Protect the Litchfield-Finniss region from uranium & lithium mining

Submission Writing Guide – URO application for a mineral exploration licence EL33285

Submissions due before 7 October 2022 by emailing This email address is being protected from spambots. You need JavaScript enabled to view it.

Summary

On 7 September 2022 URO Corporation Pty Ltd advertised in the NT News notification of their application for a minerals exploration licence covering 299km2 of land adjacent to Litchfield National Park (see above map). The application states that URO Corporation will explore for uranium, lithium, rare earth metals and precious metals. However the significant target of their exploration is uranium with drilling planned in year two of the exploration licence, if it is approved. We believe that the environmental, social, cultural, and recreational values of Litchfield National Park and the Litchfield-Finnis region are seriously threatened by this proposal and that the public should be fully informed about the potential impacts. We know that the residents of Darwin, Palmerston, Litchfield-Finniss and other areas of the Northern Territory and want to see Litchfield National Park and the Litchfield-Finniss region remain safe and healthy for the decades to come.

What is involved in URO Corporation’s application for mineral exploration licence EL33285?

The proponent of the exploration application EL33285 is URO Corporation Pty Ltd.

The mineral exploration licence EL33285 proposal involves the possible exploration of approximately 299km2 of land in the Litchfield-Finniss region adjacent to Litchfield National Park near Wangi Falls (see blue outlined area on map) over a period of six years, including clearing land and drilling for uranium. During exploratory drilling for uranium the environment and waterways could be exposed to toxic contaminants. Any contamination would need to be managed and possibly removed from the site which would include being transported through Litchfield National Park.

What are the problems with the project?

  • Exploration for uranium can threaten human health
  • The possible clearing of land for exploratory drilling will destroy wildlife habitat
  • Tourism and local business can be negatively affected
  • Cultural sites may be affected
  • Possible contamination of land and waterways from Litchfield National Park to Channel Point through seasonal flooding

What should I include in my submission?

The most important thing to convey in your submission is your concern about possible negative impacts of the proposed exploratory licence and your interest in seeing the environmental, cultural, social, and recreational values of Litchfield National Park, the Litchfield-Finnis region and Channel Point protected. It is powerful to discuss the issues that are relevant to you through your recreational, professional, or cultural connection to the area. We need to demand transparency and accountability and ensure that the public are fully informed about the toxic activity planned for the Litchfield-Finnis region.

More points and wording for a submission can be found in the Protect the Litchfield-Finniss region from uranium & lithium mining petition on Change.org at https://chng.it/QWf92Tx5 and in the example submission letter on the following pages.

How do I make a submission?

Submissions are due to the Mineral Titles office before 7 October 2022 by emailing This email address is being protected from spambots. You need JavaScript enabled to view it.

Could you include the This email address is being protected from spambots. You need JavaScript enabled to view it. in your emailed submission?

Is there anyone I can ask for help about writing the submission?

Laura Cusack can answer questions you have about the submission. This email address is being protected from spambots. You need JavaScript enabled to view it.

Your Name

Address Line 1

Address Line 2

 

Date Month Year eg 26 September 2022

 

Mineral Titles

Department of Industry, Tourism and Trade

 

By email: This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Dear Minister

 

URO Corporation Pty Ltd application for the grant of a mineral title EL33285

 

I am writing about URO Corporation’s application for the grant of a mineral title to explore for uranium and lithium on 299km of land in the Litchfield-Finniss region advertised on 7 September 2022 in the NT News.

 

[Write about who you are and how this proposal affects you] My partner and I are land owners of 20 acres of land in the proposed exploration area. We grow our own organic food and the creeks that flow through the area are our only water source for drinking and watering food crops, therefore we are directly affected by URO’s mineral title application, particularly if there is exploration for uranium and lithium by drilling.

 

I believe the licence should be rejected on the following grounds:

 

[List all points that are important to you. Additional points can be found in the petition at https://chng.it/QWf92Tx5]

 

  1. Mineral exploration, especially drilling for uranium which URO Corporation states will be their significant target, could negatively impact the environment and the creek and river systems in the area which are water sources for local flora and fauna as well as the only water source for residents who live in the area. The University of New South Wales’ Global Water Institute and the Environment Centre of the Northern Territory (ECNT) undertook a longitudinal assessment of the publicly available information on water related issues at Glencore’s McArthur River Mine over the period 2007 – 2018. The study analysis shows repeated failures on behalf of the mine site Operator and Mining Regulator to act in a timely manner to address risks to sensitive aquatic environments and has resulted in unacceptable risks to the Northern Territory environment and the downstream community of Borroloola. In 2014 the mine’s leaky tailings dam was found to be at risk of collapse and due to the leakage, high levels of lead were found in local fish stocks and 400 cattle had to be destroyed after the Department of Mines and Energy found cattle contaminated with lead after they drank from a contaminated creek (ECNT, date unknown). The water related issue at the McArthur River Mine is just one example of how the Northern Territory Government and mining companies are unable to respond adequately to protect water sources from contamination by uranium. The Rum Jungle tailing dam leakage and dam wall collapse, is another example where the Finniss river was contaminated with devastating results. We do not want to see this devastating environmental, water and business damage to occur again in the Litchfield-Finniss region.

 

  1. The proposed mineral exploration area is dangerously close to Litchfield Park’s Wangi and Cascade Falls, situated within the Litchfield National Park tourist precinct, which are Koongurrukun people’s cultural sites that require respecting and protecting by the Northern Territory Government.

