Bowdens Silver Project 2020 - Objection

My name is Clare Hamilton, I am a partner in a commercial agricultural business in the Lue-Rylstone area where my family has been involved in the production of food and fibre since 1920. I am also employed by Central Tablelands Local Land Services as the Manager of Biosecurity and Emergency Services, having previously worked in natural resource and water management across the central tablelands region of NSW. Our agricultural business has 2 full-time employees and employs several contractors across the year including shearers, agronomists and plant and machinery operators. Over the 32 years that I have lived on our property I have contributed to the remediation of environmental issues on our farm and across the district; worked with neighbours and community groups to increase the welfare and spirit of our community; and raised 3 children who have plans to continue farming our property.
I oppose the Bowdens Silver Project because it threatens all of this!

I have read the EIS Bowdens Silver Project 2020 and respectfully ask the NSW Government to REJECT the application.

I am opposed to the Bowden Silver Project on the grounds of the following:
Unacceptable health impacts
• The village of Lue with its primary school is only 1.9km from the mining operation. The proposed mining operations will cause high levels of lead in airborne dust, which we know is absorbed by the human body.
• The EIS underestimates community exposure and does not look at dust transmission pathways to the village or validate the EIS conclusions. It also fails to take into account community dust exposure levels from stockpiles, ore grinding and handling, concentrate plant and tailings facilities.
• No data is provided for arsenic bioaccessibility
• Out of date compliance levels for acceptable community exposure are referenced in the EIS.
• We know young children are the most at risk from lead poisoning, it has irreversible neurological and behavioural. The Bowden Silver Project will put our future generations at significant risk – no level of lead exposure is considered safe.
• Noise issues are not well addressed in the EIS. And when addressed are extremely conservative when compared to representative plant types at other mines.

Mining operations
• The EIS does not adequately address the risks associated with blasting and transport of explosives.
• The design does not adequately address the concern about the thousands of tonnes of toxic chemicals that will end up in the tailings storage facility.
• There are no contingencies for leakage from the Tailings Storage Facility
• Post mining rehabilitation is totally unsatisfactory for a mine that produces such high levels of toxic material. The miners can walk away, but the community and environment cannot.
• Increased traffic on local roads is of concern. Many businesses such as our regularly moves livestock across the Lue Road and the roads are busy with tourist and local traffic. The roads are also narrow and have restrictions for B-Doubles clearly showing they are not suited to the movement of large quantities of material from mines.
Water
• Water demand can only be achieved by transferring water from Ulan and or Moolarben Coal mines, both of which are in the Hunter River system, while Lue is in the Murray Darling Basin. There is no approval for water transfer across these catchments.
• With the pressure currently being experienced by the environments of the Murray Darling Basin it would be unconscionable to transfer highly contaminated water from another mining operation into the upper reaches of the Basin.
• There is no clarity on how Bowdens Silver will manage the leachate dam when the mine closes. This poses an enormous risk to the Lawson Creek and other waterways downstream of the mine. It also puts a large number of farming enterprises at risk along Lawson Creek.
• There is no consideration of seepage of contaminated water into ground and surface water systems.
• Our agricultural production is dependent on surface and ground water which will be directly threatened by the Bowden Silver Project. Contaminated water has grave consequences in the food-chain and can also impact on our ability to export agricultural produce.
Ecology
• Our district has the great fortune to be the home of a number of threatened species including the Swift Parrot and Koala. Of great concern is Bowden Silver Projects inability to address the impacts on the ecology of the area.
• There is no assessment for koala populations.
• The presence of a number of EPBC Listed species is not adequately dealt with.
• Lack of adequate assessment of threatened species habitat such as hollows and recent bushfire impacts
• Best practice guidelines for light pollution impacts on nocturnal species are not considered.
• There is no thorough review of the Grassy Woodland Community Threatened Ecological Community in the regional or local context. This is an area where significant remediation and investment has been undertaken by the community over many years.
Community
• There is no guarantee that any jobs created as a result of the Bowdens Silver Project will be available to the people who stand to lose the most from this project. Adjoining land holders, people in the village of Lue and the broader community are unlikely to fill most jobs.
• The Bowdens Silver project is estimated to operate for under 20 years. During this time, it is likely to devastate the community of Lue and the surrounding district. We have seen this same thing happen at Wollar in other sites. The short-term economic gain for a few outside the area is not worth the cost to our community. Bowdens Silver Project is a short term, inequitable result for our community.
• The Lue-Rylstone-Mudgee district currently has a balance of agriculture, mining and tourism all of which plays an important part in a balanced economy. Bowdens Silver Project does not have a place in this mix. It is short term focused with a lasting negative impact producing toxic lead just kilometers from a village and primary school, it is situated in one of our important environments for threatened species and communities and it threatens a number of significant commercial agricultural businesses.
I have read the EIS Bowdens Silver Project 2020 and respectfully ask the NSW Government to dismiss the application.

