Public Submission on the Draft Scoping Requirements

Nowa Nowa Iron Project

Submitted by, Wairewa and District Landcare Group Inc (WDLG)

2 May 1014

Introductory statement Wairewa and District Landcare Group Inc (WDLG)

This submission to the Draft Scoping Requirements, Nowa Nowa Iron Poject (5-Mile deposit) – Environmental Effects Statement, is made on behalf of the Wairewa and District Landcare Group Inc. (WDLG)

………..

Wairewa and District Landcare Group Inc was began about 7 years ago during the worse years of a ten year drought. The group has wide membership within the Wairewa Valley and neighbouring districts. Over the years many progressive land-restoration and farming inovation projects have been facilitated through the group, and those projects and the community unity offered through the group continue today.

Wairewa is a long established farming community located approximately 4 km from the proposed mine site. It has a diverse agricultural economic base including vegetable and grain cropping, apiary, dairy, orchard, and beef production. The population of the district is approximately 200 with seasonal increases beyond that.

This submission addresses concerns within the community that should this project proceed without adequate consideration, it may have serious negative effects on both the economic and other community interests of Wairewa and district. We consider that the documentation that has already been produced and displayed by the Proponent in support of its EES Referral documentation, shows very little consideration to the likely negative effects that this proposal may have on members of the Wairewa and wider local community who will not directly benefit from the project.

Identified Omissions from the Proponent’s EES Referral documentation to date:

Water/hydrology

Missing from the Proponent’s EES Referrals documentation, is any consequential discussion or substantial research on the possible effect that the proposed open-cut mine (that will cut through and operate below the existing water-table) will have upon the local ground-water supply, volume, and depth, in the neighbouring Wairewa Valley. We consider this lack of hydrological data to be a critical omission in the efforts undertaken by the Propenent to date. Comprehensive and adequate research of ground water behaviour in the locality of the mine site and the relationship of that water to the Wairewa supply, are very important to the economic interests of at least two agricultural enterprises in the Wairewa valley who rely on ground-water pumping

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for irrigation.

In addition, no consideration has been given by the proponent to the ground-water spring-fed sources of Hospital Creek, Bills Creek and Tea Tree Creek (all within the Wairewa Valley) which is the essential permanent water resource underpinning all agricultural industries within the Wairewa valley. The creek is sustained in periods of drought by natural ground-water springs, so any threat to that flow from mining activities must be adequately considered prior to Ministerial approval.

Transport

The Proponent’s reports fail to seriously address the possible negative effects that the highway cartage of 1 million tonnes of ore by B-Double trucks (194 trips per-day) will have on the competitive standing of the local tourist economy. That includes the direct effect on the town of Nowa Nowa and businesses in the town that rely on tourism for a substantial proportion of their income. The Proponent also fails to consider, and the Draft Scoping document also fails to identify, the effect that the project could have upon the local and wider regional economy, including a possible drop in real-estate value on highway frontages; damage to public amenity including the effects of increased road noise and associated health effects included stress, depression, anxiety, road safety, a lowering of the reputation and desirability of the region as a place to live or visit; damage to the Highway road surface, and consequential safety and amenity issues affecting visitors and adjacent communiies along the mine transport routes.

Environmental Effects

The Proponent’s identification of environmental issues arising from the project (contained in the EES Referrals) is also gravely lacking in detail and coverage. For example, nowhere in the report is a scenario or modelling presented that considers the environmental and economic effects should a disaster affect the mine. A relevant example would be a collapse in the sediment containment dams at the mine site following high rainfall. As the downstream effects of such an event could be serious, including upon the ecology of the Ramsar listed wetlands at Lake Tyers and the associated tourist industry and local amenity, the omission of such consideration is a serious shortfall in the scope of the environmental reports already produced by the Proponent. The Wairewa and District Landcare Group Inc strongly urge that such a scenario is included as a requirement in the EES requirements to be outlined in the final Scoping Document.

Economic Impacts

In the EES Referral documentation already presented by the Proponent, it is clear that an attempt is being made to limit consideration of the project impacts, as far as possible, to consideration of issues arising within the actual mine physical footprint area (i.e. within the project fences).

