Bowdens Silver

A great project for our region only made better by the proposed amendments.

As a long-term Lue landowner, I object to the project as I have continually done so. The planned changes do nothing to improve my view of the project.

The reason for my objection is there is no real material change in the visual amenity.

The ongoing irreversible damage to our local community, the disastrous environment impact, the negative impact on the health and wellbeing of both our community and visitors. The tourist destination of the local region would be lost forever with an open cut mine. Our local short stay places that rely on our local work force (cleaners, trades persons, handyman's, builders, gardeners, etc) would no longer have the important work that many in the local community rely on to survive. Our local community would change forever.

The Lawson Creek is already listed in the NSW Stressed River Assessment. The impact of poisonous lead in the air and the spill of acid forming rock from the TSF into the Lawson Creek would be an almost certain environmental and health disaster.

Water availability is very limited in the area already so the Bowdens Mine would only make the current situation worse. It seems that they are happy to ignore all the years of drought we have suffered. The updated view of the Power Lines is no real material change as it would still destroy what we see. The local community and, more importantly our tourists do not want to look at ugly power lines or an open cut mine.

Even Bowden's are not stating the mine as an 'environmentally and socially sound project'. If the mine was to go ahead then I feel it's a disaster waiting to happen environmentally and would almost certainly turn out beautiful land and community into a mining ghost town.

There are so many things that are wrong with this proposal that it is hard to know where to start but here goes.
There is just not enough water
There is simply not enough water in the area to support a mine without having a highly detrimental impact upon the environment and surrounding farming land. In other words, the mine is in the wrong place.
Lawson Creek is listed in the NSW Stressed Rivers Assessment in the most stressed category (S1) – with both high environmental stress and a high extraction rate.
It is more often than not a series of water holes with no visible flow during summer.
Mines dig big holes in the ground which have a massively detrimental effect on ground water. In the area that Bowdens proposes to mine, the ground and surface water systems are highly connected within the area. There are many springs that are the lifeblood for many humans, plants and animals in the area.
Talk to anyone who lives around Lue and they will tell you a lot of bores in the area do not function in Lue village in dry times now – this is indicative of how impractical it is to believe that Bowdens can find sufficient water locally to run the mine not to mention the consequences for all those surrounding the mine when their water supplies further dry up. The groundwater here also provides the baseflows further downstream. It can only further stress the waterways and disadvantage all who rely on that water.
On top of this there is climate change which will make droughts more frequent, more severe and longer in duration.
Bowdens would have you believe otherwise but putting it simply, the company is fudging the figures. Everyone who lives in the area knows that the Lue district is in a rain shadow and gets less rain in total and fewer days of any rain than Mudgee or Rylstone, yet Bowdens would have you believe this is not the case.
For a start, the company has used average rainfall which is problematic as this area does get years that are very, very wet but also very, very dry. A more accurate assessment would use the median rainfall which comes in at 635 and 656 mm/a respectively. In addition, the 20th percentile for Rylstone and Mudgee are 509mm/a and 494 mm/a respectively. Put another way, one in every five years, the climatic conditions between Rylstone and Mudgee, which covers the proposed mine site, are semi-arid. Any loss of available water in these years would severely impact the land and the people, plants and animals trying to survive on it.

Water quality
The presence of a tailings dam on the river system and the technology Bowdens proposes to use to process the ore present an unacceptable risk to water quality. The risk of acid forming materials leaching out of containment areas is a potential source of contamination. There is also the risk that the tailings dam could be breached or overtopped. On Boxing Day 2021, a storm went through the Lue area which dropped 100 mm of rain in less than an hour causing massive damage. Should such a storm impact upon a tailings dam Failure of the dam wall would have catastrophic consequences that would have irreversible impacts on the community's health, agricultural production and natural resources.
The risk of contamination is unacceptably high and the proposal should not be approved.
As an aside, the fact that Bowdens are not looking to use heap leaching to process the ore suggests that its claim to environmental best practice is demonstrably false as this process does not require a tailings dam.

