Sub 8

David Woodiwiss - Submission Number 1

DAVID WOODIWISS PO BOX 2032, BOULDER, WESTERN AUSTRALIA, 6432 PH: 0408 909 333 FAX: 08 9093 3355 Email: [email protected]

To:- The Standing Committee on Legislation:-

Inquiry into the Legislation Amendment Bill 2015

Postal Address:- Mr David Driscoll Parliamentary Officer (Committees) Standing Committee on Legislation GPO: Box A11 Perth WA 6837

Phone Number: 08 9222 7404 Fax Number: 08 9222 7805 Email Address: [email protected]

PROSPECTING and SMALL MINING ACTIVITIES

MINE SHAFTS, SMALL OPEN PITS, PROCESSING PLANT AND ASSOCATED INFRASTRUCTURE

Introduction and small mining operations by way of shafts and small open pits is the long established method of operating by prospectors and small miners. This is common to all goldfields and in particular to Western Australian Goldfields since mining began here over 120 years ago in 1885

Mining Amendments Act 2015 These proposed Amendments are for the benefit of the large corporate miners. The Amendments ignore the needs of the small miner.

The following gives some background detail to the operations of the small miner

Prospecting and Exploration Prospecting for takes place in many ways. Examples of these are the sampling of rock chips and soils, loaming, augering, pitting, costeaning, drilling, dishing, dry blowing, detecting and assaying of samples and rocks in the quest for a source of payable quantities of . When there are good indications that gold, or other mineralisation, has been discovered, the small miner will sink a shaft or excavate a small open pit in his quest to find an orebody. These shafts and open pits will typically be along strike of the possible structure/shear zone. The spacing of these workings maybe quite close together or dispersed along strike. This spacing depends on the findings and the course of discovery.

Typically workings can be spaced at anything from about 10 metres apart and upwards. However the total area actually disturbed by the sum of these workings will be small. There is also a safety aspect to this in that two shafts situated relatively close together are required in order to provide sufficient ventilation underground. There is also the good safety practice of having a second means of egress from the main underground shaft and underground workings. In most cases an appropriately located second shaft is utilised for this.

The aim of the prospector and small miner is to find a potentially economic orebody. After identifying one the prospector needs to ascertain if this orebody can be a payable proposition. They can do this either by drilling or by mining. Whether to do this by drilling or by test mining depends on the circumstances. Often drilling is too expensive a proposition for the prospector. Evaluation by actual mining can be more attractive because the mined ore can be processed alongside the mining evaluation and this helps significantly with the cashflow requirements because the recovered gold can be sold in a timely manner as prospecting proceeds. If by mining then operations involve removing both ore and waste, as required, until such time as enough ore has been stockpiled to process this test parcel of ore. This is referred to as bulk sampling and is a very important part of the process in determining whether an orebody is payable or not. After a period of time the overall economics can be determined.

To accomplish these ends the prospector and small miner therefore needs to be able to operate within a simple and non-complicated legal framework, that is designed to facilitate this. There are three main types of mining tenements that are used. These are exploration licences, prospecting licences or mining leases. The legal framework needs to support and encourage the prospector and small miner’s operations on all of these types of mining tenement.

The total required disturbed area for these small mining purposes would typically be no more than 25 hectares. This size of activity is very different from the corporate miner whose activities would typically cover 100’s or 1000’s of hectares.

Control by Area not Tonnage The tonnages that the prospector will be able to mine and process are determined by the total area of disturbance being no more than 25 hectares. Therefore the extent and quantum of the prospecting and small mining activities are automatically self-regulating by being within the 25 hectares of disturbance area. The area disturbed is a much more practical way of regulating prospecting operations than by tonnage limits. It is also much easier to convey the principle of an area of disturbance limit to other interested parties. An area of disturbance is a much easier concept to grasp by those administering the environment.

Processing After sinking a shaft or small open pit the prospector and small miner needs to be able to process the ore to extract the gold. There are several ways to do this: -

Set up a processing plant on site. This is often the best way forward for a prospector because of the secure knowledge that he is in full control. By this way he knows he will get best value from his efforts.

State Batteries. Traditionally prospectors who did not process their ore on site would take their ore to the nearest state battery. Since the State Government closed down all batteries in the early 1990’s this option is no longer available to prospectors.

Take the ore to a offering custom milling services. This is the remaining option. However it is only available to those prospectors who can accumulate 10,000 or more tonnes of ore. Custom mills regard this as the minimum amount that they can economically accept. This presents prospectors with significant cash flow difficulties because of the time required to accumulate this quantity of ore. In addition to this many custom mills are often booked up for a year in advance. Despite this if a prospector tries to book in a parcel of ore for a time slot 12 months away the custom mill will often not entertain him. This is because they have their big corporate clients that they look after first. They are not really interested in the prospector’s 10,000 tonnes of ore. It is too small an amount. It is simply an inconvenience for them when they are typically processing 500,000 or more tonnes per annum. It is not uncommon for prospectors to have so small a parcel of ore that it becomes regarded a nuisance factor to a third party custom mill.

Therefore it is always the prospectors preferred option, or as a necessity, to process their ore on site. Furthermore compared to the many limitations and difficulties involved with custom milling, the processing of the ore on site is often the only available option the prospector has.

