Thursday, 8 April 2010

Inishowen Environmental Group meeting about mining

From Bev Doherty (IEG)

Dear Inishowen/Derry friend, and others who would have an interest in this matter.
You may be aware that Grosvenor Exploration and Mining Services (Ireland) Limited is to be granted a prospecting licence to search many townlands in Inishowen for minerals such as gold, diamonds and other gems. Please see press articles below.
At the Inishowen Environmental Group's meeting last night we came up with a series of points and questions for the press and individuals.
Please read our statement and if you are concerned.

The Meeting Points

The Inishowen Environmental Group met and agreed a position on the proposed granting of an exploration licence to Grosvenor Mining and Exploration (Ireland) Limited.

The members wish to emphasise that the writing of objections to the Department should be made on an individual basis. While the Government may proceed with the granting of exploration licences despite any objections, the fact that the objections have been made could be important if matters move on to the consideration of granting mining licences. We find it strange that the notice of issue of prospecting licences was not sent to the local Inishowen papers, but now that is to be rectified we have a further 21 days to lodge an objection. We would ask that objections should be informed by an awareness of the following points:

Ø If a licence to explore most of Inishowen is granted, no landowner can legally object to a representative of the company entering his or her land and searching for the presence of minerals, whether they be gems, diamonds or gold;

Ø The ability of exploration individuals to enter onto private land without permission does not extend to digging or trenching or any other form of invasive activity;

Ø We should be told more about this company, as there is a well-documented history of companies in this area fronting other, more contentious companies – and unfortunately this can sometimes mean facilitating the sale of things like “blood diamonds” where diamonds which cannot be legally sold because of their provenance in somewhere like Sierra Leone, can be “found” in another – this time legal – spot, and sold on (present knowledge would indicate that the two directors are Australian, resident in Perth, and with a history of expertise in diamond mining). An almost contemporaneous application for mineral exploration in SW Donegal is being made by Mylitus Mining, whose connections extend ultimately to Ghana, Sierra Leone, Namibia, Liberia and Angola – none of this information is given upfront.

Ø There is at present no map available for consultation in Carndonagh, a legal requirement on the part of the Department.

Ø Why should a repeat exercise in exploring exactly the same townlands as those surveyed in 1997 by Cambridge Mineral Resources through an aerial survey for diamonds be carried out again?

Ø Why did Cambridge Mineral Resources pass on its surveyed material to Moville Minerals Limited in the period 1998 to 2000, but this time not for diamonds, but for gold – without any public announcement, despite the Klondyke type advance notices prior to Cambridge embarking on its aerial survey? We were never told, despite promises, exactly what Cambridge found when they sent their results to Australia for analysis.

Ø Mining for gold is environmentally hazardous in the extreme – is this the real objective behind the exploration?

Ø Does the Department think that the Inishowen road infrastructure, particularly in the small local roads likely to be used, is up to carrying the heavy lorries need to carry away overburden?
Ø What is the position of our local political representatives on this, and if they don’t know, why not? It is difficult for private individuals to inform themselves.

Ø Where does the Green Box thinking enter into the exploitative nature of prospecting and possible mining of a non-essential material, be it diamonds or gold? The emphasis in Inishowen should be on fishing, farming and tourism, not spoiling one of Ireland’s hidden assets. At least one commercial organic farm is situated within one of the listed townlands; would any pollution from mining cause them to lose their organic status?

Ø Has there been an attempt on the part of this company to let local communities know what is involved, and if possible, alleviate their fears? We need only to refer to Donegal County Council’s attempt to impose a landfill site at the top of Glentogher in 1991, using legal tactics, only to be turned down eventually through the insistence of local people that their environment was seriously at risk because of unacknowledged geological instabilities leading to contamination of their water supply for people and animals. A more recent example of lack of transparency, consultation and dialogue in Co Mayo is the government’s handling of the gas pipeline project in Rossport.

Ø If there is the usual offer of jobs, is it not the case that these go to specialised outside people, well-qualified in these fields? We may be in a time of recession, but we can still see through empty promises.

Ø At a time when we should be seriously facing a future without oil and one which must get to grips with climate change, it seems frivolous to explore for diamonds which only the super-rich can buy. Synthetic diamond manufacture can easily supply industry’s needs for diamonds.

Objections should be sent before April 30th to:

Department of Communications, Energy and Natural Resources,
Beggars Bush,
Haddington Road,
Dublin 4
Phone no: 01-6782668

Press release Bev Doherty 25th April

Meeting about Gold prospecting well attended.

