VAGO Rehabilitating Mines Audit 5 August 2020 (VAGO Report)

DR ELIZABETH GIBSON, General Manager of CMPA comments on the VAGO report.

Small to medium quarries distributed throughout Victoria provide for quality, choice and competitive pricing of construction materials for the Victorian consumer (including governments).

The founding of the CMPA was in a large part driven by the previous Auditor General of Victoria, Report on Ministerial Portfolios “Restoration of Mining Sites” p.256 May 1999 (More on the CMPA is found at the end of this letter).

The VAGO Report follows a similar format with similar conclusions. However, the rehabilitation of quarries has historically occurred throughout Melbourne and regional Victoria from returning to agricultural land use to Fitzroy Gardens, Carlton and Clifton Hill (https://www.emelbourne.net.au/biogs/EM01213b.htm).

A more recent quarry rehabilitation proposal that provides the State with great benefit can be found at: https://theurbandeveloper.com/articles/riverlee-epping-masterplan. Additionally, over the past 35 years approximately only $20 000 has been expended by the Victorian government on rehabilitating quarries. This is a great testament to quarry operators, Earth Resources Regulation, and the historical legislation in place.

The VAGO Report is seriously lacking due to not clearly articulating the liability to the State as per the Mineral Resources (Sustainable Development) Act 1990. This is disappointing considering that $570K was expended by Government on the audit and this analysis of legislation is absent. It appears that the VAGO Report has been used as an opportunity for scaremongering leading to damaging the reputation of the extractive industry sector.

Attached is a Paper prepared by CMPA and reviewed by lawyers “Why a review is necessary of Construction Materials Rehabilitation Bonds” (2013) (available at www.cmpavic.asn.au) which clearly and rationally outlines the liability issues to which the Minister and Government are exposed. Already, the extractive industry operates in a highly regulated environment as otherwise stated in the VAGO Report.

This is compounded by other jurisdictions in Australia and internationally having less onerous but still effective legislation leading to, for example:

• Sand being imported into Victoria (Melbourne) from Moama, NSW;
• A proposal for aggregate to be imported into Victoria from Canada.

(Note, the prevailing ethos is that quarries are located close to where the construction material is being used to keep costs low as well as achieving a lower carbon footprint.)

This VAGO Report will be used to prevent greenfield site work plans and work plan variation approvals; or lead to only the multinational extractive
industry being able to afford an application.

Due to the deficiencies, inaccuracies, misleading extrapolations, misstatements, and evident bias against the extractive industry (quarries) I respectfully request that the VAGO Rehabilitating Mines Report, 5 August 2020, be withdrawn.

Please see specific comments on the VAGO Report, below.

The rest of the submission can be found at www.cmpavic.asn.au

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