NGO ENVIRONMENTAL WATCH GROUP
P.O.Box 2750 , Boroko, Papua New Guinea
PH # (675) 323-5552 , Fax # (675) 323-0397
Minister for Mining.
Date: 16th December 99
Dear Minister,
The impacts, known problems and uncertainties that are part of Ok Tedi Mining Ltd current mining operations clearly demonstrate that that OTML has not shown capacity or willingness to operate the mine in the area bounded by the exploration licence without substantial and unacceptable environmental and social impacts.
It is not in the interests of the Papua New Guinea state to:
Let mining exploration to continue in an area where current mining has demonstrated that it is ecologically unsustainable
Continue to allow exploration in an area were the current mine dumps 80,000 tonnes per day of mine waste into the river and further waste from the eroding rock dumps
Allow exploration by a company that has yet to make proper compensation, rehabilitation and environmental restoration plans for the damage it has caused
Risk permanent and irreversible environmental damage when it has been demonstrated by current mining in the area that there is a high likelihood that this will occur. Any further mines operating in the same manner will compound the existing problems through the cumulative impact of waste
Increase the likelihood of social instability due to environmental and cultural damage resulting from unsustainable mining practices
Damage long and medium term utility of economic resources through the destruction by mining waste of these resources
The operations of the current Ok Tedi mine have resulted in world scale environmental damage. This damage will continue to get worse for at least a decade. The impacts are expected to last for at least six decades, which is the limit of the current modelling. It is probable that the impact will last for most of the next century.
The company reports show that there are and will be substantial impacts in the following areas.
Fish
The company reports show a highly significant number of fish have been killed as a result of the mining operation. The company studies state to the following:
"In the Ok Tedi the reduction … has been in the order of 90% while in the Upper Middle Fly catches are down by around 70%." [BHP]
"Aquatic communities in the Ok Tedi and middle Fly also are at significant risk. ... Up to 90 percent of the fish species may be at risk in the lower Ok Tedi … while the magnitude of risk for other aquatic species such as invertebrates and algae is more poorly understood but potentially significant. Substantial reductions in fish species diversity … [are] predicted as far downstream as Everill Junction." [DLRA]
Forest
The waste from the mine to will continue to kill forest, even if the mine' s operations were to cease tomorrow. Moreover this impact will continue to get worse for at least a decade. The company reports reveal that:
"Mine … predicted to produce dieback along the middle Fly River for more than 50 years" [DLRA]
"Areas of dieback and stressed vegetation totalled 478 km2 in 1997 ... extent of mine related forest dieback for reaches 3 and 4 are 900 km2 (range: 700 to 1350 km2)"
"Predicted … area of forest dieback for reaches 3 and 4 are 1780 km2 (range: 1280 to 2700 km2)" based on the land and river layout. [DLRA]
Note: reaches 3 and 4 refers to the upper middle area of the Fly River and lower part of the Ok Tedi, which runs into the Fly River.
Copper
The mine waste contains high levels of heavy metals. The following impacts are expected:
"Dissolved copper concentrations in the Ok Tedi and Middle Fly will take over 40 years to return to pre-mining levels."
"Concentrations ... will be higher in the last 5 years of mine operation than at any other time of the mine's operating history." [Copper]
"Copper may be posing risk to the aquatic food web due to the high sensitivities of some planktonic species that are important components at the base of the food web. The copper risk estimates are also currently uncertain due to the lack of suitable exposure data." [DLRA]
People
The Ok Tedi mine has had a major impact on the people who live around and downstream from the mine. The communities have been significantly disrupted. Widespread concern remains over the current and future impacts of the pollution from the mine. The company has reported to a limited extent on some of these impacts:
"Potential risks to humans are uncertain at this time. …. As humans are forced to hunt and fish over larger areas, however, they may have trouble obtaining sufficient protein in their diets" [DLRA]
Food
It is now know that the impacts from the mine will last for a significant part of the 21st century. This will impose a major burden on people as their food resources diminish. The company report refers to this impact:
"The significant risks posed by mine-related stressors to terrestrial vegetation and aquatic life may also place wildlife at significant risk because they rely on these systems for food and/or habitat. Food and habitat resources will diminish as forest dieback continues." [DLRA]
These uncertainties, and issues that nothing is known about, include:
1. The BHP Peer Review Group has said that the Human and Ecological Risk Assessment is a rush-job. The Group said "given the very restrictive time frame, the Human and Ecological Risk Assessment will contain many more caveats and uncertainties (and larger uncertainties than if the time frame were more appropriate to the level of the complexity of the issue. This caution has been proven true. The Detailed Level of Risk Assessment will not be a world class risk assessment given the major uncertainties remaining". [Peer]
2. how much sediment that has been deposited in the lower middle Fly River
3. the height of the sediment wave coming down the Fly River over the next 10 years or after
4. the present extent of the die-back front
5. the rate of expansion of future die-back
6. the true maximum extent of die-back
7. what will happen to the Middle Fly grasses in the swamp forest
8. the duration of future flooding, the major determinant of die-back
9. the impact of die-back loss on biodiversity
10. the impact of die-back loss on eco-system function
11. the impact of die back loss on food resources
12. the impact of die-back loss on increased risks of malaria and other water related illnesses
13. whether the copper spikes will cause toxicity
14. whether the copper spikes will affect the food chain
15. the reactivity of material stored on the floodplain
Unless and until Ok Tedi Mining Ltd demonstrates that it is able to operate the current mine in an environmental and socially acceptable manner it is not in the interest of the Papua New Guinea state for Ok Tedi Mining to explore for further mineral deposits in this area. If the company does not demonstrate this the PNG state and community will pay the true and full costs of the mining.
