Bowdens Silver

submission attached

submission details attached.
Please save the people of Lue and the lawson creek

The reasons why I object to this project are found in the attached.

Dear Sir or Madam,

Thank you for the opportunity to comment on the Bowden's Silver submission. I would like to raise my objection to this project.
Having grown up in Lue, and with many friends and family still in the area (and living locally myself), I am deeply concerned by the negative impact this project will have on the area. While I recognise the economic benefits to the district, I feel these are easily outweighed by the negative environmental, health and other impacts of this project.
Of particular concern are the following points:
- The close proximity to the village of Lue (I fear the village could be destroyed, similarly to the village of Wollar).
- The light, noise, dust and lead pollution to which the village would be subjected.
- The increase of traffic on the Lue Road (which it has not been designed for).
- The impact on the water table (including possible pollution).
- Devaluation of property values of landholders in the area.
- The irreversible impact on the environment in the area.
I hope these impacts are considered and mitigated before any project is approved. If this is not possible, my hope is that the project should not go ahead.
Regards,
Concerned Mudgee Resident

This statement is an OBJECTION to the proposed development.
This objection relates more specifically to the proposed water pipeline between the mine site at Ulan and Moolarben, and the mine site at Lue, and the 3.87Km stretch of pipeline on the landholding at 2778 Ulan Road, Cooks Gap NSW 2850.

We make this objection on the grounds that the Bowdens Silver Mine (henceforth the Applicant) has not engaged in adequate consultation with us (the Landholders) in the planning of this pipeline, and has therefore failed to consider or acknowledge the significant negative impact that the construction and ongoing maintenance of the pipeline will have on our ongoing business operations.

The Agricultural Impact Statement and Biodiversity Management Plan also misrepresent land use and land and soil capability as, in their own words “For some portions of the proposed water pipeline, land access agreements were not in place at the time of the field surveys. In this instance, a combination of air photo interpretation, ‘over the fence’ survey and the use of existing data, was used qualitatively to ‘best-guess’ the BVT and presence of TEC in those portions” (9a: Biodiversity Management Plan – page 9a-44). In the case of the property in question, aerial photo interpretation would have been the only method used. It is worth noting that there is still no land access agreement in place, and Bowdens Silver has made no attempt, beyond an initial meeting to inform the Landholder of their plan, to establish any such agreement.

Our objections, detailed in the attached document, relate to the following:
1. Misrepresentation of the use of land on which the planned pipeline is to be constructed
2. Interference of the development with existing farm infrastructure
3. Violations of the NSW Biosecurity Act 2015
4. Misrepresentation of the land and soil capabilities in the region
5. Inaccurate representation of the impact of their water pipeline on land value

This statement is an OBJECTION to the proposed development.
This objection relates more specifically to the proposed water pipeline between the mine site at Ulan and Moolarben, and the mine site at Lue, and the 3.87Km stretch of pipeline on the landholding at 2778 Ulan Road, Cooks Gap NSW 2850.

We make this objection on the grounds that the Bowdens Silver Mine (henceforth the Applicant) has not engaged in adequate consultation with us (the Landholders) in the planning of this pipeline, and has therefore failed to consider or acknowledge the significant negative impact that the construction and ongoing maintenance of the pipeline will have on our ongoing business operations.

The Agricultural Impact Statement and Biodiversity Management Plan also misrepresent land use and land and soil capability as, in their own words “For some portions of the proposed water pipeline, land access agreements were not in place at the time of the field surveys. In this instance, a combination of air photo interpretation, ‘over the fence’ survey and the use of existing data, was used qualitatively to ‘best-guess’ the BVT and presence of TEC in those portions” (9a: Biodiversity Management Plan – page 9a-44). In the case of the property in question, aerial photo interpretation would have been the only method used. It is worth noting that there is still no land access agreement in place, and Bowdens Silver has made no attempt, beyond an initial meeting to inform the Landholder of their plan, to establish any such agreement.

