Bowdens Silver

I'm in support of the project due to reducing the processing water usage by 390ML per year and that the power lines will be moved closer to the mine site.
This project will create stable, local jobs that will benefit the local community for many years.

I object to the Bowden Silver mine and its subsequent amendments for the following reasons:

Lead which is what the mine will produce is poisonous and is in close proximity to a junior school and homes. Lead even in extremely small doses is EXTREMELY harmful to children in particular.

The proposed mine will have an unreliable water supply and this will mean that the mine will have to shut down during droughts.
Lawson Creek is identified in the NSW Stressed River Assessments to be in the most seriously stressed category with a high level of environmental stress as well as a high extraction rate it is unsuitable to have a mine relay solely on this water source, putting undue pressure on this already stressed water source.
Bowdens Mine proposes to transfer water licences from further down the Macquarie catchment as well from the Sydney basin catchment, further depleting Lawson Creek which is unacceptable for the community.

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 sister’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 not to mention the effect it will have on the platypus and koala population.
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

This Amendment , proposing that sufficient water for mine operation can be extracted from the immediate area of the mine site, ignores reality.
Any attempt to do so would have devastating effects on environmental flows in local creeks. Taking water from groundwater reserves would have ongoing negative effects on bores in Lue, which are already stressed in dry periods.
The pit resulting from mining operations would form a groundwater sink , capturing more water to replace evaporation and causing an ongoing waste of water. The tailings dam would create an even more serious threat . Acid Mine Drainage from the dam is inevitable and would have ongoing effects.
There are many instances where this has occurred in Australia eg Sunny Corner (near Portland), Woodlawn (near Tarago), Captains Flat (near Canberra), Rum Jungle, N.T. There is no reason to expect this would not occur at Lue. If permission to proceed is granted Bowdens must be required to lodge a bond sufficient to ensure effective containment of toxic waste for hundreds of years.

There is absolutely no feasible reason for this mine to go ahead. The major concern is inadequate availability of water. The original mine project included a proposal ton pipe surplus mine water from the Ulan and Moolarben Mines near Mudgee but this idea has now been firmly scotched. Instead they have put in an amendment whereby suddenly they believe they can find enough water on site. The community has been given just two weeks to comment. It is totally unfeasible.
Please see detail notes in the attachments.

These are significant amendments for which there has been totally inadequate community consultation and the timeframe for comment – a mere two weeks – is far too short and places even more stress on the community.

Water
There is not enough water for this mine. This was recognised at the beginning, hence the original proposal to pipe water from the Ulan and Moolarben mines. The onsite water availability has not magically increased just because the pipeline cannot be built.

The independent review of the data used for the water modelling has found some serious mistakes such as:
• They have used an average of combined data from Mudgee and Rylstone when it is well known that Lue is in a rain shadow and has less rainfall than either of those two places.
• They have conveniently left out the driest years in their data.
• Australia’s climate variability is well recognised: in their modelling they allow for highs of 30% above average but only allow for lows of 14% below average. This is ludicrous. Any landholder who keeps rainfall records knows that dry years can go as low as 50% below average.

The conclusion that there is negligible impact on downstream water users is wrong. Any loss of water in dry times is critical.

I refer you to the independent critique of the water assessment and water modelling for all the technical details. The critique clearly demonstrates there is NOT ENOUGH WATER for this mining project.


Transmission Line Relocation
This new proposal is not much different to the original proposal, so all previous objections stand. These are:
• I object to the whole process of an amendment being added even before the Department has released an assessment report. This should have formed part of the original submission and been properly considered in the EIS. The original EIS was highly flawed and we see a continuation of poor environmental assessment with this amendment.
• It is a travesty of the environmental assessment process that this amendment is being considered even though the exact location of the realignment is not known.
• The realignment will result in destruction of 12.6 ha of native vegetation, including the threatened ecological community, Box Gum Woodland. With only 5% of this ecological community left in the Central West, every hectare is precious.
• As mentioned above inadequate environmental assessment has been done. Of particular concern are hollow-bearing trees significant to Barking Owls and Greater Broad Nosed Bats, which have been identified close to the clearing for the transmission line. The importance of tree hollows (particularly large hollows in old trees) should not be underestimated, especially following reduced habitat due to the the 2019-2020 bushfires.
• Adequate assessment has not been done of the impact on Aboriginal cultural heritage. This is yet another example of the significant negative cumulative impact of mining being ignored.
• The proposed realignment will have a huge negative impact on the visual amenity of the region which is a major tourist destination. This has not been addressed.
• It is of great concern that there have been no discussions with the community regarding visual amenity, dust and noise associated with the amendment – yet another travesty of the planning process.
• I understand alternate options for proposed realignment were considered. Should this realignment go ahead, the condition that a route that places the line on lower
topography, avoiding the ridge and less destruction of native vegetation must be enforced.)

