================================================================================ Gary R. Henrie Attorney at Law 8275 S. Eastern Ave., Suite 200 Telephone: 702-616-3093 Las Vegas, NV 89123 Facsimile: 435-753-2947 E-mail: grhlaw@hotmail.com January 12, 2007 Via EDGAR THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION Mr. John D. Reynolds Assistant Director Division of Corporation Finance Mail Stop 3561 Washington, D.C. 20549 Re: Pioneer Exploration Inc. Registration Statement on Form SB-2 Filed July 13, 2006 File No. 333-135743 Dear Ladies and Gentlemen: On October 13, 2006, Pioneer Exploration Inc. (the "Company"), filed amendment number one to its registration statement on Form SB-2 in response to the staff's comment letter dated July 21, 2006. In response to the staff's comments, amendment number one added subsections entitled "History of Chilco River Holdings Inc.", "Connections between Companies" and "Rule 419" at the end of the section titled "Business" in the registration statement. Subsequent to the filing of amendment number one, the staff contacted Company and orally reissued comment 1.b. of the letter. This letter accompanies the filing of amendment number two to the registration statement. In amendment number two, the three sections added in amendment number one have been expanded to more fully respond to comment 1.b. Other changes to the registration statement in amendment number two are updates to the filing to bring it current. Very truly yours, /s/ Gary R. Henrie Gary R. Henrie