❓ A WA parliamentary question on notice regarding KCGM's environmental license and management of cyanide, saline, and alkaline constituents, focusing on compliance with the Environmental Protection Act 1986 and public consultation.
AnsweredQoN 2884Legislative Council
QuestionView source ↗
I refer to a letter dated October 10 2005, signed by D Carew Hopkins, Acting Director General, Department of Environment (DoE) reference ceo1162/05 addressed to Mr L Mills -
(1) Can the Minister explain why the DoE imposed condition W2 on the licence issued to KCGM given that under the
Environmental Protection Act 1986
the licensee has an obligation not to cause pollution?
(2) If no to (1), why not?
(3) Can the Minister explain how the licensee manages the storage of all matter containing cyanide, saline or alkaline constituents within holding facilities, in a manner which prevents pollution?
(4) If no to (3), why not?
(5) Can the Minister explain and define what are holding facilities under condition W2?
(6) If no to (5), why not?
(7) Is Prospecting Licence 26/3126 not owned or occupied by KCGM considered under the licence by the DoE to be a holding facility to contain cyanide, saline or alkaline constituents along with heavy metals and other toxic chemicals?
(8) If yes to (7), why?
(9) If no (7), why not?
(10) Can the Minister define and explain what non- trivial degradation means, which was stated in the letter dated October 10 2005?
(11) If no to (10), why not?
(12) Can the Minister define and explain what potential degradation means which was stated in the letter dated October 10 2005 above?
(13) Can the Minister specifically state what all the comments made by the DoE back to KCGM concerning the KCGM seepage and groundwater management plan were?
(14) If no to (13), why not?
(15) Can the Minister specifically state and identify all of the comments verbal and written that were raised by concerned parties with the DoE, but were not raised and addressed with KCGM?
(16) If no to (15), why not?
(1) Can the Minister explain why the DoE imposed condition W2 on the licence issued to KCGM given that under the
Environmental Protection Act 1986
the licensee has an obligation not to cause pollution?
(2) If no to (1), why not?
(3) Can the Minister explain how the licensee manages the storage of all matter containing cyanide, saline or alkaline constituents within holding facilities, in a manner which prevents pollution?
(4) If no to (3), why not?
(5) Can the Minister explain and define what are holding facilities under condition W2?
(6) If no to (5), why not?
(7) Is Prospecting Licence 26/3126 not owned or occupied by KCGM considered under the licence by the DoE to be a holding facility to contain cyanide, saline or alkaline constituents along with heavy metals and other toxic chemicals?
(8) If yes to (7), why?
(9) If no (7), why not?
(10) Can the Minister define and explain what non- trivial degradation means, which was stated in the letter dated October 10 2005?
(11) If no to (10), why not?
(12) Can the Minister define and explain what potential degradation means which was stated in the letter dated October 10 2005 above?
(13) Can the Minister specifically state what all the comments made by the DoE back to KCGM concerning the KCGM seepage and groundwater management plan were?
(14) If no to (13), why not?
(15) Can the Minister specifically state and identify all of the comments verbal and written that were raised by concerned parties with the DoE, but were not raised and addressed with KCGM?
(16) If no to (15), why not?
AnswerView source ↗
Answered
14 March 2006
Responded by
Minister for Education and Training representing the Minister for the Environment
Response time
124 days
The Minister for the Environment; Science has provided the following response: The following information is correct as at 13 December 2005. (1) Yes. Condition W2 States that, " The licensee shall manage the storage of all matter containing cyanide, saline or alkaline constituents in a manner, which prevents pollution ". The licence contains conditions, including W2, that are aimed at minimising the likelihood of pollution occurring. Not applicable. (2) KCGM's Tailings Storage Facilities are managed so that seepage is kept far enough below the ground surface so as to have no impact on vegetation. (3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
The following information is correct as at 13 December 2005. (1) Yes. Condition W2 States that, " The licensee shall manage the storage of all matter containing cyanide, saline or alkaline constituents in a manner, which prevents pollution ". The licence contains conditions, including W2, that are aimed at minimising the likelihood of pollution occurring. Not applicable. (2) KCGM's Tailings Storage Facilities are managed so that seepage is kept far enough below the ground surface so as to have no impact on vegetation. (3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(1) Yes. Condition W2 States that, " The licensee shall manage the storage of all matter containing cyanide, saline or alkaline constituents in a manner, which prevents pollution ". The licence contains conditions, including W2, that are aimed at minimising the likelihood of pollution occurring. Not applicable. (2) KCGM's Tailings Storage Facilities are managed so that seepage is kept far enough below the ground surface so as to have no impact on vegetation. (3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(2) KCGM's Tailings Storage Facilities are managed so that seepage is kept far enough below the ground surface so as to have no impact on vegetation. (3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
"material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
"threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
The following information is correct as at 13 December 2005. (1) Yes. Condition W2 States that, " The licensee shall manage the storage of all matter containing cyanide, saline or alkaline constituents in a manner, which prevents pollution ". The licence contains conditions, including W2, that are aimed at minimising the likelihood of pollution occurring. Not applicable. (2) KCGM's Tailings Storage Facilities are managed so that seepage is kept far enough below the ground surface so as to have no impact on vegetation. (3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(1) Yes. Condition W2 States that, " The licensee shall manage the storage of all matter containing cyanide, saline or alkaline constituents in a manner, which prevents pollution ". The licence contains conditions, including W2, that are aimed at minimising the likelihood of pollution occurring. Not applicable. (2) KCGM's Tailings Storage Facilities are managed so that seepage is kept far enough below the ground surface so as to have no impact on vegetation. (3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(2) KCGM's Tailings Storage Facilities are managed so that seepage is kept far enough below the ground surface so as to have no impact on vegetation. (3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(3) Not applicable. (4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(4) Holding facilities refers to facilities such as tailings storage facility's, return water ponds, decant ponds, and evaporation ponds. (5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(5) Not applicable. (6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(6) No. (7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(7) Not applicable. (8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(8) Prospecting License 26/3126 is not included in the premise description for Licence 6420/10 issued to KCGM. (9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(9) Yes. The letter quoted states that, "Material Environmental Harm or pollution occurs where there is some non-trivial degradation or potential degradation of the environment". Section 3A of the Environmental Protection Act 1986 states: "material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
"material environmental harm" means environmental harm that - a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
a) is neither trivial nor negligible; or b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
b) results in actual or potential loss, property damage or damage costs of an amount, or amounts in aggregate, exceeding the threshold amount "threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
"threshold amount" means $20,000, or if a greater amount is prescribed by regulation, that amount. (10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(10) Not applicable. (11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(11) See answer to question 10. (12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(12) Yes. (See tabled papers no and no ). (13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(13) Not applicable. (14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(14) No. (15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
(15) No written comments were provided to the DoE by concerned parties on KCGM's draft Seepage and Groundwater Management Plan. This was despite repeated requests to parties who did verbally contact the DoE about this matter. DoE held numerous meetings and phone conversations with interested parties in an attempt to make sure that concerns were understood and addressed. DoE also organised for KCGM to extend the comment period on the document by over a week at the request of concerned parties. The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
The DoE on numerous occasions requested concerned parties to raise concerns in writing. Given that no formal, ie written, comments were received during the comment period the DoE considered as far as practicable the verbal comments received and provided those to KCGM in the correspondence attached as part of answer to (13).
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