CRC/C/97/D/172/2022 companies interested in exploiting mineral resources. The Geological Survey of Finland indicated in its permit application that it was looking for copper, iron and gold, and the permit was granted for the purpose of exploring for deposits of these metals and not in pursuit of some scientific mission. To illustrate the fact that the Geological Survey of Finland paves the way for private companies, the authors note that, on 20 April 2022, the Safety and Chemicals Agency granted a new reservation in respect of an area in Kova-Labba siida, called “Ruossakero”, to a company that had stated its intention to survey the area for nickel, copper and cobalt. While the authors are not seeking to include a claim based on this new fact in the communication, they bring it to the attention of the Committee to show that the State party conducts preliminary surveying before projects are taken further by private companies. 5.4 The State party’s submission is also misleading insofar as it invokes the memorandum prepared by the Ministry of Justice in November 2017, according to which consensus must be sought in all negotiations between the public authorities and the Sami Parliament (see para. 4.2 above). Not only does the memorandum have no force of law, but it also postdates the consideration of the exploration permit dealt with in the present communication and was not subsequently applied by the Administrative Court of Northern Finland or the Supreme Administrative Court, which satisfied themselves with a merely formal consultation of the Sami. 5.5 As for the State party’s argument that they lack victim status, the authors submit that the violations have already occurred, as the international standard of free, prior and informed consent was not complied with when the Safety and Chemicals Agency granted the permit and when the Supreme Administrative Court upheld that decision. In its Views in Billy et al. v. Australia, the Human Rights Committee considered that the risk of impairment of the authors’ rights was more than a theoretical possibility because their lives were highly dependent on the availability of the limited natural resources to which they had access. 13 In the present communication, taking into account the intergenerational nature of Indigenous Peoples’ right to transmit their culture to new generations, it is precisely because a chain of cultural transmission is interfered with much earlier than an Indigenous culture is destroyed (through action or inaction) that the admissibility conditions of victimhood and substantiation are already met when such interference with cultural transmission occurs. 5.6 As for the State party’s argument that the authors have not exhausted domestic remedies, the authors claim that they did raise climate change arguments in the domestic proceedings but that they have raised the issue of climate change before the Committee on the Rights of the Child not to include a claim that climate change as such would constitute a violation of the Convention but only to substantiate their claims under articles 8, 27 and 30. 5.7 As for the State party’s argument that the communication is manifestly ill-founded and that the authors are seeking to have the Committee act as a fourth instance, the authors submit that the State party is mistaken in its opinion that the domestic courts properly considered their rights, as the Supreme Administrative Court was both formalistic and wrong in stating that the international standard of free, prior and informed consent had been met merely by giving the Sami an opportunity to be heard. State party’s observations on admissibility and the merits 6.1 On 18 July 2022, the State party reiterated its observations on admissibility. 6.2 On the merits, the State party first indicates that a working group has prepared a bill to amend the Act on the Sami Parliament, proposing that the current obligation to negotiate be strengthened in order to implement the international standard of free, prior and informed consent. 6.3 The State party further submits that the mineral exploration will be temporary, that research carried out at individual sites does not cause significant disturbance to areas outside those sites, that research activities must not have far-reaching effects and that one-off surveys do not have long-lasting effects. The State party claims that, in its exploration permit decision, the Safety and Chemicals Agency complied with the Mining Act by setting several conditions 13 8 CCPR/C/135/D/3624/2019, paras. 7.10 and 8.14.