Raymond Ashwin and Others on behalf of the Wutha People v Allanson Engineering Pty Ltd & Another

[2014] NNTTA 48

NATIONAL NATIVE TITLE TRIBUNAL

Raymond Ashwin and Others on behalf of the Wutha People v Allanson Engineering Pty Ltd & Another [2014] NNTTA 48 (14 May 2014)

Application No:                WO2013/1269

IN THE MATTER of the Native Title Act1993 (Cth)

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IN THE MATTER of an inquiry into an expedited procedure objection application

Raymond William Ashwin, June Rose Ashwin, Geoffrey Alfred Ashwin and Ralph Edward Ashwin on behalf of the Wutha People (WC1999/010) (native title party)

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The State of Western Australia (Government party)           

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Allanson Engineering Pty Ltd (grantee party)

DETERMINATION THAT THE ACT IS AN ACT ATTRACTING THE EXPEDITED PROCEDURE

Tribunal:  Helen Shurven, Member
Place:  Perth
Date:  14 May 2014

Catchwords:   Native title – future act – proposed grant of exploration licence – expedited procedure objection application – whether act likely to interfere directly with the carrying on of community or social activities – whether act likely to interfere with sites of particular significance – whether act likely to involve major disturbance to land or waters - expedited procedure attracted

Legislation:Native Title Act 1993 (Cth), ss 29, 30, 31, 32, 146, 151(2), 237

Mining Act 1978 (WA)

Aboriginal Heritage Act 1972 (WA)

Acts Interpretation Act1901 (Cth), s 36(2)

Cases:Ashwin and Others on behalf of the Wutha People v Peter Romeo Gianni and Another [2014] NNTTA 23 (‘Ashwin v Gianni 2’)

Ashwin and Others on behalf of the Wutha People v Regis Resources Ltd [2014] NNTTA 39 (‘Ashwin v Regis Resources’)

Les Tullock and Others on behalf of the Tarlpa Native Title Claimants/Western Australia/Bushwin Pty Ltd [2011] NNTTA 22 (‘Tullock v Bushwin’)

Little v Oriole Resources Pty Ltd (2005) 146 FLR 576 (‘Little v Oriole Resources’)

Raymond William Ashwin and Ors on behalf of the Wutha People/Western Australia/Cliffs Asia Pacific Iron Ore Pty Ltd [2013] NNTTA 122 (‘Ashwin v Cliffs Asia Pacific’)

Raymond William Ashwin and Ors on behalf of the Wutha People/Western Australia/Doray Minerals Limited [2013] NNTTA 68 (‘Ashwin v Doray Minerals Limited’)

Raymond William Ashwin and Ors on behalf of the Wutha People/Western Australia/Peter Romeo Gianni [2013] NNTTA 88 (‘Ashwin v Gianni 1’)

Smith v Western Australia (2001) 108 FCR 442 (‘Smith v Western Australia’)

Yindjibarndi Aboriginal Corporation RNTBC v FMG Pilbara Pty Ltd & Anor [2014] NNTTA 8 (‘Yindjibarndi Aboriginal Corporation v FMG Pilbara’)

Representative of the     

native title party:             Mr Paul Tolcon, Mony De Kerloy Barristers & Solicitors

Representatives of the     Mr Jeff O’Halloran, State Solicitor’s Office
Government party:          Ms Bethany Conway, Department of Mines and Petroleum

Representatives of the    
grantee party:                  Mr Mark Clatworthy, Allanson Engineering Pty Ltd

REASONS FOR DETERMINATION

1. On 14 August 2013, the Government party gave notice under s 29 of the Native Title Act 1993 (Cth) (‘the Act’) of its intention to grant exploration licence E29/884-I (‘the proposed licence’) to Allanson Engineering Pty Ltd (‘the grantee party’). The notice includes a statement that the Government party considers the grant attracts the expedited procedure (that is, that the proposed licence is an act that can be done without the normal negotiations required by s 31 of the Act).

2. The s 29 notice describes the proposed licence as comprising 27 graticular blocks (approximately 80.7 square kilometres) with a centroid of 29^o 10’ S, 119^o 39’ E,  located 135 kilometres south of Sandstone, in the Shires of both Menzies and Sandstone.

