There is nothing in the core requirements that prevents projects from undermining climate and biodiversity goals. Add the following Core Requirement: Clearly demonstrate through evidence-based methodology that the proposed project, together with other past, present, and reasonably foreseeable future development does not jeopardize: (a) biodiversity and ecosystem health, (b) BC’s climate commitments, (c) human health and safety, including access to clean air, water and local food security.

Proposed projects cannot undermine BC’s ability to meet the greenhouse gas emission reduction targets set out in law. This must be assessed cumulatively with BC’s projected GHG emissions for existing projects and activities.

Proposed projects cannot threaten the survival or recovery of species listed under the federal Species at Risk Act or jeopardize biodiversity and ecosystem health.

Government has promised that no part of this law will be used to lower environmental standards. It should be a core requirement that any “problem to be addressed” under the Act can’t undermine BC’s environment and climate laws/goals.

All Indigenous Nations and Governments whose territory, or whose inherent rights and jurisdiction, is directly or indirectly impacted by a project, must provide Free, Prior and Informed Consent (required under UNDRIP and DRIPA) to designate any project.

Proposed projects cannot be designated if they would be located in or cause damage to any park, protected area, Indigenous Protected and Conserved Area, Tribal Park, ecological reserve conservancy, or would be located in an area of land-use designation (Crown and/or Indigenous-led Land and/or Water Use Plans) that does not currently allow industrial development or the proposed activities.

Add a Core Requirement that the project advances more than economic interests, using evidence-based methodology to clearly show the project’s social and environmental benefits.

The Core Requirements provision should include the following: Critical Minerals and Mining Project Types Additional Requirement: Any project under the Critical Minerals and Mining Project Type must meet the additional requirement of demonstrably (through evidence-based methodology) mitigating environmental and socio-cultural harms and providing sufficient bonding for full reclamation for the entire life cycle of the proposed mining project.

The proposed definition of “Project Readiness” does not prevent financially insecure projects from moving forward. Projects that are partly developed and later discontinued create serious risks for communities, the economy, and the environment. To prevent this, project proponents must have more than a plan in place for financing. At a minimum, they must have completed feasibility studies demonstrating project viability.

The capital cost threshold in the “material and significant” requirement should be removed. It assumes that a project with a capital cost of $100 million+ will have some trickle down benefits, and doesn’t guarantee that it will benefit British Columbians.

All projects should be required to show that they will provide material and significant public benefits beyond capital cost. This could include a minimum number of permanent and long-term jobs filled by communities near the project, or affordable housing units available to vulnerable populations.