The amendments which are proposed, and are related to research matters, which should further be granted by concession through public bid, in spite of a good intention of the proposer for transparency in granting concessions for detailed geological researches, in MAR consider that will provoke bad consequences.

The Managing Board of the Macedonian Mining Association – MAR within the Economic Chamber of Macedonia, on its session held on November 20th, 2007 discussed about the current problems connected with the mineral resources regulations, and especially about the amendments of the Law on Mineral Resources (Official Gazette of RM No.24 dated March,2007). The MAR`s MB has brought the following conclusions:

1. The Law on Mineral Resources, adopted in March, 2007 isn’t   implemented in practice yet, therefore its defects can not be appraised and there are no conditions created for amendments. Macedonian Mining Association – MAR within the Economic Chamber of Macedonia, are on the position that legal and sub-legal provisions for mineral resources should not be changed in such short period of time, due to the seriousness of the activity in which are included also foreign investors.
2. The amendments which are proposed, and are related  to research matters, which should further be granted by concession through public bid, in spite of a good intention of the proposer for transparency in granting concessions for detailed geological researches, we consider that will provoke bad consequences due to the following:
   - Republic of Macedonia doesn’t have complete data and results of the already made general geological researches, which should be the base of a public bid related to detailed geological researches.

• We consider that a new problem will arise in granting concessions for exploitation of the already researched fields, granted by public bid, the manner of determining the advantage in granting of concession to a company which have accomplished the detailed research works, as well as the kind of compensation to the company which made detailed geological research work and didn’t get exploitation concession.
• With the text of the new draft-law an issue remains open and very unclear, which will regulate the research of deposits which are already exploited; for zones which are in border area of the concession area of exploitation. In practice, applicable in the world,  its is the obligation of the owner of concession for exploitation to make researches  in order to utilize correctly the mineral resources, as well as to continue  the age of the exploitation of the already existing mine facility.

Due to the indicated reasons, and mostly to improve the text of the draft –proposal for the Law of amendment of the Law on Mineral Resources, with draft-law prepared by the Ministry of Economy, we request urgent meeting with Mr. Zoran Stavrev, Vice –Premier of   the Government of the Republic of Macedonia, in order to present other additional data and information about the problems which will appear if the proposed amendments of the Law will be adopted.