Bowdens Silver

Submission to DPIE addressing Bowden Silver's Amendment and other issues.

This “amendment” has been called “minor” by Bowdens. It is NOT minor. In fact “water” is the most precious of our resources. Without it none of the inhabitants of the region would be able to make a living let alone survive. Water sustains life to the environment in which we live, work and play alongside the wombats, wallabies, kangaroos and other fauna and fauna – it sustains our only habitat. Hence this being defined as an amendment is a falsehood. It qualitatively changes the original proposal and undermines the original EIS.

Lue is a semi-arid region. In 2022, like most of the Australian east coast, we have had plenty of rain and the country looks anywhere between luscious and green to water-logged. However, only 3 years ago all the dams on my and my neighbours properties were empty clay pans as I scanned the horizon at night and waited for the Gosper's Mountain megafire to consume my town, my home, my farm, my horses. The only protection I had during that time was my bore from which I had pumped water, filling a large tank in preparation to protect my home.


Groundwater
The misleading thing about this self described “minor” amendment submitted by Bowden's Silver is that those of us who are “upstream” will not experience a loss to groundwater. Not so. Anyone with a bore knows that water levels are a “table” and that during times of drought the table drops, as it did during the 2017, 2018, 2019 years. Not only did my bore water level drop, it had higher concentrates of calcium and iron. That being the case I find it astonishing that Bowden's propose to mine lead within a catchment where water is marginal a lot of the time. The problems arise not in times when water is plentiful (although freak weather events of the nature of Lismore would endanger life if the tailings dam overflowed into local waterways) but when it is dry, which the overwhelming majority of scientists are predicting will become a more regular occurrence. How are the lead particles to be damped down so as not to contaminate the community's air, roads, the employees clothes and vehicles etc? Do the community have a veto to close the mine's operation during such times? Will it be up to the community to engage an independent monitor and if so who pays for that? If Bowden's “self monitoring” contradicts the findings of alternative monitoring of lead levels in the air, and there are litigation costs involved, who pays for that? These factors are not addressed in the project proposal.




Where is the evidence in the EIS of Community Consultation?
The EIS states

“It is intended that silver/lead concentrate would be transported in sealed containers by road to either Parkes or Kelso and then transported by rail to the smelter at Port Pirie in South Australia, while zinc concentrate would be transported by road in sealed containers to either the Port of Newcastle or Port Botany for export and smelting off-shore”


While Bowden's state that there has been “extensive community consultation” regarding the project I have yet to meet a person in Rylstone (assuming trucks laden with lead ore would be thundering on mass through the booming tourist town of Rylstone en route to Kelso) who has any idea that this proposal is being put to DPIE as part of the project application. The same applies to transport to Parkes which presumably would go through Mudgee with it's booming tourist/eco-tourist trade. What consultation has been attempted to inform the vineyards, al fresco cafe owners, art and antique shops, cyclists, park runners, tour operators that trucks laden with lead will be thundering through the town on route to Parkes? There doesn't appear to be any evidence that these consultations have been undertaken.

Effects of Proposal on Mental Health of Lue and surrounds
The proposal to mine silver, lead and zinc at Lue has been hanging over the heads of Lue community 30 years. The fact that people's lives have been subjected to this uncertainty for so many years is unconscionable. Research studies abound on the effects of mining proposals on rural communities.
Evidence shows that the announcement of a mining proposal can result in psychological stress1 Most notably this was seen due to uncertainty with regard to succession planning (as often happens within farming families where the farm is handed down from generation to generation), uncertainty surrounding medium to long term investment in infrastructure, and the strain these place within family relationships1. Tensions also arose between neighbours where those who were closer to the proposed development area were most affected in that they were at risk of losing their farm, and those who's land value was diminished, depending on whether it fell inside the mining proposal, the buffer zone or adjacent to it. “The fact that there are some who are going to sell and be well compensated and some who aren't....it means for those who aren't, their property values go down if it's next to a mine, so they are forced to go”1(p67). This was believed to fracture the community and the divisions utilised by some mining companies1.These divisions had carry over effects into other social domains. For example, at school where the children of farmers directly impacted were at odds with children whose families were less affected, or those whose families saw opportunity in gaining employment in mining1.
Social tensions were also reflective of attachment to the land itself, its horizons, and aesthetics. At the time of the study, the proposal had been underway for two years with no movement, compounding the sense of powerless1. This sense of loss of ability to have influence, or loss of agency and locus of control is a well known contributor to depression2.
This psycho-social stress has been experienced by the community and its surrounding population since the announcement of Bowden's proposal as demonstrated by the following quote:
“We don't need a mine – our tourist industry is booming – there's no shortage of jobs, it's the opposite, it's hard to find workers who are able to fill positions..” Tourist operator