3. An objection to the inclusion of the expedited procedure statement may be made to the National Native Title Tribunal (‘the Tribunal’) by any person who, four months after the notification day, is a registered native title claimant in respect of the relevant land or waters (see s 29(2)(b)(i), s 32(3) and s 30(1) of the Act). (If there is no registered native title claimant when the s 29 notice is given, the application containing the native title claim must be filed sometime before the end of three months after the notification day included in the s 29 notice (see s 30(1)(a)(i)). The notification date for this matter was 14 August 2013. The three month period for filing a native title claim was 14 November 2013. The four month period for lodgement of objections was 14 December 2013, and by the operation of s 36(2) of the Acts Interpretation Act1901 (Cth), the closing date for lodgement became 16 December 2013, the next working day.

4. The proposed licence is 85.74 per cent overlapped by the Wutha people’s native title claim (WC1999/010 – registered from 15 June 1999).  On 5 December 2013, the Wutha people (‘native title party’) made an expedited procedure objection application to the Tribunal in relation to the proposed licence. No other native title claim was filed, or objection lodged, in respect of this proposed licence. 

5. I was appointed to be the Member for the purposes of determining this inquiry on 24 October 2013.

Background

1. On 14 January 2014, a preliminary conference was held at which the grantee party requested that the Tribunal make a determination, and on the same day I set directions for an inquiry.

2. In compliance with the directions, parties provided the following submissions and evidence: the Government party’s initial evidence on 28 January 2014 through the Department of Mines and Petroleum (‘DMP’); the native title party contentions on 21 February 2014; the grantee party’s contentions on 10 March 2014; and the Government party’s contentions on 21 March 2014.

3. On 10 April 2014, the Tribunal emailed all parties:

   The matter is scheduled for a listing hearing on Thursday 17 April 2014...  If all parties agree to the following points, this listing hearing can be vacated and the Tribunal will be in contact with you again once a determination is made:

   a)   you agree that the matter may proceed to inquiry before the Member on the papers (no further hearing will be scheduled) and

   b)   you do not intend to make any further submissions.

   If any party has further requests or submissions to make the listing hearing may proceed.

1. By 11 April 2014, each of the parties had confirmed via email that they agreed the matter could proceed to be heard on the papers.  Specifically, the native title party’s legal representative advised 'The Native Title Party agrees the matter should proceed on the papers and does not intend to make any further submissions at this time'.

Conduct of the inquiry

1. The native title party’s contentions expressed its intention to call witnesses to give oral evidence, and outlined the evidence to be given, if the matter were to be decided otherwise than ‘on the papers’ pursuant to s 151(2) of the Act. Specifically, the native title party stated (at (11)) that it intended to call Ms June Ashwin and Mr Geoff Ashwin, to give certain evidence.

2. The native title party’s contentions do not state the qualifications of the proposed witnesses, though I do note that Ms Ashwin and Mr Ashwin are registered claimants as they are two of the four named persons who comprise the Applicant for the native title party’s native title determination application.

3. The native title party’s statement of contentions appears to be based on a pro forma document submitted in previous expedited procedure matters involving the Wutha People, with the only noticeable differences being the tenement details. The circumstances of this matter, in terms of the native title party not providing evidence to support its contentions, are also very similar to a number of previous expedited procedure determinations involving the Wutha People made by the Tribunal. It appears that the native title party has developed a standard practice of stating in their contentions that they will provide oral evidence, but no such evidence is provided (see Ashwin v Regis Resources; Ashwin v Gianni 1; Ashwin v Gianni 2; Ashwin v Doray Minerals Limited; Ashwin v Cliffs Asia Pacific).

4. The Government party has included in its submissions (at 33) that in its view, the issues for determination in these proceedings can be adequately determined in the absence of the parties and do not require an oral hearing.  Taking into account the principles outlined at [11]-[13] by Member O’Dea in the Ashwin vDoray Minerals Limited decision, and that all parties confirmed agreement that the matter could be heard on the papers, I will proceed with this matter on the papers. There was no support from the native title party that the issues cannot be adequately determined in the absence of the parties (as per s 151 of the Act).

Legal principles

1. Section 237 of the Act provides:

   A future act is an act attracting the expedited procedure if:

   (a) the act is not likely to interfere directly with the carrying on of the community or social activities of the persons who are the holders (disregarding any trust created under Division 6 of Part 2) of native title in relation to the land or waters concerned; and

   (b)       the act is not likely to interfere with areas or sites of particular significance, in accordance with their traditions, to the persons who are the holders (disregarding any trust created under Division 6 of Part 2) of the native title in relation to the land or waters concerned; and

   (c)        the act is not likely to involve major disturbance to any land or waters concerned or create rights whose exercise is likely to involve major disturbance to any land or waters concerned.

