Considering that the…

Considering that

the Upper Beaver Project is currently undergoing an Impact Assessment,

the Guidelines require the proponent to provide information to the IAAC regarding any changes made to the Upper Beaver Project as originally proposed in the Detailed Project Description submitted to the IAAC,

the Guidelines require the proponent to consider potential cumulative effects of the Upper Beaver Project in combination with existing and future mining activities in the region, including an explicit consideration of future mining activities resulting from the merger with Kirkland Lake Gold,

all regional activities, including the Upper Beaver Project and all exploration activities, are part of the Kirkland Lake Project,

the proponent is preparing a post-merger Technical Report that will evaluate significant changes to the Upper Beaver Project and other regional activities that are part of the Kirkland Lake Project,

this Technical Report will inform the Impact Statement required by the IAAC,

current and future cumulative effects of all regional activities are at present unknown and thus cannot be submitted to the IAAC,

the Impact Assessment Act states that 'the proponent of a designated project must not do any act or thing in connection with the carrying out of the designated project, in whole or in part ...',

early exploration activities have their own long term, cumulative impacts on the environment, especially when performed over large areas,

the 8 new exploration permit applications alone encompass 90 mining claims,

if these permits would be granted, the total number of claims to be impacted by the proponent's early exploration activities would be 670+, which is more than 35% of the proponent's claims held in the Kirkland Lake Project and would cover an area of more than 100 square kilometers,

gold is not included on Canada's Critical Mineral List,

it is requested that the Ministry pause any decision making on these exploration permits until the Impact Assessment Agency of Canada has made a decision with regard to the proponent's Upper Beaver Gold Project in conjunction with all other existing and future mining activities of the Kirkland Lake Project.