.C. The park boundary was 20 miles by a good weather 4 wheel drive trail. The sign at the start of the trail said: Report to ranger station at park boundary. Choose your rut with care. You will be in it for the next 20 miles. I reported to the station 5 days later. The ranger was concerned about my going into the park because of my age and because the park was set up as a wilderness park with no services or trails except for game trails. He was concerned that I had more books in my pack then food. He offered me some smoked fish and meat and I refused as I did not eat meat and the park waters had ample fish. The ranger instructed me on how to avoid problems with grizzly bears and I hiked throughout the park for the summer. Two weeks later I asked a ranger at a fire tower to let him know that I was all right. I had diverted from my planned destination and would not make it out of the park until after the time I told him. He gave me a ride to the park boundary the following summer. From then on I spent my school holidays fighting forest fires.

9. In my late teens I started work driving truck in isolated logging and mining camps on the west coast of Vancouver Island and the Queen Charlotte Islands. The bears were a problem because of the garbage dump. They were being shot when they came into camp. The camp tried to keep the bears out of the dump by building a wire fence around it because it was the dump that attracted the bears. I suggested that they truck the garbage away from the camp and dump it in one of the many rock pits left from the road construction. This ended the practice of shooting bears in this camp and many more camps that I worked at.

10. On the Queen Charlotte Islands I stopped the road foreman from bridging a creek that fish were spawning in. I insisted that he summon the forestry engineer. The engineer instructed the foreman on the law and instructed him to bridge the creek without disturbing the creek. One year later the creek was full of logs, mud and debris. The area had been clear cut. I asked the engineer to do something about the creek. He reported the violation but the deed had been done and there was nothing else that would restore the creek, it was gone along with the fish.

11. At a camp on the Queen Charlotte Islands, I was driving a logging truck when I came across a deer run over on the road. In camp that night a driver came to me and told me that he had ran over the deer. He was upset because there was a fawn with the deer. We found the fawn and raised it in the bunk house until it was a year old. We named him Winkie as he would wink back if you winked at him. The only complaints were about missing socks and the card table being knocked over. The bullcook complained about him daily but he always left the door open so he could get in when the camp dogs were chasing him. We released him in Stanley Park in Vancouver as there were other deer in the park and the employees of the children's zoo would keep an eye on him. I saw a picture of him years later in a Vancouver newspaper. He had wandered out of the park into the west end of the city. The people chased him back into the park. This is a city where the rush hour traffic going through the park stops to let a duck cross the road.

12. There is a one of a kind tree on the Queen Charlotte Island that is called the golden spruce. It is a healthy spruce that is golden instead of green. I tried without success to produce a second tree from its cones. When exploring I came across a patch of ground containing a variety of seedlings that had been fenced off not far from camp. It belonged to the forestry engineer. He was trying to produce a second golden spruce by grafting a golden spruce on to a green spruce. His theory was that he could then use the cones from this tree to produce another golden spruce. He used his own seedlings from the plot to do this. He let me help him. He burned some of the cones to produce his seedlings. The following summer after having no success he showed me a spruce tree that was green on the bottom and golden on the top. The tree was 4 feet tall and he had been trying to graph another for years. To my knowledge he is still trying but there is still only one golden spruce in the world and one hybrid.

