Copi Mineral Sands Project

Farmers in Far West New South Wales say a mining company's failure to provide key documents on radiation risk and its history of breaching mining rules should be enough to stop its proposed $1 billion mineral sands mine.
Farmers Shane and Ferna Vagg, whose land has been subject to exploration drilling by RZ Resources, said the company could not be trusted to manage a large mining operation responsibly after it was found in 2021 to have lied to the NSW mining regulator and in 2023 was found to have flouted mining rules.
The Brisbane-based company claims to have discovered a trove of valuable mineral sands south of Broken Hill — a deposit that includes rare earth elements, zircon, rutile, leucoxene, ilmenite, monazite and xenotime — valuable for their use in renewable energy technologies and medical devices.
RZ Resources plans to mine the deposit over 17 years, creating 240 ongoing jobs during operation and a net present value of $1 billion over the life of the project, according to the company's Environmental Impact Statement, submitted to the NSW government in May.
Ferna and Shane Vagg do not want the project to go ahead.(ABC Rural: Else Kennedy)
Breaching rules
The Vaggs, who farm goats on a station between Wentworth and Broken Hill, said the prospect of RZ Resources operating a mine 1.3 kilometres from their home was "terrifying".
"If they couldn't do the right thing as an exploration company, I have a great fear that they won't be able to manage that if they ever become a big operation," Mr Vagg said.
"You can't trust them and you don't have any faith that they'll abide by the rules."
Documents obtained under the NSW Government Information Public Access Act show RZ Resources received an official caution and a penalty notice from the NSW Resources Regulator in 2021 for providing false and misleading information to the regulator.
The documents show the company made a written statement to the NSW Resources regulator in 2020 claiming it had plugged and rehabilitated drill holes on a property neighbouring the Vaggs.
"All work pertaining to the landholders (sic) requests for rehabilitation of tracks has been successfully completed and is (sic) verbally happy with what has been repaired but no written approval has been requested," the company wrote.
Four months later, the regulator met with the affected landholder, who told inspectors he had never been consulted by the company.
During a site inspection the regulator found drill holes on the property that hadn't been rehabilitated.
The incident wasn't the company's only breach of mining rules.
In 2023, the resources regulator found the company had breached mining rules 22 times while exploring for mineral sands in 2020.
The list of breaches included drilling to unapproved depths, using unapproved machinery, failing to have an adequate community consultation strategy, failing to rehabilitate land, failing to consult with landholders, digging sump and burying soil without approval, and failing to comply with requests for information.
RZ Resources signed an enforceable undertaking with the regulator in response to the findings, agreeing in 2023 to pay $160,000 to compensate the community and improve its practices.
Radiation risk
The company has submitted an environmental impact statement for public exhibition as part of the mining application process.
But a radiation health expert who has viewed the documents said it lacked important details about radiation risk.
Tilman Ruff says the statement lacks detail about radiation.(ABC News)
University of Melbourne school of global health honorary fellow Tilman Ruff labelled the documents RZ had submitted "extraordinarily deficient".
"You would expect that an environmental impact statement, which really is the most comprehensive document about the project and its implications for for the environment, for people, and for public safety, that it would be a fairly comprehensive overview of all aspects of the mine," Dr Ruff said.
"There's barely a mention of radiation, either for workers of the mine or for the public.
"And there are considerable possible public exposures to mine products, both in the vicinity of the mine [and along] the transport route."
Mineral sands contain trace amounts of uranium and thorium, which are radioactive.
In a statement, RZ Resources chief operating officer John Costigan said the company's environmental impact statement was a comprehensive document in accordance with NSW government requirements.
He said it outlined detailed plans to address all aspects of the proposed development, including handling of monazite, which was a critical mineral for the development of wind turbines and other renewable energy sources.
RZ Resources' environmental impact statement says the company will "obtain and maintain a range of radiation-related occupational health and safety permits and approvals and would implement stringent controls and monitoring to manage the health and safety of workers and visitors".
An industrial facility on the Brisbane river, pictured from a height. In the foreground are three silo-type structures.
RZ Resources plans to transport the mineral sands to Brisbane.(Supplied: RZ Resources)
Finances questioned
In a report submitted to the Australian Securities and Investment Commission in 2023, independent auditor Mark Jeffery from KPMG found there was a "material uncertainty" over RZ Resources' finances.
He said it "may cast significant doubt on the group's ability to continue its normal business activities and ensure that it operates as a going concern, and, therefore, that the group may be unable to realise its assets and discharge its liabilities in the normal course of business".
In a statement, Mr Costigan said the company was "well advanced in progressing and securing funding and investment for the capital expenditure required for the project, in line with many other pre-production mining companies".
Rare earth elements are in high demand for their use in wind turbines and electric vehicles.(Supplied: Australian Rare Earths)
Government responds
The NSW Department of Planning, Housing and Infrastructure said RZ Resources' mining proposal would undergo "rigorous assessment".
The NSW government has given members of the public 28 days to respond to the 3,000-page environmental impact statement for the proposed Copi Mineral Sands Project, with submissions closing on Tuesday.
"Following exhibition, the applicant is required to address all issues raised in submissions along with government agency advice received," a department spokesperson said in a statement.
"This includes concerns raised regarding radiation risks associated with mining and processing mineral sands."
They said the department would consider all community submissions, along with advice by government agencies and councils, as part of its assessment.
"This will include relevant legislation, policies and guidelines before a determination is made," the spokesperson said.

