Rundale

Last month we told you about the suspension of the Sperrins Gold Mine Inquiry in a piece by V’cenza Cirefice. Public consultation on this major project is currently open (running until the 23rd of April) and anyone in Ireland can make a submission.

Here we’re publishing in full the key points submitted by the Save Our Sperrins (SOS) and Communities Against the Injustice of Mining (CAIM), who have been building an all-island solidarity movement of grassroots and community organisations advocating for environmental justice against the backdrop of global extractive industry pressures. Go here to find out more about the consultation process and to make a submission.

SOS and CAIM have also prepared these four fabulous submission templates that you should feel free to use if you don’t want to write your own letter. They focus on air, water, cultural heritage and economy. These are ready to go – just copy paste the text into an email and send to the Planning Inspectorate UK at planning@infrastructure-ni.gov.uk

Go here to find out more about the consultation process.

Introduction

This is a submission to the Transboundary Consultation called by the Irish government in response to a request from the Department for Infrastructure in Northern Ireland. It concerns the application for a goldmine, 2 Discharge Consents, 2 Water Abstractions, 2 heavy duty powerline applications and a Road Abandonment application by Dalradian Gold, an American owned company, in the Sperrins Area of Outstanding Natural Beauty in County Tyrone. 

We believe the citizens of the Republic of Ireland have a right to know about the potential impacts on their water, air, land, health and biodiversity, and to be involved in the decision making, given the implications for them directly and indirectly.

It appears that the proposed goldmine and heavy duty powerline are given prominence in the request for a Transboundary Consultation but it is very important that all the other associated applications are commented on, especially the two Discharge Consents and the two Water Abstraction applications. The 8 applications need to be considered together as they are all integral parts of the overall goldmine application.

You can read more about the transboundary consultation process and how to make a submission on the EJNI website. 

Transboundary consultation process

How can a Transboundary Consultation be properly done when there is no agreement about where the boundary is? Both the RoI government and Crown Estate England claim ownership of Lough Foyle. This has been in dispute for over 100 years, since partition in 1922. This unique situation makes it impossible to submit a complete submission until the matter of ownership is resolved and the boundary is clearly marked.

Additionally, it is unacceptable to expect a submission to be completed without the benefit of a HRA (Habitats Regulations Assessment)  – which has not been provided by DfI for the proposed goldmine (only the powerlines received a HRA). This is a fundamentally important document. Will the Irish Government ask DfI to provide a HRA for Irish citizens to know the full effects of the project?

The proposed goldmine, with its associated infrastructure, and how it would affect citizens of ROI

WATER

There are a number of ways in which the waters of County Donegal would be affected by Dalradian Gold’s proposed goldmine.  These are: failure of the ‘Dry Stack Facility’, acid mine drainage, water discharges and water abstraction.

Map showing contamination path (red: flow toward the sea, orange: tidal flow)

by Save Our Sperrins

Contaminated water flowing from the mine, whether generated intentionally or by the probable failure of facilities, would flow into the Owenkillew River, which joins the Strule & Derg Rivers to become the Mourne River, which the River Finn from Donegal joins at Lifford/Strabane – which is also where the jurisdiction of NI meets ROI. The Finn and the Mourne rivers join to become the River Foyle, which flows into Lough Foyle and on into the Irish Sea. From Lifford to the sea is tidal waters, and so this also puts the River Finn at risk of contamination due to back flow. Lough Foyle is listed as one of the transboundary protected areas (Ramsar, Bird Directive, etc.) in the UNEP list

Whatever the claims of the Crown Estate of Britain, the Irish government claims (at least shared) sovereignty over the River Foyle as it runs along the contested land border, full sovereignty of the Foyle as it circumnavigates the west shores of Island More, and full sovereignty of Lough Foyle (the loughs of Foyle and Carlingford were not included in the referendum that was constitutionally necessary to change Articles 2 & 3 of the Irish constitution that gave up claims to the six counties in December 1999). Thus, Lough Foyle in its entirety remains within the jurisdiction of the Irish government, according to the constitution of the Republic of Ireland. We state these facts for the purpose of this Transboundary Consultation; however, we know very well that nature knows no borders, nor does the pollution that threatens it.