13. I went to the southern part of the Queen Charlotte Islands to help prepare a site for a new camp. By this time I had explored many parts of B.C. The environment that I found there was unlike anything that I had seen before. The forest floor was a bottomless carpet of green moss with giant red and yellow ceder trees growing out of it. There was very little underbrush except for shrubs and berry bushes that I had never seen or eaten. There were creatures living in the moss and birds that were not in my books. It was this kid's dream come true. I came across a path in the moss that was not natural. I dug down through the moss thinking that I would find gravel. I found what I thought was small hemlock logs laying side by side but there was not a hemlock tree to by seen. I followed this trail to a large inlet on the other side of the Island. When exploring later I discovered a large mound of moss not far off the trail that I thought at first looked like an old cabin that the roof had fallen in on. On closer inspection I found it to be a large ceder boat. I asked an older Indian friend who laid claim to being the last living purebred Haida if he knew about the boat and the trail. He said that the boat was a Haida War Canoe. He went on to tell me about the spiritual rituals involved from the picking of a tree and continuing until the canoe was put in the sea. He told me stories about the travels of the War Canoe along the B.C. and U.S. coast and the slaves brought back by them to the Islands. He told me the canoe was not put into the sea because the area Haida had all been killed by smallpox. I had heard about their village and he told me where it was. He asked me not to tell anyone about the canoe. The village was on a large island not far from the main island. The island and the village became my favourite hiking destination. I found the nesting site of one of the unknown birds on a rock face on the Island, they were pedigree falcons. On one of my trips I found that one of the totem poles had been cut down and removed from the village. When I told my friend about it he told me that the pole was safe. A lot of the brush pilots on the Islands are Haida and they watch over the village. An American had cut the pole down and tied it wrapped in tarps to the deck of his boat. When he stopped for fuel the Haida retrieved their pole and trashed his boat. I left the Islands for two years and when I returned I found that my friend had died. I went back to the camp and the trail was gone along with the trees. I walked up a logging road to where the canoe was. It was gone along with everything else. If I had stayed in this camp the canoe would still be there. I stayed at a Haida fishing camp for three days before going to Vancouver. The Haida were concerned about a planned strip mine on the North Island and were discussing how they could stop it. This was also the first time that I heard a discussion about clear cut logging and the effect this had on the environment. (This was in 1970.)

14. The three days had an effect on me in that I started to realised just how ignorant I was. I realised that the environment on the South Island was changing, the further south I went; it was not because the land was different but because the surrounding environment was different. The farther I went south on the west coast of the Island, the warmer the water. This was not the case on the east coast. The beaches at low tide on the west coast were littered with round thick glass balls used by the Japanese fishing fleet as floats for there nets. The Environment on the Island was different because there was a warm southern ocean current on its west coast.
15. I then started hiking in old slash from logging. I found that the land renewed itself if the slash was burned and there was natural forest surrounding it. If the slash was not burned the land could not renew itself. If the creeks were not disturbed the fish were there. If the creek was disturbed the salmon were gone forever. If the creek in the slash did not drain the natural forest surrounding the slash, the land could not renew itself. The salmon were gone because of erosion from disturbing the land by pulling stumps and roots out. I found this to be the same in areas of natural fire from lighting. The forest renewed itself by natural fires from lighting hitting a dead tree. In these areas if the fire destroyed the natural forest in the drainage area the land renewed itself as the land was not disturbed. I saw that new growth forests in old slashes had no protection from diseases without the natural forest. Large areas of new growth forest subjected the natural forest to disease. I saw areas in new growth forest that were dead from the oil and chemicals from the logging. The slashes that could be seen by the public had been reforested with new seedlings. All of the slashes I hiked in were not.

16. Environmentalists from the south were trying to save a growth of virgin timber for a park on southern Vancouver Island. A logging company had cutting rights on the land. The company agreed to give them up if the government granted them cutting rights in another area. The government agreed to this and the cutting rights granted were in Wells Grey Park. You can now drive into the park on a logging road and look at the wonder of a clear cut.

17. The last logging camp I was in was in 1975. It was 50 miles by water from a pulp mill. When the wind come up it produced a brown foam on the sea and the wind blew this brown scum into the forest. I could give up the logging but I could not give up the north and the forest. I drove truck in mining camps for a few years in the north before driving long distance truck from Vancouver to northern B.C., the Yukon, northern Alberta, Alaska and the N.W.T. I carried my corked boots and a boat with me in the truck at all times. Many trips took me three days longer than needed because of my need to explore the land.

18. Complaints I made to companies were mostly greeted with common sense by the management but not the workers. They were mostly about the bears, garbage and how to build a bridge over a creek instead of in it. One of the exceptions was at Boat Encampment on the Columbia River in northeastern B.C. One of the workers on the dam construction site told me that he was told not to fish in a diversion tunnel. He told me that the tunnel acted as a back eddy and this attracted fish to his favourite fishing hole. The workers had closed off the tunnel to the river and were draining it by pumping the water back into the river. I asked the workers how they were going to get the fish back into the river. They planned on pumping the water out and dumping the dead fish into the river with a front end loader. I asked their foreman to stop pumping the water out. He said there was no way to get the fish out. I could not think of a way to get hundreds of fish back into the river. The management of this company were in Vancouver, Calgary and New York. I reported what I knew to Fish and Wildlife and the authorities arrived by helicopter the following morning along with the RCMP. The Fish and Wildlife Department had the common sense solution and all the fish were back in the river 3 days later.