 

  1. Litchfield National Park and the proposed exploration area have also been identified as home to 21 threatened species including the critically endangered Curlew Sandpiper, Eastern Curlew and Far Eastern Curlew as well as the endangered Australian Painted Snipe, Black-footed Tree-rat, Northern Quoll, and the Gouldian Finch. Allowing mineral exploration, especially for uranium, in the area will disturb and potentially destroy the habitat of these threatened species.

 

  1. There is also the prevalence of Gamba grass (Andropogon gayanus) in the proposed exploration area. Gamba grass is a highly invasive weed that is extremely harmful to the Northern Territory's natural environment. The grass seed is spread many ways including on the wheels of vehicles. Recent news reports have stated the large number of fires in the Litchfield and nearby Adelaide River areas over the recent months have been fueled by the prevalence of Gamba grass. There is grave concern that mineral exploration and mining in the proposed exploration area would create potential spread of Gamba grass through Litchfield National Park and other areas in the region via heavy vehicle movement between properties in the area, Aboriginal land, Litchfield National Park and sale destination.

 

  1. Landowners in the proposed area operate tourism and accommodation businesses as well as cattle stations that could be negatively impacted by the approval of the exploration licence for uranium and lithium, in particular. Landowners and residents also grow their own food crops. URO Corporation and any company granted a mining exploration licence in the Northern Territory is under no obligation to assess any possible impact or substantial disturbance to landowners and residents’ income, livestock, business, assets or ability to grow food on the land which may have taken many years and significant investment to establish. 

 

  1. The proposed exploration area borders Litchfield National Park on one side and the Aboriginal lands of the Wadjigan and Kiuk people, and the Channel Point Coastal Reserve on the other. The Channel Point region is home to the Peron Island, Bulgul community and Channel Point community. The area, including the Peron Islands, is a protected coastal habitat that is an identified area of international conservation significance and home to threatened and significant fauna. The area is also an important tourism area via a permit system as well as facilitating numerous fishing charters. The proposed exploration area is home to a network of river systems that are a part of the Daly Basin, including the Anton Bay and associated coastal floodplains which connect with the mouth of the Daly River and flows into Wadjigan and Kiuk lands and the Channel Point area. Any contamination from wastewater overflow in the proposed exploration area could spill into these interconnected river systems via floodplains in the wet season and have a potentially devastating effect on a pristine environment in the Channel Point area, one of the most fertile fishing grounds in the Northern Territory. 

 

  1. With local waterways so interconnected and multiple biodiverse areas, protected habitat, flora and fauna connected to these waterways as well as these waterways providing the only accessible drinking and crop water in the area, this is a situational context that should be seriously considered in assessing this mineral exploration application.

 

  1. We are very concerned by the prospect of increased heavy vehicle movements between properties in the area, Aboriginal land, Litchfield National Park and sale destination due to the damage these vehicles can cause.

 

  1. We are extremely concerned about the methods involved in uranium and lithium exploration and mining and their environmental impacts. We understand that the methods used can be extremely damaging to the environment, water intensive with billions of litres of contaminated water to dispose of and involve a form of strip mining for pegmatite which occurs throughout the region, as well as blasting, crushing and processing using toxic chemicals. We need look no further than the legacy of the Rum Jungle mine in the Litchfield/Batchelor area for evidence of the damage of government approved uranium mining. Following the collapse of the mine’s tailing’s dam, 100 km2 of the Finniss River system was polluted killing all plant and animal life for a 10 kilometre stretch of the river (Senate Select Committee on Uranium Mining and Milling, 1997). To this day, 50 years since it closed, the Rum Jungle mine site continues to leave a legacy of environmental damage so severe that it will cost hundreds of millions of tax payers’ dollars to rehabilitate the site over decades (ABC News, 2021). The Northern Territory Government has an obligation to never allow this gross environmental destruction to occur again in the region.

 

  1. The Senate Select Committee on Uranium Mining and Milling report published by the Australian Government in 1997 found that uranium mines, including Rum Jungle, cause serious environmental damage through acid mine drainage in terms of tailings waste, production and mining processes. Tailings from uranium mining contain 80% of the level of radioactivity of the original ore as a result of the presence of uranium decay products such as Thorium 230, Thorium 234 and Radium 226. The environmental impacts of tailings have been well documented for uranium mines including the Roxby Downs and Ranger uranium mines, as well as Radium Hill and Rum Jungle. (Senate Select Committee, 1997).

 

  1. We have no faith that the Department of Industry, Trade and Tourism (the Department) will appropriately monitor and regulate the activities of URO Corporation. Section 66 (2) under the Mineral Titles Act states that “no later than 14 days after lodging an application for the grant of a mineral title, the applicant must serve a notice of the making of the application on each landowner listed in the application.” In the case of EL33285, URO Corporation did not serve notice to landowners in the area within this timeframe. Notices were served by URO Corporation to landowners nine months after the application was submitted, two weeks before URO Corporation advertised the application for the granting of a mineral exploration licence. Notifying landowners so late after the application was submitted left landowners in the area very little time to prepare submissions which are due, under the Mineral Titles Act, within 30 days of the application being advertised. Landowners and other stakeholders in the area have been severely disadvantaged by this action undertaken by URO Corporation. When the Mineral Titles Office (the Office) were contacted by phone about the notification timeframe they stated that they have no way of knowing if applicants have actually served notifications to landholders within the requirement of the Mineral Titles Act. It appears the Office does not have appropriate processes in place to ensure applicants are following the required regulations. This becomes increasingly important given that under section 58 (2)(b) of the Mineral Titles Act “the applicant must have complied with requirements under this Act” and under section 70 (2) “If the Minister is satisfied the applicant has not met the necessary criteria for the application, the Minister may refuse the application.”

 

Yours sincerely

 

Name

Address line 1

Address line 2

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