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The Queensland Small Miners Council - NQMA

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The Queensland Small Miners Council - NQMANQMA,THE,the,The,Small,small

The Queensland Small Miners Council 24th August 2010

    PO Box 210

    Quilpie

The Hon. Anna Bligh

    Premier of Queensland

    The Queensland Small Miners Council (QSMC) is an established forum for the States small-scale mining representative groups to cooperate with representation to regulatory authorities on matters that are of a mutual interest to our industries.

    The QSMC consists of the the North Queensland Miners Association (NQMA), the Queensland Opal Miners Association (QOMA), the Queensland Sapphire Association (QSPA) and the Yowah Opal Mining Community Services Association and South Queensland Miners Group, which collectively provide representation for over 850 members.

    The Queensland Small Miners Council (QSMC) request the immediate "attention and intervention" by you in our current plight, and for you to affirm that your Government does not wish to destroy the remnants of a once vibrant Small Scale Mining industry in this State.

    Small Scale miners are the "aussie battlers" that your 'Labor party' is supposed to represent!

The Labor Trade Union movement have even hijacked our emblem,” The Eureka Flag" which symbolises the

    revolt against oppression that has historically been imposed on small miners in regulation and fees, not unlike the one your Government now wrongfully imposes on us in the EP Regulation 2008.

    Small scale operators have been historically and are currently at the forefront of exploration discoveries and should be valued, respected and encouraged by Governments and bureaucrats, as they are by the regional communities where they operate.

    The Small Scale Miners generally ask nothing from Government's in any form of welfare or support. However in this instance we see little opportunity left for us, if these escalating fees are forced upon our struggling industry!

    The QSMC believe that either a deliberate or incompetent act has led to the EPA advertising the Regulatory Impact Statement (RIS) for the EP Regulation 2008, in only 3 of the 9 Mining regions and has excluded the Small Scale Mining Groups from providing representation which has infuriated small miners operating within these excluded areas.

    The researched facts on this matter, which have bought about these impasses, are attached hereto in a "Brief" prepared by the QSMC for your information. Additionally the QSMC have included proposals to resolve these impasses.

    Whilst the Minister for Environment, The Hon. Kate Jones, has made some concessions, they are inadequate to provide the security and stability our Industry requires. Sadly, during her recent absence for maternity leave, little progress was apparent with implementing the undertakings that she had made to us in respect of EA fees for small scale miners.

    These concessions would have provided immediate relief from the new fees scheduled in the EP Regulation 2008, from which RIS in 2008 we had been incredibly excluded.

Amongst these concessions given by the Minister, prior to her leave of absence, was correspondence on ththe16 July. 2009, to Secretary QSMC, which extracts stated the following:-

    Arrangements are being developed to allow the automated issuing of annual return notices to the holders of Level 2 environmental authorities.

    As part of these arrangements, DERM will be conducting information sessions for small miners about the annual return requirements and the ways in which they can apply for the amalgamation of multiple

environmental authorities into a single mining project and thereby reduce their costs.”

    Despite this concession made by the Minister, DERM has begun issuing payment notices to us but has failed to provided any services as promised by the Minister to enable miners to consolidate their EA's into single mining projects so that they need only to pay this annual fee for one "Combined EA Project"

    thAlso at another meeting on the 25 February 2010 with QSMC delegates and the Minister and her advisors

    we have recorded another undertaking by Elisa Nichols of DERM, (one of Ms. Jones’ senior staff) who petulantly remarked “you should be grateful not having to pay fees for 2009”.

    This other concession was not dismissed by the Minister at this meeting, however this concession has not materialised, with many Level 2 EA Holders being hit recently with Tax Invoices retrospectively for the 2008/2009 year.

    Naturally, the QSMC and members question why the department has not responded to the undertakings by the Minister Kate Jones to the QSMC delegation to her Parliamentary office on 25th February 2010 and to correspondence forwarded by her in response to QSMC submissions on this matter.

    We can only either suspect her staff have a blatant disregard for her position because of her relative youth, or, that they are severely incompetent and unable to follow instruction.

    Because of this Ministers department's failure to facilitate her instructions, the majority of Small Scale Operators will now again be penalised financially for these bureaucrats inactions.

    And it is now, and not without reason, that the QSMC has no confidence in the Minister or her department to respectfully resolve these impasses.

