The requirement for a scoping document is not a 'rap on the knuckles'. A scoping document is not issued/required dependent on the level of information provided. It is issued/provided dependent on the level of assessment the EPA has determined. The level of assessment is depended on the number of EPA key environmental factors potential impacted, the scale and extent of those impacts and public interest (determined via the public review period for the referral document).
A scoping document is nearly always issued (or prepared by the proponent) when the level of assessment is Public Environmental Review as TMTs project is. A scoping document is not issued when the level of assessment is 'assessment on referral information' as AVLs project mining project is, or 'not assessed' as is the case with AVLs processing projects which was referred separately. Its a big difference between the two approach - AVL has two projects (as far as EPA is concerned) looked at separately. TMT has one. Another point of difference is that AVL had one public submission (requesting public env review). TMT had 6 (2 recommending environmental review - no public review, and 4 recommending pubic environmental review)
Further, the extract of the EPA chairman determination specifically states "The proponent has provided detailed information in its referral documentation. However further studies, particularly related to groundwater and subterranean fauna, are required to determine the extent of the proposal's direct and indirect impacts, and how the environmental issues could be managed".
The two project are different, with different impacts and different public interest - that is why they are assessed at different levels - not due to poor referrals. I do this for a living and have looked at all three referrals - none are perfect, but as far as referrals go, all are certainly at a decent standard and I have no major issues with any of them.
