Bowdens Silver

Please see attachment for my comments

The mine is no good for this area, bad for the environment.
My mother lives in Lue, we purchased this house for my mother to live a nice country lifestyle like she’s always wanted. And this would crush her dream as we would look over part of it.

My submission is attached.
Thank you

Attached is the MDEG submission of objection

Silver Mines have a track record of saying one thing then doing something else when convenient. 2 million tonnes of ore per year is not economic, other projects around the world of similar size have mine 7-8 millions tonnes per year to make money (and be in less economically developed countries with less restrictions). This would mean only 3-4 years mine life rather than 17. This would not benefit the local Lue community at all. The previous owners Kingsgate knew this and hence when trying to get community support failed. Silver Mines only say anything to try woo the community. If the project gets approved the directors will get their share options and then sell out to a bigger company who will come in, re-jig the project for more tonnes, less benefits and greater environmental impact. Silver Mines have zero experience in operating a mine, only mining the share market to the benefit of directors who already have other projects on the go.

Re: Concerns about the Water impacts of the Bowdens Silver Project

Over the years I have been following the many proposals about the development of a silver mine at Lue. While there are obvious economic benefits of developing a project such as this one, especially short-term job creation, this should not come at the expense of water tables and access to water for existing farm operations and the environment.

Our region has recently come out of one of the worst droughts in history and both agriculture and the environment are only just starting to recover. Secure access to water is absolutely vital to that recovery and precedence should be given to existing long-term residents and businesses rather than to a new business that plans to be active in the region for a relatively short period of time.

As the saying goes, water is life. Without water our agricultural industry is under serious threat and important environmental water flows will be eliminated, impacting both the flora and fauna in the region.

I am no expert, but having lived in rural NSW all my life I know that our precious water supplies are far more important to our community than any silver mine.

Please refer to my submission document attached

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

I strongly object to the Bowden’s silver project for the following reasons.

There are significant health and environmental risks which make this project unconscionable, particularly as it is situated 1.9 kilometres from the village of Lue and its primary school.

There are a number of issues identified by independent experts which Bowden’s has not or inadequately addressed. Some of these are:
Failure to consider the legality of transferring mine water from the Ulan mines to site, failure to address water pollution to Surface and Groundwaters from the Tailing Storage Facility and failure to assess surface water impacts of the proposed water supply pipeline

Lead dust
There seem to be unacceptable health impacts, particularly relating to lead levels. As this project is within 2 kilometres of a primary school this is of major concern. Also many of the surrounding properties, including my own, are solely reliant on rainwater tanks for our vital drinking water. The impact of lead dust in rainwater tanks and on local crops, particularly during (increasing) periods of drought, will compromise our health.
The independent experts consulted are clear in their assessment:
“There is a lack of sufficient data to enable undertaking a transparent health risk assessment of the effects of the proposed Bowden's Silver Project on the Lue community.” according to Prof. Barry Noller, (BSc MChem PhD FRACI FRSC FFACS FIUPAC) Sustainable Minerals Institute, University of Queensland
“......air, dust and human health risks is rather opaque and does not appear to capture properly the true nature of the potential risks, particularly those associated with lead-rich depositions on the surrounding community.” according to Prof Mark Patrick Taylor
Dept of Earth and Environmental Sciences Macquarie University ~ Sydney, NSW
I refer to their full statements in submissions made elsewhere.
This project values money o er the health of Australian children (and adults) and is therfore unacceptable. The costs of these health issues will be borne by the individuals and the tax payers of this country.
Tailings storage facility and waste rock areas issues
57% of the waste rock excavated and 100% of Tailings is classified as Potentially Acid Forming. Acid Mine Drainage escaping to the surrounding environment during mine operation and after mine closure is a significant risk. The dam is located close to two local creeks. There is apparently no contingency plan to remediate leakage should it occur. There seems to be a high likelihood that the Tailings Storage Facility will pollute ground and surface waters as it is planned to be constructed on a fault. There is apparently no acid treatment plan or a plan to remediate acid leakage longer term.
The tailings will also contain lead, zinc and silver as well as arsenic, antimony, fluorine and manganese. There is no guarantee that the projected rehabilitation cost allocation will be sufficient to cover actual costs. This means that the local community and the Australian public would be bearing the cost.
Noise modelling seems to be understated according to experts: ‘All sound power levels adopted for the noise predictions appear to be very low when compared to representative plant types from other mines (e.g. D11 dozer 113dBA in first gear – typically 118dBA)’
Also risks associated with blasting and transport of explosives have not being adequately addressed. This sounds like Bowden’s is being actively misleading through understating risks and issues. Therefore Bowden’s is negating the right of citizens to correct information to enable decision making.


