Mod 3 - Processing & Tailings Storage

See attached

See attached

I've attached my pdf submission.

My submission is identified in the attached file.

Charles Stanger

I am submitting my objection to the above application for Modification. Please see Attachment below

Submission uploaded

Dargues Reef Project Application 10 0054 MOD 3
My name is Jackie French. My property is approx. 4 km downstream on Major's Creek from the Dargues Project, and was repeatedly polluted by emissions from the Project for much of the six months that Unity operated there in 2013. Except during that period in 2013 our household uses the creek water domestically, for stock use, and, irregularly, for irrigation. We hold a water license.
The Dargues Project is approx. 300 metres above us on the steep escarpment, which means that any water borne emissions from the Project reach us in ten minutes at times of high, but not necessarily extreme, rainfall.
I am 2015 Senior Australian of the Year; 2015 NSW Senior Australian of the Year; the 2014-2015 Australian Children's Laureate, representing Australian publishing in Australia and internationally; patron of organisations across Australia promoting literacy and children's welfare, including Marymead's Books for Kids, ACT SPELD; QLD SPELD; DAGS (a SA dyslexia programme); Monkey Baa Theatre for Young People and the NSW YESS programme; ACT Children's week Ambassador; Director of the Wombat Foundation; author, with books translated into more than 32 languages and which earn in excess of $3 million per annum for the NSW economy from one publishing company alone (HarperCollins will make a submission on the economic value of my work, both as a writer and an advocate). The books and have won over 60 awards in Australia and internationally as well as appearing on the New York Times Best seller list. Several have been adapted for the stage, TV and radio broadcasts, and tour internationally.
I directly employ eight staff, but the flow on effect of my work employs many hundreds, including actors, directors, musical composers, choreographers, set designers, editors, books designers, booksellers and more. I write an average of six books a year, usually one substantial work as well as smaller works for children, except during the six months of pollution episodes in 2013 and this year, where time- and potentially millions of dollars for NSW - have been wasted responding an error ridden and inadequate proposal by a minor mining company with a local record of repeated broken promises.
More than 50% of my income is given to causes I support, with royalties increasingly contracted directly to those causes. Flood, with Bruce Whatley, raised over $110,000 in three months for the 2011 QLD Premier's Flood Appeal and still continues to raise money for those affected by natural disasters. My recent projects have been speaking on literacy in isolated regional areas across Australia. Most of these, like Kalgoorlie, Coolgardie and Port Headland, are mining based communities where I admire and respect the many mining companys' work, enterprise and community engagement. The current project is personally funding the inaugural "1,000 Magic Books Project", where a list of books is given for children in need or who have literacy problems, so they can select a book that we will give them to tempt them to read more complex works.
My husband and I run an orchard, with over 800 fruit trees, experimenting with 272 species and varieties of fruit and breeding cold-tolerant varieties of some subtropical and tropical fruits. I am also a gardening writer; award winning historian; and have worked on many published studies of the area's ecology in the past forty years, including work on the common wombat, local macropods, the habitat range of Eucalyptus kartzoffiana; monitor lizards; seasonal variations in the echidna diet, and many others. Unity Mining's representatives and those closely financially associated with the company are the only people who have ever queried my integrity, truthfulness, and my knowledge of this area.
In 2013 much of our property was donated to become the Neverbreak Hills Voluntary Conservation Area and was extensively surveyed by the NSW Department of Environment in 2012 and 2013. These studies corroborated the pristine value of both this Conservation Area and the adjacent Major's Creek Conservation Area directly below the Dargues site, as well as the existence of the endangered species and forest types listed in the points below.
Both Conservation Areas share species and ecological values, as one of NSW's major bird and animal migration corridors as well as being home to at least 23 endangered, critically endangered or vulnerable species.
It should not need stating that I am not anti mining; that I value my long and continued work with mining companies, and that it took a considerable number of broken promises from Cortona/Unity to change my attitude from one of support for the Dargues Project to attempting to improve the Conditions of Approval, to then, vainly, to have all those Conditions of Approval kept by the company.

Major Reasons for Objections
1.The design of the Tailings Dam Facility, bunded areas, and other construction work for this Modification is based on false figures for the Braidwood rainfall, including reducing the estimated rainfall by 36% or overestimating it at other times by 70% according to BOM figures published on their web site.
BOM figures also show that rainfall at Major's Creek is roughly 30% higher than at the Braidwood weather station. As Dargues is at Major's Creek, and as the Major's Creek figures are accurate and available, there can be no reason to refer to the Braidwood figures unless it is because Braidwood's lower rainfall would thus reduce the size, risk potential and cost of the designs in this Modification.
The EA also overstates monthly evaporation data at the Braidwood station by between 23% and 158%. The annual evaporation quoted in the EA is 1615mm. The BOM figure is 1003 mm. This is an overstatement of 61%.
Major's Creek, however, is frequently fog covered, unlike Braidwood. These fogs can occur at any time of year and may remain for three days. Major's Creek evaporation would thus be far lower than Braidwood's.
These errors are of such major significance that the entire project design is invalidated, from the size of the tailings dam to bunded areas and safety precautions.
I submit that the Modification be rejected and the project redesigned according to the accurate data provided by the BOM.
I further submit that the origin of the inaccurate EA data should be investigated.
In addition, the Australian public has been asked to comment on false data during the Exhibition period.
The Department of Planning has a duty of care. It may be reasonable to put EA with insufficient detail on public exhibition if the proponent demands it. Publishing inaccurate data of this significance for the Project design however needs an immediate and public retraction.
It also arguably invalidates submissions prepared on the basis of this data.
I request that, unless the Department feels that the magnitude of errors that support the project design in the EA deserves and immediate refusal of the Modification, that a further six weeks be given for public consultation, with the correct rainfall and evaporation figures included in advertisements in local papers, so that the public, independent experts and government authorities may assess the project using accurate data.