Our objections, detailed in the attached document, relate to the following:
1. Misrepresentation of the use of land on which the planned pipeline is to be constructed
2. Interference of the development with existing farm infrastructure
3. Violations of the NSW Biosecurity Act 2015
4. Misrepresentation of the land and soil capabilities in the region
5. Inaccurate representation of the impact of their water pipeline on land value

To whom it may concern;

Whilst I am not a Lue resident I love visiting the region as a tourist and don't think a toxic lead mine should be allowed to proceed.
The environmental and social ramifications of a lead mine will be devastating to the Lue Region and its residents.
The picturesque nature of this region and it's wildlife need to be preserved for generations to come. In a period of environmental awareness, it would reckless of NSW major projects to consider this as mine as benefit to the community.

Enough is enough.

Kind Regards,
William Laing
(A concerned visitor to the Lue Region)

To whom it may concern,

Thank you for taking the time to read the submissions. I grew up in the local area of Rylstone and strongly object to the proposed mine by Bowden near Lue.

The local area has a unique environment and one that is not found anywhere else in the world. Farmers locally depend on the water to be as clean and healthy as possible, as do all flora and fauna in the region.

We are in a time of ecological crisis and supporting and funding another mine is strongly unadvised and will not be remembered as a sensible decision in years to come. Furthermore, the damage caused can never be fully reversed.

Please carefully consider these issues. Local communities have the right to live in a clean and safe environment.

Thank you for your time.

I wish to submit my positive position pertaining to the submission by Bowden Silvermines to develope and operate a mine at Lue in NSW. After reading and evaluating the information made available I believe that the company will manage the operation in a responsible manner and in line with government guidelines. Especially under the current situation (Covid19) Rural NSW will require many such projects to assist in rebuilding the states economy. This operation will assist not only the State but especially the Regin by providing both direct and indirect job opportunities and community benefits. As there are already mining sites in operation and the proposed mine will utilise certain aspects of the infrastructure should be seen as a positive step. In closing I ask that considering the above and Bowden Silvermines commitment they be allowed to proceed with the development and operation.

I have had a longstanding connection to the Mudgee community and region for over 26 years, through very close friends who live there, and from numerous short-term and long-term family visits and family holidays.
I was horrified to hear of the proposal to build a massive open cut mine just 30km from Mudgee, in the Lawson Creek valley, and I object in the most strenuous terms.
The reasons I object to this proposal are as follows:
• Mudgee is a beautiful regional town, in a beautiful part of NSW, surrounded by extensive local wineries of the highest quality, and with a deserved reputation for fine dining. Set in a pristine environment, Mudgee is an enormously popular tourist destination. The local economy is heavily dependent on maintaining the area’s reputation as an attractive, clean, safe and healthy place to visit.
• The proposed mine represents a huge risk to Mudgee’s hard-earned and justified reputation, and cannot be justified on any competent cost-benefit analysis:
• The mine will produce 95,000 tonnes of lead - a highly toxic mineral. There is no safe level to exposure of lead especially for children and this mine is just 2kms from Lue school.
• A dangerous cyanide processing plant will operate on site.
• A highly toxic large tailings dam will be constructed less than a kilometre from Lawson Creek and will be there long after the mine has been abandoned. Tailings dams regularly fail around the world and, if this were to happen here, the result would be an environmental disaster for Lawson Creek which feeds into the Cudgegong River at Mudgee, polluting the water supply forever.
• 56 million tonnes of acid forming rock, tailings and toxic chemicals from extraction will be produced. These huge waste dumps risk leaching into the water table and the surrounding catchment.
• The proposed mine will use more water from the Lawson Creek catchment than all current users combined. The water level in Lawson Creek will drop by one metre rendering much of the Creek dry for all other users, ground water levels on the mine site will drop by 25 metres, and the open cut pit will continue to draw on ground water for up to 100 years after the mine has been abandoned.
• It seems that the economics of the proposed mine do not add up (EIS Vol 5, Part 16C_ Closure Cover Design, Appendix A, p.24) The assumed silver price is US$20.91/oz (EIS S 4, Table 4.84 Key Assumptions Underpinning the Economic Assessment, p. 4-373), which has never reached this level at any point over the last 5 years. If production costs increase above budget, the mine’s financial viability will be even more at risk. A financially unviable mine represents an even greater threat as owners are forced to look for ways to cut corners which would affect safety.
• A suitable plan for rehabilitation of the mine has not been offered. When the mine closes the tailings dam and all the PAF will remain forever.