There seem to be major concerns regarding the unproven design of the Tailings Storage Facility and Waste Rock Emplacement area : There isn’t any performance history for these containment designs at other large scale sites, there’s an absence of any secondary containment / contingency planning, there seem to have been only limited Geotech investigations into the proposed Tailings Storage Facility which is 117 hectares and there were only 18 holes done. Is the clay layer thickness tested? The cover design for both seems to be unproven. Rocks could pierce from beneath and vegetation will eventually be sure to pierce from above. Wombats would dig through?
There seems to be no the guaranteed plan for post mining management of the site.

There seems to be no consideration of changing weather patterns and climate change. Periods of extended drought and floods would adversely impact the safety of this project. (Also any seismic issues.. there was a small earthquake in the area only last week)

During the wet period of the Tailing Storage Facility (as stated: an area of 117 hectares - this would be a poisoned chalice for any wildlife that drinks from it. Australian wildlife has been severely affected during the recent major bushfires and the koala population is in trouble in NSW. Koalas have been sighted in the area (I have sighted and photographed them on our property (8 km away) also) This project will impact populations even further.

My husband and I own and manage a property that is part of the Grassy Woodlands project. Therefore the environmental impact of this project is close to our hearts.
The ecological review of this project by Dr Michael Aberton, PhD, MEIANZ, CEnvP, BAM accredited Principal Ecologist - ABSolution Ecology and Dr Peter Serov, BSc, BSc (Hons), PhD Owner and Director - Stygoecologia cites major deficiencies in the application.
These are:
× application is deficient for the assessment of the Threatened Swift Parrot, i.e. wrong time of year to determine presence/absence
× The application is deficient for the assessment for the Koala populations, i.e. two out of the three key points of the recovery plan are not addressed
× The assessment for Frogs species did not appear to target likely habitat, i.e. surveys undertaken in terrestrial sites only, lack assessment of aquatic- based habitat
× Assessment is inadequate for informing threatened species habitat, i.e. Lack of tree hollow survey on size, distribution and type of hollows to inform. (Additional losses compounded by recent bushfire impacts)
× Inadequate background done on light pollution effects on wildlife especially nocturnal species and fails to address Best Practice Guidelines
× Significant discrepancies in the Threatened Ecological Communities (TEC) assessment, e.g. 19.73Ha or 91.73Ha for Maloneys Rd
× 147.87ha of the 675.2 ha reviewed under the Biodiversity Assessment Report targeted for disturbance leading to fragmentation and loss of biodiversity value
× Failure to thoroughly review the Grassy Woodland Community Threatened Ecological Community in the local or regional context
× Absence of consideration of the pathogen that is known to cause dieback disease, particularly during soil disturbance.
× The removal of TEC leading to fragmentation and edge effect of Critically Endangered Ecological Communities
× The presence of several EPBC Listed species has been dismissed without suitable targeted species surveys using appropriate survey and seasonal timing to support these findings, particularly when suitable habitat is described
× Significant oversight and / or inadequate Impact Analysis of the impact of the project on stygofauna and aquatic species within the assessment.

The ecological experts report concludes:
The applicant’s attempt to avoid impacts to threatened species & habitat through planning and design is not clearly demonstrated, i.e. biodiversity offset strategies for areas of high biodiversity value do not show how these areas will be avoided, e.g. along the pipeline alignment. Furthermore the mitigation measures proposed are typically reliant on future work. The assessment of impacts to stygofauna is completely incorrect as the assessment fails to identify stygofauna endemic to the area. The assessment either do not maintain the expertise to identify or understand the significance of these species or have dismissed the impacts. The same applies to the assessment of freshwater macroinvertebrate community.

Three years ago the country of El Salvador banned all mining for metals, deciding that the environmental damage far outweighed the short term profitability. This move was supported overwhelmingly by the population. If a small and relatively poor country like El Salvador can make this choice and choose water over silver and gold, then Australia certainly can and should.