2. In relation to the legal principles to be applied in this matter, I adopt those outlined by President Webb in Yindjibarndi Aboriginal Corporation v FMG Pilbara at [15]-[21].

Evidence in relation to the proposed act

1. The Government party provided the following documents in relation to the proposed licence:

   ·A Tengraph plan with topographical detail, tenement boundaries, historical land tenure and Aboriginal communities within and in the vicinity of the proposed licence;

   ·Reports and plans from the Aboriginal Sites Database maintained by the Department of Aboriginal Affairs (‘DAA Database’);

   ·A copy of the proposed licence application;

   ·A Draft Tenement Endorsements and Conditions Extract; and

   ·A Tengraph quick appraisal detailing the land tenure, current and historical mining tenements, native title areas, and relevant services and other features within the proposed licence.

2. The Tengraph quick appraisal establishes the underlying land tenure within the proposed licence to be as follows:

   ·Vacant crown land, overlapping the proposed licence at 99.5 per cent;

   ·Pastoral lease H91304 (Perrinvale), overlapping the proposed licence at 0.2 per cent;

   ·Pastoral lease 3114/939 (Bulga Downs), overlapping the proposed licence at 0.3 per cent; and

   ·Historical lease 395/418, overlapping the proposed licence at 7.7 per cent.

3. There are also two proposed conservation reserves that overlap the proposed licence:

   ·PCP/196 Proposed Conservation Park, to be managed by the Department of Parks and Wildlife, overlapping the proposed licence by 2.6 per cent; and

   ·P5H/33 Proposed reserve under s 5(1)(h) of the Conservation and Land Management Act 1984 (WA) to be managed by the Department of Parks and Wildlife, overlapping the proposed licence by 5 per cent.

4. The quick appraisal shows that the proposed licence has previously been subject to the following mineral tenure:

   ·10 expired, surrendered or forfeited exploration licences active between 1991 and 2013, overlapping the proposed licence between less than 0.1 per cent and 92.6 per cent; and

   ·52 surrendered or cancelled mineral claims active between 1969 and 1982, overlapping the proposed licence between less than 0.1 per cent and 1.5 per cent.

5. The quick appraisal outlines the following services located on the proposed licence:

   ·    one fence line;

   ·    30 non-permanent named lakes (including Lake Barlee and Auriferous Island);

   ·    21 non-permanent lakes; and

   ·    six non-permanent minor watercourses.

6. The report from the DAA Database shows there are no Aboriginal sites or other heritage places located on the proposed licence.

7. There do not appear to be any Aboriginal communities within the proposed licence or the surrounding areas.

8. The Draft Tenement Endorsement and Conditions Extract indicates the proposed licence will be subject to the standard four conditions imposed on the grant of all exploration and prospecting licences in Western Australia (see Tullock v Bushwin [11]-[12]). These are:

   1.All surface holes drilled for the purpose of exploration are to be capped, filled or otherwise made safe immediately after completion.

   2.All disturbances to the surface of the land made as a result of exploration, including costeans, drill pads, grid lines and access tracks, being backfilled and rehabilitated to the satisfaction of the Environmental Officer, Department of Mines and Petroleum (DMP). Backfilling and rehabilitation being required no later than 6 months after excavation unless otherwise approved in writing by the Environmental Officer, DMP.

   3.All waste materials, rubbish, plastic sample bags, abandoned equipment and temporary buildings being removed from the mining tenement prior to or at the termination of exploration program.

   4.Unless the written approval of the Environmental Officer, DMP is first obtained, the use of drilling rigs, scrapers, graders, bulldozers, backhoes or other mechanised equipment for surface disturbance or the excavation of costeans is prohibited. Following approval, all topsoil being removed ahead of mining operations and separately stockpiled for replacement after backfilling and/or completion of operations.

9. A further five conditions have also been imposed.  These are:

   5.The Licensee notifying the holder of any underlying pastoral or grazing lease by telephone or in person, or by registered post if contact cannot be made; prior to undertaking airborne geophysical surveys or any ground disturbing activities utilising equipment such as scrapers, graders, bulldozers, backhoes, drilling rigs; water carting equipment or other mechanised equipment.

