Bowdens Silver

I strongly oppose to the reconfigured water use proposed by Bowden’s at their Lue project.
The potential for damage to the environment in the area is far too great with the highly probable destruction of the water table, native vegetation and animals with adverse impacts on Lawson Creek if water is removed for the use of this mine. Water is a precious commodity for the local community and should not be used in this way for mining purposes.
There are far too many risks associated with this proposal and it is of no benefit to the local community or surrounding areas.

I support the project for the future economic benefits to the community in terms of employment and flow of income generation created from that. The project has ongoing environmental monitoring as per regulations in the various applicable legislation and therefore should not pose a great risk to the environment or local agricultural enterprises.

As can be seen in a recent newsletter silver products are used a wide range of applications that will be beneficial to people not only in the local community but also nationwide and internationally.

If this project was to get refused I feel it would be a lost opportunity for growth in the region. Bowdens is committed to fostering positive relationships with community groups and council to the benefit of the wider region.

My biggest objection to this mine is that the proposed mine is situated in a place with an unreliable water supply. The mine needs 1788 megalitres per year to operate. A large farm dam holds 1-2 megalitres, 1788ML is a lot of water. Where will the water come from during a dry time? The mine will have to shut down during droughts. We have only come out of a significant drought and the memory of its impact is still fresh. Lawson Creek is identified in the NSW Stressed River Assessments to be in the most seriously stressed category with a high level of environmental stress as well as a high extraction rate. Bowdens Mine proposes to transfer water licences from further down the Macquarie catchment as well from the Sydney basin catchment, further depleting Lawson Creek. This proposed mine will have a ripple effect into other catchment areas and will negatively affect many environmental ecosystems. I strongly object to this proposed mine.

The amendments to the Bowdens Silver Project are positive ones and I support them wholeheartedly. The reasons I am supportive of the amendment and the project in general include the following:
- The new water strategy allows the proposed mine to be fully self sufficient for water requirements and remain financially viable throughout its entire mine life.
- The inclusion of a paste thickener plant and new water management strategy reduces average processing water usage by 390ML per year.
- Improved water management techniques within the tailings dam ensure better usage and environmental outcomes.
- Removal of the pipeline reduces the need for vegetation clearing.
- The new powerline alignment is further away from residences to the west and will improve visual amenity outcomes. There will also be less towers relocated/built positively impacting the construction process for nearby residents and also economically for the company.
Overall, these amendments provide positive outcomes for the community, the environment and the company. The project will also provide up to 320 jobs within the community which in turn will also help provide economic and social stimulus within the local towns and villages. This proposed mine will also help diversify the local mining landscape within the Mudgee region as the world moves away from fossil fuels, thereby providing an opportunity for the Mid-Western region to continue to prosper in the coming years.

