Bowdens Silver

See attached letter - the mine is totally unfeasible and detrimental to the water table lands of our area.

Water supply near the head of the Lawson Creek catchment is over the years frequently inadequate to meet the desired level of extraction by existing rural users. The SVL EIS Amendment stating that all the mining and ore concentrate processes required by the proposed activity can be met with water acquired on the subject sites, without impacting on downstream users, is unbelievable. Any form of use of surface or groundwater MUST have an impact on downstream water availability and quality.

See attached letter

I am a local land owner and my family have owned property within Lue for 0ver 20 years. I am sickened that both the naturalistic beauty and the livelihood's of those farmers who call the Lue region home could be hindered by the introduction of Bowden's Silver. The recent amendment would mean that our family farm would lose its water and most likely become worthless. The tranquility and landscape is what brought my family to the region 20 years ago, I hope in my lifetime that more generations are able to see this beautiful part of the Country remain untouched by the silver mine. I ask that you refuse the project on this basis.

As a long-term Lue landowner, I object to the project as I have continually done so. The planned changes do nothing to improve my view of the project.

The reason for my objection is there is no real material change in the visual amenity.

The ongoing irreversible damage to our local community, the disastrous environment impact, the negative impact on the health and wellbeing of both our community and visitors. The tourist destination of the local region would be lost forever with an open cut mine. Our local short stay places that rely on our local work force (cleaners, trades persons, handyman's, builders, gardeners, etc) would no longer have the important work that many in the local community rely on to survive. Our local community would change forever.

The Lawson Creek is already listed in the NSW Stressed River Assessment. The impact of poisonous lead in the air and the spill of acid forming rock from the TSF into the Lawson Creek would be an almost certain environmental and health disaster.

Water availability is very limited in the area already so the Bowdens Mine would only make the current situation worse. It seems that they are happy to ignore all the years of drought we have suffered. The updated view of the Power Lines is no real material change as it would still destroy what we see. The local community and, more importantly our tourists do not want to look at ugly power lines or an open cut mine.

Even Bowden's are not stating the mine as an 'environmentally and socially sound project'. If the mine was to go ahead then I feel it's a disaster waiting to happen environmentally and would almost certainly turn out beautiful land and community into a mining ghost town.

A great project for our region only made better by the proposed amendments.

Please see attached objections given to me by people in the last few days. It was too late to post them to you so I've included them on my portal

Re: Bowdens Silver Project (SSD 5765) – Request for Water Supply Amendment
Lacking Appropriate Community Notification & Consultation
It is very convenient for Bowdens to put this significant project change through as an amendment. It was this very aspect of the project that caused Mid-Western Regional Council to originally reject this project based on the high volume of water needed. This is far from an amendment, but rather a completely different application and as such requires much greater attention. Using the amendment process lacks transparency and rigor.

To take this water from ground and surface water in this region will have immense and far-reaching impact. With such impact, there needs to be appropriate community consultation with ALL the immediate stakeholders and broader community, who will also become impacted stakeholders, due to the knock-on effects.

The inadequate community consultation suggests improper measures are being taken by Bowdens to expediently attain the approval by the DPIE. By their own admission in the document titled Re: Bowdens Silver Project (SSD 5765) – Request for Water Supply Amendment, Nick Warren, Principal Environmental Consultant, says “Bowdens Silver appreciates that this further amendment is a change to the Project as it was presented to the community,” and goes onto to say that they are in the process of undertaking community consultation.
Thus, if still in the process of undertaking community consultation ………clearly the appropriate consultation has not been done. This being the case, this submission close date of 7th April 2022 is woefully inadequate and has NOT allowed the community to be notified with an appropriate response time.
There have been no public meetings, no meetings for discussion and no appropriate community and stakeholder notification. This is completely unacceptable and not in line with the ICAC recommendations.
Some of the directly impacted landholders only received communication early April.
To be fair and reasonable more time is needed for this community and appropriate notification and consultation needs to occur. To be reasonable, the NSW Planning Department need to re-open and extend the submission time and allow for adequate and appropriate community consultation.