2. False and unsubstantiated figures for dilution rates after pollution discharges on site, caused by the refusal the company to take appropriate downstream samples in the major's Creek and Neverbreak Hills Conservation areas during the 2013 pollution events. Samples however were taken, as were expert evaluations, proving that in medium rainfall events, i.e. February 2013, pollution levels after the event can be higher in the creek bed 4 km downstream than they were at any stage below the site, as the pollution `settles out' as the land flattens, and becomes contained in drifts and fill the often vast pools of the Major's Creek Conservation area.
3. The EA claim of negligible risk to human life ignores the speed of sediment flow along Major's Creek and down the 300 metre escarpment during the 2013 discharges.
Measurements from the February 2013 Dargues Pollution event proves that cyanide or heavy metal pollution can reach our property within ten minutes, well within the period when cyanide may be lethal and undiluted by rainfall.
4. The lack of any practical means to contact nearby residents in case of catastrophic failure. This area has no mobile phone reception and our house, workshops, garden and orchard are next to the creek, where our grandchildren and other children swim. This Modification is thus a major risk to our lives, and the lives of family, friends and the over 1,000 visitors each year who attended workshops here.
5. Lack of sufficient data for expert evaluation. Expert independent reports such as those by Dr Peter Beck and others repeat the same observation: that the data in the EA is at times either absent or too sketchy to be able to draw valid conclusions. The company appears to believe it is acceptable to exclude even plans for air quality until after the submission has been approved.
6. The existence of conservatively several hundred tonnes of sediment from the 2013 Dargues pollution events still remaining on our property after two years in dunes along the creek and in the deep pools of the Major's Creek Conservation Area. This `larder of pollutants' means that if the next pollution down Major's Creek from Dargues is contaminated by heavy metal residues then it too may collect here. Eurobodalla's water supply would thus be at risk in high rainfall periods even when there no pollution is being emitted from the Dargues site.
7. The failure to assess any of the high conservation values directly below the site in both the Major's Creek Conservation Area and the Neverbreak Hills Voluntary Conservation, despite this being a Condition of Approval both prior to and during construction, and despite repeated requests for the company to do these surveys. Instead, Unity repeatedly describes of the land below their site as `degraded farmland'.
8. Five pollution events in the six months the company operated at Dargues; as well as structural collapses witnessed during on site CCC meetings, of which I am a member (Unity now denies any structural collapses).
9. Refusal to comply with all of the Conditions of Approval by the Land and Environment Court. PAC and Federal authorities, as well as claiming that the company has no duty to do so, but only to abide by the Department of Planning Management Plans, which the Department recently stated are merely part of the whole duty Compliance, and do not supersede the Conditions of Approval.
10. Repeated expressed contempt for regulatory authorities such as the EPA, and failure to follow their directives, including Unity's refusal in August 2013 to urgently contact downstream water users after the illegal use of an unregistered flocculent for more than two months. (Unity now claims the EPA did not contact them about this issue; however my phone call to the Unity Hotline the next day refutes that, as do records of ABC interviews by the EPA and the Company at the time, and articles and advertisements in the Braidwood Times.)
11. The repeated initial denial by the company of their responsibility for four of the five 2013 pollution events, and their subsequent admission and plea of `guilty' during their prosecution. According to the judge's report, this admission greatly reduced the fine which amounted to approx. $206,000 with costs.
12. The failure of the PAC process to protect the community from pollution, due to the inaccurate data provided to them and the public by the company, and the company's subsequent failures of Compliance.

Further and more detailed Objections

1. The EA states that the design of this project is based on Braidwood rainfall and evaporation figures. Braidwood rainfall is however approx. 30% lower that at the Dargues site at Major's Creek and the evaporation rate would be higher.
However according to the report by Dr O'Loughlin, the EA even uses incorrect figures for the Braidwood rainfall including reducing the estimated rainfall by 36% or overestimating it by 70% according to BOM figures published on their web site. BOM figures also show that rainfall at Major's Creek is roughly 30% higher than at the Braidwood weather station. The EA also overstates monthly evaporation data at the Braidwood station by between 23% and 158%. The annual evaporation quoted in the EA is 1615mm. The BOM figure is 1003 mm. This is an overstatement of 61%.
The extent of these discrepancies means that the entire design is invalidated. As Dr O'Loughlin states, this is an EA for an arid area project, not one subject to coastal flooding, fog, snow and hail.
The EA also excludes the irregular, highly localized extreme weather events the Dargues site is subject to. Monthly rainfall figures may be misleading if over 1000mls falls in a single day, with no rain falling on other days that month. Major rainfall events based on thunderstorms also frequently spill large amounts of water in a short time, but due to the dry compacted soil almost 100% of the water runs off. Rainfall of 50 mls would normally soak into the soil at Major's Creek, but in a drought, almost the entire amount may run over the slopes and into the creeks, causing a flash flood, leaving the land dry the next day.
Major's Creek's often low evaporation rate may also mean that the soil stays sodden for long periods even in years of average rainfall, , and on steep sites, such as Dargues, slumpages regularly occur after days of rainfall.
Unity's claims of one in a hundred year flood events do not fit the BOM data, nor the rainfall data collected here from 1974 onwards. The Hyland family's Araluen rainfall records, which I have read, go back to the 1880's.
These errors or falsifications mean that the entire design is based on a major underestimation of the necessary size for the Tailings Dam Facility, Bunded areas and sediment dams, and well as underestimating risks of slumpage, erosion, flash floods that may carry polluted material downstream and other events associated with a far higher rainfall than the EA states.
This error of such major significance that the entire project design is invalidated.
I submit the entire Development Application (DA) rests upon a design of the Tailings Storage Facility based on greatly underestimated rainfall and overestimated evaporation; a lack of any data to support their assessment of the dilution factor 1-12 km downstream to limit fatalities; and the false assumption that residents can - or will- be warned in sufficient time to prevent human casualties or use of polluted irrigation or household in a likely pollution event.
No risk assessment can be made until the tailings dam design has been redone to fit the actual and reliable data.
I submit that the Modification be rejected until such time as accurate data is provided and the project redesigned take that information into account.

I further request that the Minister use his powers to reject this Modification now. Taxpayers' money and Departmental resources should not be spent further evaluating a project with false underpinnings, nor should the local economy continue to suffer the financial uncertainties that followed the announcement of the possible Modification. It has cost the community over $3 million in lost income, fruit trees, investment, property values and much more, as well as community driven to breakdown because of their fear of the consequences of this proposal.
I submit that a company capable of so many errors with such wide implications, should not be regarded as fit to conduct a project with such potentially fatal effects on a steep and vulnerable slope at the top of a major watershed upon which over 100,000 people rely for household, business and irrigation water.

2. Implications of the inaccurate rainfall data
While it would take an engineering firm months to work out what the size and design of the tailings dam and bunded areas and sediment dams should be using the accurate data, it can be assumed that the TSF would need to be significantly larger to cope with the increased run-off, and might need a further Tailings dam below the first one to catch spillage.
It is also possible, given the Environmental Protection Agency's (EPA) request that the TSF be moved to a less vulnerable site (See GIPFO documents in appendix 3), that a TSF of an appropriate size and a secondary dam needed to catch spillage may be too large for the current Dargues Reef site.
This, however, is a subject for Knight Piésold to reassess when they have been provided with the correct rainfall and evaporation data.