My name is Bruce Christie and I have lived in the Lue area for the last 42 years. We have a family property that is within the current lease of Bowden’s Mine and live approximately 8kms from the mine. With my family we manage a grazing property and have concerns on the construction of the mine so close to ourselves, the Lue village (population 800), Mudgee township (population 11,000) and for the surrounding rural businesses.
With the recent changes to the EIS our concerns from this mine have escalated. The supply of water for dust mitigation in the original EIS was a mix of pipeline and harvested water out of the Lawson Creek Valley. With the recent changes, water supply is now reliant totally on water harvested on site or capturing surface water from the Lawson Creek system. Having lived in the area for decades I have seen the Lawson Creeks flow reduce to nothing at regular intervals with downstream landholders reliant on shallow well water, or a system of waterholes. These waterholes are also drought refugia for aquatic life that maintain the health of the Lawson Creek and limits local extinctions of the diversity of aquatic species during dry times. This water is now under threat from the development of this mine and the resultant drawdown of the aquifer.
Ground water is not homogenous and will flow through a network of paleo channels that have been laid down over millennia. With the massive void created by the mine it is more than likely that it will interrupt this flow and halt the flow of ground water ensuring that nothing gets past to water uses and townships below Lue. This will affect the businesses that relied on this ground water for stock and household use in these dry periods. Bowden’s have said that they will supply water to these businesses, unlikely, but even if true, what will happen after 16 years when the expected life of the mine will be complete. Who will supply water into the future with the Lawson Creek flow irreversibly altered?
I also feel that Bowden’s have overestimated the rainfall for the area and therefore their calculations on their harvestable rites for water harvesting. Their current calculations would be optimistic, again resulting in a lack of water for dust mitigation. There is a critical need for dust suppression due the proximity of the mine to the Lue village. A high level of toxic waste products particularly lead dust will be created. There is no safe level of lead for communities. The buffer zones from mining activities are necessary to protect the public. Given that the proposed mine pit is only 2 kilometres from Lue, there is no opportunity for a sufficient buffer zone to prevent lead dust reaching the village through single or multiple dispersion events.
The large power towers that will need to be moved were originally placed to limit the aesthetic impact by placing them where they will have the least impact to the visual amenity of the area. With the realignment of these large towers to the ridge, or just below they will still be visible and take away for what is a very scenic area and increasingly reliant on tourist traffic with many farms stays and bed and breakfasts in the area supplementing agricultural incomes.
There has been very little information available on the power supply for the mine operation. Where will that come from? What damage will it do to the Grassy Box Gum Woodland endemic to the surrounding area with the need to clear adjacent to the power supply?
On top of these recent changes to the EIS the existing issues remain with the mine and were not adequately answered in the response to the EIS from Bowden’s. There are many but a few are:
1. Damage to the Grassy Box Gum Woodland relies on offsets. Some of these offsets will be land adjacent to the mine. Hard to believe that those offsets will not be radically altered and suffer from the proximity to the mine itself with light pollution effecting all levels of biodiversity. The clearing of Grassy Box Gum Woodland that has taken thousands of years to develop for a mine life of 16 years is flawed.
2. Construction of the tailing dam is still inadequate, with admission that it will leak and leach into the ground water over time. This is totally unacceptable for what little ground water that may escape the void after it has filled (over 100 years), to then be contaminated by leaching for downstream users.
3. The proximity to the village of Lue. With the obvious lack of available water for dust mitigation there will be dust events that will disperse over the village. This will make it impossible for them to harvest rainwater (there is no town water available) or grow vegetables. There will have to be a concerted effort by the population to ensure their houses are sealed and for children, that are most vulnerable is an unacceptable risk in these modern times. It will signal the demise of Lue Village as who would want to risk their health to live so close to a lead mine? Lue will go the same way as Wollar, Ulan and Bylong, communities dispersed and no services left in the area.
The decision for this mine to go forward would be a decision that generations into the future would regret for a very long time. It would be irresponsible for the government who have been made aware of these risks to support this mine. It will open future generations to the risk of lead, a contaminated environment and open the government to litigation from future generations given all are aware of the risks involved.
The Lue community has had enough of the threat of an impending mine over their future, and it is time it is stopped.

I am a keen bird watcher and regularly visit the Putta Bucca Wetlands on the outskirts of Mudgee. I am very concerned about the potential threat to these increasingly important wetlands from acid mine leakage at the proposed Bowden Silver mine.

Nowhere have Bowdens addressed this issue. The EIS, the original response to submissions, and this amendment totally fail to have any serious discussion on acid mine drainage and heavy metal pollution. They don’t even mention it! Yet every heavy metal sulphide mine around the world has serious problems with acid mine drainage and the heavy metals it carries. This is a very serious omission that must be rectified before any further consideration of this DA.

The proposed silver mine at Lue is going to require a lot of water. This will place pressure on a water supply that is only just meeting current needs for agriculture. The drought of 2018 / 19 is evidence of this. The Lawsons Creek was reduced to water holes with no flow.
There is also a high risk that the tailings dam that collects the waste water will leak into the Lawsons Creek. Damage from an event such as this would be beyond repair.

As Manager of the Lue Hotel, I am pleased to provide this submission on behalf of our business.
The Lue Hotel is the only retail enterprise in the village and is the social centre of the village and local area.
Under the new ownership and management, we have spent a considerable amount of time and money in undertaking a range of repairs to the Hotel including upgrades to the bar, kitchen, restaurant and accommodation areas. We currently have a DA submitted for a cafe in an adjacent building. This is something the locals have expressed a great interest in.
We are excited about the opportunities the Hotel presents going forward. However, being a very small town and being the only retail business in the village we rely almost exclusively on the success of the town.
The Hotel already experiences benefits from Bowdens Silver with members of their team often supporting our business and contributing strongly to our communities.
The development of the Bowdens Silver project will certainly bring much needed business to the Hotel. With well over 200 local and well-paid jobs created there will certainly be a proportion that will be living in close proximity to the Hotel. Our new cafe will definitely receive strong support from the Bowdens workers on a day-to-day basis. This support and economic benefit will enable the Hotel to continue to increase its offerings and services to the local community. The Hotel is not just a hotel. It is the hub and heart of our community.
In addition to the benefits to Lue, the Bowdens development is critically important for the local towns of Rylstone and Kandos. Unemployment is very high in the area and Bowdens is the only new development of substance in the area that can help.
With the latest Bowdens Silver project amendment, it is welcome to see further positive refinements and in particular when it comes to water and its security.
We strongly support the Bowdens Silver development.