   6.The Licensee or transferee, as the case may be, shall within thirty (30) days of receiving written notification of:-

   ·the grant of the Licence; or

   ·registration of a transfer introducing a new Licensee;

   advise, by registered post, the holder of any underlying pastoral or grazing lease details of the grant or transfer.

   In respect to DEC-Managed Lands PCP/196 and P5H/33 the following conditions apply:

   7.Prior to lodgement of a Programme of Work (PoW), the Licensee preparing a Conservation Management Plan (CMP) to address the conservation impacts of the proposed activities and submitting the CMP to the relevant Regional Manager of the Department of Environment and Conservation (DEC).  This CMP shall be prepared pursuant to DEC-prepared “Guidelines for Conservation Management Plans Relating to Mineral Exploration on Lands Managed by the Department of Environment and Conservation” to meet the requirements of the Minister for Environment for acceptable impacts to conservation estate.  A copy of the CMP and of DEC’s decision on its acceptability under the guidelines is to accompany the lodgement of the PoW application with the Department of Mines and Petroleum.

   8.At least five working days prior to accessing the reserve or proposed reserve area, unless otherwise agreed with the relevant Regional Manager of the Department of the Environment and Conservation DEC-R), the holder providing the DEC-R with an itinerary and programme of the locations of operations on the Licence area and informed at least five days in advance of any changes to that itinerary.  All activities and movements shall comply with reasonable access and travel requirements of the DEC-R regarding seasonal/ground conditions.

   9.The Licensee submitting to the Director of Environment, Department of Mines and Petroleum (DMP), and to the relevant Regional Manager, Department of the Environment and Conservation (DEC-R) a project completion report outlining the project operations and rehabilitation work undertaken in the programme.  This report is to be submitted within six months of completion of the exploration activities.

10. The following draft endorsements (which differ from conditions in that the licensee will not be liable to forfeit the licence if breached) are also noted:

    1.    The Licensee’s attention is drawn to the provisions of the Aboriginal Heritage Act 1972 and any Regulations thereunder.

    2. The Licensee’s attention is drawn to the Environmental Protection Act 1986 and the Environmental Protection (Clearing of Native Vegetation) Regulations 2004, which provides for the protection of all native vegetation from damage unless prior permission is obtained.

    3. The Licensee pursuant to the approval of the Minister responsible for the Mining Act 1978 under Section 111 of the Mining Act 1978 is authorised to explore for iron.

    In respect to Water Resource Management Areas (WRMA) the following endorsements apply:

    4.    The Licensee’s attention is drawn to the provisions of the:

    ·Water Conservation Act, 1976

    ·Rights in Water and Irrigation Act, 1914

    ·Metropolitan Water Supply, Sewerage and Drainage Act, 1909

    ·Country Areas Water Supply Act, 1947

    ·Water Agencies (Powers) Act 1984

    ·Water Resources Legislation Amendment Act 2007

    5.    The rights of ingress to and egress from the mining tenement being at all reasonable times preserved to officers of Department of Water (DoW) for inspection and investigation purposes.

    6.    The storage and disposal of petroleum hydrocarbons, chemicals and potentially hazardous substances in accordance with the current published version of the DoWs relevant Water Quality Protection Notes and Guidelines for mining and mineral processing.

    In respect to Artesian (confined) Aquifers and Wells the following endorsement applies:

    7.    The abstraction of groundwater from an artesian well and the construction, enlargement, deepening or altering of any artesian well is prohibited unless a current licence for these activities has been issued by the DoW.

    In respect to Waterways the following endorsement applies:

    8.    Advice shall be sought from the DoW if proposing any exploration within a defined waterway and within a lateral distance of:

    ·50 metres from the outer-most water dependent vegetation of any perennial waterway; and

    ·30 metres from the outer-most water dependent vegetation of any seasonal waterway.

    In respect to Proclaimed Ground Water Areas (GWA 21) the following endorsement applies:

    9.    The abstraction of groundwater is prohibited unless a current licence to construct/alter a well and a licence to take groundwater has been issued by the DoW.