3. Further Design Implications of the Inaccurate Falsified Rainfall Figures Used in the Design.
The Tailings Storage Facility (TSF) is only designed to cope with a maximum 1500 mls of rainfall within a 72-hour period. The company states that if there is more rainfall than this, any polluted spillage will be diluted and therefore is negligible so there was no need to study the possible consequences.
Even without the rainfall underestimation error underpinning the entire design, and given the average rainfall data and given the nature of rainfall on the site, where the ridge on which the project sits is frequently subject to heavy rainfall that does not fall downstream - you can on occasion even see the curtain of rain that hangs above the site -¬ this is inadequate in the extreme.
Any adequate design must include an area where any spillage would be contained even when three times that amount can fall in a three-day period. 1250 mm can fall on that site alone, in a twenty-four hour period both as rain and hail, as happened on 1 January, 1983, with further rain falling more than an hour after a flash flood had swept down the dry creek bed. (Note: water was still contained in the State Conservation Area pools and on our property but the water in these pools did not impede nor dilute the flood debris, given the speed and height of the flash flood.)

It is reasonable to assume that the term 1:100 year flood means exactly that - the largest recorded or experienced rain episode in the area in the last hundred years. The company's estimates of the magnitude of possible storm water levels bears no relation to the history of the site. The company has been offered data about extreme events but has refused it, nor does their data cover the implications of the severe summer hail or winter snow fall and snow melt the site is subject to.
507 mls in a 77-hour period can occur five times in a three-week period - as it did in 1947, 1975, 1978 (six times in a three-week period), 1983 and others.
The report states that the spillway discharges will be diluted 10,000 times but gives no detail about how that is to happen. Where is the water to come from to dilute the contaminated water to this extent? It also ignores the danger of buildup in the soil downstream from even minor spillages over a period of years. In dry years Unity will have difficulty even providing compensatory water for that removed from groundwater and Spring and Majors Creeks.
As well as underestimating the regular and irregular rainfall of the site, Unity does not substantiate how their compensatory water dams can supply sufficient water in drought years.

4. Lack of sufficient data for expert evaluation.
This has been repeated in all the independent experts' reports. Given the company's history of poor design and compliance, it cannot be assumed that the designs, plans and data they have failed to put in the report are in any way adequate.


5. There is no model of what could happen in a tailings dam failure.
Instead, the company states there have never been such failures. This is not correct. A tailings dam failure does not need to be a complete failure to have catastrophic effects downstream. Nor has Unity demonstrated its ability to construct a site to common NSW standards in its six months of construction. Instead, in correspondence received under GIPFO, Unity repeatedly states it has the right to use the lowest construction standards of any operation in NSW, using each one as a precedent and expressing repeated contempt for any EPA request for a design that suits the site and the risk level.


6. The vulnerability of tailings taken to the tailings dam by pipe.
What if this pipe is damaged by equipment, earthquake or tremors? The site is on the Majors Creek fault zone. Pipes fail even more often than tailings dams.
While the pipe will be in a bunded area, this bund as currently designed will only contain 110% of the contents of the pipe and so relies on the swift response of staff.
The company has yet to demonstrate that it is capable of this sort of timely and appropriate response at the Dargues Reef site, as it has all too often failed to do so in the past. This design is also vulnerable to the flow on effect of the underestimated rainfall figures. and cannot be evaluated until the actual figures are used.

7. The Potentially Deadly Consequences of the EA's False and Misleading Dilution Figures
The danger to the public from a cyanide or heavy metal-rich spill from the site depends on the level, rate and speed of dilution. Unity states that any cyanide spill will be diluted by the time it reaches the confluence with Araluen Creek or within 24 hours.
Unity Mining, however, has refused, on repeated occasions, to follow the Land and Environment Court's Conditions of Approval and survey Majors Creek from Spring Creek to its confluence with Araluen Creek.
They have also refused to take any samples of polluted water from below the site to twenty kilometres below the site, where the pollution is diluted by Araluen Creek.
Unity's samples are taken below their site, on land that drops steeply to the valley, or twenty km downstream, where the pollution is diluted by Araluen Creek. This mean that Unity have no data for this vital 20 km stretch immediately below their site on which to base their claims of dilution. Luckily data exists, including photographs and expert's assessment.
Once pollution reaches the valley, the speed of the water drops as it reaches more level ground. Heavier material drops out of the stream. This is acerbated by the deep pools in the bedrock that are the only source of water for the more than 23 endangered, critically endangered and vulnerable species (see Appendix) of the Conservation Areas.
Instead of being diluted, the pollution settles in those pools, including the ones where tourists and family and friends swim, and other pools from which we take our household, business and irrigation water. Because of the deep pools in the bedrock - none of which have been surveyed at any stage by Unity despite requests and the provisions of the Conditions of Approval- the pollution can stay in those pools, undiluted, as fresh water flows over the heavier material at the bottom of the pools until a larger flood finally scours them clean, while lighter silt material is captured by the crevices in rocks and smaller, higher pools.
Evidence of the 2013 pollution events can still be seen in those pools, as there has not been a flood large enough to clean them out. But that material at the moment is the relatively benign sediment from the project's preliminary earthworks.
If instead if the material on our property and in the Major's Creek Conservation Area had been contaminated with heavy metals, either from a spill from the tailings dam, from a tear in the lining, from movement along the Majors Creek fault line on which the mine sits, from a break in the pipe carrying contaminated material to the tailings dam, from an overturned truck or from simple human error (which the work on the Dargues Reef site has already been prone to) then the scenarios might catastrophic, in the case of a truck containing cyanide overturning near the Major's Creek bridge in wet weather or when the road is patched with black ice in winter, or difficult to navigate in the areas impenetrable fogs.
A less immediately deadly but sadly probable scenario is a series of small spills containing heavy metals, at a time when the rainfall is not enough to carry the material down past Araluen Creek where greater water flow may dilute it.
This would mean an accretion of heavy metal tainted material, contaminating the water; any land that was irrigated by it; and greatly impacting human health for anyone who used bit or the children who swim in it.
While we can warn family and friends not to swim in the creek, the extent and many access areas where tourists walk down or up the creek, or camp on properties along the creek, not just at the camp site, means that it would not be possible to even signpost them all as dangerous' Do not swim' or `do not drink the water'.

