April 7,2016


Sadly, this news this morning from the Solomon’s, underscores the universality of the issues of disenfranchisement and lack of accountability to fundamental community needs and values that is indemic to the “social license to operate” as defined and promulgated by the mining cartel but also, as in this case,  adopted by local communities and indigenous peoples themselves.  In this case,  the mine owners are disgruntled landowners, a collective of 17 tribes of indigenous peoples who owned the land of the mine site,  who foolishly orchestrated a sort of hostile takeover of the  never profitable Gold Ridge Mine.  Local control motivated by profits and a piece of the pie without adequate technical knowledge and adequate capital is as dangerous and as disenfranchising to surrounding community as operation by any miner


All mines require adequate capital, excellence in techincal and scientific knowledge, and a standard of deisgn and  operation  that is accountable in the first instance to environmental security and preservation of community.  Local control and local input must be about securing this for every mine that is allowed to operate and expand.


This 20 million cubic meter  50 m  high TSF  has hovered on the brink of collapse for almost two years. Landowners sought what St Barbara had been denied before it was locked out: permission to dewater at a very high rate of release and without treatment. Because of downstream community and environmental issues UNESCO stepped in at the request of the Solomon Island Government ( SIG) with its own independent technically expert team and established standards on a safe rate of release and a requirement for treatment.  Local government had been prepared to and actually did grant an untreated release at unsafe levels far in excess of what UNESCO advised: 12,000 cubic meters per day vs 3, 572 cubic meters per day.

SIG & landowner/mine owners opted to await the  installation of the water treatment which only went on line March 29th .  By then overflow conditions had already been reached. Apparently also beginning that date an emergency untreated release was authorized but in fact it is literally overflowing the crest of  spillway  with no means of control or diversion so it cannot be properly called an “authorized release”.  All that , from UNESCO report  ’til March 29th, took a long time and the dam was in a crisis when all these discussions began ( as at Mt. Polley).    Nothing was ordered by SIG or initiated by  the 17 tribes who now own the mine to catch and hold any overflow even though it has been known for some time that an overtopping was likely.   Local control  has not brought increased levels of accountability to environmental security or to the safety and preservation of downstream communities.  



Like so many other mines that have failed at a catastrophic level this deposit was never properly assessed in the first instance. Flow sheets, and tinkerings with them over several turnovers in ownership, all propped up by the World Bank, IFC and the Australian Export Credit Agency never found a flow sheet that could profitably mine this anomalous deposit.  Recovery rates at each new expansion or tinkering got lower and lower from only 86% at outset to 69% when last operated. The latest tinker and expansion had already been initiated  and miners already knew it had failed again when they  went looking for some hapless buyer that they found in St. Barbara, after quite a time. (there was no long line of eager offerors).  St. Barbara has since admitted they did no independent assessment pre acquisition but relied on the representation of Australian Government.


Very shortly after St. Barbara’s ill advised acquisition, the rapid rate of deposition to the TSF, well beyond what facility designers had prescribed (it was filled to near max in a much shorter time than was planned life of mine)  had pushed it to the verge of crisis.  This is the story behind almost all catastrophic tailings failures.  Bad practice and/or miner incompetence.  Important to note that according to Golder , serving as ad IFC , the TSF was not built according to the state of the art plans submitted to all by Ross Mining, the original developer.  Critical aspects of the drainage system were never put in place.  No as built drawings of the TSF have been presented in Golder’s work for IFC or by UNESCO. 

St. Barbara went back to Australia leaving no personnel to manage the mine or reduce the threat level when local government refused to allow them a huge discharge of untreated water to avert collapse. (Such a release was not allowed under the terms of the IFC financing ) St. Barbara refused to install the promised water treatment facility which was destroyed  during their absence their site was taken over by  artisan  miners.  Government refused the security and protection St Barbara expected as a condition of returning in any way. (Throughout the life of the mine, miners and the Australian Government have “papered over” the fundamental issues of technical incompetence that plagued this mine  as a matter only of political risk and social unrest, of unpredictable fluctuations in commodity prices, and a disorganized and incompetent local government.)


Local government locked St. Barbara out and local landowners who were owed much money under prior agreements took control and ownership  including responsibility for all liabilities. SIG had refused to do so. They naively assumed , as many citizens do, that all mines are cash in the ground and that there would be a long list of interested parties to co venture with landowners in the reopening and operation of the mine. 