19. I started driving truck from Saskatoon to northern Saskatchewan in 1979. The road to the Rabbit Lake Mine is best described as a wilderness game trail. This became my favourite destination for the next 5 years. The area was better suited to boating than exploring and one day hikes instead of 3 day hikes. When unloading at the mine my face and exposed skin were being stung by sulphuric acid from the acid plant. It was raining acid without a cloud in the sky. There was little pin holes in the paint of all the trucks hauling sulphur to the mine. One of the drivers told me that he was going to complain to the general manager at the mine about the acid burning holes in his new truck. Half an hour later I asked him how he made out. He said the manager was yelling at him about how environmentally safe the mine was. He said that the general manager had "flipped out". In 1984 I could not turn down the opportunity to work in the north again at this mine. I arrived at the mine with my pack, my books, maps, 2 telescopes and my corked boots. There were a lot of small lakes around the mine. Two to the north were slowly dying. They were close together with a short connecting creek. I watched these lakes for two summers. There were beaver and ducks nesting, the duck eggs and shells were normal and I saw no adverse effects on the wild life. There was no signs of pollution in the stream feeding the lakes. I could find no connection between the mine and the lakes. I came to the conclusion the lakes were dying because there was not enough water in the stream feeding the lakes. Trees to the north had small pin holes in their leaves. A lake to the south east was polluted by the mine tailing. The water was a dirty grey brown. It was teaming with fish. On two occasions I saw two employees of the mine fishing in this lake. I suggested to them that no one in their right mind would eat fish from the lake. They were freezing the fish in camp and taking them south and selling them. The lake was connected to Wollaston Lake by a short steam. The fish could come into the lake but could not find their way out because of the pollution. The area to the west of the mine was undisturbed. There was no bear problem at the mine except for the odd cookhouse bear that was trapped and taken out to the bush and released. When hiking along a cut line south of the camp I saw a black cloud of smoke coming from the tailing area. It was going north over the hill I was on towards camp. I could smell that it was kerosene. The cut line ended at the gate house and I was told the mine was burning the kerosene from the SX. I did not know at this time that it was contaminated with Uranium Oxide. I found the people working at the mine to be ignorant of the environment they worked in. I asked a young lady taking pictures of the trees behind camp why she was doing this. She said that her father lived in southern Saskatchewan and had never seen trees before. I pointed out a cut line that was easy hiking and told her that she could take pictures of a winter den, lakes, ducks, beaver and eat all the berries she wanted all within a half hour walk. She was afraid of the bears and told me about the man in camp that was attacked by a bear. I told her about the bears and that the bear was not attacking the man.

20. I have detailed the spills at the mine in the affidavit before the court and will not cover them further here. I was required to report fuel spills at the mine to two mine employees whose incompetence resulted in the spills. These same two employees then covered up the spills by changing the mine records. This was not done to protect the mine but to protect themselves. The mine management had no knowledge of the fuel spills. I believe the yellowcake spill was encapsulated in cement because the mine did not know what else to do with it. There was no way to get it out of the pit.

21. I have not had much to do with environmentalists except to distribute posters about the strip mine on the Charlottes. I realised that they have done more to protect the environment then I have. If not for them there would not be a park on Moresby Island on the Queen Charlottes. I hiked this land and I know what a loss it would have been to the world if it had been destroyed.

22. At the mine they blocked the road one summer. They camped at the gate on both sides of the road. A peaceful bunch of southerners camping and having fun. They would rattle the gate and the RCMP would don camp coveralls over their uniforms and head for the gate only to find they had stopped rattling it. The RCMP would go back to camp and drink coffee until they rattled it again. When they left, they forgot something. On both sides of the road in their camp were bottles, cans and every kind of garbage you can imagine. The issue was Nuclear Energy not the environment and the land.

