The declaration said the council gave "landowner approval" for Santana’s proposed goldmining activities on land occupied by council-owned roads. "CODC’s putative decision to give ‘approval’ on a secret basis, without prior consultation or public discussion, may be illegal," he wrote. It is presumed Mr Kelly signed the declaration on behalf of the district council, but it is not known. Mr Taylor advised in his letter that Mr Kelly should retract the declaration by way of a notice to the EPA’s fast-track panel convener Jane Borthwick. Mr Kelly was asked to comment on EDS’ letter but did not.
