I, Brian Merwin, hereby declare as follows:

INTRODUCTION

1. I am Vice-President Strategic Initiatives for Mercer International Inc. (“Mercer”), the largest Northern Bleached Softwood Kraft (“NBSK” or “kraft”) market pulp producer in the world. My date of birth is [________________], and I currently reside at [_________________]. I offer this testimony to recount my personal knowledge and experience of the treatment to which the Province of British Columbia has subjected Mercer’s significant investment in Canada, the Zellstoff Celgar Mill (“Celgar” or “Celgar Mill”). The Celgar Mill is one of the largest and most modern kraft pulp mills in North America, which utilizes an integrated, joint production process to produce market pulp and to generate electric power.