23. Not long after this I received a message to call the dispatcher in Saskatoon. He told me that the driver of the grocery truck had reported that he was being followed by environmentalists. My imagination got the best of me and I could not get to sleep as I could not stop laughing. At 1 am I received a request to go to the gate house. The mine manager was there waiting for the truck that I knew was not going to arrive until 7 am. I told him if the driver drove through to the mine without sleeping he would be at the gate by 2 am. While we waited he talked about his early years picketing in Europe against the deployment of nuclear weapons and the recent road blockage. He had a lot in common with the environmentalists. I asked him why he was not out chasing grocery trucks. When the truck did not arrive, I assured him that the driver was sleeping and would arrive at 7 am as usual. I told him if the truck did not arrive at 7 am he could assume the environmentalists had got him and call the RCMP.

24. I never got involved in a environmental issue after the damage was done. I could not bring salmon back to a creek where the spawning grounds have been destroyed. The War Canoe was a part of the land but I could not bring it back. I got involved in issues where the damage had not been done. The spills at the mine are an issue where the damage has not been done.

25. I have seen a lot of things in the north including a one of a kind tree to a river that runs backwards. I have seen a large lake in Saskatchewan that drains in two different places. It drains through northern Alberta, through the N.W.T. to the Arctic and through northern Manitoba to Hudson's Bay. It is the largest lake in Saskatchewan with the world's largest lake trout. I can only imagine with horror the damage that would be done to a large portion of northern Canada if this lake was polluted by uranium oxide or fuel oil. Wollaston Lake is very unique and extra special care must be taken to see that it is protected by the Laws from pollution. The damage will be done if no one cleans up the uranium oxide and fuel to ensure that it does not get into this lake.

26. I am not a weekend hiker. Other than my early teens I have never worked in the city. I have lived and worked in the north or supplied the north all of my life. I have worked in many logging camps along the west coast of Canada accessible only by air or water. I would have float planes drop me off at remote lakes and I would hike out of the bush. I have been a beachcomber and operated a water taxi service on the northwest coast of Vancouver Island. I travelled down remote rivers and creeks on an air mattress. I have hiked in areas of dessert in the Yukon to glaciers in northern B.C. The law may say that the land does not belong to me but I will not sit on my ass and watch anyone screw it up because of ignorance.

The existence of alternative procedures

27. I am required by law to report spills of which I have knowledge. I reported the spills to Mr. Don Elliott and Mr. Lorne Taylor at the mine, as well as, Larry Bautz, terminal manager of Siemens Transport. I did not have to report the yellowcake spill to Mr. Taylor as he was the one that confirmed the spill to me. The spills were reported to Environment Canada. I wrote five letters reporting the spills to Jake Epp, the Minister of Mines and Resources. I reported the spills to SEPS. I reported details of the spills to Richard Pichard (SEPS), Fred Ashley and Tom Viglasky (AECB), and all I got for my troubles was hostility. I reported the spills in court to the Minister of Justice in the Court of Queen's Bench. Instead of receiving the information and acting on it the Minister responded by saying that he could sue me in the court of Queen's Bench but I could not sue him. The Minister took a defensive action against information that reported and detailed spills. The court ordered that the information be sent to Environment Canada. This again resulted in no action. I then wrote to my M.P. He demanded that the minister responsible for Environment Canada take action. This resulted in the AECB report. Not once was I or anyone contacted by the AECB to ask for information or details about the spills. A sodium chlorate spill and other spills I reported and were contained in the information ordered sent to Environment Canada were not even mentioned in the AECB report or investigated. I have valuable information about the spills and not one of the Ministers responsible wants it. After the AECB report was issued I again wrote to the Minister of Energy Mines and Resources detailing inaccuracies in the report and asking why no one else apart from the mine and SEPS were contacted. I was then contacted by the AECB requesting the information which I supplied. The response from the AECB was that further investigations would not be a fruitful way of spending taxpayer dollars. There is no way that I can appeal the AECB Report to the courts. I reported a spill of yellowcake from a transport truck and that it was discovered in Saskatoon. Not one word have I heard about this from any of the agency or the Ministers responsible. Environment Canada has Acts, AECB has Acts and SEPS has Acts all designed to protect the Environment. I am sure that there are Transportation Acts for the safe transportation of yellowcake. What good are they if they are not enforced. What good are they without a watchdog. I have no argument with the Acts and feel that they are designed to protect the environment. I do have a right to expect to have a spill that I report to be investigated and the spills cleaned up. I have a right to have a spill investigated the same as any other citizen would. I should not be treated differently because I reported spills involving Cameco and The Government of Saskatchewan.

