Bowdens Silver

Hello, thank you for letting me have a say in whether I think this mine should go ahead or not. I hope not. I strongly disagree that it should be allowed because of the environmental damage it will do during its life and also the mess it will leave behind for years and years and years.
As you would be aware water is a very serious problem in our country areas – if you allow Bowdens to take all the water they plan to take from Lue it is going to impact the water table and loads of people rely on that water for their drinking, vegie gardens, to water their stock and the local wildlife depend on it too. Bowdens are planning to use 2 gigalitres of water a year running their mine – that’s more water than the rest of Lawson Creek Valley put together! Just ask some of the locals how important this water is and how much they have to spend on buying water when they are in the middle of a drought – doesn’t that show they don’t have enough water to go around already and this mine wants to take more?!? And after the mine uses all the water it will be poisoned and left sitting in a tailings dam and expected not to make its way back into the water supply then leaving Lue residents with a contaminated water supply which is not only useless but downright dangerous to their health and the wildlife alike.
Apart from the obvious water supply issues I also foresee many other issues including the increased traffic on Lue Road – have you used Lue Rd? There is only a couple of safe overtaking spots available and I fear people getting frustrated and trying to get past B Double trucks are going to cause accidents apart from the damage to the actual road caused by these trucks.
Please reconsider letting this mine open at all.
Thank you for your time.

Please find my Submission in the attachment below

Rylstone District Environment Society objects to the project because it does not adequately address concerns about potential long-term impacts on the environment. Concerns include:
Potential for contamination from the mine site affecting local waterways and groundwater.
In particular, serious shortcomings in the design of the proposed tailings storage system could expose the Cudgegong Valley to long-term environmental risks that would need to be managed forever. Who would be responsible for dealing with this?
Inadequate information about potential for lead dust contamination, how this would affect the surrounding communities and land, and how this would be managed.
Lack of information on how potential for acid mine drainage will be managed.
Long-term depletion of the valley’s water resources.
Unacceptable likelihood of damage to habitat for local native plants and animals, including failure to address protection of threatened species.
Based on the information available to the community, the proposed mining operation poses unacceptable risks to the environment and human health, and fails to acknowledge the burden this would place on future generations.

As a Mudgee local and business owner I wish to object to the proposed Bowden’s Silver Mine on the basis of the proposal demonstrating a number of fundamental short comings and devastating impacts on society and the environment. A proposal for an open cut mine in a scenic agricultural landscape close to an existing village and on the door step of a growing tourism region is certainly not in the public interest. I wish to object to the proposal on the following grounds:
1. Detrimental social impact to residents in and surrounding the village of Lue and the greater Mid-Western Region both in the 7 day operation of the mine, its proximity to Lue and increased heavy traffic.
2. Detrimental environmental and climatic impacts associated with open cut silver mining at a time when climate change is the single biggest threat facing humanity, including impacts on water, noise, dust and toxic materials such as lead.
3. Detrimental impact on the Tourism potential of the greater Mid-Western Region.
4. That an open cut mine located so close to Lue and the greater Mid-Western Region is not in the public interest.
5. Contravention of the subject site’s land use zone objectives in the Mid-Western Regional Local Environment Plan 2012.

Items 1-4 should not even require further explanation and these points alone should be enough to refuse this proposal outright, however to further understand item 5 it is necessary to reference the recent ruling and precedent set by The Rocky Hill Coal Proposal (SSD 5156) and the Stratford Extension Project Mod 1 (SSD 4966 MOD 1). Part of the determination found that the creation of an open cut mine located on RU1 and E3 zoned land would contravene the zone’s objectives and have a detrimental impact on the adjoining towns and areas and was therefore not in the public interest.