Health
The WHO has determined the safe level of lead in the environment is zero. While Bowdens calls itself a silver mine, it will mostly be extracting lead and nickel with silver as a by-product.
The is close to Lue village, Rylstone and Mudgee. It will produce dust that is contaminated with cyanide and heavy metals including lead and cadmium. During drought years the tailings dam will be drawn down for day-to-day operations exposing tailings to wind and leading to more toxic dust being spread over the surrounding area.
As I have noted above, there is not enough water for the mine and this lack of reliable supply – especially during drought years – will impact on Bowdens ability to undertake dust mitigation by spraying roads, ore piles etc.
It is just wrong to lob into an area characterised by agricultural land and relatively pristine bush and start digging it up which spreads toxic dust everywhere. This mine should not be approved.

Visual impact
Bowdens propose to realign Transgrid’s 500kV transmission line. The new route would be highly visible as it follows a ridge line and is 500 m closer to Lue village. This would undermine the peaceful rural character of the area and is a form of visual pollution.

Traffic
Bowdens propose to use B-doubles to truck concentrate north to a rail line. Lue Road may be gazetted as a B-double road but this was intended for the occasional stock truck, not for multiple daily trucks heavily laden with lead, nickel and silver concentrate. The road is narrow, windy in parts and lightly constructed with few opportunities for cars to pass slow moving B-doubles. The malfunction of a load cover also presents the risk of spreading contaminating material from one end of the road to the other which is an unacceptable risk to public health.

Economic viability
Lue is a pretty little village that is in the midst of developing a tourist industry as it becomes a stopping point on the road between Rylstone and Mudgee. The proposed mine would spoil the peaceful rural feel of the village and risks the viability of Lue Primary School as its operation impacts upon the noise, air, water quality and visual amenity of the area. People living in the area have seen this happen with Wollar village. In addition, young children in particular are more vulnerable than adults to lead poisoning and this risk in itself should be enough to reject the mine.
While Bowdens are attracted to the area by high metals prices, the fact remains this is a small deposit; the company estimates the life of the mine to be only 15 years while the destruction wrought on the neighbouring lands, people, plants and animals will last forever.
The project is not “an environmentally and socially sound project” as Bowdens claims, it is a toxic waste dump that will destroy the water resources of the surrounding area forever.
This mine should not be allowed to proceed.

Employment – Destruction of existing industries – economic loss
No discussion or analysis has been submitted for the destruction of current employment in the region because of this project. The report: Bowdens Silver Project Part 15: Economic Assessment Report No. 429/25 fails to outline the businesses that will be lost and destroyed, should this project go ahead.
This region has a strong agricultural, viniculture, and vibrant tourism industry that employs a significant population. The economic report fails to mention any of these business losses.
The agricultural community have generational farmers that have produced food and fibre for our country for over 100 years. The significance of this contribution and their ongoing contribution has not been noted and accounted for. Furthermore, the mental health implications this generates has not been considered.
The vibrant tourism industry both directly and indirectly employs people in Lue, Rylstone, Kandos and Mudgee.
Diversity in employment strengthens community and the economy. A mining project takes away this diversity and economic strength.