28. In paragraph 38 of the Applicants Memorandum they say that under section 4 the minister responsible may issue a "clean-up order" which is appealable to the courts. Why would I appeal a clean-up order? I am not responsible for the spills.

29. In paragraph 62 it says "the judicial concern that in the determination of an issue a court should have the benefit of the contending views of the persons most directly affected by the issue." The environment can not talk. I can.

30. In paragraph 64 the Applicants say that the Environmental Assessment Act ensured there were other means by which the issue raised could be brought before the courts. This sounds like pass the buck or pass the Act. This action would end me right back to the Minister responsible to investigate the commission of an alleged offence as stated in paragraph 65. The Minister already knows about the offenses and has done nothing about them. I have reported spills as required by the law. I am not interested in telling a Environmental Assessment Board about the mining practices of Cameco. I am interested in seeing that the spill are cleaned up as required by law. I have tried everything to get the Ministers responsible to act without any action with the exception of the Applicants ongoing attempt to cover-up the fact that the spills happened.

31. In paragraph 68 it says "But the admission is not fatal to the Applicants' position unless the Respondent can demonstrate the "investigatory relief he seeks as against the named department is available at law". Does the Court of Queen's Bench not have the jurisdiction to enforce the laws of Saskatchewan when the Government of Saskatchewan refuses to?

32. In paragraph 33 it says "what is at stake is the right of the citizens of Canada to have the Consolidated Revenue Fund of Canada applied in accordance with the law". I am a citizen of Canada and I have a right to have the Environmental laws of Canada applied in accordance with the law.

33. The judgement of Thurlow C.J. in the Federal Court of Appeal in Finlay is instructive:
" My understanding of the judgments of the Supreme Court in the Thorson, McNeil and Borowski cases is that the according of status to bring an action for declaratory relief in such situations is within the discretion of the court. The rules developed by the court on the subject are but principles to be applied in exercising that discretion. They teach that the discretion is to be exercised sparingly and is to be restricted to cases which raise justiciable issues that it is important in the public interest to have resolved." (emphasis added)

34. It is in the public's interest to have the spills cleaned up.

The Issue of The Unknown Remedy

35. I am not a lawyer and I have no extensive knowledge of the law but there is no better place to have an investigation into the spills than the Court of Queen's Bench. What better person could be found to hear the allegations that has nothing to gain by the outcome then a Justice of the Court. Employees of Cameco are reluctant to talk about the spills as the mine has a history of firing anyone who does. The court could provide some protection. The result of the action would be the enforcement of the Environmental Laws and the clean-up of the spills. The fact that I do not know how to form a Statement of Claim is not fatal to my claim. There are provisions in the rules with respect to amending the claim. The Applicants in their Memorandum have made numerous mention of the confusion caused by the Statement of Claim and I agree but it can be fixed. I do not believe that anyone can argue that I am not committed to seeing these spills cleaned up. I have talked with a lawyer. If I can not show grounds for standing there is no point in filing an amended Claim. The spills will not be cleaned up without the services of a lawyer to amend the claim. I will place an add in the Toronto Glob and Mail for one if I half to. I will do what ever it takes to see that the Claim is amended and filed by a lawyer. It will be based on the law and not frustration with the non enforcement of the law as my Claim is.

ALL OF WHICH IS RESPECTFULLY SUBMITTED

Dated at Saskatoon, Saskatchewan this 3rd day of June, 1994.

James Hunter
On his own behalf
Address for Service: Same as above
Telephone: 652-8414
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