The deliberate and repeated refusal to test pollution levels in the Major's Creek Conservation Area and our property means that Unity have no data about dilution rates.
Luckily the EPA did do such tests, as did we.
These tests show that while the water tested was diluted, in three of the four sediment events the long term pollution residues on the stream bed were far higher on our property than just below the site.
Indeed, the stream that was classified as a ` ... pristine rocky steam bed' by the Dept. of Environment in 2013 when we converted our property to a Voluntary Conservation Refuge is now solid with Dargues Reef silt. This material can still be tested and compared to the Dargues sediment, and was recognised as similar to material seen on site by Dr Beck on his inspection here, immediately after his site inspection of the Dargues site. (Unity now claims that Dr Beck did not do a site inspection of the Dargues site, despite an email exchange copied to CCC members, of whom I am one, arranging this inspection.)
At least 100 tonnes or more of sediment is still sitting in the upper reaches of Major's Creek in the Araluen valley from the 2013 pollution events. This sediment is not stable. It consists of banks of mud, silt and grit along the banks of the creek and filling up to a third the capacity of the deep pool in the two Conservation areas.
If this material were contaminated with heavy metals or cyanide residues they would be a vast reservoir of potential contamination for Eurobodalla's water system. Depending on the force of water it may betaken down river and washed out to season one major event, or, more dangerously, deposited along the riverbed, a series of `pollution time bombs' where it may be impossible to predict when they would reach Eurobodalla
There has been no major rainfall event or flood since the project in 2013, but when the next one hits, this silt will progress down to Deua to Moruya. A similar scenario with material containing heavy metals would mean disaster.

While heavy metal contamination is most likely, even using the inaccurate data in the company's EA, catastrophic events from cyanide cannot be ruled out, given the local road hazards of ice and fog, as Dr Beck's report points out.
Ten minutes or even twenty minutes is not enough time for cyanide to become volatile and cease to be dangerous or deadly to humans and animals. Nor is ten minutes enough time to warn us of an accident above us, even assuming the company would do so. (When the EPA requested that Unity tell downstream users to quarantine all water from Majors Creek in 2013 after the company had used an unregistered flocculent, Unity refused and continues to refuse to do so. In August 2013 the EPA were forced to call downstream water users at night, urgently warning them to stop using all water from the creek and to inform others as soon as possible. The EPA then took out public advertisements in local newspapers for those who had not been informed.)
Unity's track record of admitting errors or accidents is not just poor, but appalling. They have yet to admit that any household, business or area of the local environment, including the fish and frogs Major's Creek is rich in, might have suffered any harm from any of the events of 2013, nor offered any reason why throughout those incidents they refused to test water in the creek or water systems on our property beyond:
. You did not request it (See the appendix recording our many requests, which were followed up by repeated calls to the Unity Hotline, at those times it happened to be manned. I also publicly requested water testing on ABC radio, which eliciting the ` we respect your privacy' response which was followed by an incredulous comment by the presenter, Genevieve Jacobs: `But she is on air asking you to test the water on her property.')
Other reasons for not testing the pollution levels here have included:
. It is not cost effective
.it is not included in the Departmental Management Plans, which supersede Conditions of Approval.
. That is a special case and will not be discussed further
Given that the company crosses Major's Creek on our property, just opposite the house every three months, with our permission, to take water samples from their test bores on our property: and that we have on each pollution event have contacted the company repeatedly by email, phone, in person, at the Community Consultative Committee (CCC) and - as a last resort- on radio, to ask for water samples to be taken; and given that on at least two occasions Unity staff visited here during the sediment pollution events but refused to take samples either of the creek water or the water in our household tanks, is it possible that Unity prefers not to have data on pollution levels and effects in this area?
A risk of catastrophic pollution
Given the ten- twenty minutes needed for pollution from the site, or Major's Creek Road on the way to the site, to travel to our property after a rainfall of 72 mls over three days, there would be a major risk a lethal dose of cyanide or heavy metals in the event of a spillage of toxic material on site, or on the Major's Creek road leading to the site, for anyone on our property, in our house and in the orchard adjacent to the creek.
If we extrapolate Unity's pollution record, that would mean two potentially lethal events a year.
The very severity of this risk makes it difficult to assimilate - that any company could be allowed to propose something so dangerous, with no assessment of the land and water and inhabitants below the site, and where the have repeatedly refused to source the data.
Even small diluted amounts of heavy metal would settle and collect in the deep pools and then, in times of flood when a large part of the Araluen valley is under water which I witnessed in 1974, 1975, six times in January 1983 and in 1988, (although the worst and longest lasting flood was in 1947, when much of the valley was inundated for over three weeks after a freak snowstorm upstream).
Successive releases of small amounts of mercury and copper (as admitted in the EA) would build up in the soil. Unity have not admitted there may be traces of zinc, cadmium, lead and uranium also in the tailings that would otherwise have been trucked away for processing, but Unity's cavalier attitude to data does not inspire confidence.
The EPA has stated that the tailings dam should be moved to a safer site. They have had a long and close experience of the company's attitude to compliance, as well as their refusal to admit to and take responsibility for pollution events or test after them. I urge the Department to heed the advice of the EPA.


8. The Implications of the Potential Concentration of Pollution Immediately Downstream of the Dargues Site
The half-life of cyanide in water may be less than twenty-four days, as the EA states. It is not less than ten to twenty minutes, the time it takes for a flash flood to reach our water system - and that of others in the Majors Creek catchment.
It took only ten minutes in February 2013 for the sediment released in the first pollution event to reach us-I ran down to the creek as soon as Bill Waterhouse's email arrived stating that orange muck was issuing below the Dargues site, and his email was sent just as the sludge became visible. Even if it took him another five minutes to reach his computer, fifteen, twenty or even an hour might still have deadly consequences for our household or those swimming in the creek or playing or working beside it. (Our house and my study sits just above the creek, and my husband`s workshop sits within 20 metres of it.)
The company's report notes that a sixty-fold dilution factor would be needed to ensure that the cyanide-polluted water was remedied to drinking water standard. It is unlikely in the extreme that, given the way storms fall in the area, and the close proximity of houses and businesses that use that Major's Creek water, that a 60 fold dilution would occur before our household and others were affected, as there are no major dilution points downstream until the confluence of Major's Creek with Spring Creek.
Unity has made no study the water flow in the gullies, springs or even the terrain downstream of their site. They cannot in any way substantiate their desktop claim that a 60 fold dilute is possible, much less likely, before many of those below the site are affected.
Dargues Reef sits on Spring Hill, given its name `Spring' for good reason. It is at the end of the Monga Ridge and is subject to not just higher rainfall tallies but is also the site of snow and hail storms as well as thunder storms that the area downstream misses out on. (Araluen's rainfall figures are well below that of Majors Creek's.)
There is every chance a cyanide spill would still be at deadly concentrations by the time it reached out house and environs, north by the creek, or if I or students were in the Majors Creek gorge, where it takes a mere five minutes or less for the pollution to arrive.
There is an even greater likelihood that related small emissions would deposit heavy metals in the pools in Majors Creek, which contains the only water in dry times, and which is also a major corridor for migratory birds and wildlife between the Monga and Deua systems.