This is a project which will potentially benefit a number of people financially, depending on the price fluctuations precious and base metals. It will also bring some jobs to the area. However, there are many ways in which jobs could be created in a much less risky and far more sustainable way, such as theough tourism. This project lies in the middle of a beautiful area, close to many natural places of beauty and close to the wineries of Mudgee. The risks to health and the unavoidable damage to the environment seem to be completely out of proportion to the benefits of this project.

See attached submission letter OBJECTING to the proposed mine

Please see attached

As per Bowden's Environmental Impact Statement (EIS) much of the ore that will be removed from the site is lead. There is no safe level of lead exposure. The EIS submitted by Bowdens Silver fails to address, with any confidence, the potential for contamination of water supply or containment of lead dust from open-cut blasting. The mine site is 2km from a public school. Research studies have shown significant affects from lead exposure in communities like Mount Isa, with vulnerable populations such as the Indigenous Community are more affected in that instance. Subjecting local children to potential brain damage would be a terrifying outcome of this mine. The probability of this outcome, under the plan submitted with the EIS is actually very high. Whilst Lue is a small hamlet, the contamination risk is not borne by residents of Lue only. The prevailing winds may carry lead dust from blasting to the nearby township of Rylstone (including over water supply) and potential overflow from the tailing dam could also affect Lawson Creek, with the mine site being upstream of Mudgee. Another toxin, cyanide, will also used in the processing of ores with substantial risk of water supply contamination.
Not only will significant risk exist over the life of the mine, there appears little plan for rehabilitation of the site when mining has finished, leaving the local community to deal with contamination risk in perpetuity.
The plan around sourcing water is completely inadequate in this EIS. There is the possibility of sourcing some recycled water from Ulan coal mining operations, but that deal has not yet been finalised and is subject to risk. In any case, should such a deal be reached, it would only supply a small proportion of the overall water requirements of Bowdens Silver. There will also only be one water truck on site, significantly increasing the probability of lead dust exposure for surrounding communities due to inadequate dust suppression. There is no town water supply to surrounding residences, meaning that tank water is generally used for drinking within the Lue community. With the mine site only a couple of kilometres away and clear dust suppression issues, the likelihood of contamination is high. There are also several holiday accommodation businesses within the town, so holiday-makers, as well as residents, will be affected.
It is my understanding that the company has no experience in silver mining. Accordingly, Bowden's apparent confidence in their own ability to prevent contamination of the air and water seems implausible.
I note also that Councillor Peter Shelley lists on his LinkedIn profile that he has been Community Projects Coordinator for Bowdens Silver since September 2016. Hopefully, this potential conflict of interest has been managed. However, it presents very poorly that a councillor is on the payroll for a mining company currently applying for a project in the local area. Remembering that the Bylong Valley, with all the problems with Obeid/Macdonald conflict of interests that were manifest in that area, is just around the corner. Surely this community has been subject to enough political misconduct with mining projects.

Bowdens Silver Project 2020 - Objection

My name is Clare Hamilton, I am a partner in a commercial agricultural business in the Lue-Rylstone area where my family has been involved in the production of food and fibre since 1920. I am also employed by Central Tablelands Local Land Services as the Manager of Biosecurity and Emergency Services, having previously worked in natural resource and water management across the central tablelands region of NSW. Our agricultural business has 2 full-time employees and employs several contractors across the year including shearers, agronomists and plant and machinery operators. Over the 32 years that I have lived on our property I have contributed to the remediation of environmental issues on our farm and across the district; worked with neighbours and community groups to increase the welfare and spirit of our community; and raised 3 children who have plans to continue farming our property.
I oppose the Bowdens Silver Project because it threatens all of this!

I have read the EIS Bowdens Silver Project 2020 and respectfully ask the NSW Government to REJECT the application.

I am opposed to the Bowden Silver Project on the grounds of the following:
Unacceptable health impacts
• The village of Lue with its primary school is only 1.9km from the mining operation. The proposed mining operations will cause high levels of lead in airborne dust, which we know is absorbed by the human body.
• The EIS underestimates community exposure and does not look at dust transmission pathways to the village or validate the EIS conclusions. It also fails to take into account community dust exposure levels from stockpiles, ore grinding and handling, concentrate plant and tailings facilities.
• No data is provided for arsenic bioaccessibility
• Out of date compliance levels for acceptable community exposure are referenced in the EIS.
• We know young children are the most at risk from lead poisoning, it has irreversible neurological and behavioural. The Bowden Silver Project will put our future generations at significant risk – no level of lead exposure is considered safe.
• Noise issues are not well addressed in the EIS. And when addressed are extremely conservative when compared to representative plant types at other mines.

