Gilbert Cochrane
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Argyle, 3523
12 February, 2012
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Argyle, 3523
12 February, 2012
To whom it may concern
Dear Sir/Madam
Re: Notice by AGD Operations to amend their existing
licencing volume from 179 million litres (ML) per annum to 350 million litres (ML) for
the purpose of mine dewatering on land described as Crown Allotment AB3 at 43
Tobin’s lane in the Parish of Heathcote.
Our family property is situated between 2 and 3 km
downstream of this proposed expansion of this destructive development. The
current dewatering program exercised by AGD has already had a detrimental on
the flow of both the Wappentake and the Majors Creeks system; springs in this
system have run dry for the first time since selection in the early 1850s. This
has resulted in us having to cart water and to incur costs associated with
watering our stock for the first time.
These matters have been tabled by myself on numerous
occasions over the last decade of this mine’s existence. At no time have I
received a single acknowledgment of these facts, nor have I received any
reliable evidence that it is not the mine and its attendant dewatering process
that has caused this situation. There has been much denial of responsibility
for this scenario, but nothing in the way of empirical evidence to support
AGD’s contentions.
AGD’s URS hydrological representatives claimed drought as
the reason for our dry springs; however there have been many severe droughts recorded
in this area over many years and no drying up of springs has ever previously
occurred. And let us consider this ridiculous scenario in any case: that it is
deemed acceptable by a Water Authority to permit the dewatering of the
groundwater of an admittedly drought-stricken area – an area whose natural
springs have dried up forcing the local primary producers to cart water for the
survival of their stock – so that said groundwater can be sprayed on dust and
evaporated. Is this not an adequate definition of contempt? Contempt for the
generations of farmers who have endeavoured to remain viable producers despite the
often adverse conditions with which this land confronts them.
It is essential that empirical knowledge of the area be
gained before anyone – not just AGD – be permitted to proceed with further
potentially damaging dewatering activities in the area. This is common sense.
AGD is still to complete a proposed report into the effects
of dewatering on neighbouring properties. I was an active member of the
Costerfield Environmental Review Committee from its inception until 2012, as
well as a concerned landowner, and yet am still to be able to view this report.
And yet still the dewatering continues. There can be no doubt that for the
well-being of the area this report does need to be at least completed before
any consideration is given to allow AGD – or anybody else – to relieve the area
of any further water. Surely, its completion should have been required before
the mining operation commenced. That this has not been required is merely
evidence of the report’s status as a rubber stamp that was mooted nearly a decade
ago. Worse than that, for the rubber stamping has meant that submission of the
report itself is irrelevant. More insult to the citizens of Costerfield who
have foolishly come to expect that due process and natural justice will prevail
in instances in which their interests are threatened.
And it is not as if AGD is being completely transparent
regarding the volume of water that their operation wastes. According to a
previous report prepared by URS the “volume of groundwater pumped from/for the
development of the mine (Dust Suppression Act) is not included in the table
depicting dewatering volumes” (Costerfield
Minesite Hydrological Review August 2006-07, Table 2: Dewatering Volumes). I have requested the figures that
enumerate this additional allotment many times since 2006; they have not been
made available. Why the secrecy/obfuscation? Has this discrepancy been included
in the proposed increased dewatering volumes recently announced? The gun jets I
have witnessed in use to suppress dust can deliver significant amounts of water
very rapidly. How much is AGD paying for this water?
The proposed further development also lies in close
proximity to a system of five creeks. How can it be doubted that an increased
dewatering program will further limit the amount of water entering the aquifers
in the region and that this will further affect the existing flows to the
Wappentake and Majors Creeks system?
What of the effect of the cone of depression? The Company
Work Plan in your possession reports that following investigations by URS the cone
of depression would extend to a radius of 2 kilometres; this calculation was
based on a mine depth not exceeding 100m; the mine has now exceeded 160m. What
is the current radius of the cone of depression? Does it extend to our
property? There can be no doubt that as the mine depth increases the cone of
depression will extend even further. It is only a matter of time before its
effect on our property is manifest rather than pending. Please note this for
your future reference.
This increase in depth will also require an increase in the
amount of water to be removed. The Workplan indicates that water inflow at the
mine’s 2004 depth of 60m was 1.5 litres per second (l/s). In 2012, at a mine
depth of 160m, the inflow will increase to 8.5 l/s and will continue to
increase correspondingly as the mine is deepened further to the proposed to 250
metres (AGD Variation Plan to DPI 2011).
