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I have some new information on the de watering permit application from ALBA. To me this dose not really agree with the information I received from NRW.
I now do think that the de watering permit can be granted at anytime, with no need for an appeal, as I had thought initially.
Just waiting patiently for the RNS with the good news, knowing it could come anytime.
Quote from an e mail I received from ALBA today:
"On your question about the dewatering process, as we stated in our RNS of 9 December: “…the Company continues to progress its work on a set of detailed submissions seeking a further consideration by the authorities of the Company's dewatering application.” So the process engaged in involves a reconsideration by the regulator of its decision rather than an appeal as such.
Ocelot correct,
They do have 6 months from the refusal of permit to make the appeal( end of April) they wont make the appeal until all the issues have been sorted out " constructive meetings" that have been going well. As soon as Alba have finished back and forth discussions with NRW and are happy, they will formally launch the appeal, then the permit can be granted quickly.
Have a good weekend all.
Ocelot, Cheers for the good info as normal,
Here is my message to and reply from NRW from a couple of days ago. I am still happy the permit is coming soon, and enjoying the Alba ride.
My question to NRW:
Have Alba appealed the decision, or can they get the permit without a formal appeal, just by working with you.
Will notice of any actions appear on the public register.
can you give me an idea as to when a decision will be made.
My reply from NRW:
Hello
Thanks for your emails. In response to your queries - the final determination decision to refuse granting of a permit has been made for application PAN-012667, which has been made available on the public register. There is no further action to be taken by NRW’s water quality permitting team regarding this application, as it has been fully determined and the application closed.
The applicant is free to make a new application for discharge at any time, at which time the application will be assessed on it’s on merit. NRW cannot speculate as to what the outcome would be of any new application.
At present NRW are not aware of any formal appeal lodged regarding the determination to refuse granting of application PAN-012667. If one was to be made, then due process will be followed for making information available on the public register.
If you have any further questions about this site, then please can you contact our customer contact hub and ask to speak to the local area team regarding the matter, for there is little else we can tell you about the application and decision made that isn’t already available on the public register.
Kind regards
The de watering will not affect the bats, it can if it affects the humidity levels, but Alba have evedence/data that shows it wont be a problem. Alba have already agreed to avoid the the times of year when the bats are roosting ect. Alba have agreed not to work in the mine during certain months "Works will not be permitted to take place within the known bat-inhabited areas of the mine between November – March (inclusive), eliminating potential effects to hibernating bats"
Ocelot,
I think that the "written appeal request" is the only quick way to appeal, but it has dose to be a formal request according to NRW. I had that confirmed in my e mail by NRW, I have been on them for a few weeks to get an answer to this.
Quite quiet on here so just some thoughts and a bit of info on the permit that some may find interesting.
On Jan 13th on a vox market interview George basically said Alba had very constructive meetings with NRW, and when Alba send of their final submissions for the permit appeal they hope for a very quick turnaround in getting the permit. George felt Alba had have been answering all their remaining questions and have been putting to bed any doubts that NRW have about the permit. He also said the exercise is all very straight forward and robust and hoped to get a formal decision by the end of February.
I have been checking out the appeal procedure and I have concluded the only way Alba would get such a quick decision would be to make a "Written Representations Procedure 28. The written procedure for dealing with an appeal is an exchange of statements between yourself and the regulator, followed by a visit to the site by an Inspector who will determine the appeal. This is usually the quickest, simplest and most cost effective way of deciding an appeal"
Any other type of appeal looks like it would take many weeks/months to get a decision after submitting the appeal. Even with this Written Representations Procedure , it seems like it could take up to 4 weeks to get a decision once submitted, although it could be shorter and would depend on NRW being kind to us to get it done quickly. This is only my own deductions on reading the appeals procedure, i am not an expert on this. It is quite complicated and not a one size fits all procedure.
However I do have one fact, as on Tuesday 15th Feb 2022 -3 days ago to be clear, Alba had not yet made the formal appeal to NRW. That info came to me directly from NRW(private e mail) and is was like getting blood out a stone to get it. When Alba do make the formal appeal, notice of it should appear on the public register, but in my experience this information is often delayed and can appear late, so its not a sure way to found out anything concrete.
So we may get the permit by the end of Feb, or we may have to wait a little longer, no worries the main thing is we will get that permit sometime soon.
Harry Guest is starting a new job for Kuniko Norrge As, in March, whilst Alba do offer fantastic invaluable experience to young geologists, they rightly so do not offer big salary's right now. The young ones gain experience and move on to higher paid jobs.
Harry has done a great Job for Alba, maybe he will be back one day!
Your welcome gla
I guess I should have said I am 99.9% certain.