Mining operations
• The EIS does not adequately address the risks associated with blasting and transport of explosives.
• The design does not adequately address the concern about the thousands of tonnes of toxic chemicals that will end up in the tailings storage facility.
• There are no contingencies for leakage from the Tailings Storage Facility
• Post mining rehabilitation is totally unsatisfactory for a mine that produces such high levels of toxic material. The miners can walk away, but the community and environment cannot.
• Increased traffic on local roads is of concern. Many businesses such as our regularly moves livestock across the Lue Road and the roads are busy with tourist and local traffic. The roads are also narrow and have restrictions for B-Doubles clearly showing they are not suited to the movement of large quantities of material from mines.
Water
• Water demand can only be achieved by transferring water from Ulan and or Moolarben Coal mines, both of which are in the Hunter River system, while Lue is in the Murray Darling Basin. There is no approval for water transfer across these catchments.
• With the pressure currently being experienced by the environments of the Murray Darling Basin it would be unconscionable to transfer highly contaminated water from another mining operation into the upper reaches of the Basin.
• There is no clarity on how Bowdens Silver will manage the leachate dam when the mine closes. This poses an enormous risk to the Lawson Creek and other waterways downstream of the mine. It also puts a large number of farming enterprises at risk along Lawson Creek.
• There is no consideration of seepage of contaminated water into ground and surface water systems.
• Our agricultural production is dependent on surface and ground water which will be directly threatened by the Bowden Silver Project. Contaminated water has grave consequences in the food-chain and can also impact on our ability to export agricultural produce.
Ecology
• Our district has the great fortune to be the home of a number of threatened species including the Swift Parrot and Koala. Of great concern is Bowden Silver Projects inability to address the impacts on the ecology of the area.
• There is no assessment for koala populations.
• The presence of a number of EPBC Listed species is not adequately dealt with.
• Lack of adequate assessment of threatened species habitat such as hollows and recent bushfire impacts
• Best practice guidelines for light pollution impacts on nocturnal species are not considered.
• There is no thorough review of the Grassy Woodland Community Threatened Ecological Community in the regional or local context. This is an area where significant remediation and investment has been undertaken by the community over many years.
Community
• There is no guarantee that any jobs created as a result of the Bowdens Silver Project will be available to the people who stand to lose the most from this project. Adjoining land holders, people in the village of Lue and the broader community are unlikely to fill most jobs.
• The Bowdens Silver project is estimated to operate for under 20 years. During this time, it is likely to devastate the community of Lue and the surrounding district. We have seen this same thing happen at Wollar in other sites. The short-term economic gain for a few outside the area is not worth the cost to our community. Bowdens Silver Project is a short term, inequitable result for our community.
• The Lue-Rylstone-Mudgee district currently has a balance of agriculture, mining and tourism all of which plays an important part in a balanced economy. Bowdens Silver Project does not have a place in this mix. It is short term focused with a lasting negative impact producing toxic lead just kilometers from a village and primary school, it is situated in one of our important environments for threatened species and communities and it threatens a number of significant commercial agricultural businesses.
I have read the EIS Bowdens Silver Project 2020 and respectfully ask the NSW Government to dismiss the application.

Clare Hamilton
0428 791 359

Objection to the Bowden’s Silver Mine Lue NSW

I am deeply concerned about the health, social and environmental impacts that the proposed Bowden Lue Lead, Silver and Zinc Mine will bring to Lue and neighbouring communities if it reaches production stage. I strongly object to this proposal and hope that the NSW Government refuses to approve this project in recognising that the immediate and long-term consequences largely outweigh the Mine’s potential economic returns.