Only secondary and cursory consideration has been directed in the documentation so far produced by the Proponent, to issues beyond the mine site, including such

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important matters as the negative effect that the project must have upon certain sectors of the regional economy, environment and community. The strategy of the Proponent is clearly aimed at “fast-tracking” the mine approval processes, and hence the economic interests of the company share holders. But if this approach is accepted by the Department overseeing the process (DTPLI), and the assigned Technical Reference Group, then the wider interests of the East Gippsland community will not be adequately considered in this EES process, and the Minister will not be given a sound document on which to base his final decision.

Economic Effects

The EES process so far, including the Draft Scoping Requirements and the Proponent’s EES Referral Documentation, lacks a detailed and comprehensive economic analysis of the East Gippsland economy, including the main industries, areas of employment, accumulated capital, demographics, areas of growth and decline, and most importantly, the effect that the project would have upon that economy. The report should consider how the project may displace certain areas of market advantage currently enjoyed by certain industries already prominent in East Gippsland including the tourism industry. The EES should also address actual economic viability of the project over the project life, and the effect that a potential failure of the project mid-stream would have on the regional economy.

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The following section of this submission sets out to address the various section headings presented in the Draft Scoping Requirements document. Where appropriate this submission will address specific deficiencies identified within the Scoping Draft.

Additions to the existing text - italic, will be marked by red text and pasted onto existing text to show context within the draft.

1.2 The Project and its setting.

Additions marked in red.

….The project footprint comprises a single open pit, a waste rock dump (WRD), a low grade ore stockpile area, run of mine area, processing and management facilities, water management installations, access roads and land to be used for various supporting purposes. The project would also entail relocation and construction of several kilometres of Nowa Nowa Buchan Road along a new alignment outside the mine works footprint. The total area to be subject to works for the project amounts to about 146 hectares. Waste water, sediment and rainfall will be contained at the mine site by 3 dams built across existing water courses at the mine site.

….The estimated life of the project is approximately eight to ten years. At the conclusion of mining, the land would be rehabilitated according to an agreed plan, with a lake to form in the open pit. The economic viability of the project relies on a selling price for iron ore of $95 per tonne to be sustained for the duration of the project.

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2.2 Technical Reference Group.

Considered includions into the makeup of the TRG

VicRoads.

VicRoads must be included in the TRG for this project as the iron ore will be trucked on VicRoads managed roads within Victoria on the route to the port at Eden. Issues arising from that include, maintenance costs, road use levy, traffic volume control and public safety.

East Gippsland Shire Council.

The participation of East Gippsland Shire Council on the TRG is not justified as the mine is operating on DEPI lands, and ore-cartage will proceed on VicRoads managed roads and not council managed roads. Nor does the project require a Planning Approval from EG Shire Council. The Council has published statements including within a MOU between it and the Proponent, stating that all environmental effects of the mine are managed under the responsibility of state government agencies and are not Council responsibilities. The only other role that the public can assume was intended by inclusion of the EG Council on the TRG was that as a representative elected body, representing the interests of the East Gippsland community in the EES process. We consider that the Memorandum of Understanding signed between the Council and the Proponent shows that the Council has already pledged to support the project before the conclusion of the EES or public consultations.

For these reasons the responsibilities of the East Gippsland Shire Council in this project is not significant and therefore should not be represented on the TRG.

Gippsland Lakes Ministerial Advisory Committee.

The GLMAC was established by the Victorian state government to promote coordinated action for the management of the Gipplsland Lakes. As the Nowa Nowa mine proposal will be situated within the catchment of the Gippsland Lakes system, and Ramsar site, any water-borne waste lost from the mine site will affect that system. We believe it is very important that GLMA is represented on the TRG so that the expertise it has gathered will have appropriate consideration.

Community Representation

The Ministerial Guidelines to the Environmental Effect Act, do not specifically define what body, agency or entity should sit on the TRG. The brief outline contained in the Guidelines reads thus; “A TRG’s membership is drawn from bodies such as Government agencies, regional authorities, and municipal councils that have a

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statutory policy interest in the project.” However limiting the TRG participants to government agencies or municipal entities does not appear supported by wording that excludes the inclusion of other entities that may add value to the considerations before the TRG. Indeed Southern Rural Water is actually a company, albeit government owned, and for that reason we believe the TRG in this case, should include community representation beyond representation by Municipal Council (for the reason described above under the tile East Gippsland Shire Council). Such community representation should be in the form of a representative of relevant community, environmental or commercial associations, including for example tourism based groups, community-based land management organisations such as Landcare, etc.

