It's all about avoiding those who get in the way, apart from aligning the ToR timetables for EA and EAA legality;

1) Avoid the FN and environmentalists by maneuvering the CEAA to accept a Comprehensive Study Environmental Assessment (EA) process, instead of a full Joint Review Panel (EA).

2) Included the $800M Mine Site concentrator, OPF, so they won’t need the province’s approval under the Mining Act to send that quasi-processed material to China or India. Ontario can not stop the chromite ore from leaving the province or country.

3) Withdraw the the Ferrochrome Production Facility (FPF) from EAA, so that it is not subject to the provincial EA process to bypass Ontario.

4) Add an option not to build the Ferrochrome Production Facility (FPF). In the ToR, it's on an independent time line than the mine, OPF or ITS. Wait until Ontario gives them the power for about 4 cents per kilowatt or put it in Quebec.

5) Circumvent the applicatory "Class EA for Provincial Transportation Facilities (Ontario, 2000)" by having the transport corridor "all-weather access road" deemed not a "highway" under the Public Transportation and Highway Improvement Act, so that EA requirements associated with the road would be considered through the less stringent "Class EA for MNR Resource Stewardship and Facility Development". It's called "environmental assessment avoidence", like "tax avoidence", all legal.

6) Hire a Canadian tax expert with detailed knowledge of Canadian transfer pricing policies, U.S. GAAP provisions such as FAS 109 and FIN 48, and Canadian / American tax compliance for tax avoidance. It's all about providing reasonable explainations to tax authorities for different valuations of assets as they move through processing and then to market, during an international audit.