August 22, 2023 British Columbia Environmental Assessment Office

Since the proponent has chosen not to configure the project components so as to respect the integrity of the community and the natural environment, the proposal must be rejected, and the proponent should be encouraged to develop a proposal to meet these reasonable and achievable standards. [...] (2) The following matters must be considered in every assessment: …(i) alternative means of carrying out the project that are technically and economically feasible, including through the use of the best available technologies, and the potential MiningWatch Canada comment on the draft assessment report for the Cariboo Gold Project Page 2 August 22, 2023 effects, risks and uncertainties of those alt. [...] The draft assessment report presents no justification for the EAO to have accepted the “Detailed Assessment Memo for Project Changes,” despite the fact that it represents a major change in the project configuration apparently, based on publicly available information, without any review of its implications in terms of the applicability of the baseline information and impact analysis already availab. [...] If the assessment process is to have any credibility and utility to decision-makers, the impacts of the project as described – including the April 2023 changes – and the proposed mitigation measures need to be compared with alternative project configurations, not just the ‘null alternative’ of no mine development at all. [...] Under the Environmental Assessment Act, the chief executive assessment officer’s referral of the proponent’s revised application for an environmental assessment certificate to the ministers for a decision must include “recommendations respecting whether the project is consistent with the promotion of sustainability by protecting the environment and fostering a sound economy and the well-being of B.