Bowdens state only four landholders will be affected. This is not true. Many properties have wonderful views which will be adversely affected by the appearance of the powerline on the ridge. Moving the line 100m makes virtually no difference to the negative visual impact.

This whole project has serious issues relating to water and air pollution and SHOULD NOT BE APPROVED AT ALL.

Please find attached a pdf of a Powerpoint I have developed on the problem of Acid Mine Drainage, which Bowdens has ignored. I do not support the project as it stands as this has not been discussed or addressed by Bowdens, who has in no way demonstrated how it will minimise the problems of Acid Mine Drainage. This is a major oversight that needs to be corrected.

Dr Haydn Washington, environmental scientist who worked on heavy metal pollution from sulphide mines for 7.5 years in CSIRO

I strongly object to the project. See attachment.

As a community member, employee and shareholder, the amendments to the project could only be viewed in a positive light.
Clearly the company is acting in good faith with interlocuters removing and adjusting visual and physical impacts, while also continuing to optimise outcomes related to water. In short removal of infrastructure has reduced the impacts under assessment. Asides from the changes proposed in the amendment the changing and uncertain geopolitical climate has highlighted that dependence on global supply chains is fraught with risk. Globally there is an accelerating shift from fossil fuels to renewables that will require additional silver production to electrify all parts of our and other societies. For example two ounces of silver are in every Tesla, of which it is proposed to produced multiple millions in the coming years and globally some 55 million ounces is currently used in electric vehicle production, not to mention that consumed in solar panels. This material should be sourced from a first world jurisdiction where corruption is minimal and proper environmental controls are enforced; not approving such projects merely shifts the responsibility from the nations and states who consume it. Surely a state and a nation wishing to persist and thrive locally or globally, should look to build a functioning society over the short and long term. In the longer term Mudgee and the surrounding LGA undoubtably draw great benefit from coal mining and there looms the end of an industry, as more efficient methods of energy production and reducing agents in steel production are utilised. Regional economic drivers such as mining unless approved by the state today will be absent tomorrow.

Mineral exploration discovery and the industry as a whole, can only be successful if there is a clear pathway through to development. Bowdens have done everything they can to reduce harm to the environment, and as such this project can now coexist with stakeholders and provide valuable contribution to the economy of the region and future of mining in NSW.

Similarly to Bowdens/Silver Mines, my organisation Marlee Minerals, is testing innovative concepts in project generation and discovery. Bowdens is a testament to 'outside of the box' thinking, and growing a discovery through hard work. I sincerely hope they are successful.

the Bowdens Silver project is part of a resurgence of silver-base metals mines. New projects and world-class assets come along so infrequently. For NSW to have a primary resources sector, the regulators and committees must say yes to this project. Otherwise, exploration is dead in NSW.

The development of a new metals mine will provide valuable jobs and is part of the post-coal transition required for the primary resources industry in NSW. The proposal by Bowdens Silver is well thoughtout and will undoubtedly provide innumerable benefits for this region, NSW and Australia.

I frequent this area of the proposed mine on a very regular basis and i am very concerned about the ongoing environmental effects this project will have on the local Lue area. I also have grave concerns about the mine directly accessing the natural water ways that also use the water for there farms and domestic use.

i believe the Bowdens silver project will help boost the small community of Lue through providing jobs for the locals living in and around Lue and surrounding towns, as well as provide support for other businesses and facilities around the region.

Project will provide long term employment while providing materials necessary to support green energy.
Removal of pipeline will help minimise long term impact of project post mine life.