    Therefore the QSMC and our members will now accept nothing less than, your personal attention and intervention to help assist resolve with these matters.

    In light of the circumstances explained herein, and as detailed in the "Brief" attached, the QSMC confirms support for all small miners who hold EA's to refuse to pay the current EA annual invoices as a means to express their legitimate grievances.

    This is a temporary protest to draw attention to the issues already raised (and ignored) and is a deserved response given the incompetences of the department.

    The protest is intended to bring about a genuine meaningful meeting of QSMC representatives and DERM decision makers that will result in a fair outcome.

    In the meantime the QSMC formerly request that you instruct your Minister for Environment, not to penalise, fine, or cancel tenements for the actions taken by these protesters, as the QSMC will regard any such negative action as an "Act of War".

    QSMC would like this matter resolved as quickly as possible so the matter does not needlessly escalate, and a delegation from the QSMC member groups is readily available, providing genuine government decision maker's (not enforcement officers) are able, to attend a meeting with the intention to develop a genuine fair and workable outcome.

    Please advise when a meeting can be arranged, the location and the list of genuine government decision makers that will attend.

We trust your supportive and prompt attention to this most urgent matter.

Sincerely

Kevin John Phillips'

    Secretary QSMC

    Queensland Small Mining Council (QSMC)

    Brief for the Premier of Qld

    with relation to the EP Regulation 2008 and the impasses to resolving matters brought about by

    bad governance

Part 1 The EP Regulation- A brief history

    Part 2 The RIS EP Regulation 2008 process or lack thereof Part 3 What should have happened - The States responsibilities Part 4 The QSMC Summary

    Part 5 The QSMC recommendations for better governance Part 6 Proposed resolve by QSMC

     -the States obligation to righting wrong

Part 1 The EP Regulation - A Brief history

Introduction ....... "At the beginning of time"

    The Environmental Protection Act (EP Act1994) sought to achieve its objective by setting out a program for the identification and protection of important elements of the environment (environmental values) and by creating a range of regulatory tools for controlling the activities of individuals or companies. The EP Act established a system of licences and approvals for conducting particular activities. These activities are referred to as "Environmentally Relevant Activities" (ERA's) and are listed in the Environmental Protection Regulation. The purpose of this system is to allow the authorities to set conditions for conducting the activity which should prevent or minimise the risk of harm to the environment. Conducting an Environmentally Relevant Activity without the relevant licence or approval or failing to comply with conditions of your licence or approval are criminal offences.

    However, showing that you were acting in accord with the conditions of your licence or authority is a defence against a charge of causing environmental harm.

    Mining was deemed to be an "ERA" and became an activity originally administered by the then Department of Mines and Energy (1994-2001), a "one stop mining shop" which provided all services including Environmental Service's in Regional areas through-out the State at no charge to miners, given the Rents and Royalties contributed by these Mining Businesses to the States "Consolidated Revenue" which more than offset the associated costs of fulfilling the States Environmental Policy

    The Queensland Small Scale mining Representative Groups were mostly established and played important roles in the the development of Codes of Compliance for the Industry with the EPA, and other State and Federal Agencies over matters that had impact on our industry.

In 1998 a Review of the EP Regulation 1994 was undertaken.

    At this time Small Scale mining representatives delegation met personally with Mr. Beattie, the then Premier of Queensland ( even though there were no cameras present)

    The Hon. Peter Beattie intervened on imposing annual fees on small scale miners as he recognised that Small Scale Miners of Opal, Gold and other precious stones made little impact on the environment.

Although he introduced a levy of $200.00 per Environmental Authority Application Fee, he instructed to :-

    "exclude these small types of mining operations from annual fee's"

    Whilst the vast majority of miners were bewildered at this new environmental application fee cost of $200.00+ Annual CPI, it played little if any deterrent in Small Scale Miners applying for Mining Leases and Exploration Permits, as it was a "one of" fee for that tenement and relatively affordable for these tenement types effected.

    In 1998/1999, the Beattie Labour Govt. established a new department, the "Environmental Protection Agency" (EPA) to administer and regulate a range of Industries under the EP Act 1994, however the EPA did not take over the administration of this the EP Regulation 1998 for mining from DME until 2001.

    (The EPA were created to save the trees .....so they had them all knocked down, recycled into wood chip, reincarnated into ECO documents and filed away in virtual forests called storage cabinets.)