It concerns me re the Acid Mine Discharge "AMD"; It would be impossible to guarantee any barriers for permanent retention of any liquid waste. Toxic heavy metals can travel far down stream. Pollution of this kind in a food producing area and in the waterways would have an effect for many years to come. Aquatic life will be affected. There is no sign of the pollution ceasing down stream of the Sunny Corner Silver Mine after 98 years. This project should not be approved.

I OBJECT TO THE AMENDMENT AND PLEASE REFER ATTACHMENT FOR DETAIL.

See attached document

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 brother’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.
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

Wendy Griffits
377 Coal pt rd
Coal pt 2283

I object to this project because it poses a critical, long term threat to our region.
The potential risks of this project significantly outweigh the benefits.
It will leave a toxic legacy in our region forever.
Please see attached.

Employment – Destruction of existing industries – economic loss
No discussion or analysis has been submitted for the destruction of current employment in the region because of this project. The report: Bowdens Silver Project Part 15: Economic Assessment Report No. 429/25 fails to outline the businesses that will be lost and destroyed, should this project go ahead.
This region has a strong agricultural, viniculture, and vibrant tourism industry that employs a significant population. The economic report fails to mention any of these business losses.
The agricultural community have generational farmers that have produced food and fibre for our country for over 100 years. The significance of this contribution and their ongoing contribution has not been noted and accounted for. Furthermore, the mental health implications this generates has not been considered.
The vibrant tourism industry both directly and indirectly employs people in Lue, Rylstone, Kandos and Mudgee.
Diversity in employment strengthens community and the economy. A mining project takes away this diversity and economic strength.

There are so many things that are wrong with this proposal that it is hard to know where to start but here goes.
There is just not enough water
There is simply not enough water in the area to support a mine without having a highly detrimental impact upon the environment and surrounding farming land. In other words, the mine is in the wrong place.
Lawson Creek is listed in the NSW Stressed Rivers Assessment in the most stressed category (S1) – with both high environmental stress and a high extraction rate.
It is more often than not a series of water holes with no visible flow during summer.
Mines dig big holes in the ground which have a massively detrimental effect on ground water. In the area that Bowdens proposes to mine, the ground and surface water systems are highly connected within the area. There are many springs that are the lifeblood for many humans, plants and animals in the area.
Talk to anyone who lives around Lue and they will tell you a lot of bores in the area do not function in Lue village in dry times now – this is indicative of how impractical it is to believe that Bowdens can find sufficient water locally to run the mine not to mention the consequences for all those surrounding the mine when their water supplies further dry up. The groundwater here also provides the baseflows further downstream. It can only further stress the waterways and disadvantage all who rely on that water.
On top of this there is climate change which will make droughts more frequent, more severe and longer in duration.
Bowdens would have you believe otherwise but putting it simply, the company is fudging the figures. Everyone who lives in the area knows that the Lue district is in a rain shadow and gets less rain in total and fewer days of any rain than Mudgee or Rylstone, yet Bowdens would have you believe this is not the case.
For a start, the company has used average rainfall which is problematic as this area does get years that are very, very wet but also very, very dry. A more accurate assessment would use the median rainfall which comes in at 635 and 656 mm/a respectively. In addition, the 20th percentile for Rylstone and Mudgee are 509mm/a and 494 mm/a respectively. Put another way, one in every five years, the climatic conditions between Rylstone and Mudgee, which covers the proposed mine site, are semi-arid. Any loss of available water in these years would severely impact the land and the people, plants and animals trying to survive on it.

Water quality
The presence of a tailings dam on the river system and the technology Bowdens proposes to use to process the ore present an unacceptable risk to water quality. The risk of acid forming materials leaching out of containment areas is a potential source of contamination. There is also the risk that the tailings dam could be breached or overtopped. On Boxing Day 2021, a storm went through the Lue area which dropped 100 mm of rain in less than an hour causing massive damage. Should such a storm impact upon a tailings dam Failure of the dam wall would have catastrophic consequences that would have irreversible impacts on the community's health, agricultural production and natural resources.
The risk of contamination is unacceptably high and the proposal should not be approved.
As an aside, the fact that Bowdens are not looking to use heap leaching to process the ore suggests that its claim to environmental best practice is demonstrably false as this process does not require a tailings dam.