3rd April 2022
https://www.planningportal.nsw.gov.au/major-projects/project/9641

Dear Sir/Madam,

The purpose of this letter is to object strongly to approval of the Bowdens Silver Project (SSD 5765) – Request for Water Supply Amendment.
I regularly visit my brother’s cattle grazing property at Lue and am surprised at the lack of professional behaviour by Bowdens Silver in failing to adequately plan the supply of essential resources such as water and power for their proposed mine.
Bowden’s initial EIS submission included a 58.5km water supply pipeline from Ulan to Lue, however this supply has apparently failed because they overlooked the basic step of gaining the approval from Ulan Coalfields and relevant authorities.
Bowden’s recent request to amend the water supply, now proposing that the required water can obtained from the mining site itself reflects the same lack of planning and forethought according to the report provided to the Lue Action Group by water expert Shireen Baguley (see the points extracted from her report below).
Lawson Creek is identified in the NSW Stressed Rivers Assessment to be in the most seriously stressed category (S1) – with the highest level of environmental stress as well as a high extraction rate. Most of times I’ve seen it, the creek has been a series of water holes with no visible flow, so it seems inconceivable that the additional water needed to operate the mine could be drawn from the local landscape without seriously impacting local and downstream farmers.
Further, Bowdens attempt to ‘get by’ by recovering and recycling more water from the tailings dam and leachate dam are very likely to increase the health impacts on the local community and environment. Recovery of this water will clearly reduce the water levels in each dam, exposing more toxic elements in the soil (lead/cadmium/cyanide) to wind events, which will spread these compounds further afield.
Given Shireen Baguley’s findings, it’s clear that if this mine is approved it will often be a heavily water-challenged operation, and accordingly Bowdens will be less able to undertake dust-mitigation activities such as spraying the roads, resulting in more dust movement into the local environment, especially during dry times and droughts when dust is at its worst.
Finally, Bowdens water amendment makes clear that their groundwater licenses have been purchased in the Sydney Water Basin catchment as well as further downstream in the Murray Darling catchment. The Sydney Water catchment is clearly not relevant to western waters and the NSW government has historically indicated a preference not to move licenses upstream within the same catchment, as the water is less likely to be available high up in the catchment and will consequently disadvantage local people and farmers reliant on that water.
Points extracted from Shireen Baguley’s report include:
• “The Bowdens surface water assessment data appears to show a monthly average that exceeds 75mm over summer. This is incorrect…”
• “Many of the other months are also too high when compared to Mudgee and Rylstone rainfall statistics from BOM.”
• “The number of very low rainfall years that has been experienced in this region is not reflected in the Bowdens surface water assessment annual rainfall data”
• “The surface water assessment reports the average annual rainfall as 673 mm/a…. An average annual rainfall of 654 mm/a would be a more realistic estimate.”
• “The analysis here shows that one in every five years, the climatic conditions between Rylstone and Mudgee, which covers the proposed mine site, are semi-arid. This means that any loss of available water in these years severely impacts the land, and the people, plants and animals trying to survive on it.”
• “It is highly questionable that 740 ML/a of rainfall and runoff would be available as an ‘inflow’ in a low rainfall scenario.”
• “Further, the sensitivity analysis appears to be fundamentally flawed... It is considered that the reasons for this are that a true assessment of the low rainfall and runoff’ would show that there is insufficient water to meet the proposed mine’s water demands for an unacceptable duration.”
• “the assessment attempts to quantify the loss of water to the downstream catchment, stating there would be an average annual loss of flow of 177 ML/a. This assertion is misleading as it relates only to the estimated flow from within the ‘containment system’ and overlooks the fact that the water requirements for the whole project are being drawn from within Bowdens land, both that within the ‘containment system’ as well as the Bowdens’ contiguous land holdings. The mean annual flow is 1,955 ML/a comprised of 965 ML/a surface water and 990 ML/a ground water.”
• “…this would equate to a loss of flow from 10.9% of the Lawsons Creek catchment. It is an enormous and unsustainable impact on the water resources within this catchment and a significant impact on all land downstream of the proposed mine site”
I strongly encourage DPIE to reassess the ‘facts’ and assumptions in Bowdens Water Supply Assessment and if confirmed to be questionable or overly optimistic to not approve progression of this mine,
Yours sincerely

Wendy Griffits
377 Coal pt rd
Coal pt 2283

I OBJECT TO THE AMENDMENT AND PLEASE REFER ATTACHMENT FOR DETAIL.

I am a local land owner and my family have owned property within Lue for 0ver 20 years. I am sickened that both the naturalistic beauty and the livelihood's of those farmers who call the Lue region home could be hindered by the introduction of Bowden's Silver. The recent amendment would mean that our family farm would lose its water and most likely become worthless. The tranquility and landscape is what brought my family to the region 20 years ago, I hope in my lifetime that more generations are able to see this beautiful part of the Country remain untouched by the silver mine. I ask that you refuse the project on this basis.

It concerns me re the Acid Mine Discharge "AMD"; It would be impossible to guarantee any barriers for permanent retention of any liquid waste. Toxic heavy metals can travel far down stream. Pollution of this kind in a food producing area and in the waterways would have an effect for many years to come. Aquatic life will be affected. There is no sign of the pollution ceasing down stream of the Sunny Corner Silver Mine after 98 years. This project should not be approved.