    By 2001, regional areas where small scale mining is conducted, the EPA, which was suppose to service these areas once credibly serviced by the DME Mining Districts,(Mareeba, Georgetown, Quilpie, Winton and Emerald ) now offered at best, bi-annual visits to enforce the new regulation and offered no tangible environmental services once afforded by the DME.

    Interdepartmental wrangling started early in the piece, with DME stating that they would not provide environmental services that it was EPA's job, and then EPA officials stating that money appropriated and earned from DME from Mining/ Environment had not been allocated to EPA from the States "Consolidated revenue" budgets!!

    And then... across the land there were "shit fights", "tantrums" and "hissy fits" resulting in Ministerial's between departments, meetings between Ministers, their respective Director Generals and policy advisors and their relevant shit-kickers, about funding arrangements for the new EPA.

    This fiasco went on for years, finally, in the end, with turnover of staff from both departments as is still experienced today they (Ministers, Dept. D G's and officials) eventually forgot what they were fighting about.

    Finally, under some MOU, the then DME/DMNR, agreed to be the "Eyes and Ears" for EPA and accept applications for environmental authorities on behalf of the EPA, however would not facilitate anything else.

    However, the EPA didn't get any of the funds that were once allocated to DME for facilitating Environmental Services in regional Qld. and they lived with this.

And again peace and certainty once again ruled over the land............until

    Part 2. The RIS EP Regulation 2008 process.......or lack thereof

As required by Law every 10 years, Acts and Regulation are to be reviewed.

    Prior to any regulation being amended, it is the norm that the State produce a "Discussion Paper" for stakeholders to review and submit feedback prior to an RIS.

    The Small Scale Mining Associations were not formally or informally for that matter, advised of any such Discussion Paper.

    Apparently, a "Regulatory Impact Statement"(RIS) was produced by the then EPA with the RIS notification date the 1st of February 2008, and the closing date for submissions was the 28th of March 2008.

This RIS EP Regulation 2008 was a 114 page document and apparently posted on the EPA web site.

    The vast majority of Small Scale Miners are computer illiterate" with many "New Australian's" gracing our beloved ranks and those who are computer literate wouldn't have access to internet.

    Despite the EPA holding the name of every miner who held a current EA, none were contacted in regard to providing comment to the RIS.

    Despite the Small Scale Mining Representative groups having a previously established re-pore with the EPA, assisting with any aspects of previous regulations and the Codes of Environmental Compliance only one of the groups had been contacted by the EPA.......... and only just!

    The contact with the small mining groups by the EPA prior to, during the RIS is as follows:- ? The Queensland Opal Miners Association received correspondence from the then EPA , One

     week before closing of submissions, and were able to submit a very hastily drafted submission on

     time.

     (This was not the quality of submission usually compiled by this organisation for a matter of such dire

     consequence as the recommendations in this RIS EP Regulation Proposal, in the RIS for the Mineral

     Resources Act (MRA's) 2008. the QOMA produced a 64 page submission)

    ? The North Queensland Miners Association were not officially advised or consulted

    ? The Yowah Opal Miners Community Services were not officially advised or consulted

    ? The Queensland Sapphire Producers were advised by email two days before closing and were not

     advised or offered an extension or consulted

    ? The Queensland Boulder Opal Association were alerted by QOMA of the RIS and were

     granted another week to submit their hastily prepared submission. (Copy attached)

     They had not been officially advised or consulted.

    After closing of the RIS Submissions, the EPA EP Regulation Review team, although the RIS EP provided a Consultation Report named the :- "Regulatory Impact Statement and draft Public Benefit Test for the review of the Environmental Protection Regulation 1998."

    This document boasts the EPA's Review Teams achievements yet no communication came about from them with regard to this review and the Submissions they had received from the Small Scale miners.

    The EPA received 111 submissions and the comments have been summarised in this report.

A full list of submitters is provided in this document at Attachment 1.

    The QOMA submission has been acknowledged as received in this attachment, however no mention of the submission from the QBOA lodged by them in this Attachment 1

    For a comprehensive examination of comments, the original submissions can be read on the EPA’s Central Office file, number BNE33592 volume 3.

    The Minister of the EPA at the time of inception of the RIS EP Regulation RIS 2008 was Hon. Mr. Andrew McNamarra.

    However shortly afterwards at the State election in 2009 the then EPA Minister lost his seat, with this portfolio assigned to Kate Jones Member for Ashgrove in yet another newly named environment portfolio "the "Department of Environment and Resource Management".

