Lacking risks of Latitude in Prospectus Prospectus is lacking the key risks for the Kuusamo Juomasuo mine namely lack social license (70 % disapproval), lack of acceptance by city of Kuusamo and major part of the legal risks. The city of Kuusamo has already once denied mining in Juomasuo and key regions of Latitude but Supreme adminstrative court decided that Kuusamo may not solely rule out mining from land plans (discriminate one type of industry). It looks obvious that plans can be amended to exclude all heavy industries based on their impacts https://www.miningmetalnews.com/20190802/1184/court-decision-kuusamo-cannot-limit-mining-master-plan
Land plan of City of Kuusamo and landowner approval in the change mining law The mining law has been changed so that after 1.6.2023 a land plan by the city is required for any mining projects. So Latitude would actually need to have Kuusamo to produce a specific land plan for the mine. The change of the mining law shows another risk for exploration. The permit elongation after 10 years would require approval of landowners of 50% of land area. Exploration and mining permits are just steps in the process where major obstacle is the environmental permit. Finland has realized the mining waste would be a long term problem, which would also be against Extractive waste directive of EU.
"Currently, the discussion on extractive waste and the claims presented in the appeals against environmental permits of mines relate – eg, to long-term impacts of extractive waste after closure of the mine. The aim of the project is to extend the scope of the guarantees required from mines under the Environmental Protection Act, and one can expect that a possible Government Proposal would be likely to result in further increase in the guarantees required from mines." https://practiceguides.chambers.com/practice-guides/mining-2024/finland/trends-and-developments/O15745
Environmental risks The special environmental risks have not been disclosed in the prospectus i) uranium, thorium and their daughter substances ii) acid mine drainage and heavy metals iii) natural value and fishes of Kitka-river https://www.fishinginfinland.fi/rivers_kitka_kuusinki_and_oulanka
2 million euros per year for licenses? The financial and plans working are lacking the financing of the 100 000 hectares (1000 km2) of exploration permit application when these would be granted. With the minimum price 20 euros/hectare/year the annul cost would be 2 million euros.The fees are disclosed on page 21 of HPP attorney statement, and total annual costs have tabeled by expert geologists but how these would be financed when granted is not disclosed and only fraction of the cost is in the budget. Anyway mere holding of the licenses would be 1/3 or 1/4 part of the budget, capture below page 107 of geologist, page 240 of Prospectus. The appendix B pages 1-3 of geologist report lists the landowner fees in AUD sum of the fees is about 3 million AUD per year when all applications would be granted. This about 10 times what is budgeted
Possibly they expect that the licenses would not be granted in 2 years but this may well happen as the authority has increased personnel.
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