Re: Bowdens Silver Project (SSD 5765) – Request for Water Supply Amendment
Lacking Appropriate Community Notification & Consultation
It is very convenient for Bowdens to put this significant project change through as an amendment. It was this very aspect of the project that caused Mid-Western Regional Council to originally reject this project based on the high volume of water needed. This is far from an amendment, but rather a completely different application and as such requires much greater attention. Using the amendment process lacks transparency and rigor.

To take this water from ground and surface water in this region will have immense and far-reaching impact. With such impact, there needs to be appropriate community consultation with ALL the immediate stakeholders and broader community, who will also become impacted stakeholders, due to the knock-on effects.

The inadequate community consultation suggests improper measures are being taken by Bowdens to expediently attain the approval by the DPIE. By their own admission in the document titled Re: Bowdens Silver Project (SSD 5765) – Request for Water Supply Amendment, Nick Warren, Principal Environmental Consultant, says “Bowdens Silver appreciates that this further amendment is a change to the Project as it was presented to the community,” and goes onto to say that they are in the process of undertaking community consultation.
Thus, if still in the process of undertaking community consultation ………clearly the appropriate consultation has not been done. This being the case, this submission close date of 7th April 2022 is woefully inadequate and has NOT allowed the community to be notified with an appropriate response time.
There have been no public meetings, no meetings for discussion and no appropriate community and stakeholder notification. This is completely unacceptable and not in line with the ICAC recommendations.
Some of the directly impacted landholders only received communication early April.
To be fair and reasonable more time is needed for this community and appropriate notification and consultation needs to occur. To be reasonable, the NSW Planning Department need to re-open and extend the submission time and allow for adequate and appropriate community consultation.

Powerline realignment proposed will remain a visual impediment to the rural ambience of this district. The area is frequently on the route of a large number of economically very significant tourist traffic. Any degradation of tourist appeal will lead to regionally significant reductions in economic activity and consequent employment opportunities. The powerline proposal, along with all other aspects of this mining project, must consequently be dismissed as an approved activity.

See attached letter

Murong Gialinga Aboriginal & Torres Strait Islander Corporation object to the Bowdens project .The area where the mine is situated is Culturally important to the local Wiradjuri people past/present . Aboriginal Culture is the oldest in the world but it continues to be destroyed daily.There are concerns for the Koala which is sighted in the area and had been put on the endangered list there are also the wedged tailed eagle,echidna,yellow tail black cockatoo which are important to our people culturally.The amount of ground water that the mine wants to take is potential for reduced frequency and depth of remnant pools during extended dry spells as a result of ground water being drawn.The feasibility study shows that during mining they plan to store a pile 40 million tonnes of waste rock above the Lawson Creek water table.Analysis shows that 54% of this waste rock is potentially acid forming meaning it can create toxic Sulfuric acid when disturbed.Sulfuric acid is toxic to aquatic life.It could also run into Lawson Creek which flows into the Cudgegong River at Mudgee before flowing into Burrendong Dam.If this project is approved it will be a huge impact on Aboriginal Culture, Wild life and the residents of the village of Lue and surrounding farming land with noise,vibration,dust,traffic it could also see a decrease on residents properties.We hope the department looks and addresses our concerns and not approve this mine.Kind Regards Debbie Foley on behalf of Murong Gialinga.

Water supply near the head of the Lawson Creek catchment is over the years frequently inadequate to meet the desired level of extraction by existing rural users. The SVL EIS Amendment stating that all the mining and ore concentrate processes required by the proposed activity can be met with water acquired on the subject sites, without impacting on downstream users, is unbelievable. Any form of use of surface or groundwater MUST have an impact on downstream water availability and quality.

Please see attached objections given to me by people in the last few days. It was too late to post them to you so I've included them on my portal

See attached letter - the mine is totally unfeasible and detrimental to the water table lands of our area.