Thank you for considering this submission.

Letter attached

I would like to lodge my objection to the proposal for the Bowdens lead mine.

The impact on endangered flora and fauna and the risks to groundwater, local rivers and the local population from the toxic heavy metals that will be released by the mine are unacceptable. Further, the complete lack of intent to rehabilitate simply makes this a proposal without merit and hence, it should not be approved.

Bowdens seem to be completely unaware of recent developments in mine site rehabilitation and site remediation. It is completely unacceptable that this company can lob into an area that has been settled for nearly 180 years, dig a 1.5 km by 300 metre deep hole in the ground and walk away and leave it. I do not believe this mine should be approved but if it is, best practice mine rehabilitation must be required. Bowdens should not be allowed to dig a huge hole in the ground and leave it to fill with water which can leach heavy metals into the environment for hundreds of years. The waste rock, which Bowdens intends to dump on site is similarly toxic and both represent an unacceptable risk to the groundwater in the area.

The location of this mine makes the potential health risks from the lead unacceptable. The risks of health effects are highest in unborn babies, infants and children and Lue public school is less than 2 km from the proposed mine site - this is just too close. The children of Lue should not be subjected to the risk of lead contamination. The treatment of this issue in the EIS is deficient. Consultation does not make health risks go away. Not building the mine does.

If the EIS is anything to go by, Bowdens is not going to be a good neighbour and this mine should not be approved.

According to the EIS, the metal bearing ore will be processed on site and the tailings stored in a tailings dam that will cover 117 hectares with a 56m high wall and contain heavy metals and poisons such as cyanide, cadmium, arsenic, zinc and lead. There will be no secondary wall, and the dam will be less than 1km from Lawson Creek. Lawson Creek joins the Cudgegong at Mudgee, and flows on to join the Macquarie at Burrendong Dam and thence into the Murray Darling system. There is no rehabilitation available for these dams. They are capped and remain in place forever - that is, until they leak or collapse. A tailings dam collapse is an unmitigatable disaster. Rivers which have had tailings discharged in them could remain dead and lifeless for hundreds of years if there is not sufficient flow to flush and disperse the contaminants downstream.

Bowdens plan to transport the processed concentrate in shipping containers on B-double trucks using our regional roads. These trucks will travel through the middle of Mudgee town and past local schools. All trucks will use the narrow and winding Lue Road to get to Mudgee. I use Lue road to get to Mudgee and know it well, hence I find it quite unbelievable that this road was approved for B-double traffic in the first place. In addition, the traffic created by the trucks will make an already slow trip even slower and increase the risk of accidents because there are few places where a car can pass a heavily laden B-double.

The mine will destroy 381.7 ha of native vegetation including 182.3 ha of the critically endangered Box Gum Woodland. This ecological community provides habitat for a large number of endangered species listed under NSW and Federal environmental legislation. Koalas have been sighted beside the project site and there are few, if any Australian mammals more iconic, but also more endangered, than koalas. Given the ongoing devastation wreaked on these mammals, the few that are left must be protected. Mining their habitat is incompatible with this.

The EIS is also flawed in that it has not done flora and fauna surveys at the correct time of year to assess if species are present. If the ecologists have not done the work, presence of endangered species can not be ruled out but rather, must be assumed to be present.

