January 17, 2008
These are my comments on File Number S7-XX-07.
One of the only items I would like to see changed is rule 4-10. What it defines as proved oil and gas reserves. If a company proved up a significant amount of a natural resouce within high quality tar sands (bitumen) and they can provide evidence pointing to current extraction processes/techniques that are economical on other like projects, then I feel that they should be entitled to calling their defined/delineated reserves, proven oil reserves. Their may need to be a minimum measure for the bitumen quality.
Also there may be a need for a definition for what is considered an economic resource/reserve now that oil prices exceed $50.00. Local economics have to be reviewed and expected/future wage inflation of a region measured. With upwards of 100s of billions of barrels of bitumen in Canada alone, this resource needs to be counted as reserves in the future.