Dargues Reef Gold Mine, Modification 3: Impacts on Species

To whom this concerns,

I wish to provide information and commentary in support of the Department of Environment’s current assessment of the possible impacts of the Dargues Gold Mine: Modification 3 on threatened species.

-I welcome this assessment and consider it of utmost importance in arriving at the right determination on this modification. If the priority of the Department’s Assessment is indeed the welfare of threatened species potentially or inevitably harmed by the mine in its expanded form, then the Department can and should exercise its authority of refusal in this case.

-An assessment of the mine’s impact on threatened species should be of the finest grade and most comprehensive in scope, as it deals with the most sensitive living aspect of the receiving environment. It is impossible to properly assess the known and potential harm to threatened species by taking the project at face value (as it appears in the Environmental Assessment and other Proponent-funded reports), to assume that the mine will function as promised, or by focusing exclusively on the project site & immediate surrounds. I have therefore not limited this letter to those parameters.

-It is useful to view threatened species as the ‘canary in the mine’ whose wellbeing foreshadows that of the rest of the Palerang- Eurobodalla ecosystems, including its more common inhabitants, humans. Conversely, what threatens us or any common mammal, is a more immediate or even existential threat those most vulnerable – the endangered species. All human and environmental impacts of the Dargues Gold Mine are implicitly relevant to the fate of threatened species. I have therefore not limited this letter to focus on the ‘canary’ – who in any event will be the first to go. Continue reading


Dargues Gold Mine, Modification 3 as Amended: Comments on Revised Statement of Commitments

1. The Revised Statement of Commitments Does Not Honour the Land and Environment Court Order

In the minutes for the previous CCC meeting (15/12/2015), Unity claims that ‘all commitments made as part of the Land And Environment Court Action (Feb, 2012) have been retained’ in the Revised Statement of Commitments associated with Modification 3 in its second iteration. This claim is also found in the RTS, which states that the SOCs have been amended to ‘identify and retain commitments that were associated with the […] Court action,’ (section 2.5.3, p. 13).

The Statement of Commitments (SOCs), to which the Court explicitly bound the Proponent on February 7, 2012, has been slashed to pieces. Most of that 32-page document has been struck through (RTS, appendix 2). A few of the surviving lines, coloured in green, purport to represent those commitments made as part of the Land and Environment Court Action. But these are only the additional commitments made or imposed during the proceedings. The entire Statement of Commitments, including those struck through, was enforced by the Department of Planning in 2010, and reinforced by the Land and Environment Court Order of 2012. Indeed, these were a cornerstone of the court action: Continue reading


The Deua River, New South Wales, Australia

Deua River, New South Wales, Australia

Deua River, New South Wales, Australia (1)

Deua River, New South Wales, Australia (2)

Deua River, New South Wales, Australia (3)

Deua River, New South Wales, Australia (6)

Deua River, New South Wales, Australia (4)

Deua River, New South Wales, Australia (7)

Deua River, New South Wales, Australia (5)

Deua River, New South Wales, Australia (8)

Protect this river from mining development: submit your objection to the Dargues Reef Gold Mine: ‘Modification 3’ before midnight on December 18, 2015.


Letter to Fairfax Media: Dargues Gold Mine Public Submissions Now Open

Further to my previous email, re: Imminent development of the Dargues Gold Mine in the Eurobodalla Shire’s drinking water catchment and national park watershed.

Public submissions are now open regarding Unity Mining’s ‘Modification 3’ on the NSW Department of Planning website. A narrow window has been offered for businesses, organisations, government agencies and the general public to object or consent to the remaining clauses of Modification 3 (with the intention to process ore on-site using cyanide removed). Submissions close December 18, 2015.

This Modification still contains consequential changes to the original mining approval. These include increasing the mine’s total ore processing by 33% (1.2 to 1.6 million tonnes), extending the operational life of the mine by over six years (August 31, 2018 to December 31, 2024), countless ‘minor’ adjustments to previously imposed commitments, and other changes.

The Department of Planning’s advertisement for public submissions is attached. Strangely, it omits a direct link to the submission page for this project. Please feature the government notice prominently, along with this link, in the online versions of the Bay Post / Moruya examiner and all other South Coast regional online publications.

