1. My name is Lawrence Edward Smith and I reside at 1216 Beverley Blvd. SW, Calgary, Alberta. I have no past or present involvement with the disputing parties, counsel or the Tribunal as it relates to the matter in dispute.

2. I have reviewed the Claimants' Memorial, its Witness Statements, the Expert Report of David Estrin, the Whites Point Project Joint Review Panel Report, hearing transcripts and other related materials for purposes of preparing this Expert Report.

A. PURPOSE OF THIS REPORT

3. I have been asked by the Government of Canada for my opinion, based on my experience, as to the reasonableness of the treatment afforded Bilcon in the context of the environmental assessment of its proposed Whites Point Project; and whether it was discriminatory or lacked fairness as compared to the environmental assessments of other similar developments in Canada, and in particular in Nova Scotia.

4. In that regard, I have also been asked to review and comment on the expert opinion filed on behalf of Bilcon by Mr. David Estrin.