2.3 Public Consultation.

As it currently stands as per the Gippsland Iron EES Referral document 3, Stakeholder Engagement, the company has failed to effectively engage with or adequately identify stakeholders potentially affected by the mine, not represented by government agencies, GlaWAC, and an accompanying short list of others. Future public consultation and engagement by the Proponent must be set out in the EES conditions in such a way that the Proponent must make a reasonable effort to identify and invite a contribution from other stakeholders in the region.

Stakeholders completely missing from the list identified from the Proponents current list include; other communities along the Highway truck route including, Tostaree, Cabbage Tree, Cann River, Mallacoota, and isolated farms; Lake Tyers Aboriginal Community; recreational fishing groups (that may be affected by mine pollution and road traffic); business groups; farming groups and associations; neighbouring farming communities including Wairewa; Landcare groups; community groups; environment groups; etc: It is the role of the Proponent to engage with these groups and to date that task has not been adequately performed by the Proponent or its’ contracted representative – Dave Holland from the PR company Right-Angle Business Services. (See below details).

The WDLG considers the Proponent should have clearer and more specific instructions from the Final Scroping Document as to what is required for meaningful community engagement. We believe the Proponent has failed to identify potential conflict between the mine operation and the concerns over ground water, noise from blasting and transport and impacts on neighbouring farming community of Wairewa.

Equally, the WDLG believes that the Proponent should also be restrained by the conditions of the Final Scoping Requirements, in the way that it utilises the services of the East Gippsland Shire Council business development officers in the promotion of its’ business interests.

This requirement arises from a close reading of the preemptive MOU signed between the Proponent and the Shire, and the behaviour of senior Shire development officers in their promotion of the project through the local media over the past 6 months.

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Public engagement is a responsibility of the Proponent, and we consider that when that role is effectively subcontracted out to an elected representative body, such as East Gippslamnd Shire Coucil, it creates confusion in the community and has the potential to cause a decline in the trust of the public in the EES process.

The WDLG considers that to date employees of the project have caused confusion for the community in the way it identifies people working for it. During public consultation conducted by the Proponent in the town of Nowa Nowa early in 2014, the company was represented by Dave Holland who identified himself as being, an “investor” in the Nowa Nowa project. Consultation was conducted with the public during which Mr Holland took no notes. At later dates Mr Holland also attended and addressed a public meeting called by the Wairewa Landcare Group. At that meeting he again introduced himself as only an “investor”. In fact Mr Holland is a Director of Right Angle Business Services Pty Ltd, a PR company with a contract to supply community contact work on behalf of GIPL.

2.5 EPBC Act

As identified in the Draft Scoping Requirements, this project has the potential to have a damaging impact on the Ramsar listed Gippsland Lakes wetland system. This could arise from a disastrous dam collapse or overtopping at the mine site resulting in the loss of sediments and contaminants (including acid sulphides) into the Boggy Creek then into Lake Tyers. This fact was recognised by the referral of the project by the Victorian Minister to EES assessment. That being the case the Federal Environment Department should consider the project proposal under the EPBC Act as was done with the Stockman Project at Benambra. However the Federal Department has declared on 30 March 2014 that, it (the department) does not consider the project a controlled action under the Act.

Without the assessment of the Federal Act, the Scoping Requirements need to address the shortcomings that will result from the Ramsar issue only being considered by state agencies, which do not have jurisdiction to act on the EPBC Act, and determine if that will be adequate or need further legal referral.

3.1 General Approach

The WDLG request that the following important point be added to the listed subject areas:

Consideration of the risk and economic circumstance that could precipitate a complete economic collapse of the project before the completion of the predicted 10-year life expectancy. Develop a model of such an event including the environmental consequence, including site clean-up and down-stream (aquatic) ecological damage including Nowa Nowa Gorge, Boggy Creek and Lake Tyers (Ramsar Site), and the long term site management costs

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without a continuing contribution from (a bankrupt or failed) Gippsland Iron Pty Ltd.

