Bowdens Silver

Lue does not have enough water to allow for a mining operation like Bowdens mine is planing to operate in its new amendment.

With regular blasting and mine operations so close to the township of Lue and surrounding, residents will be subjected to lead contamination through dust in the water.

This lead contamination is proven to have a wide variety of negative medical impacts, especially in young children.

I am a Mudgee resident and I write in support of Bowdens Silver SSD-5765 EXH-39437454. My reasons for supporting the proposed development are set out below.
1. The removal from the project description of the proposed water supply pipeline on the basis of the updated on-site water management and supply strategy will significantly reduce disturbance to land and minimise biodiversity and heritage impacts.
2. The proposed increased recycling of water through the process circuit and Tailings Storage Facility (TSF) management will support the proponent's commitment to "no competition for water with local agriculture and no impact on environmental flows" and its paramount commitment to protection of Lawson Creek from impacts associated with the proposed development.
3. The proposed development's water management and TSF design has been subject to extensive and rigorous technical scrutiny and peer reviews.
4. The proposed realignment of the 500kV power line, bringing it closer to the proposed mine site, will result in improved visual amenity for landholders to the west and southwest of the proposed mine site, and reduce the number of towers required.
5. Approval of the proposed development will be a significant diversification to the regional economy which is currently focussed on fossil fuels.
6. The silver and zinc produced by the proposed development will form an essential raw material critically required to ensure the viability and efficiency of renewable energy technologies leading to reducing global carbon emissions and global warming.
All of the above demonstrate the proponent's continuing commitment to protecting the environment to the greatest extent possible, and to ensuring that community values and amenity are protected to the greatest extent possible.

Transmission Line Relocation

This new proposal is not much different to the original proposal. Moving the line a mere 100metres from the original proposed route does not ameliorate any of the objections made previously some of which I have reproduced below

The power line will still have an enormous impact of the visual amenity of the region which is a major tourist destination. Bowden’s statement that only four landholders are affected is simply wrong. Many properties have wonderful views which will be impacted by the appearance of the powerline on the ridge. Moving the line 100m makes virtually no difference to the negative visual impact.

The realignment will result in the removal of Box Gum Woodland, a threatened ecological community of which only 5% remains in the Central West, thus making every hectare precious. We cannot afford to lose any more.

Once again cumulative impact on a range of issues has been ignored. These include the above mentioned endangered ecological community, aboriginal cultural heritage and loss of habitat (eg hollow bearing trees affecting Barking Owls and Greater Broad Nosed Bat, and koala habitat). Cumulative impact is a serious issue that is never addressed in each single application but results in continuing loss of habitat of a variety of endangered species. This must be properly addressed.

I am lodging this submission, as I strongly object to Bowden's development of a lead, zinc and silver mine and associated infrastructure.

I am a landholder and live downstream of the proposed lead, zinc and silver mine near Lue. Bowdens proposal to source all water for this mine directly from our catchment area is outrageous and cannot be approved. The detrimental effects of extracting water from our catchment area will negatively impact directly on the Lawson Creek - identified as already seriously stressed in the NSW Stressed River Assessments - and our environment downstream of this project, including Mudgee, NSW. The transfer of water licences from further down the Macquarie and Sydney Basin catchments is corrupt and is taking unfair advantage of a system designed to protect our waterways.

Furthermore, this mine which aims to extract ore from our environment in an open cut mine is exposing many local families to poisonous substances such as lead. All to benefit the greedy pockets of individuals. This must not be allowed to happen.

Running Stream Water Users Association was formed in response to concern about the negative impact of mining on water resources. We are extremely concerned about the negative impacts this mine, if it goes ahead, will have on the water resources of the area.
Right from the start this mine proposal has been dogged by the lack of sufficient water resources, with two attempts (that we are aware of) to source water from elsewhere: the original owners, Kingsgate contemplated trucking the ore elsewhere for processing, and Bowdens in their DA submission proposed a pipeline from the Ulan and Moolarben mines. To propose such an expensive solution indicates Bowdens were well aware there was insufficient water available on site. Conditions have not changed so the question has to be asked how they now think there is sufficient water.
It seems Bowdens have achieved the right numbers on water availability either by using inaccurate water data or excluding relevant data.
The amendment refers to 673ml annual rainfall for the mine area, whereas the BOM gives 614ml/a for Lue. Bowdens refer to annual rainfalls for Mudgee (656ml/a) and Rylstone (635ml/a), but this is misleading as it is well known by locals that Lue lies in a rainshadow and receives considerably less. Data for the years 1888 and 2019 is missing. These were the two driest years on record in the area. One asks why is this data missing? Furthermore, nowhere is there discussion of impact of reduced rainfall due to climate change.
Australia’s climate variability is well recognised: in their modelling Bowdens 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.
Bowdens’ original EIS, when water was going to be piped from elsewhere, included a table showing the 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 incorrect.
Another major concern with this proposed mine is the impact of acid mine drainage. Nowhere is this issue addressed, either in the original EIS or this amendment. Acid mine drainage has the potential to leach heavy metals into Lawson Creek and this could impact fauna and flora along the creek for at least 20 km over many decades, thereby endangering the Putta Bucca Wetlands on the outskirts of Mudgee.

