Hello all
A number of us contributed to the previous CMA review which was eventually shelved when the government decided to broaden the scope. The upshot is we've now been waiting several years for another opportunity to have our say on this vital issue.
This time the discussion document essentially proposes to manage permitting for gold mining (and certain other minerals) in two tiers:
Tier 1 seems to be geared toward large scale operations where known reserves can be quantified with some degree of accuracy and significant royalty payments are made. In this scenario a more complex permitting regime is justified by a higher and more certain rate of return to the governments coffers.
Tier 2 on the other hand would cater for the majority of current mining gold operations where royalties paid don't cover the cost of government administration or aren't required to be paid due to low output.
Thus the basic driver for the changes is the cost of administering the permitting system. As we all know, the present system doesn't differentiate between different scales of mining and therefore someone with a small suction dredge has to pay the same application fees as the likes of Macrae's. This is as costly for the government as it is for us.
While the proposed changes don't go quite as far as we'd like, I do however believe they're an improvement. One of the key points to consider is that the changes would potentially simplify the requirements for obtaining a mining permit (for small scale operations) and hopefully the cost would also reduce in proportion.
We've all bemoaned the present system which has allowed large tracts of land to be effectively locked up in prospecting and exploration permits. Much of the current exploration is geared toward identifying additional hard rock gold deposits in both previously mined and virgin ground. Keep in mind that only relatively small areas will have commercially viable reserves, and in some cases access to that land for mining purposes would never be possible.
In most cases prospecting and exploration permits would probably not be issued for the same area and mineral a second time as the applicant would need to demonstrate that the exercise of the permit would add something to what is already known about mineral reserves. Therefore when current prospecting and exploration permits expire it is likely that there will be a significant amount ground available for mining permits again.
In the meantime the proposed changes would also make it easier to carry out a small scale mining activity in an area within a prospecting or exploration permit (with the consent of the permit holder of course).
All in all this review represents a good opportunity for us to advocate some changes that would be to our benefit, but we have to be realistic in what we're seeking.
To stimulate some discussion:
- Where does metal detecting sit in this review?
- What is the best manner to make our voice heard? (e.g. standard submission format)
- Clarification of costs for Tier 2 permit applications?
With regard to the last point;
the previous minerals programme made provision for designated areas to be set aside for non-exclusive small scale suction dredge mining
"as an income earning recreational activity or as a supplementary income earning activity . . . providing for a low cost mining permit to be granted by a streamlined, comparatively quick process." Unfortunately that provision did not continue in the current minerals programme. Something along those lines broadened to include scope for other equipment such as metal detectors and sluices, highbankers etc. could be a useful bridge between the restrictions of fossicking areas and the expense of full-blown permits.
The previous review attracted a lot of submissions from small scale mining permit holders concerned that the value of their permits would be eroded by the proposed changes. That was a fairly reasonable reaction as a majority of small scale mining permit holders have invested heavily in their permits. They deserve the exclusivity and return on that investment so we need to ensure that any changes we propose wouldn't disadvantage such people.
Regards
KM
Edited by user Saturday, 10 March 2012 9:31:35 AM(UTC)
| Reason: Not specified