Bowdens Silver

I strongly object to the project. See attachment.

3rd April 2022
https://www.planningportal.nsw.gov.au/major-projects/project/9641

Dear Sir/Madam,

The purpose of this letter is to object strongly to approval of the Bowdens Silver Project (SSD 5765) – Request for Water Supply Amendment.
I regularly visit my sister’s cattle grazing property at Lue and am surprised at the lack of professional behaviour by Bowdens Silver in failing to adequately plan the supply of essential resources such as water and power for their proposed mine not to mention the effect it will have on the platypus and koala population.
Bowden’s initial EIS submission included a 58.5km water supply pipeline from Ulan to Lue, however this supply has apparently failed because they overlooked the basic step of gaining the approval from Ulan Coalfields and relevant authorities.
Bowden’s recent request to amend the water supply, now proposing that the required water can obtained from the mining site itself reflects the same lack of planning and forethought according to the report provided to the Lue Action Group by water expert Shireen Baguley (see the points extracted from her report below).
Lawson Creek is identified in the NSW Stressed Rivers Assessment to be in the most seriously stressed category (S1) – with the highest level of environmental stress as well as a high extraction rate. Most of times I’ve seen it, the creek has been a series of water holes with no visible flow, so it seems inconceivable that the additional water needed to operate the mine could be drawn from the local landscape without seriously impacting local and downstream farmers.
Further, Bowdens attempt to ‘get by’ by recovering and recycling more water from the tailings dam and leachate dam are very likely to increase the health impacts on the local community and environment. Recovery of this water will clearly reduce the water levels in each dam, exposing more toxic elements in the soil (lead/cadmium/cyanide) to wind events, which will spread these compounds further afield.
Given Shireen Baguley’s findings, it’s clear that if this mine is approved it will often be a heavily water-challenged operation, and accordingly Bowdens will be less able to undertake dust-mitigation activities such as spraying the roads, resulting in more dust movement into the local environment, especially during dry times and droughts when dust is at its worst.
Finally, Bowdens water amendment makes clear that their groundwater licenses have been purchased in the Sydney Water Basin catchment as well as further downstream in the Murray Darling catchment. The Sydney Water catchment is clearly not relevant to western waters and the NSW government has historically indicated a preference not to move licenses upstream within the same catchment, as the water is less likely to be available high up in the catchment and will consequently disadvantage local people and farmers reliant on that water.
Points extracted from Shireen Baguley’s report include:
• “The Bowdens surface water assessment data appears to show a monthly average that exceeds 75mm over summer. This is incorrect…”
• “Many of the other months are also too high when compared to Mudgee and Rylstone rainfall statistics from BOM.”
• “The number of very low rainfall years that has been experienced in this region is not reflected in the Bowdens surface water assessment annual rainfall data”
• “The surface water assessment reports the average annual rainfall as 673 mm/a…. An average annual rainfall of 654 mm/a would be a more realistic estimate.”
• “The analysis here shows that one in every five years, the climatic conditions between Rylstone and Mudgee, which covers the proposed mine site, are semi-arid. This means that any loss of available water in these years severely impacts the land, and the people, plants and animals trying to survive on it.”
• “It is highly questionable that 740 ML/a of rainfall and runoff would be available as an ‘inflow’ in a low rainfall scenario.”
• “Further, the sensitivity analysis appears to be fundamentally flawed... It is considered that the reasons for this are that a true assessment of the low rainfall and runoff’ would show that there is insufficient water to meet the proposed mine’s water demands for an unacceptable duration.”
• “the assessment attempts to quantify the loss of water to the downstream catchment, stating there would be an average annual loss of flow of 177 ML/a. This assertion is misleading as it relates only to the estimated flow from within the ‘containment system’ and overlooks the fact that the water requirements for the whole project are being drawn from within Bowdens land, both that within the ‘containment system’ as well as the Bowdens’ contiguous land holdings. The mean annual flow is 1,955 ML/a comprised of 965 ML/a surface water and 990 ML/a ground water.”
• “…this would equate to a loss of flow from 10.9% of the Lawsons Creek catchment. It is an enormous and unsustainable impact on the water resources within this catchment and a significant impact on all land downstream of the proposed mine site”
I strongly encourage DPIE to reassess the ‘facts’ and assumptions in Bowdens Water Supply Assessment and if confirmed to be questionable or overly optimistic to not approve progression of this mine,
Yours sincerely