Thirty million tonnes of sulphide ore is planned to be mined. The EIS notes on pp. 8–16 that pyrite (iron sulphide) is the most wide-spread sulphide material found. Fig 10 of the leachate columns shows that the pH of the leachate of one sample was consistently pH 3 or less (i.e. quite acidic). The assessment by Bowden Silver thus fails to show that acid mine drainage will not occur. It has occurred with every other sulphide mine. It will occur here also.
We need to be shown the design of the waste rock dump to see exactly how air and water will be sealed off from entering in the long term.
We need to know the long-term security of the tailings dam, with multiple redundancies to ensure it will not collapse (as has happened at Clarence Colliery).
There needs to be a higher bond on the company for long-term measurement of acid mine drainage and heavy metals and a serious fund to treat this, possibly for decades.
Bowdens have failed to discuss any of these issues. All will have substantial cost and the community should not have to pay the cost.
Yet another concern is the relocation of the powerline. Moving the line a mere 100 metres from the original proposed route does not address any of the objections made previously. The power line will still have an enormous impact on the visual amenity of the region which is a major tourist destination. Bowdens’ statement that only four landholders are affected is simply wrong.
The power line realignment will result in the removal of Box Gum Woodland, a threatened ecological community, of which only 5% remains in the Central West, thus making every hectare precious. We cannot afford to lose any more.
This submission is written in haste because of the incredibly short timeframe – a mere two weeks – allowed for community response. We therefore do not have time to properly reference the points we make. However, we are aware of experts in the field who will be submitting detailed referenced submissions which will corroborate the points made here.
Yours sincerely

Fiona Sim (President)
on behalf of Running Stream Water Users Association

A mine must have a secure water supply to operate. A cobbled together collection of rainfall and runoff, harvestable rights, creek water and bore water is not a secure water supply. This mine must be assessed as unviable and the application refused.
Bowdens have said for many years that they have enough water licenses to supply their mine site and keep the water within the small mine site area. Well… they have access to almost half the water in the state via the aquifers which lie under their site. These licenses were not secured prior to the EIS, as we were led to believe, and are not confirmed as they are in a recent release by the department. There is no evidence that Bowdens hold these licenses or entitlements and they do not have any water approvals to pump this water.
There are reports and evidence to support the conclusion that Bowdens will take water at the expense of other users. In fact they say themselves that other water users will be protected by the law. Do we presume that means they will happily pay the fines to the regulator when they pump more water than they should. Why should the regulator or the NSW Government be required to police these invaders? Bowdens might as well, like Putin, send the tanks in to destroy Lue. It will be the same end result.

In regard to the above project I would like to object about the water retention on site, the building of the huge dam which will contain hazardous chemicals that will be stored
on site, this is contrary to the original submission. This storage also can be a danger to the local creek and river systems as well local pasture if any water escapes from the storage dam.
Not only are they planning this water storage dam they are also planning a huge bore of somewhere between 300-400 mt. deep which place it into the large aquifer within the artesian basin which will probably take decades to replace if ever.
The fact that silver mining requires the use of cyanide for the silver to be extracted can also be fraught with danger to humans and animals if the slightest accident because
of it's hazardous nature.
Finally the fact that Bowden's refuse to rehabilitate the whole site from the open cut mine to the hazardous tailings dam is nothing short of environmental vandalism, as a lot of the old open cut mine within our area is being or has been remediated and this just shows that they are not really interested in the local community of LUE

The Bowdens submission and water report appears flawed and cannot be relied upon for reasons set out in the attached report prepared by an independent environmental auditor. This report was prepared in the short time available for submissions. Further work by this and other experts would no doubt reveal more serious concerns with the project.
The short exhibition and submission process will not ensure a balanced evaluation of Bowdens' amendments and claims of negligible impact.
The availability of water is fundamental to the project's viability and is a critical ongoing risk to the surrounding and downstream lands, farms, communities and environment. An exhibition period of only 2 weeks is far too short to evaluate and respond to a brand new report that miraculously confirms 'hey, actually all the water we need is available locally after all and moreover there are only negligible impacts of us taking it'! How can this be credible? Bowdens have submitted one view. They have not submitted much of a sensitivity analysis or differing views on consequences if this single report is wrong or actual circumstances are worse than forecast. For example, what would have been all the consequences had they taken their water needs (increased by a reasonable safety margin) before and during the recent 2 year drought and also for that 2 years hypothetically extended for say another 2 years. The exhibition process should be extended to allow other professional and independent analysis to be performed. Furthermore, the Department of Planning should rigorously audit the accuracy of the underlying assumptions and conclusions of the Bowdens report, assess how realistic they are in the actual circumstances of the area and in particular fully take into account worst case scenarios of drought that are becoming more the norm. A couple of good rain years may improve some averages and some short term looking out the window observations. There are, however, very recent horror stories and photos of the impact of drought and subsequent fires to the community in the immediate and wider area. The mine should not proceed as the risk to water and the consequences of getting it wrong are too great.

