Bowdens Silver

I strongly support the project for the following reasons.
Firstly the jobs created by this development are desperately needed throughout the immediate and surrounding areas and the commitment by the company to source as many jobs as it possibly can from the local area is a huge boost for the the local economy. The project is also a boost for the State and Federal economies at a time when the those economies desperately need it due to the impacts of covid 19. Approval would also provide a huge benefit to people's well being with the prospect of jobs and increased economic activity.
The very rigorous and thorough EIS shows not only the positive benefits but also addresses the many issues which could cause concern for a community such as human health, noise, traffic etc and shows how seriously the company has taken these issues and the work done to address any community concerns.
I am also aware of the industry leading way in which the company has genuinely, honestly and diligently engaged with neighbours of the project and the broader community so they are fully informed throughout this process.

I do not support the Mine project - see attached letter outlining my objections

Please refer to my submission document attached

I believe this state significant project would greatly benefit NSW and its local economy, with silver price increasing and current COVID-19 situation, the project would be a much needed boost to local jobs for many years to come

I think the project is vital as part of NSW's recovery from the financial impact of COVID 19. It will also provide more jobs, which is dearly needed at present.

I am a resident of Mudgee and concerned about several aspects of this project.
Despite what Bowdens say this is a lead/zinc mine. Silver makes up a mere 0.5% of the recoverable material mined.
Bowdens advertisement in the Mudgee Guardian of July 10 misleads by quoting projected revenue figures for the project, which obviously places silver at the top of the revenue table, but ignores the minute amount it earns relevant to the total mine output. Regardless of whatever is being mined, no mine should be allowed to operate 2km from a population centre. A mine extracting lead bearing material that distance from a school must never be allowed to operate. The threat to the health of children is extreme.
The plan to divert water from the Ulan Coal mine will rob the Goulburn River of a supply vital to its health, and must not be allowed to proceed.
Toxic run-off from tailings and acid bearing waste rock will have detrimental effects on water and land in the adjacent areas.
The transport of material through Lue and Mudgee by road will pose additional risks to people, property, agricultural production and infrastructure.
The often promoted, and usually discounted, claim for jobs generation cannot be relied on.
This project must not be allowed to proceed.

I appreciate the opportunity to make a submission regarding the Bowdens Silver Project.

This project should not be approved, as it will result in the destruction of endangered ecological communities and threaten the survival of threatened species.

As a landowner on the Cudgegong River downstream of the Lawson Creek's confluence and friend of several landowners on the Lawson Creek I feel qualified to voice my objection to the proposed mine for the following reasons;
* The highly toxic tailings dam is to be constructed less than a kilometre from Lawson Creek. These dams often give way in extreme rain events - leading to pollution in a major way in the Lawson Creek.
*This mine will produce 95,000 tonnes of lead. A toxic element such as this close to family's homes and schools in Lue etc is just not on in 2020.
*The mine is to operate 24/7 - surely an unfair imposition on a population who settled and bought into the area with the knowledge of no such mine existing there.
*A deadly cyanide processing plant will operate on the site.Is this environmentally appropriate in 2020?
*The extra traffic placed on the Rylstone/Mudgee road due to 227,000 tonnes of ore being trucked from the mine will present a serious likelihood of potentially fatal accidents - this is a windy and narrow road.
*The mine cannot source sufficient water locally so propose to pipe it from Ulan or Moolarben mines - this is not sustainable in dry years.
* Ground water levels will drop by 25 metres- the open cut pit will continue to draw water for up to 100 years after the mine has been abandoned.
*Waste dumps (of potentially acid forming material) produced by the mine above the water table will most likely leach into the water table and the surrounding catchment.
*Bowdens do not offer a suitable plan for rehabilitation of the mine - hardly the level of concern required of a company disturbing the environment so radically.
* This mine covers habitats of koalas and regent honeyeaters. Any disturbance on the scale proposed for this mine would ruin these habitats forever.
* The economics of the mine are marginally viable at best ( the assumed silver price in the EIS is US$20.91/ oz. - a price not achieved in the last 5 years)) which leads to the inevitable cheaper methods of running the operation and the consequent worse results environmentally and socially.

I think this is an amazing opportunity for the local area, to create much needed job opportunities.
NSW has a bad reputation for slow process approval which has really slowed the development of the mining industry of NSW, this is deterring investment into NSW. We need investment to grow local job opportunities.

In reference to this project I am objection to the potential of power infrastructure of any size being constructed within or within the vicinity of my property at 1857 Castlereagh Highway, Cudgegong.