3.3 Project description.

The WDLG request in reference to the second point ending with:

“… and implications of the project not proceeding,…” the additional point as follows, “… and implication if the project fails or stops prematurely due to the market situation.”

In addition add the following condition… “That the economic feasibility of the project be justified, including set-up costs, operating costs, iron ore sale price required to establish profitability, mine closure restoration costs, accrued royalty payments over life of mine”.

3.4

Applicable Legislation …

Add to point; FFG Act, Action Statement (for relevant list large forest owl species related to SPZ Zone).

3.7 Draft Evaluation Objective.

Within the table, under heading “Catchment values” add the following inserted indicated in red.

Catchment values - To ensure that local and downstream hydrology, surface water and groundwater quality, accessibility and volume, (including, Nowa Nowa Gorge, Boggy Creek and Lake Tyers, part of the Gippsland Lakes Ramsar wetland of international importance) and associated beneficial uses, including the local tourism industry, are adequately protected from adverse impacts arising from the project.

(including negative public perceptions arising from the project including trucking congestion and downstream pollution).

And at:

Cultural Heritage - To avoid or minimise adverse effects on Aboriginal and historic cultural heritage values, sites and places, including areas of important Aboriginal cultural significance that occur on and around Lake Tyer and Boggy Creek, and downstream of the GlaWAK Land Title claim boundaries.

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And at:

Health, Social and Amenity - To protect the health, safety and wellbeing of residents and to minimise the negative effects on any nearby residents and local communities, including impacts arising from project-related transport operations, and to propose a system of compensation or mitigation measure to reduce those effect to acceptable levels.

And at:

Sustainable Development - Overall, to prove (delete – “demonstrate”) that the project would achieve a balance of economic, social and environmental outcomes that contribute to ecologically sustainable development and provide a net community benefit.

4 Assessment of Specific Environmental Effects.

In the following paragraph remove the word “might and exchange for “must”.

Key issues for objective, in terms of significant issues or risks that the project poses to the achievement of the draft evaluation objective. In addition to addressing the highlighted issues, the proponent must (delete – “might”) undertake an appropriate environmental risk assessment to identify other significant risks.

4.2 Resource Development

Following on from the opening paragraph add the following, marked in red.

Draft Evaluation ObjectiveTo enable an economically viable mining project that makes the best use of available iron ore resources and of forest produce resulting from site preparation, and that does not have a significant negative effect on other sectors of the regional economy.

And at Assessment of likely effects: include additional points marked in red:

Assess the positive and many negative economic effects from construction and operation of the project, including income to the State and regional economies, employment and opportunities for local suppliers and the temporary and permanent impacts on forest resources. And, identify the likely negative effects that the project may have upon the important regional tourist industry, and other business, conduct a comparison of the cost benefit to state government, for the cost of road maintenance

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issues caused by the project, versus the input to state revenue from the Project mining royalty payments.

4.3 Biodiversity.

Add the following text red to the following Draft Evaluation Objective:

Draft Evaluation ObjectiveTo minimise adverse effects on native vegetation and habitat and on threatened flora and fauna species and ecological communities, including any relevant species listed under the FFG Act, and address opportunities for offsetting potential losses consistent with relevant policy and the P&E Act. Consider the effect of the project on biodiversity beyond the mine site, including any other area that is affected by the mining operations, including areas downstream of the mine.

Add the following points in red under the heading: Key issues:

Key issues Direct loss of native vegetation and any associated listed flora, and threatened

species known or likely to occur in the vicinity of the project site.

Direct habitat loss for listed fauna and threatened species.

Indirect loss of vegetation or habitat quality resulting from edge effects, habitat fragmentation or other disturbance impacts.

Potential for other indirect impacts on biodiversity values including changes in hydrology and risk of significantly increasing mortality of FFG Act listed threatened species resulting from mine-related traffic (e.g. road kill).

Effect on large forest owls of blasting operations on the edge of adjoining Special Protection Zone for large forest owl species.

