Bowdens Silver

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My name is Niall MacNeill. I have an astronomy observatory at Wattle Flat, NSW about 57 kms from the proposed mine site. I am part of an international community of astronomers who submit images to various forums and databases to be used by the international scientific community as well as organisation like NASA and ESA for their planetary studies and mission planning. This work will be severely threatened by the proposal, due to the impact of the light pollution from the site. Australia’s reputation as a contributor to the advancement of planetary science is greatly enhanced through this work, which will be put at risk by this proposal.
The Part 8B: Lighting and Sky Glow Assessment is manifestly inadequate and shows no understanding that the forecast levels of light pollution as being no worse than the full Moon, are utterly incompatible with astronomy.
The preservation of the close to pristine night skies of this region is vital to future tourism opportunities and I believe will far outweigh the potential economic benefit of this mine, both in terms of employment and GDP. More importantly the world is at risk of losing what our ancestors have enjoyed and wondered at for millennia. That is an unfettered view of the night sky.
Please help us preserve this natural resource for our children.
Your sincerely, Niall MacNeill

I appreciate the opportunity to make a submission. I do not believe the project should be approved or proceed in its current form.

General comments:
We live approximately 7kms from the proposed site and we and all others in the general area will suffer serious ongoing negative effects from the project eg exposure to lead and other highly toxic pollutants; loss of existing rural amenity ie the project would result in noise pollution (24/7) and light pollution where there is none now; and loss of groundwater. The project will be unsightly in the current rural, woodland and critically endangered box gum grassy woodland landscape and will impact the habitat and survival of native fauna. Serious pollution risks will remain many years after the project ends with no redress.

Some more specific comments:
- the project is termed a silver mine but it actually is more a lead (42%) and zinc (58%) mine with silver only 0.5% in terms of tonnes of production.
- the location of a lead mine (incl tailings) within 2kms of the Lue primary school and private residences is just not credible. Does the government believe the immediate and longterm health risks from production and tailings storage So close to the school and community justify the economic benefits? Surely no level of risk is acceptable here.
- the company is a recently formed single purpose company with no operational experience. Its directors and parent company would have mining experience but it does seem limited and far from being sufficient to operate a mine of this magnitude and to effectively manage the short and longterm risks associated with it.
- the company's obligations (incl risk mitigation and all remedial action) should be guaranteed by its listed parent company Silver mines Ltd and its directors.
- the project has a history of partial development and then resale. Operation by any subsequent acquirer should be conditional on a new EIS (or the current EIS where that is more onerous on the operator) and its demonstration of proven expertise in the specific field and successful management of risks of the kind facing the project.
- the EIS runs to several thousand pages and it is not clear that it has met all requirements of SEARS. Does the government Or other independent body audit that the EIS meets these requirements in all respects and identify all shortcomings. This should be done.
- all areas of impact and mitigation are supported by highly technical analysis. Does the government or other independent body audit that the analysis is done with proper and world class scientific method. This should be done.
- the project is an SSD but also has serious health, pollution risks attached. Some of these risks may only eventuate long after project end eg tailings dam seepage or failure. I submit this requires all mitigation areas be addressed with world class solutions. I have not seen in the EIS an analysis of what is world class and how it could be implemented. This should be done.
- noise pollution. We (and other areas) currently experience little man made noise during the day and almost none at night - and what there is lasts only a few minutes. I am concerned we will hear noise from the mine. Our property is listed in the EIS report as vacant, but it has been occupied for at least 15 years as residential. All fixed mining operations, eg crushing etc should be conducted in sheds with suitable sound protection methods.
- light pollution. We and other areas are probably in a genuine dark sky area (although not formally acknowledged as such). We have no light glow from Mudgee or Ulan. The EIS notes that the operations will not impact Siding Springs. But measures should be taken to protect more local night skies through the use of world class measures available to keep light from the operations from impacting the night sky.
- the proposal for managing tailings and toxic waste product is not adequate. There is serious risk of failure at some time. For example the base layer appears to be a 1.5mm membrane - this is almost guranteed to be punctured or fail at some stage. There is no secondary dam planned. Failures of tailings dams overseas and in Australia are well known and documented. Even BHP has failed. For this project a world class solution is required and also a methodology developed to guarantee that any leaks will be picked up in the future especially post mine closure. There should be weekly audits to ensure no leaks until such time the tailings dam and its contents are benign.
- water usage. The project requires considerable water. There has been insufficient analysis of impact to the water table and to current users in the region. Water is a scarce resource and will become scarcer under current warming trends. There should be scope for rationing water (and mining production) during droughts and reduced water table available to other users.
- dust suppression. More work needs to be done to guarantee dust with lead and other toxic particles will not spread to the school, community, and rural residences and water tanks
- we have regular sightings (and sounds) of koalas on our property (on which fyi we have a conservation covenant agreement with the NSW government). I understand koalas are also present around the proposed mine site. There should be a more detailed study done of impact of the mine to koala habitat, corridors and survival given its rare and endangered status in NSW.

