EXCERPT FROM THE SUBMISSION:
“27. Our client’s submissions and comments on the draft ESIA, in summary, are that the Competent Authority should find that:
27.1. the Public Participation Process has been neither adequate nor meaningful;
27.2. TEEPSA has not obtained its Social Licence to Operate nor received the Free, Prior, and Informed Consent of the Indigenous Peoples and Communities who will be most impacted by the adverse effects resulting from TEEPSA’s exploration activities;
27.3. the proposed Project is neither needed nor desirable;
27.4. TEEPSA has failed to demonstrate that its proposed Project is consistent with the ICMA as a whole, including that it is needed or desirable in the interests of the whole community; and
27.5. TEEPSA has failed to place the necessary relevant information before the decisionmaker to allow them to make a decision which is consistent with the provisions of the ICMA.
For the avoidance of any doubt, our client’s submission of these comments on the draft ESIA should not be construed as support for the Project, and to the necessary extent, our client’s rights to oppose the Project remain reserved.”
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