1. In accordance with Article 3 of the arbitration rules of the United Nations Commission on International Trade Law of 1976 (“UNCITRAL Arbitration Rules”) and Articles 1117 and 1120 of the North American Free Trade Agreement (the “NAFTA”), the Claimant Lone Pine Resources Inc. (“Lone Pine”) hereby initiates recourse to arbitration against the Government of Canada with this Notice of Arbitration under the UNCITRAL Arbitration Rules (the “Notice of Arbitration”).
A. DEMAND THAT THE DISPUTE BE REFERRED TO ARBITRATION
2. On November 8, 2012, Lone Pine served the Government of Canada with a Notice of Intent to Submit a Claim to Arbitration under Chapter Eleven of the NAFTA (the “Notice of Intent”) in connection with a measure undertaken by the Government of Quebec in 2011 in accordance with Articles 1118 and 1119 of the NAFTA. More than six months have elapsed since the events giving rise to Lone Pine’s claim in accordance with Article 1120(1) of the NAFTA, and more than 90 days have elapsed since Lone Pine submitted its Notice of Intent in accordance with Article 1119 of the NAFTA, during which time the parties have been unable to arrive at a mutually agreed upon resolution. Therefore, pursuant to Article 1120(1)(c) of the NAFTA, Lone Pine hereby demands that the dispute be referred to arbitration under the UNCITRAL Arbitration Rules.