We have current arrangements and have entered into an agreement with the Biodiversity Conservation Trust and I believe this would directly impact that arrangement.

I believe that any infrastructure associated with this proposal constructed within the vicinity of my property would directly affect the value, our in place conservation agreements and the aesthetics of the area.

Regards.

Re: State Significant Development No. 5765

The purpose of this letter is to object to the granting of a mining lease to the Bowdens Silver Mine - State Significant Development No. 5765.

I visit Lue and the broader Mudgee district to spend time with family, enjoy the cultural offerings and the natural environment.
My objection is on several grounds, as detailed below.

Water Availability and Use

The region is expected to be impacted by increased temperatures, reduced rainfall and increased bushfire weather, such as strong winds, due to climate change (AdaptNSW).

Yet, the EIS and support documents acknowledges that this mine is expected to result in the loss of baseflow contributions to streamflow due to the impacts on the local groundwater profile. This is both during the operational period and post mining, where the reduction in baseflow is expected to increase, resulting in ongoing water losses to the Macquarie Bogan Unregulated and Alluvial Water Sources – part of the much maligned Murray-Darling Basin.

The EIS indicates most of the water for operations will be obtained on site by breaking through aquifers drawing down the groundwater. This groundwater is critical in maintaining the waterholes along Lawson Creek – waterholes that were vital to keeping stock alive on farms all along Lawson creek during the drought.

Notwithstanding the use of groundwater and local surface water, this project does not have sufficient water for its operations. The EIS indicates they are planning to source about one fifth of their water via a 58km pipeline from Ulan and Moolarben coal mines, however there is yet to be any evidence of an agreement or planning proposal for this pipe. Ulan and Moolarben coal mines are obliged under their mining leases to return all excess water to the Goulburn catchment to help maintain environmental flows – they have no approval to sell eastern-fall water over the Great Dividing Range for a proposed western-fall mine.

Water Contamination

The Social Impact Assessment annexure to the EIS identifies the concerns of stakeholders that the Project may contribute to lead contamination should the TSF walls fail, significantly impact ground and surface water and resulting in potential health issues.

This happened in the wider region already at the Newcrest Cadia Gold Mine, near Orange, in March 2018, resulting in the movement of more than 1.3 million cubic metres of mining waste material. An expert report on the failure of the TSF wall at the gold mine has urged Newcrest to assume that two large dams were at risk of a repeat incident.

The Social Impact Assessment notes that despite the mitigation action to regularly check the dam walls, concerns remain that if the dam was subject to a large influx of water, resulting in flooding, then impacts could still be experienced. A break in the dam wall at the proposed mine would flow into Lawsons Creek and then contaminate the whole water course into the Macquarie Marshes.

Additionally, the EIS and associated studies confirms the excavation below the water table in the open cut pit will expose potential acid forming (PAF) material. When exposed to rain, PAF forms sulphuric acid and can lead to the acidification of groundwater and mobilisation of heavy metals.

Acid mine drainage is considered one of mining’s most serious threats to water resources. There is no comfort in the EIS and supporting documents that the proposed management strategies (e.g. liners, capping and cover systems) will limit seepage.

Terrestrial Ecology

According to the EIS, the Project will result in the removal of over 381ha of native vegetation that has the potential to be a habitat for a range of native fauna, including threatened species.

Those impacts are reportedly not expected to the “significant” but with Australian native flora and fauna facing major extinction events in the near future, does the proponent of a silver mine determine what is “significant”?

There are 370 flora species (267 native), including three threatened ecological communities and a critically endangered ecological community, and 168 fauna species, 14 of which are listed species under the BC or EPBA Acts, including the Koala (vulnerable in NSW and Australia) in the survey area that will be affected by the Project.

The Squirrel Glider (vulnerable in NSW) and the Regent Honeyeater (critically endangered in NSW and Australia) are also predicted to occur within the footprint of the mine.

Only 43% of the required offset area has been accounted for, with the remaining area not documented in the EIS and only demonstrated through “potential” expressions of interest from nearby landholders. Offsetting removed flora species does not automatically result in creating an environment for the revival of fauna species lost through land clearing. These are not like for like actions.

Greenhouse Gas Emissions

The discussion in the EIS around greenhouse gas emissions bordered on offensive, with over 1.25 million tonnes CO₂-equivalent Scope 1 and 2 emissions projected over the life of the mine (17 years).

It was noted that the emissions estimates are “conservative” as they do not account for the GHG emissions through the increase in vegetation biomass from offset areas to be established for the Project.

This “increase” is to offset the biodiversity impacts from the removal of vegetation. Those offsets have not been established for offsetting carbon emissions, they are required through the BAM assessment because the mine is unable to avoid land clearing.