Toxic Tailings

Dalradian Gold proposes to extract, through the use of explosives twice daily for 25 years, thousands of tons of rock which, they state, would be crushed to the fine consistency of flour and floated in a chemical mixture to extract the gold ore. Dalradian proposes to store the waste in a huge 54 metres high, 17 storey “Dry Stack Facility” which is also known as a “Filtered Tailings Stack” in the industry. Technically, it is not “dry” as it contains at least 15% water. According to Dr S. H. Emerman, an eminent hydrologist and global expert on mining, ”there is a major risk of catastrophic failure of the filtered tailings stack, with loss of life.” He says it would slide down the mountain, devastating all in its way, due to its composition of toxic waste, and follow the path of the rivers (as stated above) flowing into Lough Foyle and on to the Irish Sea.

The failure of tailings dams happens unfortunately frequently – Dr. Emerman, in his expert opinion, states that it is not a matter of if tailings stacks will fail, it is a matter of when. He says that failure is due to the volume and type of waste material stored, and the heavy rainfall which increases the water content of the filtered tailings stack. Another expert, Dr Steven Vicks states: “Closure design is unlikely to be maintained much beyond 100 years. For closure, system failure is inevitable, so closure risk depends solely on failure consequences.” 

A report by the Church of England, whose pensions and investments are tied up in mining projects, showed that more than a third of all tailings dams worldwide are at high risk of causing catastrophic damage to nearby communities if they crumble. Dr. Emerman’s experience and research directly questions the ‘if’ in this statement.

A recent example of a failed tailings facility can be seen in the devastating disaster in Brumadinho, Brazil, in 2020, where the collapse of a dam killed 272 people, flattened entire villages and led to massive environmental destruction. In 2024, another landslide occurred in a mine waste pile at the Turmalina Mine, in Brazil, which was the same design as Dalradian’s proposed Curraghinalt project. For an example within Europe, in 2000 the Baia Mare waste dam collapsed in Romania, sending 100,000 cubic metres of cyanide contaminated waste water into rivers that spread across three countries, killing fish and disrupting water supplies for millions of people (Antypas and Gulacoy, 2001).

Dalradian’s mine closure plan falls catastrophically short. They initially proposed just five years, however in their Statement of Case in October 2024, they state they will monitor 15 years post closure. They also state that a figure of £20 million would be the ‘proposed subject of a financial guarantee with DfI’ – this is very ambiguous and does not seem at all like any kind of ‘guarantee’. Moreover, the Society for Mining, Metallurgy, and Exploration Tailings Management Handbook states: “The mining industry has a significant challenge in that these TSFs [Tailings Storage Facilities] will last for perpetuity. Unfortunately, humans have no experience in designing facilities to last forever, so responsible tailings management is required for as long as the TSF exists” (Morrison and Lammers, 2022). Dalradian falls very short of forever, leaving a ticking time bomb for environmental destruction and loss of life. 

Acid Mine Drainage

The rock extracted from the mine would contain sulphides which, when exposed to air and water, would produce sulphuric acid; another term for it is Acid Mine Drainage (AMD) which would strip out heavy metals from the rock, such as arsenic, mercury, chromium, cadmium, lead, zinc, copper, etc. Acid mine drainage is a permanent problem, which, once started, continues in perpetuity, poisoning land and water. Mines in Spain operating from Roman times are still leaking (Olias and Nieto, 2015). 

Furthermore, mining activities, such as the burning of fossil fuels, can also lead to acid rain, impacting a much larger area. 

Discharge Consents for Heavy Metals

The two Discharge Consent applications are to discharge “treated wastewater” containing 24 metals, acids, flocculants, etc into two rivers, Owenkillew and Owenreagh, headwaters of the River Foyle which the River Finn from Donegal  joins at Lifford/Strabane. The application for Discharge into the Owenreagh River also includes “treated sewage.” The Owenkillew and Owenreagh rivers are designated Special Area of Conservation and Area of Special Scientific Interest because of the presence of Freshwater Pearl Mussels (Ireland’s only globally endangered species), as well as salmon spawning, otters and brown trout. The River Foyle is well known globally for salmon fishing. 

If the two Discharge Consents are granted, they would result in killing aquatic life in the Owenkillew and Owenreagh Rivers and over time they would seriously impact on the water quality and aquatic life throughout the Foyle River Basin, due to the cumulative build up of heavy metals in the river system. There would also be significant risks to Lough Foyle’s expansive shellfish aquaculture industry, various types of fishing and recreational activities along the Donegal coastline.The Foyle is a tidal river so there is an increased risk of pollution from the mine waste discharges being washed into the River Finn.