I OBJECT to the proposed SVL Bowdens Project
(1)The proposal must be rejected, due to the huge impacts its proposed water useage will have on agriculture in the surrounding area, residents in the village, those dependent on reliable bore water and downstream users. My major personal concern as a landholder engaged in an agricultural business is the potential impacts on critical underground water sources on our property, most particularly our farm 50 megalitre irrigation licence. Our ability to use our land to raise cattle and sheep is entirely dependent on underground water in times of drought and I have no confidence that any make good provisions will overcome that potential loss.
The fact that this proponent has never undertaken any monitoring of our registered 50 megalitre bore only heightens my concerns.
Using modelling projections, the proponents assert that sufficient water will be sourced from within Bowdens holdings and the mine site. Actual rainfall records, meticulously kept by property owners adjacent to the proposed mine site show that the water available to the proponent from rainfall is far less and far less reliable than claimed in the proponents modelling.
When the project inevitably falls seriously short of the water it needs, where will the replacement water come from? Even a brief analysis of the rainfall figures scrupulously recorded at our property over 35 years will show that not enough reliable water can be accessed through rainfall and the modelling is not supported by historical records.
Once again the proponents have failed to make a believable case that they can source anything like an adequate volume of water from the area or anywhere else that would justify the project’s approval.
The rainfall data below clearly shows that the annual Summer recorded rainfall falls well short of the modelled 75mm per month (450mm over Summer) on 21 of the past 32 Summers.
That is, only 33% of Summer rainfalls in the past 30 years has exceeded 450mms. Also, in only 84 of 204 summer months (41.1%) has the monthly total exceeded 45 mms.
Rainfall data from Mudgee Airport Weather Station (1994-2022) also indicates that the modelled projected Summer rainfall of 75 mm per month is incorrect. The mean rainfall figures are October (50.3), November (76.1),December (77.3), January (66.1), February (64.7), March (65.4).
Total = 399.9 mm. Monthly average = 66.6 mm.
The proponent will not be able to find the necessary water to conduct its operations without catastrophically depleting groundwater in the area of Hawkins Creek and Lawson Creek.
(2)I am also very concerned that the proponent consistently refuses to address very real community concerns about potential health impacts by at least establishing comprehensive baseline data for severe health risks such as lead. The proponent SVL advertises the project as a Silver mine. When the volume of Lead derived from this project is AT LEAST 50 times that of Silver, the glossing over of the volume of lead to be extracted and the sidestepping of any health impacts is dishonest. If, as the proponent asserts, there is NO risk to health from lead at the project, then to show good faith to the community the proponent must be compelled to carry out comprehensive baseline testing before approval is granted or any work commences. Community concerns about Lead were not adequately addressed in the EIS and the data used was historic (from 2012 and 2013 in the time of KCN ownership of the project) and discredited, derided and dismissed as out of date by the proponent SVL.
(3)Another very serious aspect of this process has been that the EIS which was put on display for community comment in 2020 is markedly different to what is being put forward as a simple amendment in 2022. The community did not have access to the current model and the far more serious effects it will certainly have on surface and groundwater in this area.
The 2020 proposal included a water pipeline from the coalfields which was to supply a significant volume of water to supplement water collected on site. Community members were assured that this would relieve pressure on local ground and surface water supplies. Some community members believed, rightly or wrongly, that this water pipeline would include a reticulated water supply system to the village of Lue. This community benefit was widely reported as being a strong reason for some Lue residents to support the project.
In the interests of giving the local community a fair opportunity to assess the real impacts of this project on the Lue community and its surrounding agricultural enterprises, an amended EIS must now be submitted by the proponent.
RESPONSE TO BOWDENS PIPELINE AMENDMENT
• Users of Surface and Groundwater: (Page x) states “this strategy would not be likely to increase the projects impacts on users of surface water and groundwater resources”.
(1) The term “not be likely” engenders no confidence in the people of Lue and surrounds who rely on surface and groundwater for stock and domestic purposes that they will continue to enjoy safe and reliable water supplies. During 2018 and 2019 drought surface water supplies were severely depleted, with many dams and water storages drying up completely. Groundwater was critical for keeping stock alive. The huge volumes of water to be used annually in this proposed project, coupled with the next severe drought, will make conventional farming and grazing extremely difficult if not impossible. The projected rainfall figures used in the modelling are wildly optimistic.

In particular, the projected Summer rainfall average of 75mm per month in a 34 year period was exceeded on only 41% of the Summer months recorded since 1987. (See detailed rainfall data below)

• Impacts on other Registered Groundwater Users: (Page xiv concedes there will be “potential impacts associated with the availability of groundwater for other registered groundwater users”. The proponent concedes in (x) and (xiv) that other users will “potentially” be impacted. There are 106 bores located within 10 kms of the project. They are used for stock and domestic purposes. How severe are the “potential” impacts likely to be in times of severe drought?
Enough to make a bore unusable? All the make good promises will be as nothing when the project concludes and a bore no longer produces water.
Has the proponent promised to “make good” in perpetuity?