Health
The WHO has determined the safe level of lead in the environment is zero. While Bowdens calls itself a silver mine, it will mostly be extracting lead and nickel with silver as a by-product.
The is close to Lue village, Rylstone and Mudgee. It will produce dust that is contaminated with cyanide and heavy metals including lead and cadmium. During drought years the tailings dam will be drawn down for day-to-day operations exposing tailings to wind and leading to more toxic dust being spread over the surrounding area.
As I have noted above, there is not enough water for the mine and this lack of reliable supply – especially during drought years – will impact on Bowdens ability to undertake dust mitigation by spraying roads, ore piles etc.
It is just wrong to lob into an area characterised by agricultural land and relatively pristine bush and start digging it up which spreads toxic dust everywhere. This mine should not be approved.

Visual impact
Bowdens propose to realign Transgrid’s 500kV transmission line. The new route would be highly visible as it follows a ridge line and is 500 m closer to Lue village. This would undermine the peaceful rural character of the area and is a form of visual pollution.

Traffic
Bowdens propose to use B-doubles to truck concentrate north to a rail line. Lue Road may be gazetted as a B-double road but this was intended for the occasional stock truck, not for multiple daily trucks heavily laden with lead, nickel and silver concentrate. The road is narrow, windy in parts and lightly constructed with few opportunities for cars to pass slow moving B-doubles. The malfunction of a load cover also presents the risk of spreading contaminating material from one end of the road to the other which is an unacceptable risk to public health.

Economic viability
Lue is a pretty little village that is in the midst of developing a tourist industry as it becomes a stopping point on the road between Rylstone and Mudgee. The proposed mine would spoil the peaceful rural feel of the village and risks the viability of Lue Primary School as its operation impacts upon the noise, air, water quality and visual amenity of the area. People living in the area have seen this happen with Wollar village. In addition, young children in particular are more vulnerable than adults to lead poisoning and this risk in itself should be enough to reject the mine.
While Bowdens are attracted to the area by high metals prices, the fact remains this is a small deposit; the company estimates the life of the mine to be only 15 years while the destruction wrought on the neighbouring lands, people, plants and animals will last forever.
The project is not “an environmentally and socially sound project” as Bowdens claims, it is a toxic waste dump that will destroy the water resources of the surrounding area forever.
This mine should not be allowed to proceed.

I originally objected to the project and am making another object in addition to my original submission. The second submission was precipitated by the amendments proposed by Bowdens.
My areas of concern are:-
1. Insufficient groundwater available for the mine to proceed without creating shortages to primary production in the local area.
2. Depletion of all waters downstream of the mine
3. Ongoing acid mine drainage during and after the life of the mine. Key risk is that Bowdens has totally ignored the problem of AMD and heavy metal pollution. The EIS fails even to mention it.
4. The use of cyanide in the extraction of metals from the base ores
5. Hazards of lead dust to local residents, especially children
6. Proximity to Lue village
7. The fact that it is being marketed as a silver mine when in fact lead is the primary metal being mined and processed.
8. Lawson Creek is listed in the NSW Stressed Rivers Assessment in the most stressed category (S1) – with both
high environmental stress and a high extraction rate
9. The amount of electricity used in this project will place more demand on fossil fuel fired power station and will have a cumulative impact of global warming.
10. The removal of the original water source, ie piped in from local coal mines, is further proof that the original proposal recognized that there is insufficient local water available for the project. Why should the amendment be approved without a source of water being utilised other than the stressed local groundwater reserves.
11. November 2019 Impact Assessment Outcomes "In order to maintain a regular water supply, it is also proposed to source water for the project from Ulan/ Moolarben Coals mines. As a result, the Project would place no additional demand on local and regional water resources" This is now not the case and as such the mine should not be permitted to proceed in any circumstance. Water is life and the lifeblood of the existing communities around Lue.
12. Noise and dust pollution. Due to the low average rainfall at Lue dust will become a major issue. The sources include the mine itself, denuded country side, dam sites, dam walls, dry creek beds (that will proliferate), access roads and the increased vehicular traffic.

