CORRESP 2 filename2.txt ================================================================================ Gary R. Henrie Attorney at Law 8275 S. Eastern Ave., Suite 200 Telephone: 702-616-3093 Las Vegas, NV 89123 Facsimile: 435-753-2947 E-mail: gary@grhlaw.net --------------- October 13, 2006 Via EDGAR --------- THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION Mr. John D. Reynolds Assistant Director Division of Corporation Finance Mail Stop 3561 Washington, D.C. 20549 Re: Pioneer Exploration Inc. Registration Statement on Form SB-2 Filed July 13, 2006 File No. 333-135743 Dear Ladies and Gentlemen: As outside counsel to Pioneer Exploration Inc., I have prepared this letter with management in response to the staff's comment letter dated July 21, 2006, regarding the matters listed above. Also, in response to your comments, management has filed amendment number one to the registration statement. In response to the staff's comments, management has added subsections entitled "History of Chilco River Holdings Inc." and "Rule 419" at the end of the section titled "Business" in the registration statement. All staff comments in your letter dated July 21, 2006, are addressed in the two new subsections. Other changes to the registration statement in amendment number one are merely updates to the filing to bring it current. Very truly yours, /s/ Gary R. Henrie Gary R. Henrie