AN OPEN LETTER FROM ASSOCIATE PROFESSOR JOCHEN KAEMPH
3 March 2014
Comment to Rex Minerals’ Response Document (Hillside Copper Mine Proposal)
To Whom this May Concern
In their response document, available at Rex Minerals Response Doc , Rex Minerals Ltd. (henceforth referred to as proponent) fail to scientifically demonstrate that dust deposition from mining operations does not lead to marine pollution in the upper reaches of Gulf St. Vincent.
The proponent decided to fully ignore this important point claiming that meeting air-quality guidelines automatically eradicated the risk of marine pollution. This claim is unsubstantiated given the trivial fact that mining dust can accumulate on land surfaces and the seafloor over time. Indeed, subsequent erosion by flooding events or storms in coastal water may create severe marine pollution (similarly, dust erosion by strong winds may lead to severe public health problems).
The proponent does not address this critical point and the fate of mineral dust deposits in adjacent gulf waters remains unknown. This lack of scientific investigation is surprising and, in my view, not justifiable. Indeed, given the close proximity to the sea, the proponent should also be obliged to meet the Water Quality Policy for any direct or indirect discharge or erosion event.
Based on its incompleteness, the mining proposal by the proponent should be rejected. If this cannot be achieved for any reason, then I strongly recommend:
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Comprehensive and detailed environmental surveys and an assessment of the state of the regional coastal and marine habitat before mining impacts. One would expect this to be within the responsibilities of the EPA, but the local community may also take a lead in this.
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Ongoing monitoring of environmental quality during mining operations by an independent authority.
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Instalment of operating license conditions with explicit references to marine impacts including indirect pollution from surface-water runoff and seabed erosion.
Regards,
A/Prof. Jochen Kaempf