Hi Portiss:
Our ESD doesn't require a Public Review, just the Environmental Review Document in Stage 3, Step 3.
if the ESD needed a public review, it would need to be explicitly stated in the Chair's determination letter (you can see this if you peruse some of letters for other projects on the EPA website, they state a # of weeks next to the ESD bullet point like our letter does for the ERD).
Everything else that you've described seems in line with the EPA procedures manual.
In General:
An interesting thing I've noticed from looking at other applications is that some proponents have applied and been granted permission by the EPA to commence 'minor or preparatory works', sometimes even before reaching the ERD step (stage 3 step 3) (refer Lynas Rare Earths,
https://www.epa.wa.gov.au/proposals/lynas-kalgoorlie-rare-earths-processing-facility). It seems that this can include minor construction of access roads, concrete pads, and delivery of plant items, etc.
Considering that VRX has been allowed to clear a section of land for a rehab trial (https://minedex.dmirs.wa.gov.au/Web/environment-registrations/details/92539), AND looks like land has been cleared in the bore announcement, AND we have installed a water bore - it appears that we have commenced some Of the prep works already.
If I were VRX, I'd push the plant & access road designs + offtakes ASAP; commence the site establishment works, service installations, & plant delivery under preliminary approvals (in or close to the trial clearing area); then construct the plant and start mining when the final approval comes in later in the year.
From the interview released the other day, it seems VRX & consultants have selected the least environmentally sensitive areas for the proposal, so the chances of the above don't seem too wild to me.
It's all fun & games when it comes to government approvals though so DYOR and GLTAH!
