Mod 5 – Extension of Mine Life

This submission focuses on surface-water risk and the use of 'closed-loop' language in the assessment of Modification 5. It does not dispute the proponent’s intent to manage water responsibly, but examines whether the framing, assumptions, and conclusions used in the Modification Report adequately reflect residual risk, exceedance conditions, and whole-of-river system impacts.

The submission is intended to assist the consent authority by identifying where conditional containment is relied upon to support conclusions of negligible impact, and where greater precision, enforceable thresholds, and clarity around risk allocation may be required to support sound decision-making.

Save Our Macleay River Inc is a community group, consisting of 8 Committee and 30 members. The attached submission sees flaws in the Modification 5 assessment, and highlights several issues that need address in the assessment, before progressing to any conditions of approval. The submission is not to prevent the mine from operating or increasing production etc. It objects to the lack of safeguards to protect Bakers Creek and the Macleay catchment from further contamination.

We strongly object to the proposed modification to the Hillgrove Mine Project.
We believe that the modification is not compliant with the Environment Planning and Assessment Act.
The details provided by Larvotto for the modification are extremely concerning, insufficient and contradictory (as details in our attached letter). The extension of mine life and increased production will have major impacts on the local community, especially in the realms of human health, the environment and loss of asset and property values

I'm in full support of this project as it will provide major benefits both locally (i.e employment) and nationally (i.e state royalties, critical minerals).

This submission addresses biodiversity impacts in the context of the river and floodplain as a highly complex interconnected living system, rather than as isolated ecological components. It highlights concerns that current assessments rely heavily on modelling, assumptions and mitigation claims that are not yet demonstrated in practice, particularly in relation to water quality, cumulative impacts, and recovery capacity.

My submission emphasises the need for precaution, transparency and decision-making that recognises the Macleay River and its associated wetlands as already under significant ecological stress, with limited capacity to absorb additional risk. It calls for governance that prioritises long-term ecological integrity and biodiversity recovery over short-term project timelines.

I support this modification; approval will provide significant economic stability to the local and wider communities.

This submission identifies potential human health risks associated with the proposal when considered in the context of cumulative and downstream exposure. The Macleay River system and adjacent floodplain communities are already subject to existing water quality stressors, including acidity, metal contamination, and episodic low-dissolved-oxygen events.
Human health risk assessment should therefore be undertaken against an already impacted baseline, rather than assuming environmental capacity or resilience. Where data gaps, modelling uncertainty, or reliance on assumptions exist, risk should not be displaced onto downstream communities, water users, or public health systems. A precautionary, exposure-pathway-based assessment is required, including consideration of cumulative, chronic, and event-driven risks over the life of the project.

I object to the proposed project as presented in the Mod 5 documents. There are several matters, outlined in the attached submission that ned address before assessment, determination and conditioning, before the Mod 5 proposal proceeds.

I support the project

I am writing to support the proposed mine extension. This mine provides steady work for many of whom live locally. These jobs help families stay in the area and give our community security and stability. The mine also supports many other local businesses, contractors, shops, and services that rely on it.
Mining has always been a big part of our community. It’s part of who we are and has supported generations of local families. Keeping the mine going helps protect that history and ensures our town continues to grow and stay strong.
The mining methods used here are carefully managed and designed to have very little impact on the environment and the land on the surface. The company monitors this closely, and the community sees the benefits of mining done responsibly.
Most importantly, this is a local mine that employs local people. The extension means ongoing work, ongoing support for local families, and ongoing benefits for the whole region. Losing these jobs would hurt our community, but continuing the mine will help keep it thriving.