    10.     The Licensee’s attention is drawn to the provisions of:

    ·the Conservation and Land Management Act 1984 and Regulations thereunder;

    ·the Bushfires Act 1954 and any regulations thereunder, and

    ·the Wildlife Conservation Act 1950 and any regulations thereunder.

Native title party’s statement of contentions

1. As stated above, the native title party’s contentions appear to be based on a pro forma document submitted in previous expedited procedure matters before the Tribunal.  As with previous matters, the native title party has not provided any material in support of its contentions and contemplates that witnesses (Ms Ashwin and Mr Ashwin) for the native title party will give evidence in support of its contentions.  And, as with previous matters, the native title party did not prosecute this intention in any way, either directly or through their representatives.  As such I make no further comment about the evidence the native title party would or would not have given should an oral hearing have been granted.

1. I refer to my decision in Ashwin v Gianni 2 where the native title party contentions are almost identical to this matter (at paragraphs [26]-[32]), and adopt those paragraphs for the purpose of this matter rather than re-stating those identical contentions.

Grantee party contentions

1. The grantee party makes brief submissions outlining their intentions in relation to the proposed licence.

2. The grantee party points to the extensive history of mineral exploration over the proposed licence (at 1) and contends that:

   ·    the grantee party has offered the Regional Standard Heritage Agreement (‘RSHA’) to the native title party (at 3);

   ·    there is evidence of ground disturbing work all over the areas of the proposed licence that the grantee party intends to work (at 5);

   ·    the surrounding area, including the proposed licence, was once a working cattle station, and the Perrinvale and Bulga Downs stations cover part of the proposed licence (at 7);

   ·    the grantee party is aware of the Aboriginal Heritage Act 1972 (WA) (‘AHA’) and will comply with it (at 3), as well as consult with the native title party to ensure the grantee party’s obligations under the AHA are met (at 4);

   ·    initial exploration work will entail rock chip sampling of outcropping rock units, detailed mapping, ground magnometer surveys by use of hand held equipment, and loaming (at 9);

   ·    access to the proposed licence will be by existing roads and tracks (at 7);

   ·    further exploration will only be undertaken if initial results are encouraging in specific areas, and will involve ‘only minimal to moderate land disturbance’ (at 10); and

   ·    rehabilitation will comprise levelling off of any stockpiles, respreading of topsoil and any cleared vegetation over disturbed areas, appropriate rehabilitation of compacted areas and the removal of any rubbish and temporary structures (at 11).

3. Attached to the grantee party’s contentions is a copy of a DMP Quick Appraisal for the proposed licence.

4. In relation to the grantee party statement they have offered to enter into an RSHA with the native title party, there is no supporting documentation in relation to when that offer occurred.  However, as the native title party have not countered the grantee party statement, I accept that such an offer was made.  The Government party, in any event, intends to impose an RSHA condition on the grant (see [33] below).

Government party contentions and evidence

1. The Government party contends, among other things, that: the rights which will be conferred by the proposed licence (if granted) are set out in section 66 of the Mining Act (and includes an extract); the exploration license is for an initial term of 5 years and is renewable; and that the grantee has indicated that it will not exercise the full suite of rights conferred by section 66 of the Mining Act (at 11-14). By way of comment on this assertion, the grantee party has not explicitly indicated it will not exercise the full suite of rights.

2. The Government party states it proposes to impose the endorsements and conditions set out in the Draft Tenement Endorsement and Conditions Extract (at 18). It also states that it intends to impose a condition requiring the grantee party to enter into a Regional Standard Heritage Agreement if requested by the native title party within 90 days from the grant of the proposed licence (‘RSHA condition’) (at 20).

3. The Government party states, in the absence of evidence to the contrary, the Tribunal must assume that a grantee party will not act in breach of the relevant statute law, regulations or conditions imposed upon them (at 24). It contends the grantee party’s submissions provide a ‘firm basis’ for concluding that the interference contemplated under the three limbs of s 237 of the Act is unlikely (at 25).

Government party’s contentions in relation to s 237(a)

1. The Government party submits there no evidence to support the native title party’s assertions that certain community and social activities are carried out on the proposed licence (at 52).  The Government party also submits (at 54) there is not likely to be direct interference with such activities given: the grantee party has stated most of its proposed exploration activities will be low impact and non-intrusive, and conducted in a manner which will respect local Aboriginal cultural concerns and not adversely impact heritage sites; the grantee party’s willingness to enter into an RSHA which provides for consultation prior to ground disturbing activities; previous mineral exploration in the area; the overlap of historical and existing pastoral leases which the native title party’s activities have already been subject to; there are no Aboriginal communities within the area; and that exploration activities are inherently capable of coexistence with community and social activities of a native title party. 