I am writing to object to the Copi Mineral Sands Project in the Wentworth Shire.

This project will adversely impact upon members of my family both now and for generations to come. I have watched my family members pour their entire lives, all their time and money into developing their farming land so that they may continue to farm there for generations to come and enjoy the way of life they have chosen. If this project goes ahead they will be unable to continue to farm in the way that they have. It will reduce their productivity and the quality of their products as well as causing them an endless amount of stress dealing with a company that has already shown a total disregard for them and their rights as landowners.

The project is already having a detrimental effect on the environment shown by RZ's inability to abide by rules and regulations and this is only in the exploration phase. It is horrifying to think that this project might be allowed to get to a point where RZ is in charge of managing radioactive material. This incompetent company have shown total disregard for the farmers and land that they impact on now, and their culture would dictate that they will not show any regard for the communities that it will impact upon in the future if this project is allowed to go ahead. Once the mining is all finished and they have got what they want (and made money off it) the people of the area will be left with the after effects of their land and waterways being destroyed and poisoned. RZ have shown that they can't manage and rehabilitate land whilst they have been exploring it, so I don't trust that they will act safely whilst mining it or return the land to a suitable state after mining it.

I am also concerned that this project will detrimentally impact my family's health with the potential for harmful waste products being so close to their house impacting on water and air quality. And when we visit my young children and I will also be exposed to this harm.

The increased traffic, dust, noise and light pollution in the area will impact on the natural beauty and the native animals.

This project should not be allowed to go ahead it will cause a great amount of damage to the environment and the people of the area. This is not a sustainable or safe way forward and I strongly object to this project.

https://www.abc.net.au/news/rural/2024-06-17/rz-resources-copi-mineral-sands-project-raises-farmer-concerns/103972214

We are writing to object to the establishment of the RZ Resources mineral sands project between Wentworth and Broken Hill. We thank the panel for the opportunity to provide this submission.

Landowners and community members are severely disadvantage with EES process, they don’t have the financial or technical resources to compete with a large corporate business, who are very much favoured in this process. All studies carried out are done by the developer using their own favourable consultants with no limit on time to prepare, to be fair these should be carried out by independent experts, and peer reviewed. Objectors on the other hand are given only days to read and research the EES, this inhibits the people who will have to live with the consequences from the mining activity, including loss of livelihood for future generations, to adequately defend themselves and the environment.
Documents obtained under the NSW Government Information Public Access Act show RZ Resources received an official caution and a penalty notice from the NSW Resources Regulator in 2021 for providing false and misleading information to the regulator. This is unacceptable. In 2023, the resources regulator found the company had breached mining rules 22 times while exploring for mineral sands in 2020.
The list of breaches included drilling to unapproved depths, using unapproved machinery, failing to have an adequate community consultation strategy, failing to rehabilitate land, failing to consult with landholders, digging sump and burying soil without approval, and failing to comply with requests for information.
While the company has promised to compensate the community and improve its practices, the best judgement of future behaviour is by looking at past behaviour, this company cannot be trusted to comply with regulations.
Radiation is of huge concern, there's barely a mention of radiation within the EES, either for workers of the mine or for the public. There are considerable possible public exposures to mine products, both in the vicinity of the mine and along the transport route. We need more rigorous examination of the effects of radiation and its implications for the environment, for people, and for public safety, that this mining activity can be carried out so close to someone’s home (1.3 kms) is unacceptable. People’s health and safety is paramount.
Landowners and community members need more government representation, mining companies are destroying people’s futures and not being held to account. Compensation does not heal the damage caused by these mining companies.


