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
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
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.
Dargues Reef Gold Project RTS Advert December 2015 Continue reading