Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697642965233.pdf (Australia)
Submission to Senate inquiry into rehabilitation of derelict mines The Problem  There are some 7000 derelict mining sites in NSW with about 550 major derelict mines sites across the state that require significant rehabilitation action.

 Because no current person and/or company can be held responsible for the rehabilitation derelict mines, any liabilities associated with these sites are the responsibility of the NSW Government.
 The top 50 of these sites are severely adversely impacting the environment and may pose a risk to human safety.

 Sites such as Yerranderie (Sydney Catchment Authority area), Woodsreef mine near Barraba, Sunny Corner near Lithgow, Conrad (near Inverell) and Captains Flat (near Queanbeyan) contribute elevated metal and sediments loads to downstream waterways.
I estimated that it would cost $40- to $50 Million to address environmental and safety issues at the top 10 worst sites, and $80 Million to address the top 50 sites.

  The Government currently provides for less than $2 Million annually to the NSW Derelict Mines program.

At this rate it will take 25 and 50 years to address the top 10 and 50 sites respectively.
 This money allocated does not consider the accelerating need for ongoing maintenance at other sites and sites that have been not been sustainably rehabilitated.

Industry does not contribute financially to fund derelict mines rehabilitation.

  The current funding is only adequate to maintain, “band aid fixes” for a few major sites and  conduct studies and prepare Remedial Action Plans.

Larger one-off enhancement funds have been provided when public pressure becomes volatile.
For example: The NSW Environmental Trust allocated $3 Million in 2000 to assist with the risk reduction works at 6 sites (4 of these are ranked in the top 11).

However, this money was well below that required to remediate sites such as Conrad, Yerranderie and Captains Flat, which require in excess of $5 million each.
 Because there is no coordinated program and there has been little activity, government agencies have little experience in major sustainable mine rehabilitation programs and need to “buy-in” landscape rehabilitation vs mining experts and as well, need to pay a premium to set up and establish works programs on remote and difficult sites.

 There is no accepted rehabilitation performance standard for rehabilitating either current mines or derelict mines.
Consequently there is wide discrepancy about the acceptability of the design, the suitability of the current works program and no independent evaluation or auditing of implemented works.

 New derelict sites will occur the post closure of currently active mines where there has been no measurable targets set and no auditing of works undertaken.

Long term remediation is expensive The cost of removing contamination and long-term threats can be very expensive.
For example, acid mine drainage from the Captain’s Flat mine near Canberra is effecting the Molonglo River, for 40 km downstream.

The cost of completely removing the threat of water pollution and significantly improving water quality could cost somewhere between $10 to $20 million, however there is at present no proven technology available.

Alternatively, currently available treatment technology is still expensive.
For example, a 2005 report on the Captain’s Flat mine suggested that the annual budget for treating acid mine drainage is in the order of $400,000 and that does not include the difficult question of disposing of residual wastes.

This represents 25 % of the annual budget, without providing a long-term solution.

Given the limited funds, the NSW Government can realistically only fund ongoing maintenance and/or a very small number of major projects.
Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 29 Prioritising Derelict Mines I have urged governments to take a more strategic and reactive approach to identify and prioritise sites, prepare long-term and staged rehabilitation plans for sequential funding and seek special funding for major projects.

A typical remediation plan can cost upwards of $50,000 per site.

A ranking system needs to consider environmental, safety and heritage issues.
Safety issues are ranked higher than environmental issues which means that some of the high risk environmental sites are further down the list.

For example, Halls Peak Mineral Field is lower on the priority list but is impacting water quality 300 km downstream to the mouth of the Macleay River, through a World Heritage National Park.
Yerranderie (in the Sydney Water Catchment) and the Conrad (in the Inverell Water Supply Catchment) have been high on the priority list, given their potential to impact on domestic water supplies.

The Conrad mine near Inverell is a good example.

This derelict mine is approximately 3 kilometres (river length) from Copeton Dam and has contributed significant loads of heavy metals, primarily lead and arsenic to sediment in the dam.
The dam supplies irrigation water under normal conditions, but when the storage level reaches 5% it exclusively supplies domestic water for the township of Inverell.

At these low storage levels, there is an increased risk that the metals contamination could impact on the water supply.

Although the potential risk is significant, studies indicate that the current impact is minimal and poses no health threat.

The risk ranking is only one factor in that decision-making process.
The decisions would be greatly improved with more information and a fuller analysis of costs and benefits Lack of Industry contribution to the costs associated with derelict mines.

The industry has acknowledged that derelict mines have a significant influence on community perception about its environmental performance and the perception is a global threat to accessing resources.
While industry acknowledges the issue, it has not identified how or whom should address the issue in an equitable and effective manner.

The Way Forward Existing derelict mine sites   Governments needs a dedicated nationally coordinated team with sufficient and assured funds to set performance targets, develop and implement sustainable rehabilitation projects, manage major programs increased assessment, auditing and reporting of rehabilitation on existing mines.
The team needs to focus on fully remediating the worst sites first, in accordance with the a national priority list based on environmental and safety assessments and urgently prepare “Remediation Action Plans” for the top 20 sites.

Clearly specify the measurable environmental and safety outcomes for mine rehabilitation program.

A high level Implementation Committee, including industry representation to oversee a the program.
  Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 29  Require the mining industry to pay a levee to contribute to the industry’s legacy as per ESD principles, i.e.

user pay, polluter pay vs externalising the cost onto the community.

A possible solution would be to establish a partnership with the Sates and industry, including a joint national funding program.
Prevent new derelict mines  Improving the attractiveness for future purchasers and limit the future liabilities for Government by : o Requiring all current mines to prepare closure plans (including subsidence issues) and implement progressive remediation.

Closure plans must deliver sustainable sites that have no ongoing maintenance requirements.

Implementing a review and standardised national approach to financial security systems for mines to ensure there is adequate funding for rehabilitation.
o Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 29