9. The True Risk of Cyanide Spillage Downstream to households to the junction with Araluen Creek
The Unity EA states Spring Creek is a small part of the overall Major's Creek Araluen catchment, and so any spillage would be greatly diluted. This is not true.
Spring Creek is the largest tributary until Major's Creek meets Araluen Creek approx. 20 downstream. The households and business on Major's Creek between Spring Creek and Araluen Creek will thus be subject to the full pollution load in the event of a sudden spillage occurring in the wake of a localised heavy rainfall event after a dry period when other creeks are not running. From 1993-2015 this occurred in (very) approximately 18% of rainfall events.

10 The Risk to Eurobodalla Water Users from Accumulated Pollution in the two Conservation Areas
The pollution risk to those downstream is not limited to times when pollution is emitted from the Dargues site.
There is now, conservatively, several hundred tonnes of sediment in the creek on our property and far more deposited in the Major's Creek Conservation Area above us, in sediment dunes at the edge of the creek, and in the formerly deep water holes up in the Major's Creek gorge.
The EPA can confirm that this material originated at the Dargues sites and came down in the pollution events of 2013. Although Unity repeatedly refused to test the pollution levels here or in the approx. 20 km from below their site to the confluence with Spring Creek where it becomes diluted, the EPA did do those tests.
Prior to 2013 this area was surveyed by the Department of Environment as part of the process of turning much of it into a Voluntary Conservation area. The creek was classified as ' a pristine rocky waterway.' No sand or sediment was visible, as 40 years of photos attest.
This sediment is not stable, and in high rainfall events is gradually carried down to Moruya. Much has already been washed down.
It does however show that the pollution levels below the steep Dargues site can be far higher here, where the valley floor levels or material in caught in the large polls, that just below the site.

The present sediment banks and pool deposits from Dargues are only sediment. Once however, material containing heavy metals and cyanide residue was deposited here, it would be a time bomb for Eurobodalla, moving gradually down river.

Relatively small pollution emissions might also collect here, and then suddenly move in dangerous amounts downstream during high rain events.

Unity's refusal to test pollution levels here means they don't have any data for the rate of dilution they rely on in the EA.

More importantly, Eurobodalla's water supply may be at risk during a high rain event even when there is no pollution from the Dargues site, as the (conservatively) hundreds of tonnes or more of previous pollution from previous pollution events becomes mobilised here.

This can all be substantiated:
The origin of the sediment on our property and in the Conservation Area from the Dargues site can be confirmed with the EPA Queanbeyan.
The previous rocky and pristine state of the creek can be confirmed by the NSW Department of Environment assessors report in the VCA agreement.
Copies of emails can substantiate our appeals for water testing and an evaluation of damage done.
The quantity of sediment still remaining after two years can be verified by observation.

11. The neglect to estimate the cumulative effect of a build up of cyanide affected heavy metal pollutants in adjacent soil, water, and deep pools of many small breaches in emissions standards, such as occur at Unity's Henty Plant. There, however, the exceedingly high rainfall usually measured in metres, not millimetres, dilutes it. This is not the case at the Dargues site.


12. Misleading data on contacting downstream users in the event of a spillage or leak or seepage or major breach, and the impossibility of doing so in an area with no or patchy mobile coverage.
In the EA the company claims that it has prepared a list of forty downstream water users, is adding to this number at meetings and has their emergency contact numbers. They also claim that they provide clean water in the event of further water pollution from the Dargues site.
None of these claims is accurate.

The company initially refused repeated requests for a register of downstream users to be established and maintained, on the grounds that there would be no pollution and so it was not necessary. At an angry meeting at Majors Creek the company agreed that those who wished to might give their names and contact details.
The company has made no effort to locate the many other downstream water users.
In four of the five pollution breaches that have already occurred, the company initially either failed or refused to contact downstream users, possibly because at the time the company was denying responsibility for the sediment, or claiming they has authority to pollute the creek as necessary as the project was never designed to be a nil emissions project.
In the fourth incident contact was made by email, and over an hour after the breach occurred. It would not have been read except by those checking their email at the time. In a rural community with no mobile phone coverage and so not ability to receive text messages, many residents check their emails irregularly and infrequently or are not on email at all.
The company has not only failed to provide water to those whose systems have been polluted by sediment from Dargues Reef, but has insisted that it has no duty to do so. This was backed up by the Department of Planning until two months ago.
The company is also liable for reparations if they do not supply clean water in the case of pollution events. They have made no response to claims for reparations. The matter rests with the Department now that they have finally admitted that the provision of clean water, and reparations if it is not supplied, are in the Conditions of Approval for surface as well as groundwater.
Notification: the only (belated) notifications by the company to downstream water users were by email. Few residents in a rural area are likely to be using their email accounts when a pollution event occurs. There is no mobile phone coverage for much of the area, and none at all for the area twenty kilometres downstream where the worst of the effects will be felt.
Even in the unlikely event that the company does change its behavior and responses and decides to contact downstream users if there is a pollution event, or becomes aware of it before it reaches residents up to six kilometres downstream, polluted material can reach to four kilometres downstream in only ten minutes at above average rainfall (e.g. 72 mls in a three-day period).
Our house sits next to the creek, as does my husband's workshop. Our employees work in the orchards by the creek. My grandchildren play in the creek - although this will not be possible if this Modification is passed.
If it took an optimistic five minutes for the record of downstream users to be located, that would leave them only five minutes to respond to a warning, even if there was any way that warning could be delivered to us if we are beyond the sound of the landline or not on email, five, or even ten, minutes is not enough time to get to safety, given the steep and narrow terrain of our property and the Majors Creek State Conservation Area where I frequently track and study animals and plants.
Given company's record, and the likelihood of an accident is almost 1005
By the company's own admission, there will be further pollution events and this, combined with the company's record of behavior in previous events and the near impossibility of timely notification of downstream water users, makes the chances of responsible management and response to an accidental release of contaminated water negligible. The company has refused to give the EPA their list of downstream water users so even the EPA may not be able to contact at least those further down the water catchment system. It would of course be far too late for us here.
The most compelling argument however against Unity's future timely notification to downstream water users- assuming that was technically possible, which in this area it is not, is the existence of this falsehood in the EA. If the company had at any time openly admitted they had made mistakes, apologized, residents are not litigious and likely to accept an apology in good faith.
Instead Unity continues with the falsehoods and to threaten in various ways those, like myself, who have attempted to have them comply with the Court-ordered Conditions of Approval. They repeatedly write in the Braidwood Times of the `lies' spread about their operation, without ever saying what those lies are- and so prevent any refutation of what those `lies' might be.
I do not lie, nor have any reason to in this case. Instead my work is based on the meticulous examination of primary sources, and obsessive accuracy. In this case I, and others, have collected and collated data that can be substantiated. But Unity may well be speaking about other's lies. Their claim of `lies' is as vague as large parts of the EA.