we thank the panel for the opportunity to express our concerns

RZ Resources is not a "fit and proper person" eligible to operate a mine. Please refer to ABC report by Else Kennedy: RZ Resources' Copi mineral sands project raises concerns for NSW farmers.
The following are impacts of concern, should mine be approved:
Radioactive and Respirable Crystalline Silica dust
Large quantities of Chemicals of Concern (CoCs), flooculants, acids, hexavalent Chromium etc used in ore processing.
Noise Nuisance for surrounding landholders, i.e. farming families
Adverse health impacts on humans and other species
Pollution of groundwater and surface water and consequent impacts on Lake Victoria and the Ramsar-listed Murray Darling Basin waterways and wetlands
Potential for Adelaide water supply sourced from the Murray to be contaminated
Adverse impacts on flora and fauna, biodiversity, and ecosystems services essential for human welfare and prosperity as well as the Environment
RZ Resources has NO SOCIAL LICENCE having treated affected persons very badly. Land access agreements not established or refused
Project does not comply with Commonwealth Critical Minerals Strategy
Impacts of agriculture have not been considered including ability for soils to be fully rehabilitated so as to be capable of agriculture in the future
Greenhouse emissions created will completely cancel out any savings from any minerals recovered
Promised jobs will not eventuate. It is well-known that any new mine takes at least 10-15 years from approvals to start operations.
This mine is not in the public interest
I WISH TO BE HEARD

To Whom it may concern,

I object to the Copi Mineral Sands Project.

1. RZ resources have demonstrated a willingness to flout regulations during the exploration phase. This can either be due to not being aware of the regulations, or that they were aware of the regulations. Either way they have satisfactorily demonstrated that they are not a fit and proper organisation to be entrusted with a project of this nature.

2. It is not clear that RZ resources have the necessary financial backing to deliver the project and remain compliant, particularly given the previous comment.

3. The economic projections leave no doubt that the project is not a financial proposition before even starting. RZ resources claim that the mine will create 240 jobs and earn $1b during the life of the project - say 20 years. This means that of that $1b, assuming the average wage is $120k there will only be $424m for mine operations, finance costs, transport, refining, compliance and rehabilitation, let alone profit. Let's be clear, the projections would certainly be the most optimistic possible, the average wages would certainly be higher than $120k,particularly with senior management taking salaries many times higher, and costs are always rising. This project is doomed from the start- it beggars belief that it has got to this stage. It is NOT economically feasible.

4. The risk of radioactive dust contaminating the area is not fully understood. A peer reviewed analysis must be undertaken to understand this risk, identify preventative measures, create operational systems to implement risk minimisation strategies and then have these endorsed by the local community.

5. The local pastoral community has been creating wealth in this area for more than 150 years, and will continue to do so in the future as long as contamination from this project doesn't occur. Given RZ resources previous conduct and fines, it would seem unlikely they can deliver any risk management strategies in good faith. RZ Resources pose a risk to the local community and the long term economic opportunities of the local landholders.

6. Road network - due to heavy vehicle traffic, the local dirt road network would require major upgrades, given the concern over RZ Resources funding, it is likely that the local road network would suffer rather benefit from the presence of this mine.

7. Water contamination - there needs to be a peer reviewed study and analysis of the impacts of this mine on groundwater. The shallow hyper saline local groundwater migrates South and West, ultimately reaching the floodplains of the River Murray and Lake Victoria. During periods of high flow when the floodplains are inundated the floodplain becomes saturated, dissolving salts and other materials. Other materials are held in suspension. Upon recession the groundwater flows from the floodplains into the river. The Murray River is the lifeblood of Eastern Australia, supporting people, communities, livestock, horticulture and industry. The damage to our reputation as a clean-green producer would be tarnished, the economic fallout would be counted in tens and hundreds of billions, our environmental credentials would be the laughing stock of the modern world. To consider a mine, with this proximity to the Murray River while understanding the local groundwater movements should be considered as environmental vandalism.