The mine proposes to transfer up to 5.5 ML/day of water from coal mines on the top of the Goulburn River via a 60km pipeline. The excess mine water produced by coal mining at Ulan and Moolarben is predominantly valuable groundwater intercepted and extracted from the Goulburn/Hunter (eastern) catchment. Pumping from an eastern to a western catchment sets a bad precedent. This water is critical for the health and viability of the Goulburn River. The top priority for its use is maintaining environmental flows in the Goulburn especially during extended dry periods, when most pressure is on water access. Ulan/Moolarben water is Goulburn River water and should stay there.

Please see submission attached.

This is a great project for the area.

Bowdens Silver Project

My name is Robert Smith and I am a farmer in the Lue district where I live with my young family.
Thankyou for the opportunity to make a submission regarding the proposed Bowdens Mine at Lue.
I object to this project for a number of reasons which are outlined below:

Toxic legacy:
This mine with a short 16 year lifespan will result in a toxic legacy of lead, cyanide, arsenic and cadmium left in the tailings dam forever. It is not fair on future generations to leave them with this inheritance. There is no plan in place as to who will be responsible in the future when these chemicals start to leak into our natural environment.

Environmental issues:
This mine will result in the destruction of critically endangered grassy box woodland. This vegetation cannot be replaced with replanting as it takes many years before trees are old enough to provide habitat such as hollows. There are a number of iconic species including Regent Honeyeaters and Koalas that rely on this habitat in the Mudgee region.
The recent bushfires have shown the importance of maintaining these remnants across the landscape as many species are relying on these unburnt refuges for survival. I have seen an example of this on my property where there have been flocks of over 50 Gang Gang Cockatoos arriving since the fires where previously I might have seen 5 in a group.

Impacts on the local community:
This mine will result in decreased property values in the Lue area and less people living in our community if it is approved. No one will want to buy a house near a poisonous and noisy lead mine.
Tourism is very important for the Mudgee region both economically and socially. Mudgee has a clean and green image which it promotes for tourism. This will be impacted if this proposal goes ahead. The proposed mine is upstream of both the Mudgee township and many wineries. Tourism is an industry that will be around long after this mines lifespan has finished and it is important to protect this for the long term prosperity of the Mudgee region.
As a farmer I rely on being able to produce food which has a clean and healthy image. People are becoming more aware of where their food comes from and there is a marketing advantage in being able to promote healthy food from farms which care for the environment. If this mine is approved it will have a negative impact on my business and future opportunities for expansion as people will associate my property with being close to a toxic mine site.

In conclusion I object to this proposal as I do not believe that the short term benefits are enough to compensate for the negative long term impacts this mine will have on our region, health and businesses.

I feel that the supposed benefits which Bowdens Silver says that this development will bring are far outweighed by the disadvantages.. This development will be hugely detrimental to the very fabric of the Lue community.
The health hazards of lead are well known.
The effect on the water table must not be ignored.