    This confusing Portfolio is now also split between Minister Stephen Robertson of the Department of Employment and something or another this time!

    This departmental integration of the the then, EPA , and with the new portfolio of " Resources" , an ex section of Department of Natural Resources Management, created confusion not only between the cross over of responsibilities of the administration and Ministers (this confusion still exists today).

    Contact points with Staff that were actually running the RIS from the old EPA, were seconded to DERM and to Mines and Energy, Lands Department, in the new DEEDI.

    By the time he dust had settled the RIS process had well and truly closed and the RIS recommendations, wholus-bolus was drafted into Legislation and put to Parliament, and needless to say, despite attempts by the Small Scale Mining representative groups to request amendments with the State and opposition and Dept. Officials, nothing materialised.

    The Queensland Government amended the Environmental Protection Act 1994 and the Environmental Protection Regulation 2008.

    These changes came into effect on 1 January 2009. The Environmental Protection Regulation 1998 was replaced by the Environmental Protection Regulation 2008 and the Environmental Protection Act 1994 was amended from the 1 January 2009.

    Part 3 What should have happened - The States responsibilities

    These sections of the Statutory Instruments Act (below) describes some of the responsibilities of the State when deciding if an RIS is required and how it should be made available to the "part of the community", being us ....... the Small Scale Miners in Queensland which is approximately 850 individuals, plus their employee's and families:-

Statutory Instruments Act (Extracts)

Part 5

Division 2 Regulatory Impact statements

43 Preparation of regulatory impact statement

     If proposed subordinate legislation is likely to impose appreciable costs on the community or a part

     of the community, then, before the legislation is made, a regulatory impact statement must be

     prepared about the legislation.

45 Notification and making regulatory impact statement available

     (1) Preparation of a regulatory impact statement for proposed subordinate legislation must be

     notified in the gazette and in a newspaper likely to be read by people particularly affected by

     the proposed legislation.

     (2) If the proposed subordinate legislation is likely to have a significant impact on a particular group

     of people, the notice must be published in a way likely to ensure members of the group

     understand the purpose and content of the notice.

    QSMC are aware, after the fact, that an RIS was produced, and that it was advertised, however, the advertising that is claimed to be undertaken as reported in the EPA/DERM final "Consultation Report"

    states that notifications were also placed in the following newspapers or e-mail circulars:

    ;;Brisbane Courier Mail, Bundaberg News Mail, Cairns Post, Gladstone Observer, Gold Coast

     Bulletin, Ipswich Queensland Times, Mackay Daily Mercury, Fraser Coast Chronicle, Mount Isa

     North West Star, Rockhampton Morning Bulletin, Sunshine Coast Daily, Toowoomba Chronicle,

     Townsville Bulletin, Warwick Daily News (4 February 2008)

    ;;Gympie Times (5 February 2008)

    ;;North Queensland Register, Queensland Country Life (7 February 2008)

    ;;Local Government Association of Queensland e-mail circular (8 February 2008) ;;Queensland Government Gazette (8 February 2008)

    ;;Koori Mail (13 February 2008)

    ;;Queensland Farmers Federation Weekly Bulletin (8 and 22 February 2008)

    ;;Queensland Environmental Law Association Newsletter (29 February 2008).

    However, in Regional Queensland where most small-scale miners operate, the Department of Mines and Energy and the EPA/DERM require all mining tenure notices to be advertised in the following

    newspapers which are the main news source in these districts :-

    Mining District Affected Association Members Newspaper/s EP RIS

    Advertised

Quilpie Yowah Opal Miners The Watchman No

     QOMA members The Western Times No.

Winton QBOA members Longreach leader No

Emerald QSPA Central Qld. News No

Mareeba NQMA Tableland Advertiser No

    Georgetown NQMA Tableland Advertiser No

    Charters Towers NQMA Northern Miner No

    The facts are clear, the EPA who allege to administer environmental services to the Mining Industry in Queensland, only advertised the RIS regulation 2008 effectively to three (3) of the nine (9) Mining Districts administered by the State as the six above received no effective advertising. The three Mining Districts that were effectively advertised were Brisbane, Rockhampton, and Mt. Isa Therefore it is rightfully contended by small scale mining groups that, in this instance given the facts in the Table of Advertising scheduled above that the Statutory Instruments Act, Division 2, 45 (1)&(2). have not been adhered to by the EPA when conducting this RIS into the EP Regulation.