In closing, I assert that the economic credentials of this project do not come even close to break-even, the track record of RZ resources speaks for itself and the fact they are still in the industry must come as a surprise to many. The risk to the environment, the risk to the local ecology and the risk to our precious water resources is too high for this project to be considered for approval.

regards
James Robertson
Bellsgrove, Narweena and Chowilla Station.

As a proud resident of Wentworth, NSW, I am excited about the transformative potential of the Copi Project Mineral Sands Mine, located just 75 km from our town. This project promises to bring a wealth of economic, social, and environmental benefits, ensuring a prosperous and sustainable future for our community.

### Economic Benefits

1. **Local Job Creation**: The Copi Project will create numerous job opportunities for our community, both during the construction phase and throughout the mine’s operation. These jobs will provide stable incomes and reduce unemployment, allowing more families to thrive.
2. **Economic Boost**: The increased economic activity will benefit local businesses, from retailers to service providers. The influx of workers and their families will lead to higher demand for goods and services, stimulating local commerce and revitalizing our economy.
3. **Investment and Growth**: The project will attract new investments to Wentworth, encouraging the development of complementary businesses and infrastructure. This growth will create a more dynamic and resilient local economy.

### Social Benefits

1. **Enhanced Community Services**: The Copi Project’s support for local initiatives will lead to improved healthcare, education, and recreational facilities. These enhancements will directly benefit our residents, making Wentworth an even better place to live.

2. **Community Engagement**: The project’s commitment to regular consultation and collaboration with our community ensures that our voices are heard and our needs are met. This inclusive approach will foster a strong sense of ownership and pride among residents.

### Environmental Benefits

1. **Sustainable Practices**: The mine’s use of advanced, environmentally friendly techniques will minimize its ecological footprint, preserving the natural beauty of our region. This commitment to sustainability will help protect our local environment for future generations.

2. **Land Rehabilitation**: Comprehensive plans for land rehabilitation will ensure that mined areas are restored and revitalized. These efforts will maintain local biodiversity and contribute to the health of our ecosystems.

3. **Ongoing Monitoring**: Continuous environmental monitoring will guarantee that the project adheres to the highest standards. This proactive approach will prevent negative impacts and promote long-term environmental stewardship.

As a resident of Wentworth, I have seen firsthand the challenges our town faces, from limited job opportunities to the need for improved services and infrastructure. The Copi Project represents a beacon of hope, offering tangible solutions to these challenges. By bringing jobs, boosting the local economy, and supporting community development, the mine will significantly enhance our quality of life.

### Conclusion

The Copi Project Mineral Sands Mine is more than just a mining venture; it is a catalyst for positive change in Wentworth. The economic benefits will create a more vibrant and prosperous town, the social benefits will enhance our community's well-being, and the environmental benefits will ensure a sustainable future.

Supporting the Copi Project is an investment in the future of Wentworth, promising a brighter, more sustainable, and prosperous community for all of us. Let's embrace this opportunity and work together to realise the full potential of this transformative project.

please see attached file. If difficulties please contact myself.

To whom it may concern

We are a family with young children that hope to have a long connection and use of our land. As such we are worried about the long term effect of a mineral sands mine so close to our family home. With the possibility of air born contamination from the mining activities to affect the health of our family and the ability of us and future generation to farm and make a living off the land due to the factor of radiation and heavy metal contamination.

The ability of the mining company to control and manage their impact on the water table is also a worrying factor for the security of our stock and domestic water as well as the possible impacts to SA irrigation that relies heavily on Lake Victoria for their controlled water supply as well as the larger environment that could be greatly damaged with a simple miscalculation or mistake.

Another concern is also the very close proximity of the proposed mine site to areas of conservation of the endangered Nulla Nulla spear grass that as far as we are aware is only populated in a small area closely neighbouring the proposed mine site.

We as a family are also worried about the noise pollution and general disturbance of the natural peace of the surrounding area that will happen if the mine site is approved because both noise and light travel large distances without anything to stop them, not to mention the affect it will have on the condition of the road with staff coming to and from work.

