Regulatory Risk
Whether Liberty will be granted a UCG licence in Queensland is hard to ascertain and this poses a risk for the company. Except for the three exclusive tenures (Linc Energy MDL 309, Carbon Energy MDL 374, and Cougar‟s MDL 385), the Queensland Government has not granted approval to any other UCG pilot projects, and has just shut down Cougar‟s Kingaroy project due to environmental concerns. This underlines the current policy position to not grant any further tenures, at least until the expert panel‟s findings are actioned. The only exception is a discretion granted to the Minister to approve additional UCG pilot projects where the project has "a strong ability to further demonstrate the efficacy of UCG technology"4. As a result, Liberty will have to obtain Government approval under that exception in order to undertake any UCG component of the project, and may need to focus on using other gas sources as discussed in the models above. Whichever source of gas is used, Liberty will need to obtain the necessary government permits and approvals before undertaking this project. As mentioned above, a project of this scale would be required to undertake an EIS to satisfy the Queensland and Australian governments that the environment is not significantly impacted. Additionally, Liberty will need to obtain land and water use permits and permissions. The recent action in relation to Cougar‟s project outlines the importance of adequately addressing environmental and community concerns. In addition, the regulatory arena governing petroleum, gas, and mining projects in Queensland is changing, mostly in response to issues arising in relation to coal seam gas projects. Should the Government require additional assessments or permits, extra costs or delays could impact upon the project. Liberty Resources would need to ensure they attend to all the necessary approvals early in order to meet their targeted production dates. Should Liberty decide to undertake the project in another jurisdiction where it holds coal interests (eg South Australia or Canada), the same environmental and regulatory concerns will need to be addressed.
Extrem riskant nach dem Cougar Fehlschlag. This underlines the current policy position to not grant any further tenures, at least until the expert panel‟s findings are actioned. Es ist unwahrscheinlich, dass die Jungs überhaupt eine Genehmigung bekommen..
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