The proposed open cut silver mine is no different here. located on agricultural land close to the village of Lue and the larger towns of Rylstone and Mudgee, the proposal contravenes the objectives of the RU1 zone as outlined in the Mid-Western Regional LEP 2012 which are:

• To encourage sustainable primary industry production by maintaining and enhancing the natural resource base.
• To encourage diversity in primary industry enterprises and systems appropriate for the area.
• To minimise the fragmentation and alienation of resource lands.
• To minimise conflict between land uses within this zone and land uses within adjoining zones.
• To maintain the visual amenity and landscape quality of Mid-Western Regional by preserving the area’s open rural landscapes and environmental and cultural heritage values.
• To promote the unique rural character of Mid-Western Regional and facilitate a variety of tourist land uses


There should not be a need to expand on this any further. An open cut silver mine located on agricultural land so close to the Village of Lue in what is a growing Mid-Western Regional tourism area, contravenes every one of the RU1 zone objectives. The EIS document fails to address how the silver mine proposal satisfies the objectives of the RU1 zone. Like the ruling at Rocky Hill Coal, an open cut mine located within a RU1 zone on scenic, agricultural land so close to a village and surrounding towns, does not satisfy the objectives of the RU1 Zone, and the Bowden’s Silver Mine proposal should therefore be refused as it is not in the Public interest.

It find it farcical that a proposal such as this is even being considered. Any perceived economic benefit is far outweighed by the social and environmental impacts of this proposal. I sincerely hope that common sense prevails, and this silver mine proposal is refused in full.

Regards
Cameron Anderson | RAIA
Director | Cameron Anderson Architects PL
Mudgee NSW

I object to the Bowdens Silver mine project in Lue, NSW.
This project is not in the public benefit.
I am particularly concerned about:
Destructive impacts on human health quality
Destructive impacts on water quality
Destructive impacts on air quality
Destructive impacts on intergenerational equity

The title of this project is misleading.
According to the Ore Reserve Statement in the EIS, the project estimated yields are:
Silver: 1,871 Tonnes
Lead: 95,000 Tonnes
Zinc: 130,000 Tonnes
This project is clearly a lead and zinc mine.

There is insufficient information supplied by the proponent for the community to assess rehabilitation efficacy.

I strongly recommend that this proposal be rejected in its entirety.
Thank you.

Thank you for the opportunity to comment...
Having recently commented on the project, it is frustrating and bewildering to see yet more documents to wade through, making many people simply give up on commenting.
To be brief, i wish to comment on the amendment to the proposed power line, and the changes relating to planned water extraction.
1..The powerline amendment (of which i commented on back in Aug last year)...I find the plan to move the powerline 100 metres will do nothing to assuage the views/opinions of those affected by the original proposal and my thoughts on the original proposal are unchanged. I notice in the current submission, Appendix 8, (Water Supply Amendment), there is commentary regarding the proposal. I notice from page 11 to 19 is a visual analysis on 3 properties close to the proposed mine. I see the images are created by "modelling" and not from real, visual assessment from those properties. Also, the analysis only focusses on the views to the towers themselves, with no mention or expansion of views covering the lines attached to the towers, or, are we to assume the power cables will be invisible !
I also note the images on pages 20, 21 and 22.....These are simply images extracted from Google Street View, and in the interest of accuracy, they are all aligned in the wrong direction, regarding this powerline. All images are aligned towards Bingmans Ridge (which in fact hides some of the existing and proposed lines), and are not indicative of the view over skyline affected by the proposal. What a shame that "boots on the ground" or, an actual area visit and survey didnt take place! Furthermore, one of the images, incorrectly labelled as "East of the hotel", (it is in fact West), is actually a property acquired by Bowdens and as such probably should not be used in any assessment
Whilst the images are somewhat representative of the village (despite their poor alignment), it is interesting that no imagery was supplied from the Western side of the village, where around 10 or so properties have (by virtue of their elevation), commanding views over the area in question. I have attached an image typical of the views.
As far as i am aware, no one, especially those West of Lue have had any visit or consultation...