Conclusion
The KEPCO mining proposal destroyed the town of Bylong long before a sod of soil was turned. The social fabric of the community was shredded. Young families left, the school closed, the shop closed. The much trumpeted KEPCO mine for all it's expenditure acquiring land, talking up about the potential for jobs creation and state revenue income was not deemed viable because (in addition to other considerations) it would deplete precious water reserves. Bowden's Silver/Lead mine is another such project.

References
1. Moffatt J, Baker P. Farmers, mining and mental health: the impact on a farming community when a mine is proposed. Rural Society. 2013;23(1):60-74, DOI: 10.5172/rsj.2013.23.1.60.

2. Berry HL, Hogan A, Owen J, Rickwood D, Fragar L. Climate change and farmers’ mental health: Risks and responses. Asia-Pacific Journal of Public Health. 2011;23:119S–32S. doi:10.1177/1010539510392556.

This major project will take up all the ground water for all the surrounding areas and spread lead dust into the air around Lue

I object to the Bowdens Silver project (SSD-5765) (“the project”, “the proposed mine”, “the mine”) on the basis that the proposed mine will create multiple negative externalities to current land holders and the environment with no net benefit to the state or the community.
Bowdens Silver’s (“the company”) assessment for strategic importance of the project is greatly exaggerated, silver is not a scarce resource and recent prices increases are the result of speculation rather than substantial increases industrial demand (2021 Silver Survey). The global silver markets have been in supply surplus for five consecutive years with LBMA, Comex, SGE and SHFE holding a cumulative 1702.3 million ounces of silver (more than one year’s demand) as price control for oversupply. Lower cost producers particularly in Mexico and Peru currently have established projects in care and maintenance mode and any sustained increase in the price of silver would bring these mines back online creating supply in the market. The company points to the assumption of a US$20 per ounce silver price during the feasibility study as testament to the strength of the project but failed adequately explain the effects of current inflation levels in particular substantial increases to the costs of inputs (diesel, energy, mining equipment) all of which fall well outside the models commissioned by the company. The models also failed to account for the current increase in corporate debt rates which have risen significantly since the original studies meaning funding options the company outlined are no longer adequate. Anyone of these factors would be cause for concern for a project highly dependent on elevated commodity price levels. Obviously, this brings into question why a company would proceed with their application despite a clear uncertainty on the project being a going concern? A cynic would point to the levels of executive compensation specifically the release of options based on the mine’s approval, not earnings.
In the latest amendment to application SSD-5765 - Water Supply Amendment Report, the use ground water to supply continued operations borders on farcical. The company has not shown in amendment that they will be able to meet ongoing water requirements from harvestable water particularly in times of drought when dam evaporation is high. In an extended drought when harvestable water is depleted the projects only source of water then becomes ground water. The basic land holder rights established in the Water Management Act 2000 made domestic and stock water a public good (albeit a somewhat impure one) for landowners overlaying an aquifer. The company and the department will state that usage is monitored and that usage in of excess entitlement will be subject to a fine. For an entity where recourse is limited a fine becomes a business expense. There are many examples of this practice in the mining industry, Rio Tinto’s destruction of Juukan Gorge caves is the well-known recent example. This creates where excessive usage of groundwater is achievable by paying a fee (fine). The public good available to land holders then becomes excludible and rivalrous or in other words a private good. Should approval be granted based on this amendment, the department will have granted an implied privatisation of the aquifer creating a negative externality for stock and domestic users of the aquifer.
Mining has provided significant benefits in NSW whereby the marginal social benefit has far exceeded the marginal social benefit in most situations. This project will create enormous social cost for little social benefit. If approval is granted and the mine commences operation the margins of the project are so slim that jobs in the community will be dependent on commodity already oversupplied and reliant on speculation in commodity markets. In the unlikely situation where the global economic conditions allow for ongoing operation throughout the life of the mine the negative externalities on land holders and the community far outweigh any perceived benefit. Enterprise is under no obligation to create solutions for these costs and then the responsibility for rectification will fall on the government.