On Site Processing Plant and Associated Infrastructure: -

Ore storage Area An area is required to stockpile the ore prior to processing.

Water Supply and Water Storage Dam Whatever method of processing the ore is used a water supply is essential. Even if a dry blower is used processing water will still be required for dust control and concentrate processing.

Water supply can be by many means such as from of a water bore or from an old mine shaft. Associated with this will be a water dam in order to accumulate and store the water ready use.

Crushing Plant The ore needs to be crushed to release the gold. There are many types of equipment available that can do this. The typical types of equipment used by prospectors and small miners are jaw , cone crushers and impact crushers

Grinding Plant The crushing plant typically reduces the size of the ore down to minus 12mm. In the majority of cases this is not small enough to release the gold. Therefore the crushed ore needs to be reduced down to a smaller size in order to liberate the gold.

To do this there are various options available such as a or a stamp battery.

Gold Recovery Once the ore has been reduced to a fine enough size to liberate the gold it has to be processed in some way to recover the gold.

The typical ways that prospectors do this is by such means as gravity methods, dry blowing, tabling, vat , or a carbon in leach plant.

Tailings Dam A dam is required to store and settle the tailings which result from the processing of the ore

Waste Rock Associated with the mining of the ore there is always waste rock that has little or no gold content and this needs to be stockpiled

Workshop and Maintenance Shed A shed is required in which to undertake maintenance and to store spare parts.

Explosives magazine. Explosives may be required in hard rock conditions.

Office An office is required to store DMP statutory records such as the electrical logbook, mine logbook, maintenance records, Mining Act, Mining Regulations and to undertake daily office duties.

Camp An accommodation area is required for personnel.

Other Laydown area, topsoil stockpile, etc

Summary It can therefore be seen that the prospector and small miner needs many things in order to be able to operate professionally, practically and successfully.

Firstly prospectors and small miners need mine shafts, and/or small open pits to find and extract the ore. Then they often need an on-site processing plant and the associated infrastructure to enable the processing of the ore to extract the gold.

Onsite ore processing is usually the optimum option for the prospector for both practical and financial reasons.

The total area required to accomplish all of these activities can usually be accommodated within a total disturbance area of no more than 25 hectares. This size of activity is very different from the corporate miner whose activities would typically cover 100’s or 1000’s of hectares. Therefore the distinction between the two is very clear.

Conclusions Ever since mining began in Western Australia, and the implementation of the 1904 Mining Act, the standard mining tenement issue for prospectors has been the Gold Mining Lease (GML) and, latterly, since the introduction of the 1978 Mining Act, the Prospecting Licence (PL) and the Mining Lease (ML). It is usual for prospectors to have their workings along strike of the mineralisation. Together with these workings there are usually camp facilities and various items of processing plant, equipment and associated facilities. The prospector and small miner has typically organised his prospecting and mining leases by having a mining tenement or tenements that cover the likely localised extent of the mineralisation. If you did a survey of all of these activities by prospectors and small miners you would see that they would all be within the category of being less than 25 hectares disturbed area. This has been the norm since 1904 and so we have 120 years of history to back up prospectors claims that up to 25 hectares of disturbance is fair and reasonable.

This past practice by prospectors has resulted in little or no environmental impact in over 120 years. It is also important to note that these areas of work are in the accepted mining areas of the Goldfields that have been used for this purpose during all of this time.

Therefore the best way to encourage ongoing prospecting and small mining is to have an allocation for prospecting and small mining operations with no more than 25 hectares of disturbance open at any one time. This should be covered by a specific category within the Mining Act and Mining Regulations.

Prospectors and small miners do not need and cannot afford unnecessarily onerous controls from the Mining Act and Regulations. Their activities should be encouraged and not burdened with too much regulation. They have proved over the last 120 years that they have a great track record of controlling their own activities in a very responsible way.

The total required disturbed area that is needed for these prospecting and small mining activities is no more than 25 hectares. This size of activity is very different from the corporate miner where their activities would typically cover 100’s or 1000’s of hectares. Therefore the distinction is very clear.

The ongoing benefits from the endeavours of prospectors to the community and to the State of Western Australia and regional economies have been well proven over the last century or more. It is to the credit of prospectors and small miners that this has been accomplished in the most environmentally responsible way. They have a very good track record.

Therefore the activities of prospectors and small miners should be actively encouraged to continue. This is for the benefit of Western Australia and the economy all of the local communities.

The changes proposed within Mining Amendments Act 2015 are for the benefit of the large corporate miners. The Amendments ignore the needs of and are detrimental to prospectors and small miners. I suggest that there should be put in place a process whereby the DMP, the Minister, prospectors and small miners can convene to arrive at a mutually agreeable way forward. This way forward should incorporate a 25 hectare differential in the legislative conditions between prospectors / small miners and the large corporates.

Discussion

I would be happy to discuss this submission with the Legislative Council’s Committee when it meets in Kalgoorlie or at any other time.

Yours Sincerely

______David Woodiwiss Ph: 0408 909 333 [email protected] PO Box 2032, Boulder, WA 6432. 21st March 2016