Part 4. The QSMC Summary

    At no time were the small Scale miners approached with regard to providing input to a discussion paper pre the RIS for the EP Regulation.

    The then EPA were obliged by law (Statutory Instruments Act 1991), to promote the RIS for the EP Regulation 2008, in all of the Mining Districts administered by this department, given the "adverse impact" contained in this review of the EP Regulation toward the mining sector including the small scale operators.

    The new EA "schedule of fees", in this proposed regulation, were to impose "appreciable costs" on this "part of the community". The RIS should have been promoted in newspapers likely to be read by the Small Scale Miner Representative groups based in the mining regions, and to miners in all mining regions not just

    the 3 of the 9 mining districts where the RIS EP Regulation 2008 was effectively promoted.

    The EPA are aware what newspapers are relevant to the Mining Regions they administer as EPA legislative and regulatory controls require advertising of Environmental notices in these papers.

    The EPA's actions, in undertaking to only advertise the RIS EP Regulation 2008 effectively in three (3) of the nine (9) mining regions administered by the EPA, has excluded and denied the Small Scale Mining Representative Groups and the members they represent, fair and proper opportunity to provide a concise and complete representation into the RIS EP Regulation 2008.

    The Small Scale Mining Sector in Queensland is unanimously aggrieved by this lack of proper consultation by the EPA in this process,in particular given the EPA had engaged, and had a historic repore with, the Small Scale Mining Representative Groups since the EPA's inception for both previous Regulation and the Codes of Compliance for this sector.

    This Small Scale Mining Community believe that a that these actions breach of the rules of "natural justice" in relation to the making of the decision by the EPA Review team of what is now scheduled and entrenched in the EP Regulation 2008, and has bought about the exclusion of the small scale mining representative groups being given a "fair go" in providing submissions to this RIS EP Regulation 2008, to counter the EPA proposal in the RIS.

    The increased fees and conditions in this RIS that now impose appreciable costs to our community, which it will not likely be able bear.

    Legal opinion that the QSMC has sought, regarding the EP Regulation 2008 new Annual Fee's, strongly indicate that, "the EPA's historical services provided, and, future services proposed in regional mining districts by DERM, are at best only token" and therefore, on the evidence at hand, would deem the Annual Fees as levied under the EP Regulation 2008, an "Excise Tax".

    Many of our members and fellow miners are keen to pursue a legal challenge to the validity of not only this new Excise Tax but the RIS EP Regulation 2008 process.

At present the QSMC are reserving this right to allow your government to apply our

    recommendations listed below, which would help avoid such action and return some credibility to your government which has denied the Small Scale Mining Sector the "natural justice' that should have been afforded to the small scale mining sector under the RIS EP Regulation 2008 in accordance with the Statutory Instruments Act in the first place.

    Whilst we respect that the State should get full cost recovery for services provided, we remind your government that these environmental services were once administered by DME in a comprehensively effective "one stop mining shop" which efficiently provided these environmental services by the apportioned amount of "annual rental" and "Royalty" received from these tenements.

    It is well known throughout the Mining Industry that State's interdepartmental wrangling over access to these funds between successive state's "mining and environmental services" has never been resolved, which resulted in the EPA/DERM to find its own funds to administer these service's, which by the way are truly not apparent in regional mining districts!

Part 5 QSMC Recommendations for better Governance

    That all departments that you administer, legally and concisely should follow all laws and processes of future Regulatory Impact Statements and to remind the Ministers of relevant departments of this and that they should be more mindful of applying procedures in line with Government Policy and law.

    We recommend that a Review of the RIS EP Regulation 2008 processes undertaken by the EPA/DERM in designing and creating this EP Regulation is investigated by an independent auditor/ombudsman with a QSMC appointed delegate/s to investigate why and how this embarrassment to your government was brought about.

    The evidence at hand clearly points out there was a total lack of opportunity for complete industry consultation /input prior to introducing this new regulation.

    That the QSMC Representatives meet with you the Premier, or your delegate, to discuss an amicable outcome is reached, that has respect to and achieves all parties aspirations.

Part 6. Proposed resolve by QSMC

     - States obligation to 'righting wrongs'

    It is more than apparent that the EPA denied the Small Scale Mining Representative groups and their members the opportunity to be part of the RIS EP Regulation 2008 process.