After all remember Alba wished us all "a very prosperous new year"
Prosperous...Successful in material terms; flourishing financially, I would like to thing ALBA chose those words with a great deal of thought.
To add to my last post..You could say "what if the information from the new data loggers came back and was not the right data"
The data recovered from the new data loggers (from memory about 6 weeks worth of data) recorded before submitting the initial application showed 100% humidity, and that is what is needed to get the permit, a high baseline humidity in the cave. Hence that is why Alba are super confident of getting the permit.
I just did my own research, the permit will be granted because, no good reason it won't be. I do believe Alba know this already from whats been happening lately in terms of communication from them. I will re post one of my previous posts on the subject. Feel free to read my others on this subject should you wish, make your own conclusions of course.
Alba jumped through every hoop to avoid a bat/otter problem. Including, they readily agreed not to work in the mine during certain months "Works will not be permitted to take place within the known bat-inhabited areas of the mine between November – March (inclusive), eliminating potential effects to hibernating bats"
One thing was responsible for the dewatering permit being denied.
Failure to provide data on mine humidity levels, because Albas data humidity loggers had failed, well they in been in for a couple of years and when it was time to remove them they were found to be damaged, and the data was lost.
“There is no information to support the application as to whether the de-watering of the mine will impact humidity levels? High humidity levels are key for successful hibernation; it prevents dehydration and prevents more frequent arousal from torpor so this will need to be assessed to ensure no likely significant effect. There is no baseline data as a result of the data loggers being moved.”
"The decision to refuse the permit application is based on our assessment of the potential environmental impact on the EPS/SAC features of Lesser Horseshoe bat and Otter. It cannot be demonstrated that the proposed water discharge would not have an ‘Adverse Effect’ on Lesser Horseshoe Bats and Otter "
“In the absence of adequate survey information, the current proposal does not satisfactorily evidence no loss, damage or deterioration of these features….
It is therefore concluded that the application fails to demonstrate that bats/otter ….. will not be adversely affected.”
"With the Clogau mine forming part of the Lesser Horseshoe bat/otter habitat and any changes in humidity ventilation, temperature and disturbance could cause deterioration on the functionality of the mine for bats/otter"
Alba report stated clearly that the dewatering would not affect the humidity levels, as the conditions will not change during dewatering. They just needed the baseline data to get the box ticked.
"Effects to bats from any change in airflow and humidity levels are predicted to be of No
Change and therefore not significant. This will in no way affect the FCS of lesser
horseshoe bat or Otter within the SAC."
"The flow of water from the Llechfraith adit to the drainage adit has already been isolated, with the current conditions inside the mine mirroring those during the de-watering process and the exploration in the lower workings when dry"
Alba did put in new data loggers but they did not have long enough to gather the data before the report was due. more Conclusion more Data =permit.
Alba Mineral Resources
@AlbaMinerals
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A big thank you to everyone who came to our Community Open Day yesterday in Bontddu.
It was a fantastic turn-out, and the Alba team really appreciated the opportunity to update the local community on our work and plans at Clogau-St David’s.
I don't think shnabel would get his Europen Protected Species Licence or any other enviromental permit for that mater, so we will never know lol
Afraid you wont get to see any big fancy machinery with Alba, they don't need it for the type of gold we will be extracting but you might see some cool underground drilling tools.
Absolutely right luckybob, Alba " have various other highly promising targets even if the dewatering doesn't happen" That is not in doubt.
I personally feel that if it did not happen, it could mean Alba would struggle with NRW and permits going forward, because there is no reason NRW should not grant the permit for dewatering once "the new data is in" is in. If Alba had been incompetent with the application fair enough to refuse, but they have gone above and beyond. That is why this permit is so important. It will be granted anyway..no ifs about it.
Alba have been highlighting the Liechfraith shaft gold exploration after dewatering in the last two videos.
Harry Guests last video really shows how important the dewatering of the Llechfraith Shaft is. It has been no secret that It has always been Albas plan A to dewater and further explore that shaft. The permit delay is very frustrating but understandable NRW have to play by the book as do Alba. When that permit is issued, I do believe it will be a pivotal moment for Alba. They can crack on with plan A- quickly dewater then further explore the Llechfraith Shaft leading to substantial gold discovery then recovery in the quickest possible timeframe. Maybe more importantly it will confirm to everyone that they have the full backing of NRW to mine in the Snowdonia National Park Area. The granting of the permit should also generate a great deal of positive publicity to help the share price.
No doubt some investors will hold back until the permit is granted as they do not share my 100 % confidence of the outcome. I would think that just getting the permit will be enough to send the share price on a very big upward turn. I am thinking getting back to the levels of December 2020, then kicking on up with further news.
As pointed out in a recent post by ocelot…Alba have done nothing wrong over the last couple of years.
Just need a little more patience before thing take off