MCA Response Mineral Titles Act

Dear Minister Vatskalis,

Re : Comments - Draft Version 2 Mineral Titles Regulations

Thank you for extending the period for comment on Version 2 of the draft Mineral Titles Regulations to 6 May.

Comments provided in this submission should be read in con`|unction with our earlier submission of 15 April 2011 and the accompanying Minerals Council of Australia’s (MCA) Exploration Policy submission to the Australian Government’s Policy Transition Group in November 2010, which outlined that exploration is critical to the growth, vitality and diversity of the Australian minerals industry.

As stated in our submission of 15 April, the industry looks forward to further opportunities to provide detailed input as part of the government’s consultation process.

On behalf of our members I wish to highlight the raise the following comments for your further consideration in relation to amendments to the draft regulations detailed in Version 2.

Consultation Process
The industry is concerned at the limited timeframes associated with public comment through this process. While the MCA recognises and thanks the Minister for the extension of time to comment on this occasion, industry has been left with little opportunity to thoroughly review and comment in detail on the proposed changes, especially with the release of partially completed draft documents in close succession.

Further, given Version 2 ofthe draft Regulations were released for comment the next business day after our comments were submitted on 15 April, it is clear that Version 2 has not incorporated assessment of our comments. We therefore draw your attention to our submission of 15 April and ask that our comments be considered in addition these comments.

Once in place, poorly designed legislation is difficult to repeal and amend and a collaborative effort involving all stakeholders to develop robust legislation is paramount to retain the confidence of industry in the process. The issues being considered in this process are significant in terms of ongoing exploration activity and ultimate success, which would translate into direct and indirect economic and social benefits for the Northern Territory.

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