We object to Mod 16.
the proposal should be delt with as a part of CVO's proposed CCOP 21 EIS application

I support the project

as a representative of the orange landholders CCC group we have had the opportunity to view and hear the CVO presentations on this MOD16 --after listening to CVO and asking questions of staff and expert personnel, it appears to be a sound project to utilize these sands derived from tailings, firstly to reduce tailings being deposited into Cadia pit, but also being retained in buttressing existing structures of the tails dam walls.
subject to the protocols of building using these sands, it would seem to be a logical use of this material going forward.

I object to MOD 16 on the following grounds.
I am a friend of a local resident and have seen the lengths they have had to go to get their dust concerns taken seriously. I have also witnessed the impact on their mental and physical wellbeing, including medical test results showing harm; this underlines the urgent need for stringent assessment, mitigation and genuine community consultation.

My concerns in summary are:

1. Inadequate community consultation

- Consultation downgraded to drop-in sessions with no formal presentation/Q&A specific to MOD 16; this prevents meaningful public scrutiny.

- Newmont/Cadia must hold presentations, plus formal Q&A sessions for the EIS/CCOP before any approval; current consultation is not sufficient.

2. Significant long-term impacts from hydrocyclone sands

- The technology will be used for the life of the mine, requiring 24-hour heavy machinery for wall construction and consolidation, causing ongoing increased noise and disturbance.

- Sand deposition and bulldozing will generate substantially more dust (including crushed ore particulates) for the life of the mine, worsening existing air quality problems.

3. Non-compliance, inadequate planning and AMD risk

- MOD 16 lacks a Final Landform Evolution model, a Rehabilitation Plan, and adequate acid mine drainage (AMD) risk controls. The proposal improperly assumes future CCOP actions will mitigate risks.

- Local waterways and bores already show signs consistent with contamination; approving MOD 16 without robust AMD, dust and rehabilitation plans is unacceptable.

4. CCOP uncertainty

- CCOP is incomplete and repeatedly revised; MOD 16 must not be approved piecemeal or relied upon until CCOP is finalised and independently assessed.



Requested outcomes

- Reject MOD 16 until a full EIS is published and CCOP finalised.

- Require formal public presentations with recorded Q&A, plain-language summaries, independent peer review of technical reports (dust, noise, hydrogeology, AMD, rehabilitation), and binding mitigation, monitoring and rehabilitation funding commitments.

- Require strict controls on night works, noise attenuation, and dust suppression accounting for PFAS, heavy metals and respirable silica.

I am writing to object to Cadia Valley Operation’s Mod 16 proposal.
As a member of the surrounding community, I have attended many meetings over the last few years which have involved discussions on the hydrocyclone sand dam proposal.
I believe that the hydrocyclone technology is not the safest or cleanest option available, though it is probably the cheapest while also providing 'greenwashing' by the company around reduced diesel fuel usage.

Please find detailed below my objections and suggestions in relation to:
1. Dust and Air Quality Risks Are Still Not Fully Addressed
2. Water Contamination Risks Need Stronger Controls
3. Geotechnical Stability Must Be Independently Verified
4. Dry Stacking Should Be Properly Assessed as a Safer Option
5. Transparency and Trust Are Ongoing Issues
6. Rehabilitation and Long Term Landform Stability Need Clearer Guarantees

Detailed comments:

1. Dust and Air Quality Risks Are Still Not Fully Addressed
Mod 16 relies heavily on recovered sand, which can generate silica and metal dust when stockpiled or moved. Stockpiles and moving sand can create silica and metal dust that settles on homes and in rainwater tanks.
Even with wet emplacement, the community has already experienced dust exceedances and ventilation shaft emissions in the past. Mod 16 does not guarantee that dust levels will remain safe during 24/7 operations.
Suggestion/Request:
- Continuous real time dust monitoring at more sites around the boundary and further afield.
- Real time public warnings of dust exceedances at monitoring sites via text message. The present system of ‘watch the bureau of meteorology for wind warnings’ is insufficient and places the onus on the public to monitor these sites on a regular basis. The public should be proactively informed of issues, not have to check for them ourselves after the fact.
- Enforceable limits on exposed sand stockpile areas.

2. Water Contamination Risks Need Stronger Controls
The proposal changes how tailings and sand are handled, which can alter seepage pathways. Communities downstream face increased risk of contamination if controls fail.
Local bores have already shown elevated sulfate and PFAS levels. Mod 16 does not provide enough detail on how seepage will be prevented or how failures will be detected early.
Suggestion/Request:
Mandate independent hydrogeological review, expanded groundwater monitoring, and automatic shutdown triggers if contamination increases.

3. Geotechnical Stability Must Be Independently Verified
The 2018 embankment slump shows that undetected foundation weaknesses can lead to failure. We need proof the buttress won’t fail or erode.
Mod 16 relies on recovered sand, which has different stability characteristics than rock. The community cannot rely solely on company funded modelling.
Suggestion/Request:
Require independent geotechnical peer review, public release of stability modelling, and a comparative assessment of dry stacking as a safer alternative.