13. Unity's Lack of Construction Experience
Unity claims their Henty operation as evidence that they can construct a safe site. The Henty site, however, was constructed as a showpiece by the company that preceded Unity's ownership, Barrick Gold and the company Barrick Gold bought the site from. Unity has simply followed Barrick Gold's management criteria and, even then, was fined by the EPA in the last financial year for a major spill with no precautionary measures in place to deal with it. (Note: Unity denied this spill at the September 2014 CCC meeting, but a report by the Tasmanian EPA requested under Freedom of Information confirmed it, as well as their concern that Unity showed no preparedness for such a spillage.
Unity's Bendigo site is under care and maintenance rather than being properly closed down and remediated.
Knight Piésold provides superb work but their work can only be as good as the quality of the data they are given to work with. In this case the design is based on vastly inaccurate data.
The EA does not state that Knight Piésold will oversee the construction. After the catastrophic failure of a dam designed by Knight Piésold, in Canada, their report makes clear that they cannot be held accountable for failures on the part of the commissioning company, nor can they be held accountable if the commissioning company provides inaccurate rainfall and evaporation data .

14. All Tailings Dams Leak?
According to a mining engineer in Kalgoorlie this year, all tailings dams leak- it is a question of how much, how vulnerable the site and how trustworthy the operator is in containing those leaks.
In this case only 5 mm of matting with a life of between 35-300 years will protect the ground water from seepage. 5 mm is easily torn, by human accident, wombats, chemical damage or by rock movement in a seismically active area.
Unity has considerable experience of accidents, but not at admitting them or, as the Tasmanian EPA stated, at installing management practices to forestall them. If the lining is torn, there is little likelihood of the company admitting the problem until seepage becomes a major issue. By then Unity- or Big Island Mining- may no longer exist.


15. Unity Mining's distain for community concern
In the past three months Unity have publically stated in reply to concerns expressed by the community that:
There are no more heavy metals (lead, arsenic, zinc, uranium, copper and others) in their ore than in garden soil, and their ore is no more dangerous if washed down the creek. (A meeting at the Araluen Hall)
That there is cyanide in peaches and arsenic in strawberries (to Major's Creek residents)
That getting put of bed is dangerous. (ABC TV)
Further such trivializing comments can be quoted from local newspapers.
This demonstrates a deep contempt for residents concerns, and a campaign to deny or trivialize them.
This contempt is further illustrated when Unity states that it will not accept the EPA's recommendations of site-suitable design for the tailings dam and processing plant, but intends instead to use those applied at other sites in NSW - ones that are not on sites above steeply falling land, a major horticultural and agricultural area and a source of drinking water, as well as swimming holes that children and adults use, and rare and endangered species immediately below, including seven threatened species of fish, rock wallabies, and one of NSW's major migration corridors for both birds and animal species between the Deua and Monga National Parks.

16. Cherry Picking Data
Since 2012, Unity Mining have refused to:
. Take water samples after the five pollution events of 2013 from the Dargues Reef project, that led to their prosecution in the Land and Environment Court, on the first three of those events; and
. Take water flow measurements in the Majors Creek State Conservation Area or our adjacent property, the Neverbreak Hills Voluntary Conservation Area (VCA), to test how long it takes for pollution to travel from the Dargues Reef site to our property, the source of water for our household and 800 fruit trees, and a business that contributes more than $5 million dollars annually to the NSW economy.
They have placed the bores for testing the water quality and quantity of the Majors Creek catchment in the Araluen Valley in the catchments of Baines Gully and Rocky Gully - these gullies are completely separate from Majors Creek and collect water from farmland and bush that has no connection with Dargues Reef and the Majors Creek catchment.
Unity have repeatedly stated that the area downstream from their mine site is degraded from previous mining or farming, with no substantiation, declining to do the surveys required in the Land and Environment Court conditions of the 2013 judgment which required them to survey the creek upstream of the junction with Araluen Creek - not at the junction which is all that they have done, ignoring the twenty kilometres of creek between there and their site. Given that Araluen Creek has a larger flow than Major's Creek, and passes through disturbed land, this makes the testing there invalid, once again `cherry picking' data that will give false impression of the local ecology.
Unity has also refused to survey the endangered Araluen Grassy Scarp Forest in the above sites, although that too was a LEC Condition of Approval.
They have been given, but ignored, independent assessments by the NSW Department of the Environment showing that the Majors Creek State Conservation Area and the Neverbreak Hills VCA are areas of pristine rocky creek bed; of pools that never dry up even in a drought, the only source of water in dry periods for at least twenty-three endangered, critically endangered or vulnerable species, including rock wallabies see below as well as being one of NSW's most important corridors for migratory birds, as well as allowing species like quolls and powerful owls to move between the Monga and Deua National Parks, ensuring sufficient genetic diversity for the populations to survive.