Major project 9641 Bowdens Silver Project
My name is Bill Brown and run a grazing business in the Lue area on land that has been in our family for many generations. My great grandfather moved to Lue when his farm was bought out by the Kandos Cement Works over 100 years ago. He chose Lue because his wife’s family were well established in the area.
My western boundary is 4.3 km from Bowden Silver owned land. My house is situated on Breakfast Creek Road which is 8km from the proposed mine site.
I am very pleased to be able to write a submission on the EIS for the Bowdens Silver Project. I remember when Warwick Lord sold his farm Bowden to Silver Standard, we didn’t know what lay ahead for our community.
I have been managing my farm, "Minora" since 1993 after graduating from Orange Agricultural College with an Associate Diploma in Farm Management. I leased land from some absentee owners on land which is now in the proposed mine site.
My goal is to achieve 100% ground cover, 100% of the time on the land I manage. I have focused on riparian areas to maintain good quality water for all water that passes through my land, reducing salinity and turbidity of the creek water.
My partner and I aim to be self- sufficient with our orchard and vegetable garden. Food integrity is high on our priority. We butcher our own animals and eat our own eggs with no pesticides, fungicides, herbicides or manufactured fertilisers. Our water supply is extremely important to our business and lifestyle We rely on bore water for stock water, garden water and drinking water. We are fortunate to have such good quality underground water. Two creeks join our land, Breakfast Creek and Lawsons Creek. Breakfast Creek is a tributary of Lawsons Creek, yet it has not fed into Lawsons Creek for 4 years. It flowed for a couple of km into my place, due to the dry seasons we experience it has not flowed its full length. Last time when Breakfast Creek was flowing the council were pumping out of a waterhole on my place next to the road to supress dust and aid with grading the gravel road called Breakfast Creek Road One water truck for 4 days and the drop in level was noticeable. I had visitors camping on the creek at the time of the grading and they certainly noticed the fall in level. The EIS states that the Lawsons Creek flow rate is at 1Megalitre/day 81% of the time. I find this very hard to believe. How did they come to this figure? In my observations it only flows after rain, it is not a constant flow, it is series of waterholes.
My brother and I share a boundary with Lawsons Creek, and we enjoy fishing and yabbying in the warmer months. The water level of our permanent water holes was down a metre and a half over last summer and some holes were completely dry which I have never seen before. (I am 48 years old} Speaking of fish, my brother used to catch slippery {freshwater whiting} on Warwick Lord’s place called “Bowden”, when he was a kid. This is now the mine site.
The EIS has consultants using modelling for inflows into Lawsons Creek, based on the flow rates of the upper reaches of the Cudgeegong River. The headwaters of the Cudgeegong River are to the east of Rylstone where it is subject to easterly rainfall events and receives a very different amount of rain compared to the head of Lawsons Creek. One is a creek and one is a river.
I don’t pump water out of either of the creeks on my place, although stock have access some of the time. I rely on bore water pumped to a tank and gravity fed to water troughs. I am concerned that the amount of water required for the proposed mine and the amount of groundwater that is planned to be used will cause my bore to go dry. The creek will also drop in level and I will have to rely on farm dams, that are not reliable for 100% of the time. Catching rainwater in tanks for domestic use will be an issue due the exposure to lead from the proposed mines activities. There is no safe exposure to lead.
The EIS uses modelling for ground water. Drilling has been going on for 30years on this site. in the early days of drilling the drillers would call in at the Lue Pub and comment on all they keep finding is water. We were in drought at the time and were envious. The Ore reserve statement says that 653 drill holes were done to collate data. There should be enough data of the ground water for the mine to use.
When we drive to Mudgee which is our major centre, we travel on the Pyangle Road to the Lue Road. This route takes us through the area where the Silver mine owns land on both sides of the road. It was in this area a couple of years ago that my partner was travelling to town mid-morning and saw a Koala walking down the road in front of her car. It eventually climbed a tree. She rang me, I rang someone from Lue who rang, and so on. In 20minutes there were 20 people watching this lonesome Koala up a tree. This is the first Koala I have ever seen in our area. A friend who worked for Kingsgate had seen Koala on the Bowden site when he worked there. It was sad because the proposed mine site is just through the fence, so the future for this vulnerable Koala is not looking good. The EIS does not explain what is intended for the Koala population of the Bowden property.
On the 15th of June last year I drove down the road to the Bowden office for an open day the silver mine was having. I drove through a group of local people, most of them I recognised as local Lue people having a Lue Action Group meeting at a house neighbouring the silver mine. I said hello and drove on down the road only to find that I had to go through 2 stages of security to go to an open day. This shows how much trust they have in the community. I couldn’t believe that this was the same route I walked a mob of sheep down the road to graze them on Mr De Forrest’s place 20years earlier. I would never have imagined that a community could be so divided due to this potential mine. On arrival at the open day an employee made an unpleasant comment to me on the local residents near the front gate as I was welcomed to the site. She said was it my first time to the site? No, I responded, I came to hear Silver Standard years ago, then I came to hear what Kingsgate had to say and now I am hear to listen to what this company has to say. That was all she had to say. A fellow who did not introduce himself gave a talk on what the mine was doing and how we need silver etc. He told us we were not to ask questions in an open forum and that we were invited to direct questions to individual consultants they had employed. The speaker turned out to be the CEO of the company, the same person that has bought the local Lue Hotel. It didn’t take long to realise that I should have been at the meeting with the local people. I asked questions to various consultants, firstly giving my name as was required so they knew who asked what question. I have still never been contacted about unanswered questions. One question I asked a consultant was what will happen to the pit lake, will it be sold, I was laughed at, as he said “that could never be sold it will be poisonous forever”.
This mining project has bought up 18 dwellings, 18 local small farms have been taken out of the community and replace with employees of the mine or rented. 5 of these were weekenders which were still part of the community. The Lue hotel used to be a place to catch up with locals and solve problems of the world over a few beers, there was a great community atmosphere.
When relatives and friends come to visit me on my farm, they always comment on how quiet it is. The nights are incredibly quiet. I can hear the Lue bike track on weekends from my house. It is situated 14km to the southwest, and I can hear the difference between the two stroke engines and the four stroke on certain days. The proposed mine is 8km from my house to the west. I don’t understand the graphs and models in the EIS, yet I know that I will hear the noise day and night created by operating a mine site. When there is no noise now, it is easy to understand that there will be a constant rumble of noise from the proposed Bowden mine site.
I was outside at 10pm last week at home looking to the west, there was no moon and I could see the glow from the lights of Mudgee, which is 50 km away. The Bowden mine site is directly in front of that view 8km away, I am sure I will see the glow of the lights from the proposed mine on certain nights
The proposed mine site is approximately 1000ha with around 290ha to be cleared for infrastructure etc. This will mean that there is an increase in area with no ground cover. This barren area will increase the amount of dust to be supressed on the site. I drove a water truck for an earthmoving contractor in the Kimberly on a working holiday back in 2012 for 3months. It is such a shame to have to waste so much water to supress dust knowing that by the time you fill the truck up with water the area you have just wet is dry again. The amount water needed to supress dust on the proposed site if done correctly will require numerous trucks constantly driving around the site in dry times. There are areas on the site that will not be able to be traversed by a water truck yet will require dust suppression.
The tailings dam will have a lot of exposed acid forming material, processed ore and chemicals that will blow away as dust and be unable to be supressed. At the end of the mines processing of ore, the tailings dam will need to dry out completely before they attempt to cover it over with the plastic liner. How will the mine prevent dust at this time when the tailings dam would have the maximum amount of waste material. The other issue is if we experience wet weather this tailings dam may take years to dry out before it could be covered. They shouldn’t be waiting for approval to mine before they give a detailed design of the tailings dam. There is not enough information
The plastic cover proposed does seem suitable for a tailing da