By way of disclosure, a director of Bowdens Silver is a part owner of the Lue Hotel.

I object to the proposal because of the power line relocation amendment.
Power line relocation will result in loss of threatened box woodland vegetation, further endangering species which depend on it.
Power line relocation will also result in poor visual impacts for surrounding landowners, thereby reducing property values in the area.

I object to the proposal because the number of truck movements per day predicted by Bowdens will damage already inferior small rural roads and endanger other road users.

I object to Bowdens proposal because there has been no assessment of possible aboriginal cultural sites in the area proposed for mining or in the immediate vicinity of it.

Thank you for reading this submission. I very strongly object to the proposed amendment for the following reasons. Bowdens original assured the local community that the local water supply would not be included in its plans,instead bringing in the water via pipeline from Ulan. Thus admitting that the water here is a very precious resource, and is not always sufficient for the land and its users.
Now the story changes.
We have recently lived through a devastating drought which will doubtlessly occur again, most probably more frequently as the climate crisis deepens.
There seem to be a number of data validity issues with Bowdens’ surface water assessment - such as the omission of some extremely dry years such as 2019 from the data, affecting the average figures. The average rainfall mentioned is incorrect when compared to BOM figures. Lue doesn’t receive that amount pa. This does not augur well for trust in Bowdens communications.
The amended plan does not address how it would source water in the dry years nor does it have a plan for increasing effects of climate change.
It is arrogant and infuriating of Bowdens to state that this amendment ‘would not significantly impact other water users including the natural environment’. As shown in environmental auditor Shireen Baguley’s review (attached) there would be a loss of flow of 10.9% of the Lawson Creek catchment. This can by no means be considered as insignificant! WHY, IF THE AMENDMENT’S IMPACT IS TRULY INSIGNIFICANT AS STATED BY BOWDENS, DID THEY NOT PROPOSE THIS IN THE FIRST PLACE, BUT PLANNED FOR A RUINOUSLY EXPENSIVE PIPELINE OF OVER 50 KILOMETERS!? Again, this suggests that Bowdens cannot be trusted - it looks suspiciously as though they were always planning to ditch the pipeline but used it as a sop to the community, to add the true plan later as a ‘small’ amendment.
The local community has recently lived through the very traumatic impact of major drought on this land. The 2019/20 bushfires have left deep scars. Please do not ignore the local people of this land, who have dealt with so much already. To remove precious and much needed water from this landscape, thus increasing the effects of inevitable future droughts, will result in our community and natural environment facing an increase of the already substantial impact of climate change. Please reject this proposal and ensure the water remains where needed for the land, wildlife, farmers and wine growers on our land.
I attach Ms Baguley’s technical review on this amendment.
Best regards
Luciana Smink

I strongly oppose the entire Bowdens Silver Project, it is not an environmentally or socially sound project.
The project is incompatible with Lue and surrounding property due to the close proximity of two kilometers The community has witnessed the demise of the Wollar . Cumbo valley and ulan communities due to mining. Please refer to the Lue Action Group social impact report in the EIS submission
It does not promote the sustainable management of Aboriginal cultural heritage. Removing artifacts to "keep in a safe place" dismisses the importance of place and song lines. Song lines are integral to aboriginal spirituality.
Song lines are deeply tied to the Australian landscape and provide important knowledge, cultural values and wisdom. Aboriginal sites must not be disturbed.
381ha of native vegetation will be cleared, including 180ha BC Act listed box gum woodland and 146ha classified under EPBC Act.
95% of box gum woodland has been cleared in NSW, surely there is a responsibility for remaining areas to be kept intact.
The assessment regarding koalas was insufficient. Recently, there was another koala sighting at Bingman Crossing, 2km from the proposed open pit.
A large proportion of biodiversity off sets are owned by the proponent. The close proximity of these off sets to the proposed mine site
may in fact be a problem if species are shy of the mine area .Lue action group provided a biodiversity report in their EIS submission.

