This is a pro-regulation blog. We are not anti-mining. This is not an anti-Mandalay Resources blog.

Tuesday 3 March 2015

Submission of Objection to G-MW 13/02/12



Gilbert Cochrane
xxxxxxxxxxxx
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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