Excessive lead exposure is harmful to human health and this has not been adequately addressed through the Mine’s Environment Impact Statement (EIS), particularly in regard to the impact on children. Research has continually identified the impact of lead exposure on the health of individuals living and working in mining communities, arguing that exposure to lead should be prevented. . Australian and international studies have exemplified the neurological damage caused through lead exposure and exposure of metals, particularly spread through dust particles and water. The most contaminated children in Australia are located in lead mining and smelting towns. High levels of lead has been exposed throughout the communities of Mount Isa and Bourke, which has caused high blood lead levels in children within these communities. This has proven to cause developmental and behavioural problems, as supported by the National Health and Medical and Research Council. Further studies have found decreased auditory sensitivity and visuomotor performance among children due to lead exposure causing damage to the brain, particularly in the prefrontal cerebral cortex, hippocampus and cerebellum.” Lead toxicity also affects the renal system, with children affected often complaining of a ‘tummy ache’ due to abdominal pain.

Lead poisoning and poisoning from other metals often goes undetected and unmonitored in mining communities, taking years to identify the cumulative health impacts. I am concerned that the NSW 2003 data guidelines used for the mine does not take into consideration the blood lead level of children, which, as experts suggest, needs to be below five micrograms per decilitre in the blood stream, rather than the 10 decilitres proposed. Lead poisoning will have significant immediate and long-term health consequences for the people of the Lue community, particularly for children. Understandably, with this known and the Mine only two kilometres from Lue Primary School, many residents will wish to leave the Lue community.

The cumulative social impacts must be considered in the planning of communities directly affected by new mines. The Mine’s Social Impact Assessment (SIA) does not consider Lue as its own intrinsic social and cultural value but rather, makes vague assumptions about the social impact of the broader Local Government Area (LGA). The SIA also largely underestimates the broader social impacts of the Mine, such as population changes, mental health, noise, strain on local services and tourism, to name some.

Population changes are a concern for many Lue residents. Like other Australian mining towns, it appears that the economic advantages of the mine will flow out of Lue and into larger regional areas, bringing little economic benefit to Lue. The Mine states that they will employ people from the LGA with no guarantee as to how many jobs will be provided, if any. One common finding for mining communities is the difficulty in attracting and keeping long-term residents, as mining largely changes the demographic structure of communities that are directly impacted, with residents moving out and new families reluctant to move in.

The environmental implications of the Mine appears vast, particularly with concern of water contamination and excessive water usage. Experts claim that acid mining drainage is a key concern due to the 40 million tonnes of waste rock waste from the mine being potentially acid forming. This would contaminate the Lawson Creek, which flows into the Cudgeegong River at Mudgee, poisoning these waterways and creating irreversible damage. The availability of water is another major concern, as the EIS indicates that 1,857 mega litres of water is proposed to be used by the mine annually; an amount that is environmentally unsustainable over a 16-year period and a threat to the livelihood of the Lue community who rely on the water for farming and community use.

It is clear that the mine’s 16 years of proposed activity will be significantly short lived for the ongoing catastrophic impacts for the people of Lue, including the irreversible environmental destruction it will cause. I ask that the NSW Government prioritise the needs of the Lue community, including environmental preservation, before the immediate short-term economic returns that the Mine will bring.

I have attached the submission below

a) the health impacts of the mine are too great (there is no safe level exposure to lead, particularly for children and Lue Primary School is only 1.9km fromthe mine)
b) there is not enough water to run the mine
c) the resultant acid mine drainage will contaminate water resource be a problemfor generations to come.

Living on property beside the Lawson Creek is wonderful. This area, like the rest of the country has been through drought and fire. Rain comes and nature replenishes itself like magic. The thought of a man made disaster in this area should not be permitted, nature cannot fix mines, our creek will not live and our table drain will be severely damaged. This is not for a short period but a life time. What's more important..... people's lives, their livelihood and mental stability or a lead mine that will destroy this beautiful area. Please let common sense prevail over money and greed. You will do the right thing if you have a conscience!

Attention: The Minister for Planning NSW, Parliament House, Macquarie Street, Sydney NSW 2000

Dear Sir,

SSD 5765
Bowdens Silver Mine Proposal, Lue NSW

I am writing this submission to you to request that you reject the approval of the above proposed mine.

The times I have spent at Lue have been pure quiet undisturbed escapes from the lights and noises of the city. And I cherish that tranquillity. I wish that to continue for & with, my children, and their children further.

To think that a mine is proposed to be constructed and operating a few kilometres from my stepmother’s family farm appals me. 24 hours a day operation is pure madness. Light spillage and noise are real concerns, but dust and water pollution are also outcomes which should not be allowed.

Please reject this mine proposal, and derivatives of such, on a permanent basis.

Yours sincerely , concerned citizen.