Realignment of 500kv transmission line.
The concerns in relation to the realignment have not been mitigated by the proposed final alignment.
Visual impacts remain unchanged from the previous proposal and the character and quality of visual landscape is affected by the proposed line. Structure views have increased in the final proposal.
My property is one of the closest to the mine site and the present transmission line is not visible, however the visual analysis claims I can see two existing towers.
Images on pages 20,21,22 (appendix 8) are facing the wrong direction and there are no images taken from the Western side of the village.
Approximately 12 properties on the Western side would have good views of the proposed line. Bowdens have not communicated with me personally re the re alignment.
The NSW Stressed Rivers Assessment places Lawson Creek in the most stressed category with both high environmental stress and high extraction rate. Lawson Creek is on the North and Eastern boundary of my property so I am well aware of how the creek responds to weather events. The creek does not have the capability to withstand further water losses
Bowdens Silver announced that in order to maintain water supply, a pipeline was to take water from the Ulan coalfields in order that the project would not place additional demand on local and regional water resources.
The creek regularly ceases flow above Bara Creek and deteriorates to waterholes, fed by ground water flows.
The creek is an important source of water for wildlife and acts as a refuge in a predominantly agricultural area.
In the drought ending in 2020, the creek had dried out completely (see attached image) and multiple sections of the creek down to Mudgee
were also completely dry. Such semi arid conditions could be expected every 2 in 5 years.
Flow studies were not done on Lawson Creek but are instead, based on the Cudgegong River, upstream of Rylstone. Using studies from
the Cudgegong provides incorrect data as the Cudgegong is a totally different water catchment and stream flows are higher.
In response to the EIS submissions, Bowdens stated that "no occupants of residences within Lue or surrounds are predicted to experience a reduction to supply of groundwater or surface water due to the project"
In correspondence with Bowdens, I was informed that due to groundwater draw down induced by open pits and retention of water on site,
that "collectively these reductions would ultimately result in flows of Lawson Creek, adjacent to your property would be reduced by .5 megaliters per day".
It is clear, from the Bowdens Water Amendment, that water licenses are coming from the Sydney Basin Catchment and downstream in the Murray Darling Catchment. It is unacceptable to be transferring these licenses from other catchments and further down the Macquarie Catchment, to the Lawson valley, which is at the head of the Macquarie catchment.
Please refer to Water Amendment Analysis. Written by Shireen Baguley, attached to Lue Action Group submission.
Acid mine Drainage...Sixty four percent of the waste rock is potentially acid forming rock which is a very high percentage. The potential of acid mine drainage is a serious concern for this proposed mine. The devastating effects of acid mine drainage has been well documented Any risk of acid mine drainage occurring can not be accepted. The waste rock placement is within the Price creek floodplain. Please refer to Dr Haydyn Washingtons submission and attached power point presentation.
For technical analysis of issues raised, please refer to Lue Action Group submission.

Please see attached

The Amendment made by Bowdens Silver to allow 100% of water needed for mining operations taken from within the mine site is irrational, allowing for devastating adverse long term effects to the entire Lue area and surrounds. It is unjustifiable that no major effects will be made to all residents and landowners within the area. Lue area and surrounds does not have enough water to allow for a mining operation like Bowdens to operate alongside the already existing businesses.
Lawson Creek is already listed in the NSW Stressed Rivers assessment, in the most stressed Category (S1) with both high environmental stress and high extraction rate. It is already evident that Lawsons creek, more often that not, subsides to a series of small water holes during most summer months. A major operation like Bowdens will see Lawsons Creek empty for the foreseeable future.
All residents within the Lue Area rely on a secure water source through rain catchment and privately owned bores. With both jeopardised by Bowdens planned operations, no one would be able to survive in the area.
With regular blasting and mine operations so close to the township of Lue and surrounding residents, rain Catchment within the area will be subjected to lead contamination through Dust sediment within water catchment tanks and guttering. This lead contamination is proven to have a wide variety of negative medical impacts, especially in young children. Those of who will be attending the Local Primary school only 2km from the mine area.

220407. Bowdens Ammendment.Water

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.

There is not enough water for this mine. This was recognised at the beginning hence the original proposal to pipe water from the Ulan & 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 know 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.

Bowdens original EIS, when water was going to be piped from elsewhere, had a table showing impact of the mine on downstream catchments. Despite this significant amendment of now sourcing all water on site, there has been no change to this table. One does not have to be an expert to realise this is plain incorrect and very misleading.

I am aware there will be an independent critique of the water assessment and water modelling submitted but the serious time constraints mean this critique is not yet available for the community to access and reference. Therefore I refer you to that submission for all the technical details that clearly demonstrate there is not enough water for this mining project.

This project cannot go ahead.