RE: Lithium from Cinovec9 Feb 2025 17:15
If you have the desire and time, here are some comments on the Government Regulation... Just so you know what such a legislative process looks like :-)
Comments
Ministry for Regional Development on the draft government regulation on the determination of a deposit of strategic importance in the CĂnovec area
1. On the draft government regulation (title)
In the title, we recommend inserting the word âGOVERNMENTâ after the word âREGULATIONâ.
2. On the justification (p. 3, bullet Reimbursement from extracted minerals)
We recommend clarifying whether the rate stated here (10,692 CZK) is intended for 1 kg or 1 ton of extracted lithium. The wording is unclear and allows for different interpretations
B. On the individual provisions of the draft
1. On the title of the legal regulation
The draft government regulation uses the phrase âin the CĂnovec areaâ, which does not correspond to the text of § 1 or § 2, paragraph 1.
The draft needs to be stylistically unified.
3. Deficiencies in the identification of the CĂnovec protected deposit area in § 2, paragraph 1
We request that the identification number of the protected deposit area be supplemented by the identification of the register in which this number is kept, or the legal act by which it was assigned, as this is essential information for the entire content of the proposed government regulation. If the content of the proposed government regulation is to be based on a list of references to previously issued individual legal acts, which are thus included in the legal system as reference references, these references must have a specific form.
This comment is essential.
There should be a comma after the number 12370000.
4. Non-normative provisions of § 2, paragraph 2
According to § 2, paragraph 2 of the proposal âAnnex No. 1 to this regulation establishes an indicative graphic representation of the CĂnovec deposit of strategic importanceâ. The cited provision is in conflict with Article 39, paragraph 1 of the Legislative Rules of the Government by a non-normative provision (see â⊠establishes an indicative âŠâ).
With regard to the definition of the area of ââthe CĂnovec deposit of strategic importance by means of references to the listed exclusive deposits [§ 2, paragraph 3, letters a) to d)], which are, among other things, the subject of registration in the information system managed by the Czech Geological Survey [Raw Materials Information System (SurIS), or Geological Information System (GeoIS)], the âestablishment of an indicative graphic representation of the depositâŠâ is unnecessary and it would be sufficient to simply state it in the justification of the proposal.
We demand the deletion of § 2, paragraph 2 and Annex No. 1.
This comment is fundamental.