Water –

There are many statements made in the ‘Summary of Assessment Outcomes - EIS and Amended Project’ in relation to water impacts which are incorrect.
The proposal to use water sources from within the Bowdens’ land holdings to supply the water for the proposed mine is fundamentally flawed. The extreme dry periods experienced by the landholders within the Lue region indicate that it is inconceivable that there is sufficient water to supply both mine and landholders. The surface water assessment has failed to properly consider the dry periods, such as experienced in 2018-2019. These years saw insufficient water for the existing industries, little only the vast volume required by a Lead & Silver mine.
The surface water assessment relies on invalid data, inappropriate modelling and contains misleading statements. With water being such a critical factor for both the community and viability of the project, it is important to have a rigorous assessment.
Groundwater is a valuable resource for lands within the Lawson Creek catchment. The loss of this resource due to the proposed mine is unacceptable.
Water is our most valuable and precious resource. This was clearly demonstrated in the 2019-2020 Black Summer Bushfires where our region suffered terrible losses with the 2018-2019 drought and the subsequent Black Summer Fires. The Amendment which proposes to greatly impact the water for the Lue region and all downstream, does not appear to consider the value of the Water to our region.
I refer you to the independent Report: Water –

There are many statements made in the ‘Summary of Assessment Outcomes - EIS and Amended Project’ in relation to water impacts which are incorrect.
The proposal to use water sources from within the Bowdens’ land holdings to supply the water for the proposed mine is fundamentally flawed. The extreme dry periods experienced by the landholders within the Lue region indicate that it is inconceivable that there is sufficient water to supply both mine and landholders. The surface water assessment has failed to properly consider the dry periods, such as experienced in 2018-2019. These years saw insufficient water for the existing industries, little only the vast volume required by a Lead & Silver mine.
The surface water assessment relies on invalid data, inappropriate modelling and contains misleading statements. With water being such a critical factor for both the community and viability of the project, it is important to have a rigorous assessment.
Groundwater is a valuable resource for lands within the Lawson Creek catchment. The loss of this resource due to the proposed mine is unacceptable.
Water is our most valuable and precious resource. This was clearly demonstrated in the 2019-2020 Black Summer Bushfires where our region suffered terrible losses with the 2018-2019 drought and the subsequent Black Summer Fires. The Amendment which proposes to greatly impact the water for the Lue region and all downstream, does not appear to consider the value of the Water to our region.
I refer you to the independent Report: Bowden’s Water Pipeline Amendment - analysis of updated surface water assessment, attached, which covers off comprehensively on the water issues of this amendment of the proposed project.
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The community health and well-being will be greatly negatively impacted with this proposal.
The lead and open min proposal impacts their health and the health of generations to come.
The tourism industry will be negatively impacted by the loss of productivity for the wineries in this community
And the world renound wool producers will be negatively impacted by the loss of water and environmental impact to the region
No to this proposal

