How to Engage with the Material

There’s no way around it: if you want to write a submission or otherwise oppose misguided mining development, you have to read the documents exhibited by the proponent (the mining company). This is difficult and time consuming. Still reading? Good. The proponent’s own publications are the single best source of ammunition for you to oppose them with. Read with a critical mind, the company’s own documents arm you with detailed knowledge of the project, and the pathology that drives it.

A document exhibited by the proponent may be titled an ‘environmental assessment,’ a ‘response to submissions,’ ‘preliminary documentation’, or whatever they decide. Do not be fooled by the use of the word ‘environmental’ in the title or in the contents – these documents are written under contract to the proponent to further their interests with state planning authorities such as the NSW Department of Planning & Environment (whose title is another misnomer). Do not be intimidated by the length or apparent density of the document. Most of the page count will be taken up with appendices. The density is also illusory – for it lacks in truth and substance. The contents generally fall into one or more of three categories.

(a) Rhetoric (meaningless, numbing, or unsubstantiated use of language for effect): ‘best industry practice’, ‘minimising harm to the environment’, ‘no significant impacts,’ ‘community benefits,’ ‘community consultation’, ‘general community support,’ ‘residual concerns,’ ‘will generally comply with,’ ‘standard practice,’ etc.

(b) Evasion: referring to external bureaucratic guidelines rather than actually addressing public concerns, as seen in the persistent non-discussion of risk or consequence; ‘the proponent notes that the risk of failure of the Tailings Storage Facility embankment is a matter addressed by (a generic government guideline that we won’t illuminate whatsoever)’; ‘a consequence category of “High C” (which we will not define) was determined by (a foreign contractor with no knowledge of the region, and whose definition of consequence is based on financial losses to the proponent before environmental impact). The proponent also uses internal wormholes, referring you to other parts of the same publication; ‘the proponent notes that this issue has been addressed in section x (where the issue is similarly evaded)’

(c) Dubious and/or narrowed ‘scientific’ data, collected, collated or presented by paid contractors. This includes all of the data used in so-called ‘environmental assessments’, upon which projects and modifications are determined. Data that is gathered, and/or selectively presented under contract to industry is not science, it is marketing. In NSW, the state planning authority (Department of Planning and Environment) accepts, without any apparent scrutiny or independent confirmation, every digit provided to them by the proponent. The public at large does not have the means to conduct its own testing (to measure water quality, tailings composition, the acidity or alkalinity of waste rock runoff, etc.). But we should be as sceptical of the proponent’s data as we are of the claimed health benefits of a packet of fruit-loop cereal. For example, the Environmental Assessment for Modification 1 (table 7, p.21) presents data suggesting that leachate from tailings stuffed underground (‘paste fill’) does not exceed a single drinking water guideline for any constituent element. In other words, you should feel fine about drinking water that has passed through a slurry of heavy-metal sediment (including toxic concentrations of arsenic, mercury, nickel, lead, antimony, and others). The data also suggests that leachate would be purer than existing groundwater. With the state planning authority hypnotised by the promise of short-term revenue, is up to the public to raise a finger (any finger) to such apparent quack.

Also watch for omission: The narrowing of the agenda to focus on the above, whilst excluding from the body of every document the real business of each successive modification: the erosion of standing conditions of approval, the withdrawal of stated commitments, and the incremental expansion of the mine without any truly binding limitation.

Keep your critical mind awake, scrutinise every sentence. Identify what is absent from discussion. Most importantly, sturdy up your heart. Public submissions and speeches are systematically ignored by the NSW Department of Planning and its ‘independent’ arbiters, the Planning Assessment Commission. As it stands, the public consultation process is a farce. But the process of engaging with (a) the material exhibited by the proponent and (b) the faux-democratic assessment process is the best way to cut your teeth for the real frontiers of change, ideological, political and legal reform. Writing submissions also clarifies your arguments, eases your conscience, and leaves a record of foreseeable problems that may some day help to hold the company or state government accountable if and when pollution occurs.

There is hardly a claim made by the proponent that cannot be taken apart with argument. My rule of thumb when wading through these publications: if something sounds like bullshit, it probably is. Do not be fooled. Do not discard your intuitions, even if you feel out of your depth. Look into it. Your knowledge will never be absolute – so just read what you can, and put forward your truth, as it stands.

Remember, the proponent claims ‘general community support’ (Response to Submissions for Modification 3, November 2015, p. iii). Your silence will be taken as consent.


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