Lack of existing comprehensive research data available on endangered and listed species present at and living in adjoining or downstream areas.

Threat to Ramsar wetlands and Nowa Nowa Gorge - down stream of mine site, from the collapse of the mine sediment/pollution containment dams.

Following on from the heading: Priorities for Characterising the existing environment:

Add the following points in red:

Priorities for characterising the existing environment Describe1 the biodiversity values that could be affected by the project,

including:

native vegetation and any ecological communities listed under the FFG Act

1 The EES will need to demonstrate that appropriate and adequate information (e.g. desktop database and literature searches, seasonally-appropriate targeted surveys and/or modelling) has been compiled on the potential and actual presence of threatened species and ecological communities, having regard to the likelihood and consequence of impact. Where preliminary field studies have not identified a species but past records and/or habitat analysis suggest that it may occur locally, the proponent will need to justify why further investigations or further mitigation measures have not been applied on a precautionary basis.

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presence of, or suitable habitats for, native flora and fauna species, especially species and communities listed under the FFG Act, including the use of remote cameras, pitfall trapping or other field research methods as appropriate

occurrence of key habitat for FFG Act listed threatened native fauna species vulnerable to road kill along relevant transport routes

use of the site and its environs for movement by wildlife.

The ecology of Lake Tyers a listed Ramsar wetland site and the ecology of the Nowa Nowa Gorge and Boggy Creek.

Following on from the heading: Describe hazards that the project could present to biodiversity values including: Add the following points in red:

Describe hazards that the project could present to biodiversity values, including:

direct removal or destruction of habitat

disturbance or alteration of habitat conditions or other sources of increased habitat threat

road traffic operations that could exacerbate risk of significantly increasing mortality of listed threatened fauna due to road kill

the presence of any declared weeds or pathogens in the project area that could be dispersed.

Damage to aquatic ecology downstream of mine site caused by water-borne pollution leaving the mine site, and including, Boggy Creek, Nowa Nowa Gorge, the Ramsar listed Lake Tyers wetland.

Under Design and Mitigation measure include the following comments marked in red:

Design and mitigation measures Describe the measures both considered and proposed to avoid and minimise

the potential for significant effects on native vegetation, native flora and fauna species and in particular listed species and ecological communities.

Describe the measures and risks modelled to mitigate and rehabilitate the Lake Tyers Ramsar wetland, Boggy Creek and the Nowa Nowa Gorge ecology if a major pollution spill occurs from the mine site.

4.4 Catchment values.

At Key issues: Ammendments marked in red:

Key issues Potential impacts on beneficial uses of groundwater including neighbouring

agricultural users, due to interception and or effect on the flows or discharges to groundwater.

Potential impacts on surface water quality arising from polluted run-off from operational areas or other areas disturbed by project works.

Potential impacts on downstream waterways (including Lake Tyers) due to changed flow regimes or waterway conditions downstream of the mine site or

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discharges or releases from the lake proposed to form in the exhausted pit, due to chemical or physical characteristics of discharged water.

Potential impacts on downstream environments caused by mine containment dam/dams collapse resulting in the release of large volume of contaminated water and sediment.

Potential that project could collapse financially leaving a contaminated mine site without adequate management of water and pollutants at the mine site.

Low grade ore (delete - management) and sulphide run-off management.

Water balance and pumping capacity for long-term safe and adequate water storage.

Add additions and ammendments to the following category – changes marked in red:

Priorities for characterising the existing environment Describe the existing groundwater environment in the vicinity of works

proposed to be developed or used for project purposes, as known or inferred from available information. And, conduct adequate research to determine the probable effect that the open-cut pit will on under ground water flows to neighbouring users of under ground water users in the Wairewa Valley. And establish through adequate research, what effect the mining operation will have on the ground water springs that feed the Hospital Creek that flows through the Wairewa Valley.

Define the term, vicinity of the works in relation to this EES, to include the neighbouring Wairewa Valley in relation to consideration of ground water resources.

Describe the local surface water environment in the context of the catchment within which the project site is located.

Describe the interaction between surface water and ground water in the vicinity of the site, including the Wairewa Valley.

Identify the available licensable water allocation, having regard to existing allocations in the catchment, and consider the effect that the extraction of that addition water may have on licenced ground water users in the Wairewa Valley.