There is no proposed offsetting to account for the greenhouse gas emissions. It is typical of mining proponents to lump all environmental restoration in one bucket. The habitat restoration of the threatened species and removed habitat should be entirely separate from planting to offset carbon emissions impact – they are separate impacts.

If you take the assumption that a tree (after 10 years of growth) can remove 7 tons of CO₂ from the atmosphere, the proponent will have to plant around 180,000 trees. The CSIRO recommend 30 mature trees per hectare, so the proponent would have to plant around 6000 ha worth of trees – far greater than their biodiversity offset requirements.

Furthermore, the EIS notes the Scope 3 emissions does not provide for “the use of silver in the production of ‘green’ power generation, such as the production of photovoltaic cells and other electrical applications”.

Firstly, the role of silver in the production of PV cells has been dropping and is projected to halve by 2028. However, the point here is that the comment is redundant in establishing the emission impact of the mine - coal mines are not given positive points for the fact their coal goes on to create electricity that powers schools and hospitals.

The attitude in the GHG emissions section of the report is reflective of the attitude of the industry. It is a flippant and destructive attitude and does not lead me to conclude that this proponent would be a good corporate citizen.

Finally, I would like to draw your attention to this quote from Anthony McClure, managing director of Silver Mines:

“NSW is a pro-mining state and one of the world’s biggest coal producers. We are in a safe, high quality mining jurisdiction that gives us a real advantage.” (Mining Journal).

The approval process should not only consider the requirements of the SEARs, and the potential environmental impacts and efficacy of the associated mitigation measures. The process should look to determine the future for the people of NSW and the kind of industries NSW supports.

In the right location, silver mines may have a place. Bowdens is not in the right location, and perhaps NSW should reconsider its mining approvals approach and the unenviable label of being a “pro-mining state”.

Sincerely,
[Name withheld]

As a farmer in the Lue District I think you should consider the environmental aspects of the mine site and the EIS from Bowden's has clearly shown that the tailings dam is not up to world standard being at 1.2 and the minimum standard being 2 for holding the required materials from leaching out into the the creeks below.
I also think that you should consider the future implications that this mine site will have on our under ground water supply both during mining and for ever after.
I think you need to consider and think about the health aspects of the Lue village and the local community surrounding the village.
I think you need to consider the affect lead dust could have on the agricultural sector as we are farmers who grow crops to produce protein e.g. lamb and beef.
What happens if the lead dust and other dust particles from the mine site get into the animals through consumption via eating the crops that we have sown, and they are rejected from the abattoirs??
What do we and our future farmers do then

I was a Police Officer with NSW Police Force for almost 15 years. During this time I was posted in a rural area and the occupant of the local police residence. A building inspection identified an issue with lead paint within the residence. This immediately raised alarms and concerns, due potential health risks. I was forced to move out and the residence was decommissioned. No one has resided in this property since. I was medically tested for levels of lead in my body. This demonstrates that it only takes a very small amount of lead present in a building to cause residents to vacate.

My partner's family home is in the Lue community close to the Bowden's mine site, that would be exposing lead dust to the air and the surrounding area. This is extremely concerning and I oppose this site for an such mine. Although promises may be made that water sprinklers and other precautionary measures will be used, will Bowden's give a 100% written guarantee that no lead dust will leave the mine site?

If any lead dust was to get into the water system, vegetable gardens or on the roofs where many occupants in the local area collect own drinking water from this would cause serious health impacts and could become fatal for some residents. My partner's family collect rain water that runs from the roof that they use for drinking water and household use. This is common in this area.

My partner's family have livestock (cattle and sheep) that they use for their own consumption, if lead was to get into the waterways or onto the pastures that these livestock eat, my partner's family would then be consuming meat products that have potential lead contamination. Again this is common in this area for many residents.

I spend some time on this property and my partner is very passionate about this property and hopes that it remains in the family as it is very special to her. My partner hopes that this property will be passed on to her children in the future. I will be keeping my lawyer informed of any concerning developments in this matter.

In my opinion Silver Mines Limited should not go ahead with this devastating project with an EIS that has not been thoroughly thought out. I am concerned for the local community and it's members as the company has not provided sufficient information about the development of this project. My understanding is that there has not been substantive nor truthful documentation provided o the local community members and the council that instills any confidence in this project and its potential issues. If Bowden's were considerate of local land owners, there should have been adequate consolidation with the original land owners and full transparency of the impacts that will occur.

I strongly object to the Bowdens project.
Please see the attachment below.

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