Closer of the Nulla road will also affect the distance that our children will have to travel to receive their education. They currently travel to Broken Hill serval times a term for face to face learning and closer of the road will mean a longer and more costly trip for our family.

Best Regards

I object to this mining proposal as it appears underprepared, inadequately scoped, and lacking in substance.

The proposal contains a great deal of "word salad," using lengthy paragraphs to obfuscate rather than clarify points, thus avoiding any commitments that might hold RZ Resources accountable. This approach is highly suspicious and leads me to believe that RZ Resources will be the proverbial fox in the hen house if allowed to proceed with this project.

Particularly concerning is Appendix 14 of the EIS, which demonstrates either a lack of effort or a potential attempt to mislead. While it includes extensive government data, RZ Resources has shown minimal engagement with community concerns in the Wentworth area. Their efforts in this regard appear insincere at best.

I object to granting RZ Resources a mining license due to their duplicitous nature. However, if they are to proceed, they must be required to produce a genuine Environmental Impact Statement with real analysis and tangible goals that they can be held accountable for achieving.

As a landholder I will be directly impacted by the interference to the water table by RZ Resources, the underground aquifer runs from the north where the proposed Copi Mine would be established. The flow of salty water is tested at 120000ppm which is four times the salt levels as the sea, this flow currently causes the water table to be shallow around the south of Lake Victoria affecting the levels of salinity and the death of literally hundreds of trees. These flows are known to seep into the Murray System and the water storage of South Australia Lake Victoria. If the Copi Mine was to be allowed to interfere with this underground flow for the use of sludge mining, it would add heavy metals contaminants and radioactive particles to a water system that supply water to millions of people putting their health at risk. Heavy metals and contaminants would therefore also be in the water that is seeping into our farming land south of Lake Victoria rendering it unable to run livestock under Bio Security conditions that may find these contaminants in the meat and wool exported to the world. It seems that RZ Resources has no regard for the livelihood of people that rely on the land for their income and that contribute to the Australian economy. The Eis does not have the real view to the safety of the people that are in the vicinity of the mine as there is no protection for drinking water or ground water supplies that humans (real people) and livestock need to survive. The radioactive dust from this mine would cause cancer in both people and animals alike. RZ Resources claim to be able to make the mine site better after rehabilitation. There are several mine sites in Western NSW that could be considered baron wasteland and Copi would be no different. Perhaps a smaller version of Maralinga radioactive waste land. I ask you to consider carefully the contents of this EIS and the real facts of the Copi Mine. The people and the fragile environment should be protected from a ruthless mining company.

My submission is included in the attachment below.

I write to OBJECT to the Copi Mineral Sands project.
Please see my full submission in attachments.

Please note I have been unable to attach some supporting documents I have referenced in my submission as they are too large.
I can provide copies of these if requested.
These documents include submissions to the Goschen Mineral Sands Project on behalf of Mine Free Mallee Farms from the following authors: Harry Watts (radiation), Phillip Macumber (Hydrology), Peter Ramsay (air quality), Tillman Ruff (radiation).

Please see the below links to articles that have been referenced to in my submission:
https://www.abc.net.au/news/rural/2024-06-17/rz-resources-copi-mineral-sands-project-raises-farmer-concerns/103972214
https://www.abc.net.au/news/2024-04-22/explainer-what-is-mineral-sands-mining/103603660
https://www.abc.net.au/news/2024-05-28/family-separated-housing-crisis-rental-market-property-cost/103877562

As an adjoining landowner to the proposed Copi mine there is an issue that concerns me enough about the proposed development that in its current form I object to the project.
Having read the EIS I feel that one very important issue that has been brushed over is dust from the site that would end up on my property. There is a risk the dust would contain heavy metals and have radioactive particles in it. If this in turn is ingested by my livestock it could decimate my business as no market would take my produce.
Since this project has been proposed I have asked RZ resources on a number of occasions to provide an access agreement to drive through my property. Despite all of their assurances I am yet to see one.