After quite awhile the only partner to step forward, AXF, a conglomerate of extremely wealthy Chinese individuals, has no experience whatsoever in mining ( they are in the entertainment and commercial property development business…not clear what motivated AXF but Bowker Associates is investigating whether again tinkering by the Australian Government, perhaps in connection with qualifying for investor immigration  requirements that trades  presence and investment  of foreign entities  for investment in desired or high risk projects ).  AXF created a separate entity for this partnership which was executed in December 2015.  AXF, like the hapless landowners, probably didn’t even know what questions to ask before it signed on.


So this apparently out of control dewatering, as it seems to the excluded and most directly threatened Guadalcanal community downstream, has no mining  competent persons involved locally to assess and oversee and accomplish a safe dewatering. ( At least no contracts with competent engineers and scientists have been announced).  There is no one of competence to speak to the concerns of the Guadalcanal community; no one of competence to give any meaningful assurances at all.


Speaking concerns is not enough to solve the complex complex problems of mining  necessary to satisfactory levels of environmental and community security.   Concerns, when addressed to the absence of competence can’t possibly bring fruitful or timely solutionsTo be effective on mining threats, spoken  concerns must  come with that competence and demand that that competence be provided as part of the operating and oversight of the mine.


This applies as well to concerns about fair and equitable implementation of the Samarco settlement and to the nature of mobilization required to bring that about.


 It illustrates that local control, especially without adequate capital for management and adequate technical know how is not inherently a positive and where a serious danger is present, as at this mine, puts the entire downstream at risk with no means of mitigating  the danger.

 April 8, 2016 Additional Press & Video






Lindsay Newland Bowker, CPCU, ARM Environmental Risk Manager

Bowker Associates

Science & Research In The Public Interest

15 Cove Meadow Rd.

Stonington, Maine 04681


207 367 5145

Danger of continuing uncontrolled release recognized..dwnstream 8,000 warned but not offered any assistance .  Naezan and the coalition of 17 tribes who own the mine, whose management of it has fallen well below international standards for responsible management, had initially denied that the release was uncontrolled and that it was harmful fully aware of the UNESCO findings and warning that the maximum safe daily release of untreated waters is around 3,500 cubic meters per day.  The uncontrolled , uncontrollable release has greatly exceeded that.  Naezan acknowledged 95,00o cubic meters  over the dam without treatment since March 29th as of last Friday.April 7th.  That is an untreated release rate more 3 times the safe rate known to  SIG and Naezan’s coalition.   SIG, fully aware of the UNESCO advice which they themselves sought, had nevertheless issued a permit to Naezan’s coalition for an untreated daily release of 12,000 cubic meters.

The Naezan group’s new partner, AXF, an entertaninment/commercial property conglomerate  of wealthy Chinese investors  with no mining experience whatsoever has been silent but according to Naezan have had management control since December.  No deep pocket there though as they created a separate company for the partnership and Australian/Solomon Islands law does not have cut through provisions and strict liability as Brazil.

All are mum on cyanide also noted in the UNESCO report .  The initial plan for the mine which started in 1998 and as approved by IFC and the Australian export credit called for cyanide removal at the end for the water only but not the tailings themselves.  In a report by Golder for IFC they noted in 2011 this practice was below acceptable acceptable international standards and that the tailings should be treated before deposition and the waters treated before release..  That was the purpose of the water treatment plant.  No action was ever taken to remove the cyanide from the tailings before deposition.  ( The plan had been to close the wrongly built TSF and build a new one)

April 15 In a vague statement Solomons’ Island Environment Minister says Spill over under control and only treated waters being released now

No details were made available on how much water actually escaped and/or were pumped nder the permit for unteated release;, what the current level of water in the dam is;  whether the treated waters are being held  for monitoring and testing prior to release as advised by UNESCO to the Solomon Islands Government or whether the rate of treated release is otherwise at the rate advised by UNESCO to the Solomon Islands Government.


Should this TSF fail, based on modeling of past  failures, this 20 million cubic meter 50 m high facility could easily spill 10 million cubic meters of arsenic and cyanide tainted tailings propelling them  with that nearly 1 million cubic meters of waters and the wall of the dam itself into the settlement of the 8,000 downstream.  If that should happen it would be the  3rd TSF failure in 30 months exceeding 10 million cubic meters.  It would be only the 6th release of tis size ever in recorded history.


Even with Samarco’s man made catastrophe and its horrific images so fresh and current in global awareness, this long  unfolding catastrophe  has received no notice outside of regional and local press.