In Dalradian’s Statement of Case in October 2024, they added in “new information,” where they state that for 7 years post closure, there would be a discharge of 4,400 gallons per day from their adit into the Owenkillew River, via the Curraghinalt Burn. After 7 years, this discharge would increase to 176,000 gallons per day, forever! This is hugely worrying as this would most likely be acid mine drainage, which would join the contaminated waste flowing from the Filtered Tailings Stack, and both would pervade the entire Foyle river system, putting all aquatic life in grave danger. 

Water Abstraction

One of the Water Abstraction applications is to abstract half a million gallons of water per day for 25 years from the peatland north of Dalradian’s proposed site. Peatland is an efficient carbon store so this carbon would be lost, adding to climate change and impacting our ability to meet our climate targets regionally. Furthermore, such abstraction of water would detrimentally affect the aquifers, streams and rivers in the area, including the headwaters of the River Foyle, which would lead in the long term to negative impacts on the whole River Basin. The second Water Abstraction application is to abstract 375,000 gallons of wastewater daily from the proposed mine and discharge it, following “treatment,” into the Owenreagh River, via the Pollanroe Burn. This also would pose huge risks to the quality and quantity of water making its way to the Foyle River basin.

AIR

Toxic Tailings (again)

Dalradian state that the Dry Stack Tailings Facility would need to be sprayed with water to prevent the dust, containing heavy metals, from blowing in the wind. If dry, the toxic dust could be blown across the island of Ireland. A study in Finland found the fine dust, 2.5 particulate matter containing arsenic and mercury, on the leaves of trees 60 kilometres from a goldmine at Kittila. Jari Natunen, a Finnish Biochemist, said that it was very dangerous as it could enter people’s lungs causing respiratory diseases and cancers and that children were particularly vulnerable. 

Dalradian’s proposed site is approximately 18 miles/30 km from parts of Donegal so all the poisonous contaminants can be easily transported by air. We all remember the sand from the Sahara desert and the red dust from the Aughinish aluminium mine in Limerick blowing over the whole country. 

Radon Gas

The North West of Ireland is high in radon gas – if building a house you have to put a barrier in the foundations to prevent radon gas exposure. So a mine 900+ metres deep would release significantly more radioactive contaminants into the air. The link between radon gas and lung cancer is well established, according to the World Health Organisation.

Diesel Emissions and Particulate Matter

It is well documented that a high level of fumes from diesel emissions are poisonous – leading to increased rates of lung cancer, other heart and lung diseases and premature death. Dalradian has applied to use 3.5 million litres of diesel onsite every year for 25 years – the implications of this on human, animal and plant life has not been measured in their Environmental Impact Statements. 

The construction of the heavy duty powerline across the Sperrins Area of Outstanding Natural Beauty would contribute directly to climate change through the diesel emissions from the thousands of vehicles, as well as the removal of peatland and cutting down of trees, all referenced in the RPS report which accompanied the application for a heavy duty powerline. 

Additionally, this level of fossil fuel emissions well into the next decade, and past the legally binding date for net zero targets, has implications for climate breakdown that are far reaching well beyond the island of Ireland. 

Air, like water, doesn’t stop at borders!

SPECIES PROTECTION

Protected species are at risk due to Dalradian’s proposed gold mine – such as the endangered Freshwater Pearl Mussels. Other protected species that traverse our man-made borders are, for example, the Atlantic Salmon, who breed in the Owenkillew and swim, via the water route the toxic waste would also take, out into the Irish Sea. The River Foyle and Lough Foyle are globally known, currently, for rich salmon fishing. This would disappear if the salmon were killed by pollution. 

Other species at risk could be Whooper Swans, Peregrine Falcons and Chough, as well as migrating birds – such as the Greylag geese and Snipe.

The NIE report about the heavy duty powerline states: “Tree cutting and felling would be required along a significant proportion of the route in order to ensure a safe 10 metre wide wayleave is maintained.” This would disturb wildlife habitats and ecosystems as well as resulting in carbon loss and contributing to climate change. It should also be noted that the birds and other species of wildlife do not recognise the border.

CULTURAL HERITAGE

The Sperrin Mountains is an area rich in cultural heritage for the whole island, in terms of ancient archaeology, historical sites, stories, the Irish language and more. The landscape is very much part of people’s religion, culture, heritage and history,  as outlined in the report by Dr Amy Strecker and Dr V’cenza Cirefice, which constitutes valuable intangible cultural heritage. The cultural landscape and intangible heritage is recognised in international treaties such as the UNESCO 1972 World Heritage Convention (“Cultural Landscapes”), the 2003 UNESCO  Convention on the Safeguarding of the Intangible Cultural Heritage (Article 2), and the 2000 Council of Europe Landscape Convention (Article 1). Transport Infrastructure Ireland’s Guidelines for conducting Cultural Heritage Impact Assessment also includes intangible cultural heritage and landscape.