I believe it to be outrageous and disgusting that as a member of the outlying community of Olinda that I wasn’t notified of the huge amendments being put forward. To discover that the full EIS was submitted in May 2020 during the pandemic crisis where the whole community and country was stressed and anxious about their survival. Giving everyone no time digest a 746 page EIS that would require specialist people to help with analysis of the report.
Having a quick look at EIS – Project Objectives point 2. To undertake all activities in an environmentally and socially responsible manner to demonstrate compliance with relevant criteria and satisfy reasonable community expectations
As we have experienced so far that the environmental consideration have not been met in relation to potential huge water losses to areas , impacts to native flora and fauna due to drying up of the
Local environment and loss of income to farmers downstream due reduction in water runoff and subsurface movement from onsite storage of surface water and drilling to access underground water.
Social responsibility dealing with mental and physical health impacts haven’t been considered. Eg impact from a 24/7 processing and maintenance, potentially 24/7 mining subject to noise based on what they say is acceptable not what people say in tolerable for their families. Blasting, trucking of concentrate, building the embankment is Monday to Saturday 10am -4pm all within 2.6km from school for 23yr. How is this right?
Trucks going passed school all day carrying toxic mining concentrate. How will they guarantee the trucks staying 100%sealed from releasing toxic chemicals/particulates into school yard potentially killing innocent children for the life of the mine? They can’t. Millions of tonnes per year. Can the DPIE guarantee the immediate community and myself as a commuter passing through town to go shopping or a tourist going between towns by push bike that for our immediate and or long term health is not compromised ?
Another health concern is the removal of water from tailings dam to compliment their water needs that lack of moisture in dam means potential dust into air affecting human health. Dust entering the domestic water supply via roof water. Can this be guaranteed not to happen No it can’t
Given all the risks associated with this project from catastrophic downstream contamination , poisoning of the local community, loss of drought Resilence due to water loss, potential catastrophic fire risk due environmental changes, mental health issues caused by noise, toxins and the constant haulage by road of mining concentrate across the country causing risk to life and damage to infrastructure. It should be allowed to proceed. It should be shut down. It’s corporate greed
Point number 7. Achieve the above objectives in a cost effective manner to ensure the Bowdens silver project is economically viable. Which means spend the least amount of money possible and get away with whatever we can. Because we know that for corporations paying the fine is cheaper than doing the right thing.
Once the mine has ceased to be viable how are they going to deal with decontamination of the tailings dam and toxic stockpile? History has shown us that they don’t care, they will just walk away or do as little as possible or have no money left to complete rehabilitation of the site .
As per the EIS
The nature of the project dictates, however, that the disturbed areas associated with the main open cut pit, processing area and tailings storage facility would remain active throughout the mine life and, as a consequence, the opportunity to undertake progressive rehabilitation of these components would be minimal.
The issue of rehabilitation to these areas after the mining has ceased need to be addressed now and to think that there will be no chance of leakage and or water contamination is impossible
Based on the impacts to water loss and environmental contamination and health impacts this project needs to be shut down. Please help us
please find attached mid Western councils in the main disapproval of the mine with emphasis on the need to protect water

The proponent has not provided adequate information to support their claims sufficient water supply has been secured to support mining during extended dry periods, or will be able to effectively manage water runoff during extreme rainfall events necessary to avoid the pollution of streams and groundwater system during operations and post mining.

The reliance on advance groundwater dewatering when storage dams are likely to fail during extended dry periods provides a false sense of security. During these critical times of regional water shortage any further lowering of groundwater levels and associated loss of baseflow to local streams imposes an unacceptable risk to the environment and other water users.

The proponent’s assessment of climate change scenarios and implications for the final void pit rely on average monthly and annual datasets. This does not adequately consider for example the risk of extreme daily rainfall events on a wet catchment. WRM s claim that it is ‘unlikely” receiving waters will be impacted by “seepage, leachate and runoff’ … from the PAF material either during operations or after closure and decommissioning “ (WRM_ 6-131) does little to reassure downstream water users.

The reality of a changing climate increases the frequency of extreme events of < 1 percentile probability. This requires greater analysis and testing of the proposed response management plan; the identification of appropriate trigger values to detect trends and initiate effective and timely response actions when impacts are identified, backed up with substantial bonds to cover post mining pollution events and rehabilitation.

The history of silver-lead mining tells us there is a serious long term risk of groundwater pollution by toxic metals and acid mine drainage (AMD). This likelihood has not been fully scrutinised or adequately investigated in the EIS.

Bowdens Silver states their decision is to “defer the option to use a pipeline to supply water to the Mine Site” sourced from the Ulan coal mines. “Defer” indicates they may revisit this option in the future – any approval must not depend on this as a back-door solution if provision of adequate water supply predictions prove inadequate.