About lindsaynewlandbowker

Bowker Associates, Science & Research In The Public Interest, is an independent non profit providing self initiated pro bono analysis on key issues with a potential for massive adverse environmental impact . Bowker Associates has been an internationally recognized and cited voice in analysis of the Samarco failure, its consequence, and the possibilties for recovery. In 2015 Bowker Associates collaborated with globally respected geophysicist David M. Chambers to recompile global authoritative accounts of significant TSF failures in recorded history and to analyze these data in the context of gloal mining economics 1910-2010 ( Risk, Economics and Public Liability of TSF Failures, Bowker/Chambers July 2015) In 2014 Bowker Associates commissioned globally respected geophysicist and hydrogeologist Dr. David Chambers to undertake two technical works: (1) development of technical go no go criteria for vetting mine applications tp:// and (2) a case study of Maine's Bald Mountain, an un mined low grade high risk VMS deposit demonstrating the efficacy and accuracy of two risk assessment tools in vetting mine proposals In Maine, Bowker Associates has deeply engaged and been a public voice in the Searsport DCP LPG Tank, The Cianbro proposal for a Private East West Toll Road, JD Irvings rolling pipeline of Bakken crude to its plant in St. John and review of Phase II plans at The Callahan Superfund site in Brooksville, Maine, and Maine's revisitation of mining in statute and regulation... Our only “client”: is always “the pubic interest”. Our model is to focus on only one or two issues at a time so that we have a substantive command of the relevant field as our foundation for ongoing engagement. Our core work is in envirommental risk management, science and technology as well as bringing any available “best practices” models to the fore. The legal and regulatory history/best models are also a major thrust of our work in building and evaluating public policy. Director/Principal Lindsay Newland Bowker, CPCU, ARM is a recognized expert in Environmental Risk Management., Heavy Construction Risk Management and Marine and Transit Risks and has more than 3 decades of engagement in buiding public policy. Appointed by Governor Mario Cuomo to New York State Banking Board (served 1986-1996); President New York Chapter Chartered Property and Casualty Insurers; Environmental Committee, Risk and Insurance Management Society; Director, Convenor/Co-Chair Bermuda Market Briefing "From Captive to Cats" Hamilton Bermuda. Published Articles of Significance The Risk Economics and Public Liability of Tailings Facility Failures, co-authored with David M. Chambers, July 2015 Beyond. Polarization: Superfund Reform in Perspective, Risk & Insurance Managing Risk For Loss Prevention & Cost Control (Jan. 24, 1997). Lead Hazards and Abatement Technologies in Construction: A Risk Management Approach CPCU Journal 1997 Employee Leasing: Liability in Limbo Risk Management June 1 1997 Environmental Audit Privilege and the Public interest Risk & Insurance Managing Risk For Loss Prevention & Cost Control, April 1997 Asbestos:Holes In Abatement Policies Need To Be Plugged, Lloyd’s Environmental Risk International, May 1993 Editor Published Letters Evironmental Risk Management Beware of Facile Policies Like Fetal Protection Business Insurance 1995(?) High Court Review May Increase Sale of Bank Annuities Business Insurances August 8, 1995 Professional Profiles Protecting the Big Apple’s Core Managing Risk For Loss Prevention & Control December 1996 Major Career Highlights First rigorous analysis showing Relationship Between declining ore grades and TSF Failures of increasing consequence ( July 2015) FIrst Documentation that Gentrification Has Same Impacts as Unassisted Displacement from Urban Renewal Sites Direted Court Ordered EIS of FHA Mortgage Scandal Created Nation's First Homeownership Program for Low Income People (SHIP) Created Earliest Geographic Information Systems Using Defense Technology Developed By IBM Designed and Conducted Parallel Census Count to Show Systematic undercount in minority neighborhoods Documented Bias in ISO Territory Rating Plans for Private Passenger Auto Insurance Using ISO's own Rating Techniques Demonstrated Inherent Bias in Mortgage Policies of Banks With Inner City Branches Demonstrated that NY Telephones Plan for Area Code Split To accommodate anticipated cell phone demand was not efficient and would exhaust in 5 years ( which it did) Undertook First Systematic Evaluation of Child Protective Services Caseload Using Multi Variate Analyic Techniques Developed Child Protective Caseload Management and Tracking System (CANTS) and directed implementation in 4 client states including Illinois, Florida and New York Created and Ran Office of Risk Management for NYC DEP the Nations largest Water & Sewer Authority . Designed, Created and Administered Nation's First Owner Controlled Insurance Program (OCIP)for High Risk Tunneling Education Masters NYU Graduate School of Public Administration BSC New School For Social Research Maine Public Schools Deering High School
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