2.2.2. Justification for Proposed Amendment 2
Pipe Corridor
The justification for this proposed amendment to update Table A1 of the EA with recent and relevant
information pertaining to the Pipe Corridor mine feature alignment. The Pipe Corridor is already an
approved feature in the EA, there are no impacts on any environmental values and this proposed
amendment does not significantly increase the level of environmental harm caused by the relevant
activity.
Surface Exploration
The removal of the exploration mine domain from Table A1 of the EA is justified on the grounds that
progressive certification of point feature, that occupy a much larger mine domain polygon, is
counterintuitive. Critically, previous drill locations that comprised the surface exploration domain are in
fact point features that occur within much larger mine domains. The Mount Morgan Mine site is unique
in that exploration has historically been undertaken within the boundaries of mine domains, which is not
the case for brownfield site whereby exploration is typically conducted outside of established mine
domain boundaries.
The requirement to obtain progressive certification for boreholes that are located within larger domains
raises concerns around practicality and duplication of the certification process. The definition of mine
domain differs across jurisdictions however the precedence set in Queensland under the Progressive
Rehabilitation and Closure Plan (PRCP) framework is that rehabilitation areas/improvement areas
(which are typically identified through transitioning mine domains/mine features) have a clear boundary
demarcating the spatial extent of a polygon or polyline. In the case of the surface exploration mine
features, which are point features located within a much larger mine domain, progressively certifying
the rehabilitation of each point feature would also apply to the polygon underneath. This is considered
a perverse outcome as the progressive certification can not apply to two separate domains that occupy
the same physical area.
The progressive certification process articulated in the Progressive Certification for Resource Activities
Guideline (ESR/2022/5900 Version 1.02) states that the content of a progressive certification report
must, amongst other things, include GPS Coordinates of the corners of the certification area or metes
and bounds of the perimeter of the certification area. As the size of the boreholes are estimated to be
between 50-200mm in diameter, it is not considered practical to obtain GPS coordinates of the corners
of the disturbance.
Removal of the exploration mine domain does not prevent the EA holder from undertaking any future
exploration works at the mine features listed in Table A1 as condition A14 of the EA states the following:
“ A14 All exploration activities carried out at the licensed place must comply with each of the Standard
Environmental Conditions contained in the most recent version of the Eligibility criteria and standard
conditions for exploration and mineral development projects -ESR/2016/1985 ”.
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Wulguru Technical Services Pty Ltd – Supporting Information Report
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