Government party’s contentions in relation to s 237(b)

1. The Government party correctly states the native title party has not produced any evidence regarding sites or areas of particular significance (at 64). It contends the grantee party’s work will be mostly low-impact and non-intrusive, and conducted in a manner which will respect local Aboriginal cultural concerns and not adversely impact heritage sites (at 66). The Government party states that interference is not likely because there has been previous mineral exploration in the area and the activities contemplated by the grantee party would be the same as, or no more significant than, the previous and continuing use of the area (at 67). It also contends the State’s regulatory regime under the AHA is likely to prevent interference with any area or site of particular significance (at 68) and that the grantee party has indicated its intention of abiding by the AHA (at 69).

Government Party’s contentions in relation to s 237(c)

1. The Government party states this limb of s 237 is only attracted when there is a significant, direct physical disturbance of land or waters, and that the grant of the proposed licence is not likely to involve such because (at 78): the grantee party has stated that most of the proposed exploration will be low impact and non-intrusive; any ground disturbing activities (such as drilling) are intended to be conducted in a way which will not adversely impact on heritage sites; the State’s regulatory regimes will likely avoid any such major disturbance; the Government party intends to impose conditions and endorsements on the proposed licence; the proposed licence has been subject to previous mineral exploration; and there is an absence of any particular characteristics on the proposed licence that would be likely to result in disturbance to land or waters from the activities of the grantee party (at 78). Again I accept these arguments in the absence of contrary evidence from the native title party.

Considering the Evidence in context of s 237 of the Act

Interference with community or social activities – s 237(a)

1. The Tribunal is required to make a predictive assessment as to whether the grant of the proposed licence and activities undertaken pursuant to it are likely to interfere with the community or social activities of the native title party (in the sense of there being a real risk of interference) (see Smith v Western Australia at [23]). The notion of direct interference involves an evaluative judgment that the future act is likely to be the proximate cause of the interference and must be substantial and not trivial in its impact on community or social activities (Smith v Western Australia at [26]). The assessment is also contextual, taking into account other factors which may have already had an impact on a native title party’s community or social activities (such as mining or pastoral activity) (Smith v Western Australia at [27]).

2. I accept the Government party’s arguments (as outlined at [35] above) that the native title party has not made out any likely interference with community or social activities, even assuming the grantee party was to assert the full suite of rights available to it. As such, I conclude it is unlikely that the grantee party activities will interfere with the community or social activities of the native title party for the purposes of s 237(a) in this matter.

Interference with sites or areas of particular significance – s 237(b)

1. In relation to s 237(b), the issue the Tribunal is required to determine is whether there is likely to be (in the sense of a real chance or risk of) interference with areas or sites of particular (that is, more than ordinary) significance to the native title party in accordance with their traditions.

2. I accept the Government party’s argument that the native title party has not provided evidence to suggest there are sites or areas of particular significance on the proposed licence. Even had there been such sites, based on the available evidence, I accept the State’s regulatory regime in this matter would have been sufficient to protect such sites given: the previous mineral exploration activity over the area; the Government party will impose the RSHA condition on grant; and the grantee party's contentions in support of its approach, including its willingness to sign the RSHA. As such, I conclude there is not likely to be a real chance or risk of interference with sites or areas of particular significance in this matter for the purposes of s 237(b).

Major disturbance to land or waters – s 237(c)

1. The Tribunal is required to make an evaluative judgment of whether major disturbance to land and waters is likely to occur (in the sense that there is a real risk of it) from the point of view of the entire Australian community, including the Aboriginal community, as well as taking into account the concerns of the native title party (see Little v Oriole Resources at [41]-[57]).

2. I agree with the Government party that the native title party has not made out any particular features or aspects on the proposed licence in this matter, and I conclude a real risk of major disturbance to land or waters is unlikely to occur, based on the available evidence for the purposes of s 237(c).

Determination

1. The determination of the Tribunal is that the act, namely the grant of exploration licence E29/884-I to Allanson Engineering Pty Ltd, is an act attracting the expedited procedure. 

Helen Shurven
Member

14 May 2014