Characterise the risks associated with potential acid forming materials which may be disturbed or exposed by mining activities, including the potential risks to the downstream aquatic environments within the Boggy Creek/Nowa Nowa Gorge and Ramsar listed Lake Tyers wetland.

Prepare a water balance model for the project to quantify the volume of groundwater to be extracted and released and the volume of surface water to be captured during the establishment, operational, rehabilitation and post-closure phases of the mining project. Include in the model the pumping-volume of the pumps that will fulfil the requirements of the project design, especially during times of exceptional rainfall. Explain how the long-term production at the mine will be stopped following water diversion into the pit to mitigate release of contaminated run-off, and how that will be factored as a cost.

Describe and quantify the likely release regime for accumulated water in the exhausted pit post-mine closure, with reference to volume, periodicity and the expected physical and chemical characteristics of the water.

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Assessment of likely effects Using appropriate models or other suitably robust predictive tools, assess the

risks to surface water quality, groundwater quality and downstream ecological values resulting from the conduct of the project, and including risks which may continue after project works have been completed (such as likely quality, periodicity and volume of discharges from the pit lake post-closure).

Include a model that can describe a catastrophic situation resulting from the collapse of the containment dams/dam at the mine site during high rain event, and the consequential release of contaminants downstream, the clean-up strategy, ecological restoration, and estimated costs.

4.5 Cultural Heritage.

Include the following additions marked in red:

Assessment of likely effects Assess potential effects of the project and relevant alternatives on:

identified sites or places of Aboriginal cultural heritage significance; and

sites and places of historic cultural heritage significance, having regard to the Heritage Council’s Guidelines for Investigating Historical Archaeological Artefacts and Sites (2012).

Include in this assessment consideration of areas that have importance to Aboriginal people but which are not covered by GlaWAC Native Title or authority, including areas down stream of Nowa Nowa on the Boggy Creek and the environs of Lake Tyers. These areas have the potential to be effected by down stream effects from the mining operation.

4.7 Health, Social and Amenity Impacts.

Add the following text marked in red.

Draft Evaluation ObjectiveTo protect the health, safety (delete - and) wellbeing and economic situation of residents and to minimise effects on any nearby residents, and residents living along planned transport routes, and local communities, including impacts arising from project-related transport operations and blasting at the mine site.

4.7.1 Public Health and Safety

Add the following text marked in red.

Approach to manage performance Outline proposed measures to ensure that the public is not exposed to levels of

airborne particulate matter exceeding PEM or SEPP criteria, including measures to monitor and control exposure to such hazards. Include in assessment the effect of dust emanating from B-Double trucks, and the health effects of that on residences on truck route. Propose mitigation with use of sealed trucks.

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4.7.2 Social and Land-Use

Add the following text marked in red. Key issues Adverse changes to community wellbeing due to reduced amenity and/or other

concerns over the project, including, community concern that property values will drop in areas affected by increased vehicle movements and truck noise, negative effect on local economy especially tourism resulting in a decline in the diversity and quantity of local employment.

Concern over desirability of region as a “good location” to live due to increased truck use on highway, damage to road, increased danger for community using roads utilised by mine trucks, increased frustration and stress on residents lives.

Beneficial social effects of employment opportunities for local workers at the mine and related business services.

Negative effect on businesses in region that depend on tourism and nature based tourism.

Changes to existing and future land-uses, including recreational uses, due to the project.

Priorities for characterising the existing environment Characterise the residential population in the vicinity of the project area, the

wider Nowa Nowa locality and East Gippsland Shire, in terms of population distribution and demographic, socio-economic and cultural aspects of the population. Include detailed studies of the attitudes of people living along the proposed truck route, and people dependant on the tourist industry for employment.

Characterise the members of the Board, and Managing Director of the Company, Eastern Iron Pty Ltd, and, Gippsland Iron Pty Ltd, including their place of residence, demographic position, cultural attitudes and cultural aspects.

Describe recreational values and use of the project site and its environs, include a description and estimate of the yearly usage of the Mt Nowa Nowa Mountain Bike track, the East Gippsland Rail Trail, and tourist recreation around Lake Tyers and the Nowa Nowa Gorge.

