OIAD 5650 Response Keith.pdf

Suze Keith
Whare Kaupapa Atawhai
Conservation House

18-32 Manners Street,
fyi-request-32312-
PO Box 10420,
[email address]
Wellington 6011

doc.govt.nz

25 November 2025

Ref: OIAD-5650



Tēnā koe Suze
Thank you for your request to the Department of Conservation (DOC), received on 15
September 2025, in which you asked for:
1. I would like all correspondence, reports, documents, meeting minutes, file
notes, etc, you have on record regarding the proposal to develop 4 open cast
mines, underground mine, industrial cyanide processing plant, permanent waste
tailings dam, engineered land forms and miners caravan park in the Bendigo
Ophir - Dunstan Mountains area by Matakanui Gold / Santana Minerals.
Regardless of whether they are associated with fast track consenting or any other
process.
2. From August 25, 2025 until present day.
We have considered your request under the Official Information Act 1982 (the OIA).
On 13 October 2025, we extended the timeframe for responding to your request to 25
November 2025, due to the substantial volume of information sought and the time required to
compile a response.
During the pre-application phase, Santana Minerals submitted materials to DOC for
assessment. This information was provided under an obligation of confidence. Both the reports
and DOC’s feedback on these reports contain technical and sensitive information related to the
Fast-track consenting process.
To maintain transparency while protecting the integrity of the process, DOC has either provided
descriptions or summaries of these documents under section 16(1)(e) of the OIA or withheld
them in full where necessary. This approach ensures official information is released while
preserving Santana Minerals’ ability to lodge its application without prejudice.
Santana Minerals lodged its Fast-track application on 3 November 2025. The Environmental
Protection Authority (EPA) is currently assessing the application for completeness. Once initial
checks are complete, the application wil  be published, a process that typically takes one to
three weeks. Until the formal application is publicly available, any reports provided by Santana

Minerals to DOC remain commercially sensitive. Therefore, withholding or summarising this
information is stil  required where referenced.
As advised, we have provided descriptions of some reports submitted by Santana Minerals, as
they remain commercially sensitive and were provided under an obligation of confidence.
However, the full reports are withheld under section 18(d) of the OIA, as the information
requested is or wil  soon be publicly available when the EPA publish the application.
-  Appendix A lists the documents withheld in full, along with the relevant grounds for
withholding.
-  Appendix B contains summary information for documents too sensitive to release in full at
present, pursuant to section 16(1)(e) of the OIA, as well as withholding grounds for which a
summary has been provided.
-  Appendix C includes correspondence and any remaining documentation within the
requested period. Where applicable, email attachments are provided beneath the relevant
email chain unless they are addressed elsewhere, withheld in full, or have been provided
and declined in previous requests.
I have decided to release the relevant parts of the documents listed above, subject to
information being withheld under one or more of the following sections of the OIA, as applicable:
•  personal information, under section 9(2)(a) – to protect the privacy of natural persons,
including deceased people,
•  commercially sensitive information, under section 9(2)(b)(i ) – to protect the commercial
position of the person who supplied the information, or who is the subject of the
information,
•  information provided in confidence, under section 9(2)(ba)(i) – to protect information
where release would prejudice the ongoing supply of similar information.
•  free and frank expression under section 9(2)(g)(i) – to maintain the effective conduct of
public affairs,
•  advice subject to legal privilege, under section 9(2)(h) - to maintain legal professional
privilege,
•  improper gain or advantage, under section 9(2)(k) – to prevent the disclosure or use of
official information for improper gain or improper advantage.
In addition, some information has been removed and marked as ‘Not in scope’ because it is either
administrative in nature or falls outside the scope of your request.
In making my decision, I have considered the public interest considerations in section 9(1) of the
OIA and determined there are no public interests that outweigh the grounds for withholding.
You are entitled to seek an investigation and review of my decision by writing to an
Ombudsman as provided by section 28(3) of the OIA.
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Please note that this letter (with your personal details removed) and attached documents may
be published on DOC’s website.

Nāku noa, nā

Lynn Hansberry
Acting Director Regulatory Systems Performance
Department of Conservation
Te Papa Atawhai

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Appendix A

Documents withheld in full
Document description
Withholding grounds
Draft DOC Concession and Conditions for Access Route to CIT Battery
9(2)(b)(i ), 9(2)(h), 9(2)(j)
(5 Sept 2025).docx

Draft DOC Concession and Conditions for Ardgour Rise (5 Sept
9(2)(b)(i ), 9(2)(h), 9(2)(j)
2025).docx

Draft DOC Concession and Conditions for SH8 and Ardgour Road
9(2)(b)(i ), 9(2)(h), 9(2)(j)
Intersection (5 Sept 2025).docx;

Draft DOC Concession and Conditions for Willow Clearance (5 Sept
9(2)(b)(i ), 9(2)(h), 9(2)(j)
2025).docx;

Critique of the Habitat NZ invertebrate report. W. Chinn..docx
9(2)(b)(i ), 9(2)(g)(i),
Part H - Working Draft Rules Assessment for RMA Approvals (29 August
9(2)(b)(i )
2025) - for DOC.docx
Section 4 - BOGP Working Draft Substantive Application Report -
9(2)(b)(i )
Approvals Sought (29 August 2025) - for DOC.docx
Email to Environmental Solicitor, dated 29 August 2025, 2:56PM
9(2)(h)
FW: Bendigo-Ophir Gold Project - fast track pre-lodgement consultation
Email attachment of further email correspondence from in-house solicitor,  9(2)(h)
Malcolm Lucas, to DOC staff, dated 8 September 2025.
‘RE: Section 78 conditions – next steps’
Feedback on the Vegetation Values Assessment:
9(2)(b)(i ), 9(2)(ba)(i), 9(2)(g)(i)
BOGP_preapp_vegetation_advice_2025090.docx - 4 Sept 2025

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Appendix C

Document schedule
Item  Date
Document description
Decision
1
24 August to 15  Email correspondence
Released in part
September
2025
2
9 June 2025
DOC Response Santana Minerals Ltd 09062025
In full
3
August 2025
Memo - Economic impacts of BOGP updated for
In full
June 2025 Pre-Feasibility Study
4
1 September
R239296_Map1_Topo_PCL
In full
2022

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