I've been working and travelling in this area for some time now, and have come to love the country, with its diverse native plant and animal life, on a recent trip I was shocked to see the effect just an exploration drill hole had, with dead trees around the hole.
It's a concern if the aquifers are that salty and are distributed, bringing this water to the surface could be devastating to the surrounding area.
Also the radioactive component of the mineral sands hasn't been addressed, this is not a( she'll be right mate, we'll figure it out later) kind of thing, especially considering the proximity to Lake Victoria, a vital water supply to south Australia, and a culturally significant site, and the Murray River, and everything down stream.

As a frequent visitor and seasonal worker to the area of Wentworth and surrounding areas including lake Victoria, the Murray and Darling rivers, homesteads and stations in the area where the mineral sand project has been proposed to take place causes great concern to me and my family. First and foremost mineral sands contain trace amounts of uranium and thorium, which are radioactive can cause cancer and other life threating health implications. The mineral sand
can be easily spread by the wind into the water systems which is not only consumed by the the livestock it could contaminate the water supply for a vast amount of homes across the Riverland but also as going as far as Adelaide which is supplied by Lake Victoria. This puts a great number of people at risk of consuming this radioactive, heavy metal ridden supply of water.

Secondly, the damage to the land and wildlife will be extensive. The use of chemicals radioactive dust and loud machinery will no doubt have a impact on the local wildlife including the protected wedge tailed eagles who come to nest in the area not to mention all the native trees and plants that will be destroyed by the salt water being pumped out while trying to obtain the minerals so desperately wanted by the mining company potentially leading to decades or even centuries for the land to be farmed on. Where does that leave the farmers who own the land and rely on the regrowth to feed there animals? What will happen to the Kangaroos, Emus, Echidnas and birds that we love to see roaming and flying round the paddocks?

I strongly disagree to the development of this Mineral Sand Project and hope my concerns will be taken seriously.

I completely object and oppose to the Copi Mineral sands project proceeding.

This project and its “estimates” do not justify the long-lasting negative impacts it has on the community, the agricultural land, the livelihood, and livestock.

I as an indigenous woman, use one of the impacted property’s this property to connect to the land and culture when I often go out bush with my family. If this project was to proceed it will impact my connection to the land and my culture. I am not convinced that the evidence given or consulted with, will maintain, and preserve the Aboriginal history that resides on this land. If this project commences it cannot be reversed and our history dies with the drilling. The protection to artifacts and sacred sites presents now and yet to be revealed will be affected, destroyed, lost within this project. Despite the estimate or protective factors proposed, the risk is too great. Our people have already lost too much and are still suffering the consequences. Native animals and fragile ecosystems will be impacted and destroyed and cannot be repaired by planting other plants to replace them.

Long-term suitability of farming CANNOT occur due to impacts caused by this project. I do not trust that this company will comply with protocol or standards that are claimed in this Environmental impact statement (EIS). I am aware and have done research on this company’s poor compliance history. Yet already, this poor establishment has already have committed numerous offences with no accountability for not following mining legislation. This company only seeks for power and profit. “ESTIMATES” in the (EIS) is NOT ENOUGH!

All farmers in this remote community and wider rural community are significantly negatively impacted by this project. EVERYBODY has the responsibility and duty of care to prevent negative outcomes. This project has radioactive materials planned. Radioactive products, dust and waste WILL have significant impacts on the health of farther families, and animals causing morbidity and mortality. Life expectancy rates will be reduced, high cancer risk will be increased, and poorer health will occur due to the radioactivity! Farmers health will be at risk! Our government already are trying to close the gap and create better health outcome, and this will be another step back.

I strongly object. Do better, don't repeat history.

Strongly disagree with project as not enough local public consultation has been made. Does not look like enough studies have been done to make sure the underground water tables will not be affected. Increased heavy truck traffic on the silver city highway will be detrimental to the already deteriorating conditions of the highway surface. Radio active dust is a major concern for locals around the project.

I believe that this project should be undertaken with the utmost care. The things that Rz have done incorrectly or haven’t fixed up in this exploration stage shows that they may cut corners when the project starts. We as a community here do not want to live with others poor decisions and have our lives and our children’s lives at risk or exposure.

Please see my attached submission.
I OBJECT to this project.

Please note I am unable to attach the second document relating to RZ Resources' Enforceable Undertaking (due to document size). The document can be viewed at:
https://www.resourcesregulator.nsw.gov.au/our-role/enforcement-action/enforceable-undertakings-mining-act