Agree with @gafia, an exploitation licence application has been made under the previous legislative regime. I'm not sure if they can amend that application under the existing laws, but I would be surprised if the law would not allow this. But this is moot.
What the GoG is doing is applying the law retrospectively to that application in order that this application is made redundant. In simple term, they can now just refuse it because of that retrospectivity.
The GoG is also saying that GGG must make a new exploitation license application under the new laws. So there is the double whammy, obviously, as the current application would not meet the arbitrary 100 ppm figure in its present form. So they would have to amend their EIS/SIA etc to cover all this off, go back through an advertising process, public consultation and likely still face refusal cause these knuckles are hell bent on stopping the mine.
In terms of your comment on this so-called 'surrender rights' document, the recent release clearly states that GGG feels the GoG is appropriating their rights and they have legal remedy. Seems to me they still believe the law as it stands strips their rights.
That's all speculation but so are your comments, so touche. But the bottom line is, GoG is being too smart by half and it will come back to bite them whatever we think.
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