Thank you

I am concerned about the long term effect of water quality of the whole valley from Lue to Mudgee .Also the potential damange to the area over the longer period long after the mine is closed

I object to the Bowdens Silver mine because I feel the environmental impacts will affect my business and community. The water use on already diminished and drought affected ground water systems and the risk of lead getting into water sources or traveling by air are of concern to my business of grape growing and tourism. I am not convinced by the proposed plan of regeneration. I don't think that it creates the jobs for local people that it states.

Objection to EIS on Bowden Silver mine, Project SSD-5765
I oppose the Bowden Silver EIS on the basis that I am a cattle farmer and tourism
operator on a property in the Lue/Bara area. My concerns are:
The surface water and underground water table being effected by such a large mine hole and the long term effects on all the aquifers as we are dependent on surface and underground water in this area.
The mine will produce 95000 tonnes of lead - a highly toxic mineral. There is no safe level to exposure of lead. Lead is a cumulative toxicant that affects multiple body systems. A deadly cyanide processing plant is proposed to operate on site.
As a cattle farmer supplying to the Australian market, I am very concerned as if there is any trace of lead in their blood, they will be deemed unsalable.
A highly toxic large tailings dam will be constructed less than a kilometre from Lawson Creek and will be there FOREVER long after the mine has been abandoned - these dams have been known to fail. The result would be an environmental disaster for Lawson Creek which feeds into the Cudgegong River at Mudgee. It will pollute our water supply forever. Tailings dams regularly fail around the world, in fact there 23 tailings dams have failed in the world in the last five years including the dam at Newcrest Mining’s Cadia Gold Mine near Orange NSW.
Tailings dams fail during significant rain events. We have rain records showing 225 mls overnight in February 2002 which caused major destruction in the Lawson Creek catchment. We regularly have large floods in Lawson Creek which dissipate very
Richard Nagel Old Bara 631 Bara Road Mudgee NSW 2850 [email protected] 02 6373 6555
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quickly. Bowdens would be subject to the same variations and suffer the consequences of extreme rain events.
The mine will produce two massive dumps of 56 million tonnes of acid forming rock and tailings (crushed ore remnants post processing) above the water table and local creek catchments of Price Creek, Hawkins Creek and Lawson Creek. 26 million tonnes of rock is PAF potentially acid forming which will be stacked over the water catchment covering 77 hectares. These waste dumps will most likely leach into our water table and the surrounding catchment.
Acid mine drainage from heavy metal mines is one of the great ‘forgotten’ issues in terms of environmental impact, even though it has been with society for thousands of years. The pollution from such mines can continue for hundreds of years after a mine is closed (where society bears the long-term burden of poisoned rivers).
227000 tonnes of ore will be trucked along the winding and narrow Lue Road through Mudgee town ship. Our local road is already very busy and quite dangerous as people drive too fast for the road’s conditions. Many people from Rylstone use Lue Road to commute to Mudgee and beyond for work. Currently B Double Trucks are restricted yet I believe that ore will be moved by B Double Trucks. The road must be upgraded significantly should the mine go ahead.
This will have a huge effect on the tourism industry in Mudgee if these B Double trucks continuously travel through Mudgee.
The mine will operate 24 hours a day seven days a week with blasting allowed 6 days a week - this is totally unacceptable and reasonable for the residents of Lue and Bara.
Bowdens does not offer a suitable plan for rehabilitation of the mine. When the mine closes the tailings dam and all the PAF will remain forever. Where is the maintenance plan for maintaining the tailings dam? This would be essential as feral animals such as wombats are very likely to destroy the proposed lining. Who will be overseeing this after the mine ceases to exist?
This project, if it goes ahead, will have a massive effect on agriculture, viticulture and tourism all of which are essential for the survival of the Mudgee region, both on financial and health levels.
I believe this project should be rejected. Thank you for taking my submission into consideration.
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Comments on the powering of the Project.

See attachment.
Regards Andrew

I am most concerned that Bowdens EIS substantially understates the fearful consequences of acid mine drainage affecting the Cudgegong River forever. If this proposal went ahead, future generations would have to deal with the legacy of this environmental vandalism.