Over 80 people attended a meeting last Friday night in Carrowmenagh to find out why the Department of Communications, Energy and Natural Resources want to grant licences to Grosvenor Mining PLC to search for gold, diamonds and gem minerals in townlands stretching from Malin Head to Lough Foyle.

The meeting, called by concerned residents of the area and chaired by Mary Crumlish was also well attended by local councillors. Apologies were sent by Deputy Cecelia Keaveny, Padraig McLochlainn and Joe McHugh.

Guest speaker Mike Doherty from Glentogher, Carndonagh, outlined the legal procedures involved in prospecting and the rights of landowners to refuse access to prospectors if they wished. A bill has been drawn up allowing farmers to refuse access, but it has not become law yet.

Several short films were shown, one showing the discovery and subsequent mining of gold in Co. Tyrone, just a few miles outside Omagh Town , another contained interviews with landowners in South Africa whose land has been damaged by a local goldmine. One man, who grows vegetables commercially, was told that he wouldn't be able to clean out his irrigation dam because the sediment gathering behind it was radioactive. The mining had displaced uranium particles and he hadn't been informed. Displacement of other minerals often happens with gold mining. In fact, the mine in Omagh has so far produced 1800 times more lead than gold!

Councillors Bernard McGuinness and Mickey Doherty admitted that they knew nothing of the application for licences until they were invited to the meeting, and no-one in the room knew that there were already two licences active in Inishowen, owned by another company.

Councillor Charlie McConalogue again outlined the legalities surrounding the prospecting and mining of gold, saying that he needed to do more research before he could decide if the possibility of a gold mine in Inishowen was a good thing or a bad thing. This view was held by a few, but the vast majority at the meeting agreed that it would be better to avoid a situation where mining could become a reality by urging the government to refuse the licences in the first place.

Mike Doherty cautioned that unless many letters of opposition were sent to the Department, nothing would be done to stop licences being granted. He said that an attempt by residents in South Donegal to stop the issue of licences there failed because the Department only received thirteen individual letters. Apparently petition-style letters sent in by concerned groups didn't count.

Photocopies of basic letter of objection were circulated and more are available by contacting Mary Crumlish at 9381457.Last date objections will be received is May 6th.

You are invited to add your voice to the effort by writing or emailing your objections to the Exploration and Mining Division, Department of Communications, Energy and Natural Resources

Beggar's Bush

Haddington Road

Dublin 4

Tel: 01 6782666

Fax: 01-6609627

At start, brief introduction by Mary Crumlish, chairperson, then showing of 2 video clips, allowing people to settle and providing some background information.

a) Short video clip from Overhead Britain (5 mins) on the finding of gold in the Sperrins and the beginning of the Omagh goldmine. Promising announcement of 600,000 oz. of gold in the likely lifetime of the mine, 30,000 oz. per year. This is held on a private copy for which permission was obtained from the maker for the except to be shown. Overall impression: nice, clean business, all good for the people of Northern Ireland .

b) 18 minute downloaded video on Wonderfontein Spruit goldmine experiences.

1. Grosvenor Prospecting Licence Numbers and Midas.jpg

This map shows the numbering of the various Prospecting Licence Areas in Inishowen. Grosvenor Exploration and Mining (Ireland) Limited have applied for a Prospecting Licence in each of PLAs 3586, 3496, 3094, 3062, 3007, 2964 and 3008. This has cost the company €190 for each of the area applications, and if granted, the licences will be valid for 6 years.

The press notice allows for objections to the granting of these licences up to 5th May.

If exploration proves successful for Grosvenor, it may then apply for Mining Licences for any areas in which a successful exploration is carried out.

What you should notice are the 2 PLAs with the word “Midas”, short for Midas Mineral Resources Limited. These cover numbers 3063, 3820. Prospecting Licences were granted to this company last year, unknown to most of us and certainly to me. They have slipped under our radar.

2. Map PLA 3008.jpg

This covers the area in which we are now. The first public information session on this exploration attempt is taking place, because a number of us felt sufficiently alarmed at the total lack of information available either from the Department of Communications, Energy and Natural Resources, our local authority, the company itself, or indeed from our public representatives. This is an information session. At the end of it, each individual should be able to decide to object or not to the granting of a PL on the basis of sufficient information.