    This act by State denied them, not only the opportunity to present and lobby for the resolution that would have been likely achieved which would have avoided this impasses, but has also denied them the "natural justice" that would have evolved in the EPA had properly engaged in performing the RIS in a legitimate credible manner

    The QSMC believe that the following proposals will return validity that at present is not apparent to the legislation and ensure the survival for the small-scale mining sector, whilst providing the governments environmental credential and full cost recovery.

    1. Treasury returning funds to EPA for environmental services raised from rents by DME

     That the State Treasury reallocate funds from DEEDI's earnings from Tenement "Rents and

     Royalties" to the EPA/DERM for the "environmental servicing" portion of its budget that was

     used to perform this environmental service by DME for the small scale mining sector.

     The projected yearly revenue from the new DERM fee regime is approximately $580,000 to be

     raised from Small Scale Miners, and there must be expectation that on implementation, the total

     nett gain after costs, in particular if EA's are consolidated by miners will be far far less.

     Surely this nett gain for the State is not enough to compensate for the destruction of the small scale

     gold and mineral prospectors, who have contributed so much to the knowledge base of our states’

     resources.

2. Application fee for Environmental Authorities (EA/s)

     The application fee for Level 2 Mining EA's be immediately reduced back to the EP Regulation

     1998 ($200.00 +CPI) and not be increased beyond annual CPI increases.

     It is ludicrous to expect the public to believe the cost of processing the EA Application for

     a level 2 Mining tenement by DERM costs so much for a "two page" simplistic form.

     This EP Application fee of $500 + CPI vastly exceeds total cost recovery for DERM.

     Processing time and confirmation to the applicant for this document/s should not exceed 1.2

     hours.

3. Reduced Annual Excise Fee for EA's

    (a) The current Annual Excise Fee as scheduled under the EP Regulation 2008 is to high for Level 2

     Mining EA's and will only serve to reduce the number of mining and exploration applications and

     employment opportunities in Regional Queensland.

     This excessive excise fee will have a negative effect on projected incomes for the EPA if left at this

     level as miners are presently surrendering EA's hand over fist, and may actually promote

     illegal operations.

     It is much cheaper now to operate an illegal mining activity and there is no environmental

     servicing, remember a bird in the hand or one with an (EA) is worth two in the bush.

     Miners like the idea of legitimacy, however, there is plenty of bush out here!

    (b) A smaller annual levy may be acceptable provided this was coupled to genuine Environmental

     Service and this increased service was clearly identified. This would resolve the matter raised

     above that the "fee" legally constitutes an "Excise Tax" as currently the environmental services

     currently received by the small scale mining sector is at best only token and does not legitimise a

     real service.

     This service would have to constitute the following:-

     1. Scheduling of regular regional assistance with documentation processes in the

     regional mining districts and not just the infrequent bastardisation power trips

     2. A simple DERM system where all EA’s held by one entity are amalgamated into one

     EA Project.

     This should be initially provided free as a gesture of goodwill by DERM for imposing the

     EP Regulation 2008 on the Small Mining Sector without legitimate consultation.

     3. That any fee from then on for including or removing an EA to that project be calculated at the

     real cost of implementing this service and not at the extortionate $250.00 cost now

     scheduled

    (c) Any EA Annual Excise Fee in advance on lodgement of an application should not exist.

     The term of any EA Annual Fee should be for the date of grant of the tenement + 3 months

     grace to allow for compiling data to support surrendering or amending that EA to remove that

     tenement.

     This will avoid a tenement having to be taxed whilst it is waiting for grant by the cumbersome

     tenement application of both Federal (Native Title Act) and State processes which may delay a

     tenement being granted, yet the tenement applicant is still paying for annual fee's for their EA's

     during these application processes and surrender processes.

     For the EPA to charge a fee whilst the tenement is in a "suspension" waiting for grant, could be

     deemed an "Excise Tax" as no service is being provided whilst the tenement is in this phase!

    (d) Any annual levy should not apply to any EA issued before the new legislation was introduced.

     Retrospectivity sucks, ask Kevin Rudd about the Resource Super Profits Tax!

     (e) Any annual fee in advance on lodgement of application should not exist and should only be paid

     once the tenement is granted.

    ?

    (f) A simple DERM system where all EA’s held by one entity are amalgamated into one.

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