17. Continued inadequate water management on site
The Dargues Reef site still has had insufficient capacity in its sediment dams to cope with last year's average rainfall and despite there having been no major rainfall events in the three years since the dams were constructed.
The site has unique geographic and rainfall challenges and to date Unity Mining has been unable to meet those challenges, using flocculent to clean water pumped from their present sediment dams.
It is of great concern that Unity Mining appears to believe that these dams are adequate, despite their need in a year of average rainfall to regularly pump water from them to maintain sufficient capacity for future rainfall events.
It is also of great concern that Unity Mining appears not to have a license to discharge this flocculent-treated water on site, despite requests by the EPA to do so. Although the company states is pumped onto grassland, and thus does not need EPA approval, the slope of the site means possible contamination of the Majors Creek/Deua River system, due to the sites unique combination of sudden severe storms, long periods of rainfall and poor soil porosity.
Of even greater concern is the fact that these inadequate sediment dam designs were approved by the Department and Planning Assessment Commission (PAC), and that they have not been enlarged sufficiently to cope with existing conditions on the site. If work of any kind is to recommence, these dams need to be redesigned to ensure their safe use, and the safe discharge of flocculent treated water should be a priority.
It is difficult to hide the sound of pumping at night, at a site next to the village of Majors Creek, nor the arrival of truckloads of flocculent. It appears that water is still regularly being pumped from the sediment dams but as, no license has been applied for, the company refuses to give figures for the amount of water pumped from these dams and how often.
This behavior is not indicative of a company that values openness, transparency and that is committed to ensuring that the area below the site is not polluted and, as seen below, the company denied any such pollution until taken to the Land and Environment Court by the EPA for the first three of their five pollution events in 2013 in the six months during which work was proceeding on site.
The EPA have stated the need for a new, adequate and comprehensive plan for managing the storm water basin, as
The company's continued refusal to accept EPA conditions for their site management implies that the company's chief objective is to minimize construction and operational costs, not to put into place best practice or practice necessary for the safe running of the site.
It is noteworthy that in 2014 the EPA in Tasmania, where the company also operates mining ventures, stated that the company did not have sufficient contingency plans for spillages and fined them for a spillage as well as for their lack of contingency plans.

18 False claims of compliance
Unity Mining claims a record of operation in NSW based on the periods when their site was mothballed, i.e. when no construction work occurred, rather than on their six months of operation when the area was free from pollution from sediment or unregistered flocculent for approximately five weeks.
Even during the mothballed period, Unity has been unable to manage the amount of water in the sediment dams, pumping regularly and using a flocculent. Despite the EPA request to apply for a license to discharge, Unity has refused to do so.
Department of Planning personnel have aided this appearance of compliance by refusing to admit that certain Approval Conditions existed; by refusing to enforce Conditions of Compliance; by their failure to even study the Conditions of Compliance to know what they were; and by accepting Unity's assurance that every complaint by the public was untrue. Not surprisingly, those in the local communities soon ceased reporting complaints to the Unity Hotline, especially after some who did so were abused or harassed. (Several local residents will give statements substantiating this if requested).


19. The company's record of contempt for truth and community relations.
See attachment 3 where for four of the five pollution events the company publically denied responsibility until, suddenly, when in court, they decided to admit to them and thus receive a smaller fine, totaling over $200,000 with costs, with the presiding judge stating that the fines would have been much higher if the company had not so readily admitted liability.

20. To Spill or not to Spill?

Unity's EA appears to allow for one to two spills per year, except where it states there will be no spills. The projected impact of these spills, however, is based on inaccurate rainfall data, severely underestimating the rainfall at the site (see Dr O'Loughlin's submission and the work of Roger Hosking', but this also tallies with the data collected by myself over a forty-two year period).
According to GIPFO documents EPA regards the original and present rainfall and climate modeling as insufficient to model the actual rainfall on site. This had been proved correct ever since work began on the project.

21. Failure to assess the risk of incremental build up of heavy metals on the Majors Creek, Deua River and Moruya River water catchments
The company has provided no risk assessment for the leakage of heavy metals from the dam on the grounds that this will not occur. Given the potential magnitude of the problem economically, environmentally and to human health, this is an extraordinary decision.
It also presumes there will be no accidental spillage, nor mistakes in construction, which given the company's record of almost constant pollution during their six months operation on the site cannot be justified.
Even if the tailings dam were to be designed and constructed to meet the inherent challenges of the site ¬ including topography and rainfall which are both neglected in the company's report ¬- this lack of any consideration for downstream businesses, people and is consistent with the company's previous actions.
At a minimum, assessment must be made of the consequences of small or large spillages of heavy metal material downstream of the site.
There also needs to be data on the speed of waterborne pollution from the site. As far as I am aware, I am the only person who has done this, despite repeated written and verbal requests to the company.

22. Lack of Disaster Management Strategies in the EA.
As Unity has mismanaged accidents both at Dargues and Henty and been reprimanded by the NSW and Tasmanian EPAs for their lack of strategies in dealing with spillages and other accidents, it is crucial that Unity provide comprehensive and detailed strategies for dealing with disasters, from an overturned truck spilling cyanide into Spring Creek, bushfire or human error.
The Modification assumes there is no need to consider the consequence of spillage of cyanide products or by-products, as they would be contained in bunds. It does not consider the measures that would need to be taken if there were to be a spillage outside the bunds i.e. on the way to the site or within the site but not within the bunded area. Given the steepness of the slope, the extreme rainfall events and the company's history, this is neglect of basic precautionary planning.

23.The company states it will comply with all Clean Air provisions but it does not state how it will do so.

The company needs to identify all potential sources of polluted air and comply with all the EPA requirements. It is noteworthy that the company has objected to this n documents obtained under GIPFO. The company stated it is unreasonable to provide details given their small-scale operation.
Air quality however is a major concern to residents given the strong prevailing winds and the `sink' which air can sit for days in the frequent event of a Majors Creek mist. The lack of data on this point is negligent and shows a major lack of concern for community health and respect for EPA expertise.

24. Failure to Evaluate Major's Creek's Katabatic Winds
There is no mention in the EA of Major's Creek's extreme and unusual katabatic winds, where hot air rising from the Araluen valley causes cold air to sink, thus creating local wind levels of up to 94 km an hour shortly before and after dawn in autumn and spring. These winds have the potential to blow a heavy metal contaminated material across the Major's Creek village and associated farm houses, as well as down into the Araluen valley, where many households use rainwater tanks using water from their roof as drinking water. It is impossible to measure the risk to air quality without at least a 12-month measurement of these winds, and a chart that shows not just average wind speed, but actual speeds achieved.