2...Water supply.
Having knowledge of the water supply issue, Bowdens attempted to obtain water from one of the coal mines near Ulan. Worth noting here is that these mines already have obligations regarding the water encountered in mining, and, also of note is that this water is in another catchment area, being the source of the Goulburn river. I will not going into further detail as to whether Bowdens were able to secure the water or not, but, recently they announced the water was not required due to "technological improvement". They claim a significant reduction in water requirements. However, doubt always remained in the community that they could supply enough water from the mine site alone, with this backed by an article written by Shireen Baguley. This article will be supplied in the submission by LAG (Lue Action Group).
Having been in the area for over 20 years, in close proximity to Lawsons Creek, i do possess some understanding in the behavior of the creek. It has a highly varied flow, rising quickly in heavy rain and subsiding quickly to its normal flow rates. Outside of exceptional seasons like the one just past, the creek regularly ceases flowing above the junction of Bara Ck (some 8km West of Lue). I would estimate a normal average flow of under 20lt/sec when the creek is flowing. Usually in summer it ceases flow and is reduced to several waterholes topped up by groundwater flows through the gravels and along rock shelves. The creek is used for stock and domestic supply by several landholders but has no further capacity for larger withdrawals like irrigation. Couple this with the creeks value as a wildlife habitat in a predominantly agricultural area and its value becomes apparent. i feel the water use/drawdown at the proposed mine would have drastic effect on the creek. Any open cut mine Bowdens would also act as a sink, attracted groundwater which would then be confined to the property. After mining has finished, this will continue, with the water being retained and then lost by evaporation, causing the water to become more saline and unusable. In effect, this means any open cut would then mean a permanent reduction in groundwater flow to the creek, a situation causing a permanent change in the nature of the creek, effectively killing it in any sustained period of dry weather.

My name is Lily Wilson and I am based in Wagga Wagga NSW. I grew up in the Lue area, and my family own land used for agriculture. I am pleased to have this opportunity to dispute the Bowdens Silver Project as there are many reasons why this project should not be allowed to proceed.

1. Evidence on the Effects of Lead on Human Health
Health effects as a result of lead exposure differ substantially between individuals. Factors such as a
person’s age, the amount of lead, whether the exposure is over a short-term or a longer period, and
the presence of other health conditions, will influence what symptoms or health effects are exhibited.
Lead can be harmful to people of all ages, but the risk of health effects is highest for unborn babies,
infants and children.
It is well established that blood lead levels greater than 10 micrograms per decilitre can have harmful
effects on many organs and bodily functions. Effects such as increased blood pressure, abnormally
low haemoglobin, abnormal kidney function, long-term kidney damage and abnormal brain function
have been observed at blood lead levels between 10 micrograms and 60 micrograms per decilitre in
adults and children.
Encephalopathy—which is characterised by irritability, agitation, poor attention span, headache,
confusion, uncoordinated walking or movement, drowsiness, convulsions, seizures or coma—can
occur at blood lead levels of 100–120 micrograms per decilitre in adults and 70–100 micrograms
per decilitre in children.
Death can occur at these blood lead levels in some cases.
The evidence for health effects occurring as a result of blood lead levels less than 10 micrograms per decilitre is less clear. NHMRC’s comprehensive review of the health effects of lead found an association between reductions in Intelligence Quotient (IQ) and academic achievement in children
at blood lead levels less than 10 micrograms per decilitre. There is weaker evidence that blood
lead levels less than 5 micrograms per decilitre are associated with reductions in IQ or academic
achievement.
For blood lead levels between 5 micrograms and 10 micrograms per decilitre, an association was
observed between higher occurrence of behavioural problems (poor attention, impulsivity and
hyperactivity) in children, increased blood pressure in adults (including pregnant women) and a delay
in sexual maturation or puberty onset in adolescent girls and boys.
The relative contribution of lead to the above health effects is difficult to determine. The effects of
blood lead levels less than 10 micrograms per decilitre on IQ, academic achievement and behavioural
problems is likely to be small, with stronger influences being exerted by other factors such as
socioeconomic status, education, parenting style, diet, or exposure to other substances.
For more information visit the source of this article:
www.leadalliance.com.au