We should be able to demand full disclosure of all information related to the company’s plans and licences provided by the government. The EC directives pertaining to the Arrhus Convention, which Ireland has signed up to in 2001, but not yet ratified – alone of all EC countries –

1) emphasise the right of everyone to receive environmental information that is held by public authorities ("access to environmental information"). This can include information on the state of the environment, but also on policies or measures taken, or on the state of human health and safety where this can be affected by the state of the environment. Applicants are entitled to obtain this information within one month of the request and without having to say why they require it. In addition, public authorities are obliged, under the Convention, to actively disseminate environmental information in their possession;

2) the right to participate in environmental decision-making. Arrangements are to be made by public authorities to enable the public affected and environmental non-governmental organisations to comment on, for example, proposals for projects affecting the environment, or plans and programmes relating to the environment, these comments to be taken into due account in decision-making, and information to be provided on the final decisions and the reasons for it ("public participation in environmental decision-making");

3) the right to review procedures to challenge public decisions that have been made without respecting the two aforementioned rights or environmental law in general ("access to justice").

How come Midas got the Prospecting Licences to 2 areas in Inishowen without us knowing?

3. The Company. Grosvenor Exploration & Mining Services ( Ireland ) Limited.pdf [information got by paying privately]

Not so Irish: the two directors, Mr and Mrs. Spencer, have a residential address in Perth, Australia, and Roy George Stamford Spencer got his BSc degree at Natal University in South Africa in 1971. He has been a director and/or on committees around the world in various diamond mining companies. Their capital of €100k does not seem a large investment, considering that the company has to have adequate insurance cover to protect against claims or mishaps. No telephone number has been given for the company address in Dundalk, Co Louth.

Before moving on to what is involved in exploration licences, I’d like to give a short summary of the various surveys done over the past 20 years in Inishowen. In 1997 we had a flurry of headlines calling Inishowen a possible Klondyke, a promising new source of diamonds and so on. The first company, Cambridge Mineral Resources Plc, did a 2 year aerial survey of 10 PLAs, and pronounced the findings promising enough to have them sent to Australia (or was it Canada ? It’s very hard to pin down the information). Nothing seemed to come of this, until a new (or was it new?) company called Moville Resources – nothing to do with our Moville but a Moville in Australia – obtained 2 PLs for Inishowen, this time looking for gold. They used the data provided by Cambridge ’s research. Their licences ceased 5 years ago.

Bringing us up to date is Midas Minerals’ 2 Prospecting Licences. I can find very little on this company, other than that it has a capital of E10Million, and is based in Galway . The directors appear to be Irish, and their interest is in gold.

And now Grosvenor. We need to know if it is a junior company that is looking for a find to sell on to a larger company that would actually mine, or does it already have the backing of a larger company, where do they raise their money? If there is an international company behind it, then there may be support groups that look at the operations of that company that can be contacted for support and information.

It’s important to express objections early so that they are on record in written form. Objections could be on the basis of impacts not just from exploration but also on potential impacts of mining. If exploration shows that there are minerals and if it is economical to exploit them then the chances are mining will proceed - otherwise why explore. We must, if possible, avoid falling for the argument that it is only exploration, and that longer term impacts will not be considered at this stage.


I make no apology for showing and reading through these guidelines. They come from a detailed list given by the Government DCENR to any company applying for a prospecting licence; I have given the website address for the document, which runs to 4 pages. The main points are given below. In general, anyone with an exploration licence has the right to access to your land. The State owns the minerals that lie below the topsoil. If it decides to grant a mining licence, then it has right to extract any minerals that may be below your house, your property, your farm.




All environmental standards to be adhered to, with adequate insurance cover to be in place.

There must be close liaison between the company and relevant landowners, and regulatory authorities.


Agreement to be reached with landowners before entering lands for geological mapping, surveying, trenching, drilling. Agricultural activities take first place. Prior compensation to be agreed before drilling or trenching takes place, and there must be an appointed field supervisor who gives his name, the company address and telephone number to landowners.

Field equipment not to be left unattended in fields or roadsides (apart from heavy drill or excavating rigs). Everything to be cleared up at the end.

Before starting to drill or excavate, the field supervisor should discuss and identify powerlines, entry points, stock watering points, pipelines etc. Particular attention to be given to crop harvesting, foaling/lambing/calving, possible disease spread etc.

Careful checks to be made for sensitive ecological sites or archaeological features.

The field supervisor must inform the landowner about remedial measures to be taken if water or land pollution should occur.


