Scotgold Resources Ltd are holding two “consultation” events at Tyndrum Village Hall on 10th and 24th May between 10.30 – 20.30 on new proposals for the Cononish goldmine. Their proposals are set out in a scoping report which is now on the Loch Lomond and Trossachs Park Authority Planning Portal (see here). The Report does not contain a clear description of how the new proposals differ from those already granted planning permission or the rationale for the changes.
The core of the proposal however appears to be that instead of a large proportion of the waste being returned to the mine (underground waste facility in map above) and the eventual restoration of the tailings facility (within orange line above), Scotgold is now proposing that all the waste from the mine be left outside.
The consequence of this, which you can see by comparing the two maps, is that the waste from the mining operation will now cover a far larger area of ground. Instead of the orange area in the first map, about half the ground within the boundary to the mining operation contained within the red line would be covered in mine waste. In order to make this acceptable Scotland are proposing that the waste be shaped to look like hummocky moraine (outlined in blue).
To give an idea of the potential landscape impact, its worth considering the photomontage of the temporary tailings facility in the original proposal (above). Under the new proposal it appears waste will cover over three times the area of ground.
The proposal to create artifical moraine out of mine waste
While the proposal to create artificial moraine appears clever, it would be a major alteration of the landscape formed by glaciers. There is an extremely fine hummocky moraine field at the head of the Cononish Glen around Dalrigh but none below the Eas Anie, the fine waterfall just above the mine entrance – that’s not an accident. Hummocky moraine would never have developed here, its too close to the steep sides of Beinn Chuirn. What Scotgold is proposing therefore is totally artificial and out of place in this landscape. Its inappropriate for a National Park created to protect the landscape.
There is nothing in Scotgold’s scoping report to say how they intend to construct moraine out of mine waste. Moraine normally comprise blocky till set within a matrix of grit and sand which holds the landform together and has done so successfully for thousands of years. Scotgold have said nothing about whether the mine waste would contain the right mix of material to construct artificial moraine let alone how they would do this. Nor have they said what will happen when the Allt Eas Anie, which flows through the middle of the proposed artificial moraine field, changes course as it will at some point and starts to erode into the side of the moraine mounds. Will the whole thing collapse or will both burn and mound be held together with concrete?
In the original planning consent for the mine the LLTPNA made a number of requirements in respect to waste from the mine, including:
“removal of all materials within the TMF [tailings management facility] and recirculation pond (which were not won from within the TMF) which shall be returned to the underground mine in the first instance until it reaches capacity, and the remainder used to re-grade the mine platform/processing building area; and the landscaping and re-vegetation of the track from the farm to mine platform)”
REASON: To minimise the adverse landscape and visual impact and ensure that the site is restored to a satisfactory standard in this sensitive area of the National Park.”
In my view they should stick with those conditions and uphold the original reasons for that decision.
What cost our landscape?
Whether the LLTNPA will do so however is another matter.
The new proposals appear to be all about money or, more accurately, saving Scotgold money in order to make a profit for their investors (who would appear no longer to include Owen McKee, the former LLTNPA Convener of the Planning Committee (see here) at the time the original planning application was approved). Scotgold have been running a trial, following the alteration granted to the original planning permission in January 2015 which allowed them to store waste in bags, and my guess is that from that trial they have quickly discovered that there is not enough gold in the ore to pay for their original waste storage proposals or full restoration of the land (or for the jobs that that restoration would create). It would be much cheaper simply to leave the waste on site, hence the present proposal.
Its dressed up of course with a few sops to the public:
The risk is the LLTNPA will use these sops as an excuse to approve the new proposal when a planning application is submitted. What drove LLTNPA approval of the goldmine was the promise of jobs – the lure of gold – and this is reflected in the planning permission granted for the current trial:
The question for the LLTNPA – to which I will return – is whether the creation of a few temporary jobs justifies this destruction of the landscape and whether the proposals meets the LLTNPA’s legal obligation to promote sustainable economic development.
The need for transparent decision making
The list of secret LLTNPA Board Meetings since 2010 FOI 2016-002 Appendix A list topics at Board Briefing sessions shows that the number of such meetings puts those of the Scottish Police Authority which has recently been forced to go public into the shade. Three considered the Cononish application: 13/12/10; 20/06/11 and 19/01/15. Just why, in the case of the January 2015 meeting, Board Members had to be briefed prior to considering the application in public, should I believe be a matter of major public concern. While the slides, some of which are included in this post, appear quite neutral – unlike some of the Your Park slides – the real issue is what was discussed. We will never know as no minutes are kept of these sessions.
If Board Members are not capable of understanding the papers put to the public meeting, there are questions about their fitness to serve on the Board. If the briefing was not for that purpose, the only other explanation appears to be that the Board was in effect deciding what should happen in advance, in secret. That is wrong. The new LLTNPA Convener, James Stuart, really does need to stop this practice and make a public declaration that it will no longer consider planning applications in secret. If he fails to do that, the Scottish Government should step in and require the LLTNPA to do so.
The other problem with the LLTNPA’s failures in terms of transparency is illustrated by the Owen McKee case. Owen McKee had traded in Scotgold shares after consent had been given into the goldmine going ahead. The LLTNPA conducted a sham investigation into what happened (see here for example) which concluded that the basis of that planning decision had not been undermined by Owen McKee’s actions. The unanswered question is the degree to which Owen McKee, as Planning Convener, influenced other members to reverse their previous decision to refuse the goldmine application as inappropriate for a National Park because he hoped personally to profit from this at some time in the future. Its quite possible of course that Owen McKee never thought of buying Scotgold shares until after the planning consent had been granted although its probably impossible to answer this question now. The LLTNPA however never even asked the question which suggests that there were other agendas present. If so, those may still be relevant to how the new proposal is determined.
The public should be very sceptical about the whole planning process. As a start the LLTNPA should make public on its website all the information from the secret meetings which considered the Cononish application – the slides published above are not on the Park’s website – and the monthly monitoring reports which Scotgold has been required to provide since the current “trial” started.