We call upon the minister to refuse the extension of the exploration licence on the above grounds.
Yours Respectfully,
…………………….
Wep Kanawi O.B.E
Convenor and Spokesperson- N.E.W.G
NEWG - PNG's environmental watch group . This is a pivotal group of social and environmental NGOs and individuals who have become extremely concerned about unabated / uncontrolled permanent ecological damage inflicted on the environment and social fabric of communities by development enclaves particularly mining. Our concern is no different to likeminded people in developed countries who demand a healthy and unpolluted environment. Unlike communities in developed countries where it would feasible for them to be more easily relocated; PNG's societies depend entirely and permanently on their local ecologies for food, water, shelter , medicine and cultural well being.
Reference:
BHP: BHP and Ok Tedi Discussion Paper, October 1999
Copper: River Chemistry Model, Simon Apte, OTML August 1999
DLRA: Detailed Level of Risk Assessment, Parametrix & URS Woodward-Clyde, OTML August 1999
Peer: Comments on the Science Underlying the Human Health and Ecological Risk Assessment, Peer Review Group, OTML August 1999
P.O.Box 2750 , Boroko, Papua New Guinea
PH # (675) 323-5552 , Fax # (675) 323-0397
Minister for Mining.
Date: 16th December 99
Dear Minister,
RE: APPLICATION FOR EXTENSION OF EXPLORATION LICENCE TENEMENT NUMBER 581 BY OK TEDI MINING LTD
We are writing to object to the application for extension of exploration licence tenement number 581 by Ok Tedi Mining Ltd. The granting of this application would not be in the best interests of the state.The impacts, known problems and uncertainties that are part of Ok Tedi Mining Ltd current mining operations clearly demonstrate that that OTML has not shown capacity or willingness to operate the mine in the area bounded by the exploration licence without substantial and unacceptable environmental and social impacts.
It is not in the interests of the Papua New Guinea state to:
Current Ok Tedi Mine
Ok Tedi Mining Ltd has yet to show that they can operate their current mine without having an unacceptable impact on the environment and upon the communities that depend on the rivers and forests downstream of the mine for survival.The operations of the current Ok Tedi mine have resulted in world scale environmental damage. This damage will continue to get worse for at least a decade. The impacts are expected to last for at least six decades, which is the limit of the current modelling. It is probable that the impact will last for most of the next century.
The company reports show that there are and will be substantial impacts in the following areas.
Fish
The company reports show a highly significant number of fish have been killed as a result of the mining operation. The company studies state to the following:
"In the Ok Tedi the reduction … has been in the order of 90% while in the Upper Middle Fly catches are down by around 70%." [BHP]
"Aquatic communities in the Ok Tedi and middle Fly also are at significant risk. ... Up to 90 percent of the fish species may be at risk in the lower Ok Tedi … while the magnitude of risk for other aquatic species such as invertebrates and algae is more poorly understood but potentially significant. Substantial reductions in fish species diversity … [are] predicted as far downstream as Everill Junction." [DLRA]
Forest
The waste from the mine to will continue to kill forest, even if the mine' s operations were to cease tomorrow. Moreover this impact will continue to get worse for at least a decade. The company reports reveal that:
"Mine … predicted to produce dieback along the middle Fly River for more than 50 years" [DLRA]
"Areas of dieback and stressed vegetation totalled 478 km2 in 1997 ... extent of mine related forest dieback for reaches 3 and 4 are 900 km2 (range: 700 to 1350 km2)"
"Predicted … area of forest dieback for reaches 3 and 4 are 1780 km2 (range: 1280 to 2700 km2)" based on the land and river layout. [DLRA]
Note: reaches 3 and 4 refers to the upper middle area of the Fly River and lower part of the Ok Tedi, which runs into the Fly River.