The retention of extra surface water runoff will have to have an adverse effect on the downstream waterways and the wildlife relying on the water. Landowners will also lose water already available for stock.
The short and long term effect of the drawdown effect on the groundwater is unnacceptable.
Bowdens make a sketchy and frivolous attempt at justifying their disdain of biodiversity and it's value to the wider community.
The Application attempts to justify the destruction of 381.17ha of native vegetation. 180ha of this is EndangeredBox Gum Woodland, 146ha of this is Critically Endangered Community!!
This must be considered in context with other mining activity around the State and the entire country as having a cumulative and devastating effect on wildlife listed as Threatened and on other unlisted but important species.
There are six species listed as threatened or migratory.Envirokey claim no significant impact on these with the exception of the
rgegent Honeyeater.
How advanced are the offset plantings?will they be mature enough to supply food and shelter for when the land is cleared? I think not.
What about the other five species listed? Koalas - now Endangered, Squirrel Glider, Silky Swainsona Pea, Small Purple pea, Large -eared Pied Bat.
The report totally ignores them!
Where are these offset areas? Can the wildlife onsite reach them before the land is cleared? Is the existing bushland already at maximum capacity? Or are they just crushed and buried. If they manage to relocate is there sufficient food and shelter for them or do they need to compete with the animals already in residence.
Some of these will no doubt perish.
How can this project possibly justify itself as an Ecological Sustainable Development?

I don’t believe that there is complete transparency and honesty in relation to jobs that will be created or lost by this mining operations. The issue of the job numbers to be created is that there is no mention of the jobs lost to the community adversely affected by a mining intrusion to the area either locally or wider ranging. As seen in other areas when the mining operation cease to continue the remaining surrounding surviving community fails to recover. The mental and human health toll that has been afflicted on a community is unacceptable and is morally wrong

I strongly object to amendment as it does not make this project safe. By scapping the pipeline, Bowdens wish to extract all water for their mining from their harvestable rights onsite, from aquifers. The amendment does not demonstrate that this mine will have a reliable water supply causing even more pollution from lead and other heavy metal and mineral dust to our local environment. The mine will have to close in dry times. Bowdens have not modelled stream flows from lawson Creek on a meter above Rylstone on the Cudgegong River - totally irrelevant. They don't know anything about local creek flows. They have not demonstrated they are suitable to operate a mine as design of the TSF is experimental and widely disputed by experts. They want to destroy our local creeks and aquifers forever to mine for a short period of 16 years. Who will care for the toxic tailing storage dam and leachate residue dam FOREVER. Experience from other similar old mines such as Captains Flat near Canberra and Sunnny Corner near Bathurst is that heavy metals cause pollution which despite repeated efforts to rectify damage, mostly at the expense of government, they cannot rehabilitate the waterways. What a prospect for the future of the Lawson Valley.
Bowdens is seeking to amend the alignment of 500kV powerlines from on top of the mine site - many residents of Lue will have suffer. Not only will they have to suffer poisoning from lead dust, dry bores, increased road traffic, noise from mining vehicles and light pollution, many of them will now look onto enormous high transmission lines. Bowdens has not yet secured a supply of electricity for the mine - they are hoping to bring a 66kV line through sensitive vegetation and many private landholdings. They cannot demonstrate they are fit to operate a mine. I don't believe they have the skill or the will to be good mine managers and the ore they are mining is particularly toxic. As a landowner near the mine and on the Lawson Creek, I am extremely worried about our future and the detrimental effect this proposed mine will have on my property. We are proud of our farm and have spent many years improving our native and improved pastures, fencing out sensitive vegetation and soils from stock, maintaining grass cover even during droughts - all to ensure we have a healthy farm producing healthy animals. We love our home. This mine threatens my home.
For many years we have battled the prospect of a silver lead and zinc mine at Lue. As time goes on, proponents get more determined and seem to have deeper pockets. One fact has not changed - mining for lead is extremely dangerous and polluting especially 1.9km from a large village and set within a fragile landscape high in the catchment. I strongly object to the Amendment and also to the Bowdens Silver Project SSD-5765

Potential for Acid Mine Drainage from long term storage and consequent exposure of mine waste is such that any Pb Zn Ag sulphide and related mining at the head of a regionally significant catchment is unjustifiable both environmentally and consequently economically.

The proposed mine is not feasible in it's current form and should not be approved. Further details on relevant issues is provided in the attached.