25. Lack of Bushfire Disaster Plan
The proposed cyanide smelter sits next to the village of Major's Creek. There is no data in the EA, nor evidence from CCC meetings, that Unity has in place a plan to manage out of control bushfire in their ore processing facility or storage area or along the route where trucks containing cyanide may be cut off by bushfire.
Given the high bushfire risk in the area, and the high incidence of fires at Major's Creek, as in all urban fringes, this is negligence. The recent fire with stored cyanide in China is evidence of the widespread damage such a fire might cause.
Fires travel fastest uphill. The Dargues site is almost at the top of the ridge, and the area has been burnt in at least three bushfires in the past century that I have data for. As I have made no specific study of this, there are likely to have been more. The site is particularly vulnerable with its areas of ribbon gum forest, where crown fires can leap from tree to tree, it's large area of flammable broom, and with the updraft from the Araluen valley adding to the speed at which the fire moves.

26. The need to substantiate creating 120 jobs
The number of promised potential jobs on the Dargues site has crept up from 20 to 40 to 120 with no stated increase in work to be done on site. The first increase came after locals pointed out that Robyn Clubb's orchards employ 26 people. If the 120 jobs includes flow on figures, or taking skilled local trades people from their current employment i.e. not creating new jobs, and putting additional strain on the local economy, this should me made clear.
27. The absence of any plan to consult with and remediate those affected by Dargues Pollution or accidents
The mine has not produced an accident plan. This is surely mandatory? The company has shown itself to be prone to accidents on the site, with five environmental breaches in the first six months of operation, three of which have resulted in hefty fines. A Google search shows how dangerous gold mining is and how this leaves desolation behind, especially in inhabited areas. Unity's mine in Bendigo is an example.

28.Absence of data from the Unity Community Survey of early 2015.
In early 2015 after several public enquiries the CCC were informed by email that Unity had commissioned a survey to gauge public attitudes to the Modification. CCC members were asked not to make this public so that responses would not be biased. A month after the survey period three community groups surveyed all households along Major's Creek, Araluen and Deua and Moruya Rivers as well as those in close proximity to the mine, all of whom could be reasonably be expected to have views on the Modification. None had been surveyed. Households as far north as Kiama and as distant from the mine as Reidsdale however had been surveyed.
While the methodology was questionable, surveying households unlikely to be affected by the development instead of those who were, it is curious that Unity have not given the results of the survey to justify their claims of public support.
Since the announcement of the cyanide ore processing, there have been no letters of support in the Braidwood Times apart from those with a personal financial connection to the project, or those who hope to have one. It is noteworthy that the district's largest employer, supermarket owner Jeremy Campbell-Davys, an initial enthusiastic supporter of Dargues Mine because of its then perceived employment potential, has put in a submission condemning the Modification.
At a Palerang Council meeting on Thursday, 20 August 2015 a packed National Theatre condemned the Modification. Thirty one members of the community spoke against it. Only the Unity spokesman and one other spoke in favour of it.
Like many communities, most people in the Palerang and Eurobodalla Shires have little interest in development issues unless they are next door, and possibly regarded the proposal to mine at Dargues with vague approval for the jobs it might create. This Modification however has elicited widespread anger and condemnation, not just because of the dangers of the Modification, but because of the company's broken promises and denials of responsibility for their pollution incidents. It is noteworthy that many previous enthusiastic supporters of the mining proposal have felt it necessary to state on their Facebook page their condemnation of this new proposal. It would be difficult to find an issue that has so united so many diverse areas of the community.
Many, or most of us in this area support mining, but this company's record of broken promise, sudden sackings of nearly all staff at Christmas time, failure to pay for the renovation of the recreation ground as promised and other behavior has turned public opinion. Mining: yes, but not by this company, on this site, with a Modification that uses cyanide, keeps heavy metals above a major water resource, and where the EA is based on incorrect data.
Unity has no social license whatsoever to develop the Modification.

29. Failure to Provide Data on Cyanide Transport Route
Unity states that as they have not confirmed the supplier they cannot confirm the route. However as there is only one commercial route, passing through Braidwood between the two schools and then out on the single road to Major's Creek past the site. Unity's reticence on this subject may be to prevent the inevitable protests about trucks containing cyanide travelling along a narrow school bus route, with sharp bends and blind corners, frequent fog at any time of the year, and, in winter, black ice.
While Cortona/Unity did promise the community that their trucks would not use the road in school bus times, this promise has also been broken.
The lack of other access roads also increases social and business difficulties if this single road is blocked by accident, especially if that accident involves toxic materials that may take days or weeks to secure safely, assuming the accident did not happen near one the many water courses between Braidwood and Dargues, where remediation might not be possible.

30. Unity's Perpetuation of their Myth of `Degraded Farmland.
The company states that the land downstream of the site is variably degraded agricultural land. On the contrary, the area downstream was classified as `pristine rocky waterway' in 2013 when the Neverbreak Hills VCA was declared by the Department of Environment which, unlike Unity, have actually surveyed and studied the land below the project site.
Lower down the Araluen Valley is one of NSW richest agricultural area+

Please find attached submission.

see attached document

Submission attached

I object to the Modification Part 3 A for changes to the gold mine at Dargues Reef, Majors Creek. I attach a file outlining the reasons for my objection.
I recommend the draft report prepared by GHD commissioned by the Eurobodally and Palerang Shire Councils highlighting the scale of the unacceptable risks associated with the proposal.

I strongly object to this application and have uploaded a Submission .

This is an attachment to the main submission sent last night.
The entire submission appears to be too large for the site to accept.
This is the second of the two sections of the submission so far.
I will attempt to add the other two appendixes, but if not, will call to se if there is another way to submit them.

I object to the application for the reasons given in the attached file.

See submission in attached PDF file.

As a local resident I am objecting to the third modification to the Dargues Reef Gold Mine Development Application - which would allow the use of cyanide as a leaching agent - as this process poses the risk of heavy metals contaminating the drinking water of Eurobodalla residents.

My detailed objections are contained in the file attachment 'Objection to Dargues Reef Gold Mine Modification'

I object to this proposed third modification by Unity Mining to the Dargues Reef Gold Mine Development Application.
I am a resident in the valley below and downstream of the minesite.
Please see the attachment for my reasons and beliefs regarding this issue.

I object to the proposed modification - please see attached.

To whom it may concern,

Please find attached (File attachment 1) my submission regarding the Dargues Reef Mine 10_0054 MOD 3.

Regards,

Anne Rault
2391 Araluen Road
Deua River Valley NSW 2537

To whom it may concern,
Please find in File attachment 1, my submission regarding the application to modify at the Dargues Reef mine, 10_0054 MOD3.

Regards,
George (known as Alan - second name) Rault
2391 Araluen Rd
Deua River Valley NSW 2537