Yet another major concern for local residents and producers
is that the area’s aquifers will lose their porosity and, once pumping ceases,
never fully recover. This is an outcome that has already been observed in
Australia and the United States (Ground
Water Issues Chapter 8). Goulburn-Murray Water’s own literature supports
such a conclusion. Importantly, this same G-MW literature is also supportive of
the concept of the aquifers’ affiliation with the creek systems.
In a wonderfully disingenuous application of scientific
ignorance, URS, despite empirical evidence to the contrary, originally stated
that it was ‘probable’ that the alluvial and basement aquifers were not connected. Then in 2006, URS stated
that there may indeed be a hydrological connection (URS Report 2006-07). As events have shown (the previously stated
drying up of springs) this is undoubtedly true. Where does the water come from
otherwise? Given the lack of downstream monitoring bores and the dearth of
scientific evidence regarding the effects of dewatering on the surrounding
properties, it would seem to be, at the very least, irresponsible to permit an
increase in the volume allowed to be pumped and evaporated from the area, thus potentially
exacerbating the numerous existing problems associated with dewatering
(photographic evidence of spills; destruction of roads; noise pollution: these
matters have all been raised before).
That no one has listened to us is an insult. And it is
certainly insulting, too, to the many residents of the area who have struggled
to maintain responsible use of Australia’s most precious and scarce resource, that
they must now watch it evaporate – purposelessly and in ever-increasing amounts
– before their very eyes.
Perhaps GMW should take into consideration the return of
this water to the environment. There are now many processes, are there not, by
which contaminated water can be made acceptable – near-potable – in order to
achieve this objective. It is my contention, and that of many others to whom I
have spoken, that if mining companies are not prepared to leave the environment
as close to its original state as possible, then such companies should not be
permitted to operate. Mining is a ‘one-off’ endeavour. If the miners get it
wrong the first time, there are no subsequent opportunities for them to get it
right next time.
(During 2011 the mine was granted permission to cart
millions of litres of water to the non-operating open-cut mine adjacent to
Victoria Hill Rd Heathcote; a distance if approximately 15 km. I suggested at
an ERC Meeting that the water be released into the Brunswick Pit (open cut mine
at Costerfield in close proximity to the present mine). I was informed by an
EPA representative at that meeting that the water in the Heathcote Mine would
‘better dilute the toxins in the water’ (!). I considered the answer to be
puzzling in the least, as the water in the Brunswick Pit would have been of
similar chemical composition to the carted water. I then put forward the
proposal that the water would be recycled. Silence was the loud reply.
This can only serve to further verify the hydrological
interaction that takes place in the area.)
Dewatering is currently already
taking the amenity of water from our property and from the properties of others
in the area, and this problem does not need to be exacerbated by further
removal.
It is truly bewildering that it is possible – in the present
climate of environmental concern – that a WATER authority could issue an
increased dewatering allocation to anyone, let alone to a mining company for the
sole purpose of evaporation. There will soon be no water in the area for the Authority to hold sway over.
Before concluding this submission I wish to pose the
following summarising questions:
1
The mine is now reported to be owned and
operated by Mandalay Resources. Why is the application listed in The McIvor Times of February 1, 2012, p. 5 as “Notice of
Intention to apply for a licence to take used ground water and operate works”
in the name of AGD Operations?
2
Why would AGD find it necessary to hold such a
licence if it were granted, rather than Mandalay Resources?
3
Would such a licence be transferrable to, say,
another company should AGD strike hard times? Let us speculate and say,
hypothetically of course, to Mandalay Resources?
4
Why is there a discrepancy between the current
allotment of water and the water actually used? Is the water used for dust
suppression, which AGD need not register, somehow qualitatively different to
that water for which AGD must account?
5
How much per litre is the company paying for
usage of water currently, and how much will they pay if the proposed increase
in dewatering is permitted?
6
What amount of money represents the current mine
rehabilitation bond?
7
Who has contributed the money to this bond, AGD
or Mandalay Resources?
8
Does the bond provide any compensation for the
destruction of the alluvial and basement aquifers in the area (i.e., destruction
of the porosity of the aquifer) should that occur?
9
Who is responsible for any rehabilitation if AGD
holds the licence and Mandalay is the owner?
10
Have the mine’s water usage allocations been
taken into calculation in the Murray Darling Basin proposals (Environmental
flows - WIN News 6/2/2012 )?
11
If it has not, why not? Surely these numbers
would form a significant part of environmental flows in the Murray-Darling
Basin discussed on that program.
We, the Cochrane family, and many members of the Costerfield
community, would appreciate direct answers to these questions.
Please do not add to our current problems by granting AGD permission
to increase their dewatering allocation from 179Ml to 350Ml per annum.
Yours Sincerely
Gilbert Cochrane
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