Please see attached

Please refer to the attachment

I dont believe the amendment regarding water use by the mine issue addresses the original objection- the amendment is unacceptable

The other issues originally objected to- noise, lead pollution, and effect on value of properties -have not been addressed in the amendment.

I am writing to protest against the proposed Silver mine in Lue.
Mining should not be happening at all ..
I live in this beautiful district and believe the mine would be very destructive to the local water ways.
I don’t believe it can be created without great scarring to the natural environment.
I also don’t want more trucks using the small country roads …. the impact would be horrendous ….

One of my biggest concerns is the huge requirement for water to operate the mine. It absolutely wrong to allow the mine to extract the required water from the above ground landscape or underground sources. Any loss of surface water or underground water is totally wrong. As evident by our previous drought. History shows that it will occur again so we need to keep all the water available during good times to increase the water in the soil profile. It is critical that all the farm land downstream have no natural flow rate reduced so as able to produce healthy food in the future There is also evidence of BSAL land downstream with is the best agricultural land rating which should not be jeopardised under no circumstances Water conservation is a critical concern for future land and stock management and should not be given to a mining project

I object to the mine on the basis of environmental degradation and water use. The Lawson valley catchment cannot support this much water use. It’s already a stressed and fragile water source. This can absolutely not be allowed if there is to be a productive future for the catchment. Loss of native biodiversity is guaranteed of this goes ahead.

I object to the project. The proposed mine will have an unreliable water supply and lead is poisonous for Lue.

7 April 2022 Submission to Dept of Planning, Industry and Environment (DPIE) re Bowdens Silver Project (SSD 5765)- re amended application -pipeline amendment
We are landholders and primary producers (cattle) in the Lue region and continue to vehemently object to Bowdens Silver Projects amended pipeline amendment application to build a Silver Mine in the Lue region. We strongly object to the proposed mine development.
This submission should be read in conjunction with our previous opposition submissions on 27 July 2020 and 16 August, 2021
We ask that you reject the Bowdens Silver Mine application.
In this submission we want to emphasise that we have concerns with-
• Water security
• Increases in local traffic
• Effect of the mine on the Lue natural environment.
• Noise issues.
• Air quality

Re Water Security
The Mid- Western Council in its letter to DPIE on 27 July 2020 made excellent points stating ‘the significant and long term water usage of the Mine is a serious ongoing concern for Council, particularly in light of (recent) drought conditions and rural hardship experienced across the Region. The recent drought has demonstrated that water is a highly valuable resource and Council does not support any potential threat to existing town water supplies or the amount of water available for rural property owners for domestic and agricultural purposes.’

In addition, the original EIS was going to draw up to 5 ML of water a day via the pipeline and now that is all to be managed onsite. We do not believe that the amended EIS adequately caters for contingencies during periods of prolonged drought and the huge demands for water that the mine will require. We are hugely concerned that the mine will be consuming large quantities of local water especially in the 1 ½ year establishment and construction phase. We agree with the Council’s original concerns and still do not feel that the Mine’s pipeline amendment application adequately addresses the local residents water concerns, just purchasing water licenses is not enough. Once the ground water has been used up it is gone forever.

In summary we are extremely concerned that the proposed Mine will have a negative effect on the local ground water available for the local village of Lue and neighbouring farming properties.

Noise, Air and Environment
Despite the Mine’s amended pipeline submission report we continue to be concerned with the effect of the Mine on local traffic, Noise, Dust suppression using large quantities of local water and effect on the air quality and finally the effect of the mine on the local natural environment. Should the Mine go ahead, we know that the Lue village and neighbouring farms will be adversely affected.

We ask that you reject the Mine’s application.

I strongly object to the development of the Bowdens Silver mine near Lue for many reasons. In particular I am concerned with the health of villagers in nearby Lue from the mine’s unavoidable and inevitable multifaceted pollution- including lead, noise, light & increased traffic Also Lawson creek is already under threat in fact it has been 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 will only exacerbate these issues with its high demand for water. This will have far reaching negative implications for town resources, as well as agriculture and farming that the Lawson flows through.
Lead is poisonous for Lue- I’m aware of the disastrous implications lead has on the health of children- working as a paediatric Physio for over 40 years I vehemently oppose any development that will place the health of children in particular and their families at unnecessary risk.

The proposed mine is not feasible in it's current form and should not be approved. Further details on relevant issues is provided in the attached.

I object to this project as building an open lead-mine two kilometres from a primary school and a township it is horrible and terrifying.