Water-Air-Noise-Health

The health issues that the proposed Bowdens Lead-Silver Mine presents are monumental

The “Water amendment” completely changes the project. Such a major amendment demands a whole new application. A new development application needs to allow 3 months of time for community consultation. It is reprehensible that this “amendment” be allowed as such, and not go through the rigor of a new application. The mental anguish caused by this major amendment is a huge cost to our community. The seemingly deliberate disregard for community notification and consultation suggests underhanded elements at play.

Water is critical for all aspects of the community, the environment, tourism and the existing primary industries. Both the potential lack of, and pollution of, the surface and ground water are unacceptable risks. Mid-Western Regional Council have outlined on 27/7/2020 the concerns that this project presents regarding water. This recent “amendment” intensifies these concerns. Interfering with the ground water will be irreversible. Polluting the water supply will also be irreversible.

Tailings dams ultimately fail. With the recent weather events causing major flooding in our region, a tailings dam with its’ contaminates would have flooded and spilled into the surrounding waterways. This won’t be the last weather event. There are many other tailing dam environmental disasters and this, should this project go ahead will be another one – there is absolutely nothing to mitigate disasters arising from these now more common weather events.

Dust from the mining operation will pollute the air and the surfaces, ultimately polluting the water. Most residents harvest their drinking water from roof surfaces, which, with this project, will be contaminated with Lead, amongst other things. We are encouraged to take the lead out of petroleum for our vehicles, how do you justify adding lead to the air and the drinking water. It is inconceivable that in this day, and age, we would be having this discussion. Again, it suggests underhandedness, as I find it difficult to believe that this is not common sense.

Noise pollution from basting that goes from 10am to 4pm 6 days a week 2km from the local school can hardly be considered healthy. This project has extraordinary aspect that are completely unacceptable.

The EIS, a 746 page document, released in 2020 during COVID lockdown, when community could not come together and decipher the extent of this project, further disadvantages an overwhelmed community exasperating mental health issues.

I object to the Bowden’s Silver Mine for the following reasons:

1. The site does not have sufficient water
The town of Lue, Mudgee, Rylstone, and surrounds cannot afford to sacrifice water from the Lawson Creek for this project.
Lawson Creek is already considered at the extreme rating of ‘highly stressed’ by the NSW Stressed Rivers Assessment.

2. Toxic dust
If water is taken from a tailings dam, there is a high chance of exposure to toxic dust as the water is extracted. If there is a wind event this toxic dust will be spread in the air and adversely affect human and animal health.

3. Dust mine
A mine that does not have enough water will not be able to mitigate or supress the movement of dust through actions such as, spraying the roads with water. During times of drought and wind, this will be deleterious for all of us in the Central West area and beyond.

4. Affect on Lawson Creek catchment
The mine’s massive daily usage of water will reduce the Lawson Creek catchment and thus negatively impact everyone who live downstream of the mine.

5. Acid mine drainage
According to Dr Haydn Washington, a former CSIRO Scientist, specialising in acid mine drainage and heavy metal pollution, 30 million tonnes of sulphide is ore is planned to be mined at the Lue Bowden Silver Mine. According to Dr. Washington, when sulphide is exposed to water and oxygen, acid mine drainage is created which is highly toxic with heavy metals. Even at low levels acid mine drainage is lethal to any aquatic life i.e. fish. This pollution will remain for hundreds of years detrimentally affecting human and animal health.

I whole heartedly disapprove of any project that has such devastating effects on the environment. I have a 10-year-old son and I therefore have a responsibility to protect his future. I am also a WIRES carer, and I am passionate about protecting native fauna that also rely on a healthy environment.

It is for the above reasons I do not approve of the Bowden’s Silver Mine Water Pipeline Amendment (SSD-10371-Mod-1).

Our water resources are precious . We live in a dry environment and the last thing we want is a mine requiring 1788 megalitres per year to operate.

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