4. Dry Stacking Should Be Properly Assessed as a Safer Option
Global data show that hydrocyclone sand facilities have experienced failures. Reducing water in tailings (dry stacking or farming) materially lowers catastrophic failure risk.
Mod 16 does not include a proper comparison of long term risks, costs, or environmental impacts between wet sand buttressing and dry stacking.
Suggestion/Request:
Require a full feasibility study comparing Mod 16 to dry stacking/farmed tailings, including lifecycle risk, water impacts, and long term stability.

5. Transparency and Trust Are Ongoing Issues
Many residents, myself included feel that the community consultation processes undertaken by Cadia Valley Operations provide lip service at best to the concept of consultation. The community is only ever advised what ‘will’ happen, and genuine, informed and scientific concerns are not given any meaningful responses. Past incidents (2018 slump, 2022 dust audit) have eroded trust, and there has been no improvement.
Mod 16 does not include new mechanisms for transparency or community oversight.
Suggestion/Request:
Require independent community oversight committees, transcribe CCC meetings to ensure honesty in publicised minutes, public access to real time monitoring data, and mandatory reporting of all exceedances within 24 hours.

6. Rehabilitation and Long Term Landform Stability Need Clearer Guarantees
The final landform must be “safe, stable, non polluting, and self sustaining,” but Mod 16 does not provide enough detail on erosion control, vegetation success, or long term monitoring.
Given the scale of the buttress, the community needs assurance that the landform will not degrade or release contaminants over decades.
Suggestion/Request:
Require legally binding rehabilitation bonds commensurate with the scale of the project and potential for contamination, independent audits, and long term monitoring commitments.

I am personally concerned about the Mod 16 and how well the new technology of hydro cyclone sands has been tested on a worldwide basis. How wil this now effect the local community if it fails like the current tailings dam wall has? To what extent has there been proper scrutiny of these changes?.
Since 2025 Newmont has reduced the level of community consultation from whole community meetings to drop in sessions only. This is just like the local council, where they don't like to have a variety of questions from people for everyone to hear many perspectives and other issues that not everyone has thought of. To the best of my knowledge the community has not received a presentation with a question and answer session for Mod 16. The one on one sessions are poorly attended simply due to the nature of them. They have generally been held in Orange at a Cafe, which is further distance for me to travel to attend, being a 120km round trip. I don't believe the community has been thorougly consulted on this Mod 16 by Cadia VO.

From my understanding Hydrocyclone sands technology will require 24 hour operation of heavy machinery to build the walls, does this not mean there will be a significant increase in noise for local residents? Will this therefore continue for the life of the mine?
I believe the tailings dam walls are to be built from the larger particles of “sands” generated by crushing the ore and particles will be deposited via pipes pumping from the processing area to the tailings dams. These deposits will then be moved around and consolidated by large track bulldozers. Will this not create more dust blowing over the local community for the entire life of the mine?. The community has already been submitted to phenomenal levels of dust for over the past decade and the authorities owe it to the community that they now have air which is free from crushed heavy metals, silica and PFAS in order to repair the damage done to the landscape and human health.
There does not seem to be any Rehabilitation Plan?
Has there even been a geochemical analysis that will guarantee the community that there will be no acid mine discharge? This is of particular concern given there is already evidence of this developing in the district in our local creeks, bores and the Belubula river.

In conclusion I don't believe the community fully understands what is proposed in this CCOP. There have been countless changes, rewritten reports and missed deadlines. It is therefore difficult to even know what the final CCOP includes.

Mod 16-"NTSF hydrocyclone sands buttressing" is being used as a back door type of approval for a new process & new technology, that has been strongly questioned at community consultation meetings but no significant or clear answers have been given to the community. Hydro cyclone sands will have the effect of significant change in the impacts of CVO on the local community & especially to close nearby residents like me who are located very close to the mine & will be even closer if this buttressing is constructed. There has been no proper scrutiny of the changes this will have in different ways on the community & surrounds.
They have not been able to answer how loud this technology will be & how loud acoustically it will then effect nearby neighbor's such as myself on the eastern side of the mine. There is also the question of light pollution from the these hydrocyclone sand towers as there is to be lighted areas surrounding them. but they will not address this question.

During construction there is planned to be 24 hour operation of heavy machinery to actually build the walls, this will increase operational noise both in time & duration that nearby residents will have to endure & it will be a significant increase operational hours that we will have to endure more noise, especially during normal sleeping hours for the community. This will continue and for the foreseeable future & you would expect it to increase under CCOP for the life of the mine.
The community was told that Mod 16 was about buttressing the northern wall. What has been communicated to the community has been misleading, especially about the scale of what is planned. Now it appears that Mod 16 expects to supposedly buttress the northern dam wall with “sands” and deposit excess sands as a stock pile in heaps on the southern dam surface.
The community doesn't know what is proposed with the latest CCOP concept, it has changed so many times & in so many different ways & the community consultation information nights have been poor at best & treated the community with disdain, even saying "it is too complex for you to understand". They have missed some by more than at least a year with supposed expert's reports being rewritten. They say that the critical elements are the same as CCOP but we don’t know what CCOP looks like anymore. The format of the community engagement meetings has been changed multiple times without consulting the community & when we have requested to go back to the original type of format with everyone in the same room & being able to ask questions & discuss it, we are told " this new format is better". We aren't being LISTENED TO & we are definitely NOT BEING HEARD!
Lastly, Mod 16 does not comply with the Global Industry Standard on Tailings Management (GISTM).