Support

Support

Please find attached a pdf of a Powerpoint I have developed on the problem of Acid Mine Drainage, which Bowdens has ignored. I do not support the project as it stands as this has not been discussed or addressed by Bowdens, who has in no way demonstrated how it will minimise the problems of Acid Mine Drainage. This is a major oversight that needs to be corrected.

Dr Haydn Washington, environmental scientist who worked on heavy metal pollution from sulphide mines for 7.5 years in CSIRO

These are significant amendments for which there has been totally inadequate community consultation and the timeframe for comment – a mere two weeks – is far too short and places even more stress on the community.

Water
There is not enough water for this mine. This was recognised at the beginning, hence the original proposal to pipe water from the Ulan and Moolarben mines. The onsite water availability has not magically increased just because the pipeline cannot be built.

The independent review of the data used for the water modelling has found some serious mistakes such as:
• They have used an average of combined data from Mudgee and Rylstone when it is well known that Lue is in a rain shadow and has less rainfall than either of those two places.
• They have conveniently left out the driest years in their data.
• Australia’s climate variability is well recognised: in their modelling they allow for highs of 30% above average but only allow for lows of 14% below average. This is ludicrous. Any landholder who keeps rainfall records knows that dry years can go as low as 50% below average.

The conclusion that there is negligible impact on downstream water users is wrong. Any loss of water in dry times is critical.

I refer you to the independent critique of the water assessment and water modelling for all the technical details. The critique clearly demonstrates there is NOT ENOUGH WATER for this mining project.


Transmission Line Relocation
This new proposal is not much different to the original proposal, so all previous objections stand. These are:
• I object to the whole process of an amendment being added even before the Department has released an assessment report. This should have formed part of the original submission and been properly considered in the EIS. The original EIS was highly flawed and we see a continuation of poor environmental assessment with this amendment.
• It is a travesty of the environmental assessment process that this amendment is being considered even though the exact location of the realignment is not known.
• The realignment will result in destruction of 12.6 ha of native vegetation, including the threatened ecological community, Box Gum Woodland. With only 5% of this ecological community left in the Central West, every hectare is precious.
• As mentioned above inadequate environmental assessment has been done. Of particular concern are hollow-bearing trees significant to Barking Owls and Greater Broad Nosed Bats, which have been identified close to the clearing for the transmission line. The importance of tree hollows (particularly large hollows in old trees) should not be underestimated, especially following reduced habitat due to the the 2019-2020 bushfires.
• Adequate assessment has not been done of the impact on Aboriginal cultural heritage. This is yet another example of the significant negative cumulative impact of mining being ignored.
• The proposed realignment will have a huge negative impact on the visual amenity of the region which is a major tourist destination. This has not been addressed.
• It is of great concern that there have been no discussions with the community regarding visual amenity, dust and noise associated with the amendment – yet another travesty of the planning process.
• I understand alternate options for proposed realignment were considered. Should this realignment go ahead, the condition that a route that places the line on lower
topography, avoiding the ridge and less destruction of native vegetation must be enforced.)

Bowdens state only four landholders will be affected. This is not true. Many properties have wonderful views which will be adversely affected by the appearance of the powerline on the ridge. Moving the line 100m makes virtually no difference to the negative visual impact.

This whole project has serious issues relating to water and air pollution and SHOULD NOT BE APPROVED AT ALL.