Copper
The mine waste contains high levels of heavy metals. The following impacts are expected:
"Dissolved copper concentrations in the Ok Tedi and Middle Fly will take over 40 years to return to pre-mining levels."
"Concentrations ... will be higher in the last 5 years of mine operation than at any other time of the mine's operating history." [Copper]
"Copper may be posing risk to the aquatic food web due to the high sensitivities of some planktonic species that are important components at the base of the food web. The copper risk estimates are also currently uncertain due to the lack of suitable exposure data." [DLRA]
People
The Ok Tedi mine has had a major impact on the people who live around and downstream from the mine. The communities have been significantly disrupted. Widespread concern remains over the current and future impacts of the pollution from the mine. The company has reported to a limited extent on some of these impacts:
"Potential risks to humans are uncertain at this time. …. As humans are forced to hunt and fish over larger areas, however, they may have trouble obtaining sufficient protein in their diets" [DLRA]
Food
It is now know that the impacts from the mine will last for a significant part of the 21st century. This will impose a major burden on people as their food resources diminish. The company report refers to this impact:
"The significant risks posed by mine-related stressors to terrestrial vegetation and aquatic life may also place wildlife at significant risk because they rely on these systems for food and/or habitat. Food and habitat resources will diminish as forest dieback continues." [DLRA]
Uncertainties/Unknowns
In addition to these acknowledged areas of impact there are significant uncertainties. Not only is the full extent of the impact documented above uncertain but these concerns are compounded south of the Everill Junction on the Fly River. The company has stated, for example, that it does not know the extent of the contamination of the sediment in the estuary region from the Ok Tedi mine. These uncertainties, and issues that nothing is known about, include:
1. The BHP Peer Review Group has said that the Human and Ecological Risk Assessment is a rush-job. The Group said "given the very restrictive time frame, the Human and Ecological Risk Assessment will contain many more caveats and uncertainties (and larger uncertainties than if the time frame were more appropriate to the level of the complexity of the issue. This caution has been proven true. The Detailed Level of Risk Assessment will not be a world class risk assessment given the major uncertainties remaining". [Peer]
2. how much sediment that has been deposited in the lower middle Fly River
3. the height of the sediment wave coming down the Fly River over the next 10 years or after
4. the present extent of the die-back front
5. the rate of expansion of future die-back
6. the true maximum extent of die-back
7. what will happen to the Middle Fly grasses in the swamp forest
8. the duration of future flooding, the major determinant of die-back
9. the impact of die-back loss on biodiversity
10. the impact of die-back loss on eco-system function
11. the impact of die back loss on food resources
12. the impact of die-back loss on increased risks of malaria and other water related illnesses
13. whether the copper spikes will cause toxicity
14. whether the copper spikes will affect the food chain
15. the reactivity of material stored on the floodplain
Objection
Ok Tedi Mining Ltd has yet to commit to any measures that will stop the direct discharge of mine waste into the river. It has also yet to commit to measures that will stop the erosion of waste rock dumps. If the company believes it is not technically feasible to take these measures due to geography, cost or geological activity then the same problems will be perpetuated at any further mineral deposit in the exploration licence region.Unless and until Ok Tedi Mining Ltd demonstrates that it is able to operate the current mine in an environmental and socially acceptable manner it is not in the interest of the Papua New Guinea state for Ok Tedi Mining to explore for further mineral deposits in this area. If the company does not demonstrate this the PNG state and community will pay the true and full costs of the mining.
We call upon the minister to refuse the extension of the exploration licence on the above grounds.
Yours Respectfully,
…………………….
Wep Kanawi O.B.E
Convenor and Spokesperson- N.E.W.G
NEWG - PNG's environmental watch group . This is a pivotal group of social and environmental NGOs and individuals who have become extremely concerned about unabated / uncontrolled permanent ecological damage inflicted on the environment and social fabric of communities by development enclaves particularly mining. Our concern is no different to likeminded people in developed countries who demand a healthy and unpolluted environment. Unlike communities in developed countries where it would feasible for them to be more easily relocated; PNG's societies depend entirely and permanently on their local ecologies for food, water, shelter , medicine and cultural well being.
Reference:
BHP: BHP and Ok Tedi Discussion Paper, October 1999
Copper: River Chemistry Model, Simon Apte, OTML August 1999
DLRA: Detailed Level of Risk Assessment, Parametrix & URS Woodward-Clyde, OTML August 1999
Peer: Comments on the Science Underlying the Human Health and Ecological Risk Assessment, Peer Review Group, OTML August 1999
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