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The document argues that protecting critical biodiversity and hydrological areas from mining is in the national interest and essential for climate change mitigation and adaptation. It proposes a list of areas for total prohibition and a set of procedural restrictions for other sensitive zones to improve decision-making and environmental oversight.

The application seeks to address whether the 'police powers' exclusion from expropriatory measures includes bona fide non-health environmental measures, arguing that such a legal clarification is necessary if California's MTBE ban is not found to be a public health measure.

The Canadian Association of Physicians for the Environment (CAPE) and other applicants argue that the Canadian Gas Association (CGA) has engaged in greenwashing by marketing natural gas as a clean and affordable energy source. The document asserts that natural gas has a lifecycle climate impact comparable to coal, causes significant indoor and outdoor pollution, and is less affordable than heat pumps, especially as carbon pricing increases. The applicants request a Competition Bureau inquiry, a public retraction of the claims, and a $10 million fine.

The Centre for Environmental Rights (CER) has applied for the suspension of a decision by the Minister of Mineral Resources and Energy to grant extended mining rights to Mineral Sands Resources (Pty) Ltd and Tormin Mineral Sands (Pty) Ltd at the Tormin mine. The CER argues that the expansion occurs within Critical Biodiversity Areas and that the environmental impacts are irreversible and inadequately assessed.