Clare Hamilton
0428 791 359

Bowdens Silver Mine

I strongly object to the proposed Silver Mine at Lue. As a former resident of the Lue community who lived on the Pyangle Rd I have witnessed first hand the appalling impact this proposed mine has had on the cohesion and very social fabric of this once tight knit community.
The project from its initial proposal back in 2011 by Kingsgate has been flawed due to the basic fact that it is too close to the village of Lue and its surrounding properties. The risks inherent in a silver mine that produces 99% heavy metals of zinc and lead and 1% silver is great.
The array of risk factors include but aren’t limited to Lead Dust covering the village , contamination of the Lawson Creek, contamination of the drinking water in the village of Lue, noise and light pollution form the mine itself, devastation of the water table and increased traffic along the already dangerous Lue Road, the presence of a tailings dam filled with toxic waste would be an enormous risk to the environment. These risks are all exacerbated by the fact that Silver Mines Limited have never owned or operated a mine before.
This mine will have a devastating impact on the community of Lue -likely to go the way of Wollar and become a ghost town. What a travesty if 140 years of history is destroyed because of a ill conceived project is allowed to proceed.

My property, East Ridge, is situated to the east of the mine site with the farm house approximately 3 kilometres from the site boundary.

I am very concerned that dust from the mine site will contaminate my drinking water which is collected from the house and shed roofs. Any heavy metal contamination will pollute our drinking water. This will affect my health, my wife’s health and the health of our grandsons and any visitors to the property.
Contamination of my drinking water will make my property uninhabitable and greatly reduce the value of the property

I am concerned that any airborne contaminants, particularly lead will affect my olive grove and render the business unviable. The business was established in 2003 and consistently produces award winning olive oils every year. Any detectable levels of lead or other heavy metals in the Extra Virgin Olive Oil from our grove would make the oil unsaleable, thus effectively closing the business.
The property value will decrease considerably if the olive grove is no longer viable.

My property, East Ridge, is currently in an area zoned general rural and part of its attractiveness is the relative peace and quiet afforded by its isolation and outlook.
Noise from the site will be a significant factor in the amenity of the area. Modelling may suggest that the noise, particularly at night, will be very low but to the human ear, the current level of background noise is so low that any increase will be very significant and disturbing.
Noise from the mine site, increased local traffic, dust and visual pollution from the site will significantly decrease the value of my property during the operation of the mine.

I am concerned about the increased traffic on the Lue road given the planned movement of trucks to transport the ore from the mine site. This road is narrow and winding in sections with a poor road surface which is regularly patched and filled when potholes develop.
Increased heavy vehicle movement will only add to the current hazards of driving between Lue and Mudgee.

I believe that having the tailings dam with no secondary wall to contain the trapped cyanide, cadmium, arsenic, zinc and lead in the event of a wall leak or breach will present an unacceptable risk to the environment. The village of Lue is directly downstream of the dam.
This presents a short term financial gain with little regard for future generations that will live in the vicinity or downstream of the site.
The Box Gum woodland that would be destroyed establishing the mine is home to critically endangered species which are identified under state and federal legislation. It would seem that there is no regard given to our local environment and the fauna living in the vicinity.

Property owners who are affected by the 60 km long water pipeline from the Ulan and Moolarben mines will have no recourse to object to the pipeline being laid through their property. While mining rights afford mining companies access to the resources below ground on property that they own, it is unjust that the property owners cannot stop others accessing their private property if that is their wish.

I object to this proposal as the region doesn't need any new mines being established. The environmental impact on our region cannot be undone and I am genuinely concerned about the water impacts, along with pollution. The communities that live within Lue will be negatively impacted. We need to consider the local impacts of mining on our region and tourists do not visit the area to see mines. Please do not let this mine proceed as it will ruin the landscape. The risk of toxic contamination and pollution are not worth it. Please put community and our environment first, say no to this proposed mine.

The environmental impact on the people of Lue has not been taken into consideration.

I am all for progress and job creation when it does not pose a significant negative effect on the community and future generations.

1- I am concerned with this project and the destruction of agriculture land and access to water. Bowden proposes to use approx 2000 Megalites of water each year. Most of this water is proposed to be taken from the Lawson Creek Valley. The Mine will use the groundwater from the mine pit and Bowdens admit they will reduce the water table by 25 metres on site. It will have a direct effect on the bore we use at our property and many other farms in our valley as well.