Archaeology

It is claimed by local historians that the Sperrin Mountains were one of the first populated areas on the island. There is a wealth of archaeological sites in the area, more than 100 in an 8 mile radius, dating back to various ages. One site of note in the designated ASAI (Area of Significant Archaeological Interest) is the six thousand year old Beaghmore Stone Circles – one of the largest and most complex sites of its kind. 

According to NI Department of Agriculture, Environment and Rural Affairs (DEARA):

“The Sperrin AONB contains extensive archaeological heritage. With concentrations of Neolithic and Bronze Age sites; numerous raths along valleys; historic field patterns including ladder fields and traces of former open-field systems. The landscape has influenced spiritual and religious values of people living in the area over the millennia.” 

Cultural History

In terms of Celtic history, the proposed mine site cuts across the historic Green Road – the road that Hugh O’Neill travelled with other Celtic Kings  in 1607 on their way to Rathmullan in Donegal, as part of the Flight of the Earls. The proposed road abandonment plan is to abandon a road that is connected to this Green Road and which is still used daily by the local population. People also use these roads to visit a Mass Rock which dates back to Penal times (1691 – 1760), when the local population’s religious rights were denied and had to be exercised in secret. A nearby statue of the Blessed Virgin Mary, to which people come from across the country on pilgrimage, has been defiled since more people have been coming on pilgrimage and as support for the rejection of the mine. 

The region is also full of stories and histories of important cultural figures who have shaped Ireland today. For instance, Padai Laidir Mac Culadh is featured in the National Museum of Ireland, as a master craftsman who could fashion a horse harness and saddle out of straw. Padaí Láidir Mac Culadh, Eoin Ó Cianán, Peadar Joe Ó hEachaidh, Seán Ó Cairealláin and more than 20 other native Irish speakers were all well known Gaeilgeoirí, and are included in various books eg.”Padaí Láidir Mac Culadh agus Gaeltacht Thír Eoghain”, “Tyrone Folkquest,” &  “Scéalta Muintir Luiningh.”

Irish Language

The Sperrin Mountains was known as a Gaeltacht area where the local population spoke Irish as their native language up until the 1950s. Despite the decline in the language, as with the rest of the island, there has been a recent revival and now the language is thriving. It’s one of the few places on the island where the language is regaining some of its former prominence, and this is due to the strong sense of connection to place. Greencastle, Co. Tyrone, where the resistance site is based, is still known locally by its Irish name – Sheskinshule, which means ‘moving bog’. Thus, local people know that Greencastle, Sheskinshule, is not a suitable place for a water intensive goldmine. The aliveness of the Irish language in this area highlights the relational interaction with place and a sense of an entwinement and intimacy with the land, common with many indigenous languages globally (McCarty, et al., 2021). This shows the stark contrast in worldview between local community and extractive industries. 

Across the world and in Ireland Indigenous languages were directly and systematically threatened by colonialism to erase and sever cultural identity and continuity, as well as connections to land and waters. Reclaiming language then becomes an important way to challenge colonial and extractive logics on the Island and a form of community revitalisation. Irish language learning is also tied to community regeneration, as can be seen at An Creagan Visitors Centre & Greencastle Community centre – where Irish classes run alongside many other community enrichment initiatives. An Creagan sits on the edge of a raised bog, and a walkway brings visitors out onto the bog itself; the community knows that you can’t love what you don’t know, and when you know it, you’ll love it, and protect it. 

ECONOMY

Fishing

With the likelihood of water and aquatic life, particularly salmon, affected by the contamination from this mine, the livelihoods of fisher people could be gravely affected on both sides of the border. The heavy duty powerline would cross several rivers either by directional drilling or open channel cutting which could impact water quality and disrupt aquatic ecosystems and have a knock-on impact on the Foyle of which they are tributaries and headwaters.

Agriculture

Animals and crops will be affected by the toxic dust and contaminated water. The dust would settle on the grass that is eaten by cattle, sheep and other farm animals. This will affect the livelihoods of farmers and the ability of the population of Donegal, and of course Tyrone, to rely on their produce – such as beef, dairy, chickens, eggs and crops. 

Tourism

Many people come to the Sperrins from across the island and beyond for walking or hiking, birdwatching, cultural history and sightseeing. The history of the North West includes the first settlement of humans on the island and the last flight of the Celtic Kings; this could be the basis for a cross-border tourism project in future years. Indeed, many tourists unofficially follow this stream currently, looking for connection with their cultural heritage.