This must take place downhill from water sources or limestone area, uphill from pollution sites. A full photographic record must be kept.

All access roads must be agreed beforehand with the landowner.

There are strict regulations regarding fuel storage and spillage, and likewise with any removal of water.

Noise must be minimal and not happen during unsocial hours.

Drilling areas are to be fenced against grazing animals.


Same safety regulations as for drilling, and preferably to take place during dry weather. A full photographic record must be kept.

Topsoil and subsoil to be kept separate, and restored on completion to satisfaction of landowner. If excavations have to be left open after exploration and before proceeding to mining, planning permission must be sought: advice to be obtained from the Local Authority. N.B. Planning Permission doesn’t have to be sought in other instances, except in the case of Restricted areas (below).


Alternative water supplies to be made available immediately if any damage is done to original supplies.


Emergency backup to be available at all times. Local Authority to be informed before tests for arrangements and approval.


These are Special Areas of Conservation or Special Protection Areas. There are restrictions here, and approval is needed in writing 1 month beforehand from the Exploration and Mining Division.

REPS: no work to be done without the prior approval of the landowner.

Here I have to say that I don’t fully understand the status of the lands that will be explored - are these private property - what are the implications if land owners do not want to allow exploration activities? Are there communal owned lands involved - what if people with usage rights to these lands refuse to allow exploration activities? Again it seems to me that the public consultation process required by the Aarhus Convention would offer such answers. Perhaps someone in the hall could inform us after this presentation.

5. Video UTV interview.

The history of gold mining generally throughout the world is not a happy one, and here I’d like to – I must – consider what is taking place about 50 miles from here, at Cavanacaw Gold Mines in Co Tyrone, just a few miles SW of Omagh. The names of the company keeps changing, but at the beginning it was Rio Tinto Zinc that proposed the area as one meriting exploration for gold. Open-cast goldmining operation at Cavanacaw was granted planning permission in the face of very strong local opposition in 1995, after a public enquiry in 1994. The sites covers 60 hectares, almost 150 acres, the excavation 40m deep, 850m long and up to 100m wide. Neither cyanide or mercury is used; instead, after crushing the rock, a flotation method to separate metals from unwanted materials results in a separation of metallic particles from tailings. A lot of water is required. The foam is then taken from the top of the cell, cleaned and dewatered. The metallic concentrate goes to Canada for treatment and extraction of gold.

In the Omagh mine the ore is graded at up to 7g/tonne. This means you get 7 grams of gold out of one tonne of rock. In fact you need to move far more than one tonne of rock to get those 7 grams. The gold in the ore is actually not visible to the naked eye (as in most gold deposits, gold starts to be visible only when the grade reaches 30g/t).

6. Cavanacaw opencast Gold/Lead Mine Grazing.jpg or

At Stormont on 02/06/09 Dr Kieran Deeny MLA said, “Metals other than gold are released when rock is crushed, including lead, cadmium, nickel and arsenic, which are all potentially toxic and dangerous. Heavy metals in such unnatural concentrations can pose enormous problems because they will not break down or disappear completely. All the heavy metals released are also present in dust and sediment. An open pit operation such as the one in Cavanacaw, produces a lot of dust and especially in a windy location such as this one fugitive dust is a problem. It is easily transmitted and poses a danger for surface vegetation, crops, livestock, and humans. Pregnant women, the elderly, and sufferers from asthma are particularly at risk.
Condition 28 of the planning consent stipulated that fixed water sprays be installed on the haul roads to limit dust transmission – this was never carried out. Condition 29 stipulates that stockpiles of rock shall be sown with a range of plants to limit the transmission of dust outside the site boundary, this was never done and Condition 30 says the ore stockpile shall be retained in a covered area for the same reason, this wasn’t done either, (these three Planning breaches were confirmed by Planning service.) Nobody can have any idea how much toxic dust blew across the fields in this windy location or indeed how much of it entered the food chain through crops or cattle and sheep grazing as environmental health officer David Gillis (Omagh District Council) confirmed that little or no monitoring of the site had ever taken place”. (End Dr Deeny’s quotation).

Omagh Minerals has an appalling track record on planning breaches generally, 12 recorded in 2009.