My extended family have farmed the country surrounding Bowdens Silver Mine for 5 generations. I have spent my entire life visiting the area every couple of months. I am highly aware of the issues relating to the proposed Bowdens Silver Mine and how it would affect the surrounding country.
The reasons why I object to this proposal are
1. The mine will operate 24 hours/7 days per week and is only 2km from Lue Village and the primary school, it is expected that mine will produce massive increase in noise levels and directly impact those in the village.
2. There is no suitable plan for rehabilitation of the mine. When the mine closes the tailings dam and all the PAF will remain forever. This is likely to directly impact the community and generations to come.
3. The tailing dams are likely to have an impact on the surrounding catchment of Lawson Creek. If the tailing dams fail, there will be permanent damage to the water catchment. Further to this, the tailing dam will be highly toxic and based on data 23 tailings dams have failed in 5 years including nearby by Newcrest Mining’s Cadia Gold Mine near Orange.
4. The ground water levels will be directly impacted by mine and drop by 25metres. The open cut mine will draw on water for up to 100 years.
5. The economics of this mine are based on an assumed silver price in the EIS is US$20.91/oz, a price that hasn’t been reached over the last 5 years. If this price is not achieved, the viability and cost-savings in place would be questionable.
I strongly object to this mine and ask the Department to consider my objection.

This is heart-breaking to hear of the beautiful country of Mudgee/Lue.
We visit the area often from Sydney.
Please reconsider.