The heavy duty powerline that would accompany the mine would result in visual and landscape impacts from 322 poles being erected 11-20 metres in height and a 10 metre clearance around them, going through the Sperrins Area of Outstanding Natural Beauty (AONB). People from Donegal & other parts of RoI travel to Derry, Strabane, Omagh & through other parts of Tyrone regularly and would object to such an obtrusive construction on the AONB, as it would be like a scar on the beautiful landscape.

The multiple vehicles associated with the construction and maintenance of the proposed powerline would lead to traffic congestion on the roads and increased risks of accidents. It would also deter people from visiting the area, thus affecting tourism.

People may have concerns for their health from exposure to electromagnetic fields from the high voltage powerline. The World Health Organisation (WHO) classified magnetic fields in 2002 as “possibly carcinogenic to humans,” and many research studies support this claim. Therefore some tourists may avoid the area.

Does ROI Want an Extractive Economy?

The EIA Directive states alternatives must be considered – have alternatives to mining been considered? Our governments North and South advertise that ‘Ireland is Open for Business’ – we are considered as one island in the eyes of the mining industry, with many of the same companies present on both sides of the border, and when it suits our governments when selling us off. If this major mining project goes ahead in the North, it will open the doors for an intensification of mining in the South, and an entrenchment of the extractive economy that is destroying communities and precious ecosystems, and bringing us Climate Breakdown. 25% of Northern Ireland and 27% of RoI has already been given out to mining companies under prospecting licences. This number fluctuates and is likely to soon increase as new prospecting licences are currently out for consultation in both ROI and NI.

In addition to the two economies already being closely intertwined, there is a high probability of constitutional change – bringing both jurisdictions into one, within the proposed lifetime of the mine. Once extractive companies are in the door, it is very hard to get them out. So what is permitted in the North now may soon be the responsibility of the entire island. What kind of economy, what kind of society, do we want to create for this new Ireland? One that destroys life or one that sustains it.

Conclusion.

When one considers the cumulative impacts of all Dalradian Gold’s applications, the precautionary principle has to be applied and these applications refused.

Goldmining is a toxic industry which pollutes water, air, land, health and biodiversity and as such, should not be allowed in any part of Ireland, North or South.

Legislation/regulations which would be contravened by a goldmine and associated infrastructure in the Sperrins AONB

European Convention on Human Rights 1950, 

UN Universal Declaration of Human Rights1948, 

Aarhus Convention 1998,  

International Covenant on Economic, Cultural & Social Rights 1966,  

International Covenant on Civil & Political Rights 1966, 

UN Convention on Long-Range Transboundary Air Pollution 1979,  

Espoo Convention on Environmental Impact Assessment in a Transboundary Context 1997, 

UN Convention on Biological Diversity 1992, 

Ramsar Convention on Wetlands of International Importance 1971, 

European Landscape Convention 2000

European Convention on the Protection of Archaeological Heritage 1992

UNESCO Convention on Safeguarding of Intangible Cultural Heritage 2003 – ratified by the UK Government 2024

Transboundary Convention/Water Convention

References: 

Antypas, J. and Gulacoy, S. (2001). Transboundary Environmental Governance and the Baia Mare Cyanide Spill. Review of Central and Eastern European Law, 27(4), pp.639-691.

Cirefice, V., Mercier, S. and O’Dochartaigh, A. (2022). ‘Resistance to Mining and Pathways to a Sustainable Rural Environment’, in A. Attorp, S. Heron and R. McAreavey (eds.), Rural Governance in the UK: Towards a Sustainable and Equitable Society. Routledge, pp. 99-119.

Olías, M. and Nieto, J. (2015). Background Conditions and Mining Pollution throughout History in the Río Tinto (SW Spain). Environments (Basel, Switzerland), 2(3), pp. 295–316.

McCarty, T. L., Noguera, J., Lee, T. S. and Nicholas, S. E. (2021). “A Viable Path for Education”—Indigenous-Language Immersion and Sustainable Self-Determination.  Journal of Language, Identity & Education, 20(5), pp. 340-354.

Morrison, K.F. and Lammers, H. (2022). Chapter 1—What are tailings?: In K.F. Morrison (Ed.), Tailings management handbook—A life-cycle approach (pp. 3-12), Society for Mining, Metallurgy and Exploration, Englewood, Colorado, p.1004. 

Vicks, S.G. (2014). Planning, Design and Analysis of Tailings Dams. Vancouver: University of British Columbia Library.