At the September meeting of Omagh District Council Cavanacaw Goldmine Sub Committee, councillors were shocked to learn that large quantities of highly toxic lead were being extracted from the mine. The company's own sales figures for the second quarter of 2009 showed sales of 1,977 troy ounces of gold, 5,972 troy ounces of silver and 90.4 tonnes of lead. Nobody had ever envisaged that such a high percentage of lead would be produced at the mine. These figures equate to 1800 times more lead than gold being produced. The figures published by the company for the 2nd quarter of 2009 give the amount of gold at 1,977 troy ounces of gold, 5,972 troy ounces of silver, and a staggering 90.4 tonnes of lead. The goldmine has become a leadmine.

7. Video 140 trucks per day

From June 2008 until February 2009 800,000 tonnes of aggregate were removed from the site and used in the Aughnacloy bypass, until Sammy Wilson MLA halted the operation on Feb 6 2009, and served the company with an enforcement notice in June 2009. Think of our narrow roads if this were to happen; see the difficulties experienced by the milk tanker in the video. Accusations are now being made by those close to the Aughnacloy by-pass that water containing lead is leaking from the roadworks and affecting the groundwater.

This movement of aggregate has removed 20 jobs from two local quarries. In the meantime the mining company has stockpiled 1 million tonnes of aggregate for future possible use in the dual-carriageway to stretch from Aughnacloy to Derry , starting 2012. Remember that under the company’s terms and conditions, the hole made in their opencast mining would be filled in and everything restored as it used to be!

The point that usually is made in favour of job-creation in respect of mining is a weak one. We have seen here the loss of quarry jobs, and the loss of credibility on the part of local farmers whose cattle are exported widely - the danger of lead poisoning means you simply cannot have agriculture and lead mining in close proximity to one another. Few specialised jobs will go to local people as a result of gold-mining; they lack the expertise.

The emphasis in Inishowen should be on fishing, farming and tourism, not spoiling one of Ireland ’s hidden assets. At least one commercial organic farm is situated within one of the listed townlands; would any pollution from mining cause them to lose its organic status?

At a time when we should be seriously facing a future without oil and a future which must get to grips with climate change, it seems frivolous to explore for gold which only the super-rich can buy.

8. Kinnagoe beach.jpg

9. Emailed objection.pdf

Read words printed on slide:


I object in the strongest terms to the proposal to grant a licence to explore the Inishowen Peninsula for diamonds, gold and other gems.

We have had enough of exploitation and of greed to accumulate wealth in the past few years and the commodities under discussion are only available to the wealthy and HAVE NO TRUE INTRINSIC VALUE, because they cannot be eaten, worn, nor do they provide shelter.

How much more appropriate it would be if investment were made into the truly beneficial work current on the Inishowen Peninsula, namely farming, fishing and tourism. If the licences to explore were to be extended into licences to mine, all these current sources of income and livelihood to the local people would be destroyed, or, at best, damaged.

I look forward to learning that this matter is given a proper opportunity to be debated in public - and ultimately to hearing that the licences have not been granted.


(Heading of this article from the Inishowen Independent)


Dear Ms. Reilly,

The current position is that all the objections have been received and listed and the matter will now be considered by the Minister since the legislation provides that the granting of a licence is a matter for his decision. If the Minister decides to grant the licences each person who submitted an objection will be notified by letter and the reasons will be clearly outlined. I'm afraid I can’t give an actual date as to when the decision might be reached but I would expect that it would be in the near future.

Please feel free to contact me if you need any further information.


John King
Exploration & Mining Division
Department of Communications,
Energy & Natural Resources
Beggar's Bush
Haddington Road
Dublin 4
' ++ 353 1 6782661
7 ++ 353 1 6609627

Latest 30th July 2010
Hi all,
Now I am getting entirely pi**ed off. Words fail me, so I shall forward the most recent correspondence between our own veteran environmentalist, Mike Doherty , who so skillfully pointed out all the dangers facing a small peninsular community at the meeting in Carrowmenagh, and the ALL POWERFUL Somebody in the Department of Whatever Applies to Inishowen, on who's decision we shall all perish at our own cost, who decided "ON BALANCE" (how DO you balance 400+ letters containing similar concerns? ) to permit prospecting, willy-nilly to people who barely know the geography, let alone the geographical isolation and difficulties facing the community of our area, taking only into account the possibility of millions of revenue to the country at large (i.e. Dublin) and not the realistic damage that mining (why else are they prospecting?) will do to our amazing locality. Please forgive my poetic slant, sure deosn't all great prose come from desire??!
I now hand you over to Mike Doherty, please read the entire mail - PAY PARTICULAR ATTENTION TO THE PATHETIC APOLOGY IN THE OPENING PARAGRAPH FROM MR. KING (and remember that over 400 of these letters have been sent out) - and feel free to reply in large numbers to the department, and don't forget to forward this information to anyone you think might not have recieved it. (and always apologise for cross postings - folks don't like it...)
Best Regards, Mary Reilly..
Dear Mr King.