2- I have a concern that there will be permanent scarring to the land and it's sorroundings. Bowdens have declared that they will not rehabilitate whole site. It will cost too much to repair the damage. With this sort of attitude at the start we do not want another Cougar Energy as witnessed in QLD with negative lasting effects to the community and environment after they left.

3- With farming and drinking water being the looser in this development, due to the lack of professionalism and experience, this project has disaster and environmental vandalism written all over it. Bowdens will build a 68 m high single wall tailings dam less than 1 km from Lawsons Creek. Bowdens will pump it full of chemicals like Arsenic, Cyanide, Cadmium and Lead. There is no second safety wall for the dam so if it leaks, and it will, it will flow to Lawsons Creek and then to Mudgee and the Cudgegong River.

Bowden does not have the interest of the community and the environment in mind. All they want is profit fast and quick. Support the farmers and the quality of the region, stop destroying it.
Mudgee and this region needs to think of job creation in smarter value adding industry not another hole in the ground.

I am proud to be part of the team that is presenting the Bowdens Silver project for development for the Mid-Western Regional LGA.

The outstanding depth and quality of work conducted over the years by not only Bowdens Silver own professional teams but also by independent consultants and experts at the top of their fields has conclusively demonstrated and validated a robust, responsible, safe and environmentally sound silver mine development.

It is widely recognised and acknowledged that this development will be critically important for the region. I spend most of my time living and working in Lue and like the rest of the Bowdens Silver team, I have invested considerably in understanding the issues faced by locals as well as by those in the region more broadly. This project will have a major positive impact.

During construction, the project will employ around 320 people and once operational, will employ a permanent staff of around 230. Priority will be given to locals for these jobs with all site staff required to live locally. In addition to the number of jobs created through direct employment, another 2.5 jobs per person will be created through the use of local businesses and services. This kind of boost will not only help these towns survive, but will help them flourish.

It has been concerning to see that in some of our regional towns that prospects are so limited for school leavers that many go straight onto welfare or are forced to move to the cities to find employment. This changes the social and economic fabric of these towns with populations that are increasingly ageing or reliant on social assistance. Regional towns need strong businesses like Bowdens Silver to invest in these communities and provide opportunities for a better future.

The success of a business such as Bowdens Silver is reliant on having a strong socially and moral contract with its stakeholders and neighbours. We have chosen not to compete in any way with agriculture or other enterprises. We are very proud of that fact and indeed we will continue with our own farming activities alongside our mining activities.

Our performance of the past years will be testament to our future. Our team has and always will adhere to the very best standards and will continue to build their lives and invest in the communities in which they live.

We look forward to continuing our positive contributions and making a substantial difference to our neighbouring communities as well as to the State as a whole.

I encourage everyone to either get in touch, or to visit the Bowdens Silver website www.bowdenssilver.com.au as there is a considerable amount of clear, factual and interesting information available.

I commend this outstanding project.

We object to this project.

We have read summaries from a number of scientific experts who have reviewed the EIS for this project. These reviews have demonstrated numerous failings of the EIS and we refer you for details to those reviews that will have been submitted.

We are particularly concerned about the unacceptable health impacts. There is no safe level of lead exposure. This project has inherently high levels of lead in the mine area, and lead analysis for the project area demonstrated high bio-accessibility rates (i.e. it will be absorbed by the body). Lue village is only 2 km from the mine. This is totally unacceptable.

Water is another major concern. To begin with, there is not enough water available locally to operate the mine. The proposal to pipe water from Ulan and/or Moolarben mines is seriously flawed:

• Those mines tap into the Goulburn River aquifer and the water “mined” should be returned to that river and the downstream river system.
• Water from Ulan and Moolarben is Eastern water and should remain in the Eastern catchment (Lue is in the Western catchment).
• There is no guarantee from those mines that they will send the water, and there is no guarantee that approval will be given to transfer that water.

Another major concern is the impact of acid mine drainage on the groundwater and surface water systems. This is extremely concerning, especially given that the United Nations recently labelled acid mine drainage as “the second biggest problem facing the world after global warming” (Engineers Australia, 2019). The EIS does not adequately address this issue.

The mine will leave a final void and the EIS does not adequately deal with the problems this void will produce for generations to come. Again, we refer you to submissions from scientific experts who have demonstrated the failing of the EIS in these areas.

This silver/lead mine has serious environmental impacts which are unacceptable. The project should not go ahead.