Outline of attitudes within the Nowa Nowa locality to:

the existing environment

the mine proposal

opportunities for community benefit that could arise from the mine.

Community perceptions of the negative impacts that could arise from the mine.

Risks to the local environment including the Nowa Nowa Gorge and Boggy Creek, and Lake Tyers that could occur in the event of a mining disaster, or leakage of contaminants from the mine site.

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Design and mitigation measures Outline and evaluate both proposed and potential further design and mitigation

measures that could mitigate the potential for adverse social effects, including the double glazing of windows of houses located adjacent to the Princes Highway, and a profit share by the proponent with the affected community to help with community development.

Identify potential economic effects which could result from the project, including opportunities for local business, and potential negative effects on local business.

Identify potential effects on workforce development opportunities in the wider region as a result of the project.

Identify potential effects on employment within the local tourist industry that may be affected by the development, and suggest ways that these people and business can be compensated for their losses.

4.7.3 Amenity

Add the following text marked in red. Key issues Nearby residents potentially exposed to excessive noise or vibration, including

from transport operations. Residents living adjacent to roads along full length of trucking route to and from Eden exposed to excessive noise and vibration from mine truck operation. Property prices along route potentially fall causing concern for owners. Desirability of living in region falls and affects property values. Living conditions of residents living on the proposed trucking route have life disturbed including sleep interrupted by 24-hour operation of mine trucks, resulting in general drop in physical and mental health condition of these residents.

Amenity of residents and livestock of Nowa Nowa and the Wairewa valley damaged by the noise of blasting at the mine site.

Amenity of region to tourist visitors damaged by increased volume of trucks using Princes Highway, journeys become longer and more dangerous.

Amenity of Nowa Nowa damaged by volume of mine trucks passing through the town, this effects the local tourist based industries and employers.

Design and mitigation measures Describe and evaluate both potential and proposed design responses and/or

other mitigation measures (construction and mining equipment and methods, staging and scheduling of works, management of transport equipment and operations), double glazing of all residences along proposed mine truck route, which could minimise noise and vibration and effects on sensitive receptors, and all members of the general public subject to the large increase in noise and vibration at their residences along the truck route.

Assessment of likely effects This paragraph is incomprehensible; it should be deleted in full and

replaced by a statement that details the likely effects on the public amenity caused by the mine operations including the transportation of

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ore to the port of Eden and blasting at the mine site. Predictions of likely noise and vibration levels at dwellings adjacent to the project area or transport route, and at any other sensitive receptors within the vicinity, including for relevant alternatives, during different stages of mine development and operation and different weather conditions, describing sources of uncertainty associated with the noise modelling.

Interruption and disturbance of the lives of residents living along the mine truck route to the port of Eden. Including damage to their sleep patterns, sense of happiness and wellbeing, and right to enjoy the undisturbed amenity of their properties without the 24-hour operation of a truck fleet. Disturbance to residents of Wairewa Valley and town of Nowa Nowa from persistent rock blasting at the mine site.

4.9 Environmental Management Framework

Include text marked in red.

Key issues Weak management of environmental effects during project construction,

operation and rehabilitation could result in failure to meet statutory requirements and sustain stakeholder confidence.

Poor consideration of environmental risks, and the reliance on inadequate data and poorly compiled reports, tokenistic consideration of community stakeholder input during project planning stage, could result in damage to the environment and local community, and result in the premature loss of community stakeholder confidence and support in the project.

Design and mitigation measuresAdd the following:

- Provide a proposed framework for managing the risks of adverse environmental effects, including:

- disaster management

4.10 Sustainable Development

Changes marked in red.

Draft Evaluation ObjectiveOverall, to demonstrate that the project would achieve a balance of economic, social

and environmental outcomes that contribute to ecologically sustainable development and provide a long-term net community and environmental benefit without a risk of future negative costs.

Key issues The balance of economic, social and environmental outcomes from the project

needs to be beneficial to the community interest.

The Proponent must demonstrate that the project will leave no lasting negative threats to the environment and community.

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……………………………

Wairewa and District Landcare Group Inc

Peter Vaughan

President

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