Thank you for your letter dated 23th July 2010 ref. MA286/1.

While appreciative of the information you give in your reply (paragraphs 4, 5, 6 and 7 contain information which we already knew from a careful study of the Department's website), I have some questions that require answers.

When you say that "the Minister gave careful consideration to the matter and has decided, on balance, to issue the licences to the company", would you agree that no actual reason has been given? This is not what I had been led to expect when you wrote to Mr David Simpson on May 7th "depending on the Minister's final decision, each person who submitted an objection will be notified by personal letter. If the Minister decides to grant the licences the reasons will be stated in the letter". If you disagree with me, could you dissect the letter for my benefit and point to these reasons? Are we not talking about prospecting licences here?

At a public meeting held in Carrowmenagh, Inishowen, as guest speaker I said "It is important to express objections early so that they are on record in written form. Objections could be on the basis of impacts not just from exploration but also on potential impacts of mining. If exploration shows that there are minerals and if it is economical to exploit them then the chances are mining will proceed - otherwise why explore. We must, if possible, avoid falling for the argument that it is only exploration, and that longer term impacts will not be considered at this stage". You miss the underlying logic against opposing prospecting licences. Why explore if not in the hope of mining? Why oppose exploration if not in fear of the environmental impacts that will follow from mining, in particular gold (and even diamonds)? Do you still maintain that your distinction between prospecting and mining is valid?

A crucial point for those who attended the meeting was the right for landowners to refuse permission to prospecting licence holders to enter their land. I realise the Department says that drilling or trenching is essentially non-invasive, yet we can read from their published 2002 report that Cambridge Mineral Resources plc did extensive trenching and drilling during the course of their prospecting in Inishowen. What I would here ask you to clarify is: has a landowner the right to refuse permission to the prospecting licence holder to drill or trench on his or her land?

Prospecting licences are being applied for, and given, without all due information given by the Department, the company or the local authority. This is contrary to the Aarhus Convention, signed by all EU countries in 2001, and ratified by all except Ireland. Much of the unnecessary speculation and fears arise from this single factor. Could you find out through Minister Ryan when Ireland will ratify this Convention?

Yours sincerely,

Mike Doherty
Upper Galwilly
Co Donegal

Dear Mr. Doherty,

In reply to your email below firstly I regret that, as you correctly point out, the reasons for the decision to grant the licences were not set out in the letter. I regret this oversight.

In reaching a decision to grant a prospecting license, regard is had to the balance between the Department's policy remit for minerals' prospecting and the relevant environmental considerations. As my letter explains, prospecting licences granted by the Minister are subject to the Department's own guidelines as well as to the requirements of the National Parks and Wildlife Service and the National Monuments Service. Therefore, in deciding to grant these licences, the Minister took full account of the balance between the environmental factors and Government policy as set out in the Department's website viz. "...the encouragement of the early identification and responsible development by private investors of the Nation's minerals deposits in accordance with best international practice" and "... promoting and regulating minerals exploration and development in Ireland".

The end-result of prospecting is of course to discover a viable mineral resource and develop it, in accordance with national economic policy, and we are certainly not attempting to conceal this. However in the majority of cases where prospecting takes place such resources are not discovered. When they are discovered, and the decision is taken to develop them, my letter explained the processes and consultative stages that must be gone through to get permission.

While the minerals exploration and development legislation does not give landowners the right to refuse permission to prospect over their land, in practice our Guidelines for Good Environmental Practice stipulate that: "Where practicable, agreement must be obtained from landowners before entering onto lands for geological mapping, geochemical or geophysical surveying, trenching or drilling." The link below shows the Guidelines and it is a condition of the licence that they must be adhered to.

I cannot agree with you that licences are being applied for or given without all due information being given by us but if you would like to point out where in particular you feel this may have occurred I will be very happy to reply.

Yours sincerely,

John King
Exploration & Mining Division
Department of Communications,
Energy & Natural Resources
Beggar's Bush
Haddington Road
Dublin 4
' ++ 353 1 6782661
7 ++ 353 1 6609627

Latest August 5th 2010

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