• Drawdown: (Page xvi): Whilst groundwater drawdown greater than 2m is predicted at only one privately-owned registered groundwater bore Jacobs (2022) considers this prediction is the result of model conservatism”. Words to strike fear into the hearts of groundwater users –
Predicted- and if the modelling is erroneous and the prediction is in error, the groundwater users of Lue and surrounds will be bearing the burden
Considers – the opinion of a consultant which may prove to be in error

• Environmental Outcomes. (Page xxi): “The residual environmental outcomes are not predicted to impose an unacceptable cost to future generations”. Once again, a consultant is making predictions about what might happen in the future. The prediction may prove to be incorrect.
How did SVL come to the conclusion that a future cost is not “unacceptable”?
The residents of LUE and surrounds are expected to submit to what the proponent suggests is acceptable. Loss of amenity, visual impacts, noise impacts, light, possible depletion of surface and groundwater, increased traffic and the parting gift of a massive void partially filled with what was once precious water in our underground aquifers will be their legacy. Agricultural land (currently growing a very impressive dryland sorghum crop) (See photograph below) which has sustained life for countless generations of First Nations people will be rendered agriculturally useless forever. This is absolutely unacceptable.


Dryland Sorghum crop on Price’s Gully, Bowdens – 7th February 2022.

• Downstream water Users: Water Supply Amendment Report (Page 4):-potential impacts – the loss of baseflow on the availability of water for downstream users in the Lawson Creek water source. (Page 41) “there would be negligible change in availability of surface water for downstream users adjacent to Lawson Creek.
Again, in times of severe drought such as in 2018 and 2019, downstream users were reliant on permanent pools fed by underground aquifers as there was no flow in Lawson Creek. Upstream diversion of underground water to the proposed mine site may well have very significant effects on downstream users. If the project were to proceed, those effects would be irreversible.

• Registered Groundwater Users. There are 106 of these within 10 kilometres of the proposed mine site. Only 24 are part of a monitoring program. My family property contains a registered bore (WAL 27907/Associated Groundwater work/Stock, Domestic/Irrigation. Sydney Basin, Murray Darling Basin). This bore has an associated 50 megalitre irrigation licence. The previous proponent KCN undertook some intermittent monitoring of this bore around 2011 -2015 and provided me with the results of that monitoring program.

Since taking over the project in 2016, the current proponent SVL, has never approached any member of my family to request access to this bore for monitoring purposes.

All 106 bores should be part of a monitoring program so there can be no dispute about the degree of loss of access to water once the proponent commences the dewatering and collection process. (Page 59. Referring to bores likely to be adversely effected by drawdown- “Monitoring for potential drawdown impacts at these bores would be an objective of the groundwater monitoring program for the project”.
Clearly, monitoring of all 106 bores to clearly indicate if drawdown impacts have occurred must be required of the proponent. The proponent has stated that “Make (No room for rest of submission) (Unable to upload attachments)

The proposed mine will have an unreliable water supply. The mine will have to shut down during droughts. Lawson Creek is identified in the NSW Stressed River Assessments to be in the most seriously stressed category with a high level of environmental stress as well as a high extraction rate. Bowdens Mine proposes to transfer water licenses from further down the Macquarie catchment as well from the Sydney basin catchment, further depleting Lawson Creek. Lead is poisonous for Lue!

I object to now taking all of the water out of Lawson Creek. It has a history of drying up which means that if there is no water to spray and undertake dust mitigation, they will be unable to reuse water and the environment and human and wildlife population will be put at risk.
In addition, the roads around Lue are not suitable for heavy vehicles.

The proposed mine will have an unreliable water supply

The mine will have to shut down during droughts

I am concerned that the proposed mine will put severe stress on Lawsons Creeks and the families and farms that currently rely on Lawsons Creek as a water source.

Lawson Creek is identified in the NSW Stressed River Assessments to be in the most seriously stressed category with a high level of environmental stress as well as a high extraction rate.  

Bowdens Mine proposes to transfer water licences from further down the Macquarie catchment as well from the Sydney basin catchment,  further depleting Lawson Creek

Lead is poisonous for Lue