This project will impact the health of the entire Eurobodalla Shire – its water, landscape, wildlife, people and livelihoods, to as-yet unknowable degrees. Everyone should be presented with this opportunity to voice their thoughts on official forum, and have them considered by the Department of Planning and the Proponent (Big Island Mining, owned by Unity Mining). Please publish the above without delay, as the the public only have a very limited time to respond. Again, the deadline is December 18, and there is much to read.

Thank you,

Tom Wells

Dargues Reef Gold Project RTS Advert December 2015 Continue reading


Letter to Fairfax Regional Media: Dargues Reef Gold Mine Coverage

Earlier this year, the Bay Post/Moruya Examiner covered the controversy around Unity Mining’s proposal to process gold ore concentrate on-site (at the Dargues Reef mine near Major’s Creek) using cyanide. Since the plans for on-site processing were canned on September 8 2015, Regional Fairfax media have fallen silent on the Dargues Mine. But cyanide was just the tip of the iceberg.

According to their Shareholder Report of 28/10/2015, Unity Mining still intends to proceed with the mine itself, along with all the other clauses of ‘Modification 3’. This includes an, open-air Tailings Storage Facility with the capacity to suspend 900,000 tonnes of mining refuse, containing enriched levels of antimony, boron, molybdenum, and silver in the Deua River / Moruya River catchment.

I have checked the TSF concentrations of these elements against Australian drinking water standards:

Antimony: 1,266.6 times maximum drinking water threshold
Boron: 12.5 times maximum threshold
Silver: 4.5 times maximum threshold
Molybdenum: 560 times maximum threshold

The potential health affects of these elements are summarised in the Australian Drinking Water Guidelines. They range from cancer to reproductive harm. For example, antimony has been linked with ‘spontaneous abortion’. But I won’t spoil it all for you. Various other affects, major and minor, probable and possible, are documented in the Guidelines.

The time it would take for these elements to be ‘mobilised’ into the environment from the structure of the minerals in which they are bound, at what rate, and in what concentration, are questions to which no precise answers exist. However, we do know that the TSF liner (itself made of tailings) is ultimately permeable, as shown in Unity’s own Environmental Assessment (p. 64). And – like all material things – degradable.

To the best of my understanding, it is inevitable that these elements will eventually seep into the groundwater as the TSF liner leaks and degrades, and as the structure of the tailings minerals decay such that their constituent elements are mobilised. It may be future generations whose health is affected by the slow, steady release of contaminants into the water table. This of course assumes that the mine functions exactly as promised and that no unscripted spillages or overtoppings occur.

It must also be made common knowledge that the engineering company contracted by Unity Mining, Knight Piesold, were the original engineers for the Canadian Mt Polley Tailings Storage Facility (TSF), which failed catastrophically on August 4, 2014. Some 25 million tonnes of heavy-metal laden mine tailings mixed with stormwater gushed into the Quesnel & Fraser river systems, poisoning the water supply to entire towns, ending tourism and depressing property value and contaminating marine and mammal habitats and food chains.

Knight Piesold is now responsible for the engineering of the Dargues Reef Gold Mine’s TSF, upon whose integrity some 60% of the Eurobodalla’s water supply will depend, along with property value within the Shire, the local tourism industry, agriculture in the Araluen and Deua River Valleys, and the ecosystem of the Deua National Park and beyond.

The Report on Mt Polley Tailings Storage Facility Breach is the definitive scientific investigation into the the causes of the Canadian disaster. Although it was not mandated to name the companies liable, It identifies the original design of the Tailings Storage Facility to be the root cause of the breach. This Review of the above report by the Centre for Science in Public Participation (‘CSP2‘) names the companies found responsible (Knight Piesold and the mine owner/operators, Imperial Metals), as do countless Canadian news articles.

I am a Deua River / Moruya resident who returned to the South Coast this year after working in Canada as a river guide (whitewater rafting). I was in British Columbia at the time of the Mt Polley spill and was in fact floating down an affected river (the Fraser) at the time. I can attest to the effects of that spill and the probable consequences of a similar incident here, i.e. permanent disfigurement to the environment and economy of the region. I can source any of the information given in this email, and am willing to provide more information and/or interview with one of your reporters (I believe it was Carmen McIntosh who covered the issue previously).

This concerns our most fundamental resource, fresh water, and I am aware of no more pressing issue to the region. Please give this due coverage and re-open the debate over the mine’s approval and existence.

Thank you,

Tom Wells

Submitted to Fairfax Media 12/11/2015 (edited for this post)


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