2. The likely possibility of Acid Mine Drainage that would affect the local community and landscape.

3. Irreparable damage to the landscape and wildlife

Following consultation with the local Aboriginal community I have the following comments regarding this project.
The Mudgee LALC would like to formally object to this project for the following reasons.
Whilst the report doesn’t consider the Aboriginal Cultural Heritage to be of high scientific or cultural significance we consider all of our Cultural Heritage to be important.
We are very concerned about the cumulative impacts on Aboriginal Cultural Heritage in our region from the multiple developments – namely mining which have destroyed and displaced our cultural heritage. This project adds another 26 sites to the list of those destroyed by mining within our region. Once these places are destroyed they are gone for good - the cumulative affect of this is having a devastating impact on the ability of our people to ensure inter-generational cultural transmission.
We believe that all areas which will be impacted by the project development during construction and operation of the mine (such as the water pipeline and any ancillary developments, access roads etc) should be surveyed to ascertain the presence of any Aboriginal Cultural Heritage materials prior to the approval of the development.
If areas are not surveyed then the impact on Aboriginal Cultural Heritage from the project may be underestimated. There may be more than 26 sites which will be directly impacted by the development so we feel it is essential that this is determined before approval of the project so that all information is present.
As such we request that a detailed Aboriginal Cultural Heritage assessment be carried out all areas which will be impacted by the project during construction and operation of the mine or ancillary infrastructure prior to development consent being sought so that decisions are made with all information present.
We feel that if there are any areas which have not been surveyed as part of the biodiversity assessments which will be impacted during construction or operation of the mine then these assessments need to be conducted and included in reporting prior to the development consent being approved. Again we feel that informed decision making is essential in the development approval process.
We have concerns about the impact of the proposed water pipeline from the Goulburn River Catchment to this project. We are not only concerned about the impacts on cultural heritage from the pipeline but also the impacts of moving water from one catchment area to another. We feel that this is not culturally or environmentally appropriate. Additionally we have concerns about the potential environmental risks to water quality and security from the project.
We have major concerns about the impacts of this project on the groundwater. Little to nothing has been investigated to other bore users from drawdown and deterioration associated with mining (only two Bore users were assessed in the EIS). All of the bores which could potentially impacted need to be fully assessed to determine potential affects and to allow the EIS to present accurate information to allow an informed decision to be made.
The EIS has discrepancies relating to the use and containment of cyanide. The groundwater model is inappropriate to assess contamination risks.
The EIS does not comply with the requirements of the SEARs.
Bowdens will not rehabilitate whole site as it will cost too much to repair the damage. The main pit will remain forever and will take 100 years to fill with water and the tailings dam will also stay with its toxic sludge thereby polluting the Lawsons Creek valley and the Mudgee river system forever. Bowdens should be required to rehabilitate the entire project area as a condition of consent.
Bowdens will build a 68 m high single wall tailings dam and will pump it full of chemicals like Arsenic, Cyanide, Cadmium and Lead. There is no second safety wall for the dam so if it leaks or overflows it will flow to Lawsons Creek and then to Mudgee and the Cudgegong River thus contaminating the catchment. Additionally the contamination from leaching and surface water contamination is a major concern.
All the ore produced at Bowdens will get transported through the middle of Mudgee. Constant and regular heavy B Double trucks full of toxic chemicals and lead past Mudgee schools, businesses and residences.The potential threat of an incident to the community is of serious concern and should not be allowed.
The impacts to residents from noise from construction, operations and blasting has been underestimated in the EIS. Data used for modelling is outdated and underestimated. It does not account for the changes in power levels of machinery, source heights or the haul road.
The health issues which could arise from potentially contaminated dust is a major threat to surrounding residents. The EIS underestimates community exposure levels as it doesn’t use concentrate, mine ore materials (stockpiled oxide material and tailings) as sources of dust.
Overall we do not feel that the EIS presents a full picture of the impacts of the project.
As such we call for the project to be rejected and that if any EIS is resubmitted for the project in the future that it is required to contain detailed reports based on accurate and up to date data and information.
Thankyou for taking the time to read our comments.
Regards
Tony Lonsdale
CEO
Mudgee LALC

Support

Please see attached document for the submission.